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NEAL R. GROSS

 COURT REPORTERS AND TRANSCRIBERS 

 1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 

UNITED STATES OF AMERICA 

NUCLEAR REGULATORY COMMISSION 

+ + + + + 

BRIEFING ON THE STATUS OF LESSONS LEARNED FROM THE 

FUKUSHIMA DAI-ICHI ACCIDENT 

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PUBLIC MEETING 

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THURSDAY 

APRIL 30, 2015 

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ROCKVILLE, MARYLAND 

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The Commission Briefing convened at the Nuclear 

Regulatory Commission, One White Flint North, Commission Hearing 

Room, 11555 Rockville Pike, at 8:59 a.m., Stephen G. Burns, 

Chairman, presiding. 

COMMISSIONERS: 

STEPHEN G. BURNS, Chairman 

KRISTINE L. SVINICKI, Commissioner 

WILLIAM C. OSTENDORFF, Commissioner 

JEFF BARAN, Commissioner 
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COMMISSION STAFF: 

MARGARET M. DOANE, General Counsel 

ANNETTE L. VIETTI-COOK, Secretary 

EXTERNAL PANEL: 

MARIA KORSNICK, Executive Director, U.S. Industry 

Fukushima Response Nuclear Officer and Chief 

Operating Officer, Constellation Energy Nuclear 

Group, LLC 

ANTHONY PIETRANGELO, Senior Vice President and Chief 

Nuclear Officer, Nuclear Energy Institute 

JON FRANKE, Site Vice President, Susquehanna Steam 

 Electric Station, PPL Susquehanna 

EDWIN LYMAN, Senior Staff Scientist, Union of 

Concerned Scientists 

STAFF PANEL: 

MICHAEL JOHNSON, Deputy Executive Director for Reactor 

Preparedness Programs and Fukushima Steering 

Committee Chairman 

WILLIAM DEAN, Director, Office of Nuclear Reactor 

Regulation 

JACK DAVIS, Director, Japan Lessons Learned Division 

SCOTT FLANDERS, Director, Division of Site Safety and 

Environmental Analysis 

RAYMOND LORSON, Director, Division of Reactor Safety, 

Region I 
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ALSO PRESENT: 

STEVEN KRAFT, Senior Technical Advisor, Nuclear Energy 

Institute 
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P R O C E E D I N G S 

CHAIRMAN BURNS: I welcome our external 

panelists, the NRC staff, and members of the public who are here today 

attending today's meeting. Today's meeting is further status on 

actions taken in response to lessons learned from the Fukushima 

Dai-ichi accident. Discussions today will touch on the status of the 

NRC's lessons learned activities, industry progress and implementation 

of post-Fukushima orders and requests for information, and the 

perspectives of some of our external stakeholders. 

And the Commission will be briefed first by the external 

panel, who's here at the table with us now: Maria Korsnick, Executive 

Director, U.S. Industry Fukushima Response Chief Nuclear Officer and 

Chief Operating Officer, Constellation Energy Nuclear Group; Tony 

Pietrangelo, Senior Vice President and Chief Nuclear Officer at the 

Nuclear Energy Institute; Jon Franke, Site Vice President, 

Susquehanna Steam Electric Station; and Ed Lyman, Senior Staff 

Scientist with the Union of Concerned Scientists. 

And following the panel, we'll have a break before we 

hear from the staff and proceed at that point. 

Would any of my colleagues like to say anything before 

we begin? All right. Very good. Ms. Korsnick, would you please 

begin? 

MS. KORSNICK: Thank you very much, 

Commissioner. I'd like to start the presentation with just sort of 

stepping back and saying what really were the overarching lessons that 

we learned from Fukushima. And if you go to the next slide in my 
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presentation, please, overarching, we would say bottom line is we need 

to be able to provide that cooling water and power under extreme 

conditions when the station and off-site power are unavailable. We 

need to retain or regain access to the ultimate heat sink and be 

prepared to handle multiple units potentially affected by the same 

hazard. 

And in addition to Fukushima Dai-ichi, we want to also 

ensure that we've learned the important lessons from Fukushima Daini 

who was very successful under very challenging circumstances. And 

so the portable equipment, high-quality site leadership, and dedicated 

personnel all were very key to their success. 

As we reflect over the items that were requested on the 

next slide, there were 35 Near-Term Task Force recommendations. 

From that, of the Tier 1 items, came three orders and two information 

requests, one on natural hazards and one on emergency planning. 

From that, 18 industry guidance documents have been worked on. 

Many of those have been approved by the NRC. And from that, 

15,000 discrete plant actions have been required. And as we, as an 

industry, look at the volume of this work, we calculate that we are 

70-percent complete with these items. 

The next slide, again, just to reflect for mitigating 

strategies, overarching was the FLEX program that we put in place, and 

that's going to be required to be fully functional by the end of 2016. In 

addition, spent fuel level instrumentation, and that's required also by the 

end of 2016. And then BWR Mark I and II hardened severe accident 

capable vents broken into two phases, the first one due by June of 2018 
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and the second by June of 2019 and, for the most part, all on track for 

those actions. 

As I reflect on the actions from the industry, I would 

suggest that we have demonstrated a bias for action as we've gone 

through these, and we've put solutions in place that have positioned us 

for an indefinite coping strategy during an extended loss of AC power. 

Compliance with the NRC orders, at least as of the end of 2014, you 

can see that, for mitigating strategies, we have six units that are 

complete, 57 more will complete during 2015, and substantially all 

complete by the end of 2016. And spent fuel instrumentation, 18 units 

completed by the end of last year with full completion by the end of 

2016. And in the BWR hardened vent order, on track to complete both 

phases as scheduled. 

In addition, we have two national support centers that 

are in operation, adding additional portable equipment that can be 

made available to any of the sites in the United States within 24 hours. 

And that we have now processes and procedures and able to allow us 

to handle natural hazards that are affecting multiple reactors at the 

same site. 

So my reflection on this is the way that we got here was 

that we worked very well together, the industry, the Nuclear Regulatory 

Commission staff, to make sure that we stayed focused on the most 

important stuff and, that way, that we put the best safety benefit in place 

the soonest. And I'll leave you with that thought because, as we work 

through our presentation today, I'm concerned in some areas that we 

have yet to complete. 
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The next slide goes into seismic and flooding. The 

seismic walk-downs and hazard re-evaluations have been completed. 

Likewise, for flooding, walk-downs, and hazard re-evaluation 

substantially complete. But I have some concerns specific in the 

flooding area, and I know Tony Pietrangelo will be covering these in his 

area. 

The overarching item here is that we have to continue 

to work very well together, industry and the NRC, to make sure that 

we're focused on the most important actions that bring the best safety 

benefit the soonest. We're challenged in that area. 

The next slide talks about BWR containment filtering 

strategy. Obviously, protecting containment is an important safety 

barrier for us. That's our primary focus. FLEX and the 

implementation of FLEX helps us by continuing to ensure that we can 

keep the core cool and, likewise, protecting containment. If, in fact, the 

core has become damaged, we have filtration strategies that we've put 

in place, including severe accident water addition, that will help us 

manage a damaged core and continue to protect containment, that 

important safety barrier. 

We've done extensive evaluations between the 

industry, as well as the NRC, on the safety benefit of an external filter 

and understand that the severe accident water addition will adequately 

filter releases. 

Going forward, our lessons learned from Fukushima 

are substantial and ongoing. 2015 and 2016 are very significant years 

for us for implementation. We've been successful when there are both 
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industry and NRC alignment and accountability for execution. We will 

achieve significant safety benefit by those actions that will be complete 

by the end of 2016. 

That concludes my remarks. 

CHAIRMAN BURNS: Mr. Pietrangelo. 

MR. PIETRANGELO: Can I get the balance of 

Maria's time? 

(Laughter) 

MR. PIETRANGELO: Just kidding. Chairman and 

Commissioners, good morning. Let's go straight to the second slide, 

please. Just a little background. March 2012, the Mitigating 

Strategies Order was issued by the Commission and employed design 

basis hazard levels for the flood and seismic hazards. Now, why did 

we do that? And I think this goes back to Maria's point about bias for 

action. Had we waited for the flood and seismic re-evaluations to be 

complete, we would just be starting the mitigating strategies 

implementation here instead of being in a position to complete by the 

end of 2016. 

So we're still on track to do that. We do have to factor 

that information back in to those mitigating strategies to make sure they 

remain viable. But the bias reaction to get the biggest safety benefit 

out there the soonest was why we moved forward, even not knowing 

what those re-evaluated hazard levels might be. 

At the same time, the 50.54(f) request for information 

on flood and seismic information went out to the industry using the 

current regulatory guidance that was used for new plant licensing, not 
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what was used for the original plant licensing. 

These submittals were staggered into three groups on 

flooding for one year from March 2013 and then March 2014 and 2015. 

The staggering was to allow a more measured resource allocation such 

that the reviews could be completed. That's not the situation we find 

ourselves in today, and I think there's a lesson learned going forward 

about how we look at these requests for the re-evaluated hazards and 

what level of review we do for those, what the scope of them are, and 

transparency in terms of the schedule for completion of those. 

The seismic re-evaluations were submitted in March 

2014 and 2015, Central and Eastern United States in 2014, and you 

just received the western plants about a month ago. So on schedule 

there. 

Next slide. Let's dig a little deeper into the flood 

re-evaluations. I think when you issued the staff requirements 

memorandum on March 30th, your first paragraph dealt with 

incorporating the flooding re-evaluations into the mitigating strategy 

assessments. That's job one from our perspective, and almost my 

entire presentation focuses on that first paragraph of your SRM. 

That's what we're really trying to get done by 2016. 

The rest of that SRM deals with, we think, longer-term 

actions in terms of guidance and decision criteria with respect to the 

entire plant, not just the mitigating strategies. But we were ordered to 

do these strategies by 2016. We would like to get these assessments 

done by 2016 and, hopefully, get as many plants through that wicket as 

possible with the time remaining. 
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When we say more than adequate for mitigation 

strategies assessment with the re-evaluated flood hazards, we 

continue to believe that the re-evaluated hazards and that methodology 

was very conservative. I think we've demonstrated that with some of 

the interactions we've had with the staff, as well as information 

exchanges with the Commission. And you're looking at that, with 

respect to mitigating strategies, for a very remote beyond design basis 

scenario. So the question is how good do those re-evaluated hazards 

have to be? 

This is not the time to get out the micrometer on the 

level of what the flood level is, for mitigating strategies at least. But not 

knowing how that information was going to be used later on, I think 

there's a lesson learned for all of us to say we need to know what the 

end game is, and then you'll know whether you need to have a very 

detailed, precise analysis versus a roughly right analysis that you can, 

depending on the context in which it's used should dictate the level of 

review. And I would strongly recommend that we have more 

transparency in terms of the scope and level of review, as well as 

schedules, and context of how that information is going to be used. 

The more we know up-front, I think -- and this happens on both sides. 

Our folks start getting very, sharpening the pencils, if you will, and staff 

is asking for more information, and that's when we get protracted 

reviews. 

We just submitted NEI 12-06, Appendix G, which is the 

guidance for how to do the use of re-evaluated flood hazard against 

mitigating strategies. We need endorsement of that to proceed with 
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the mitigating strategies assessment. We need to expedite the NRC 

staff's reviews so that we can move forward with those mitigating 

strategy assessments and get completed in 2016. 

To date, three sites have been approved with their 

flood hazard re-evaluation, seven have asked for additional information 

beyond what was requested in the 50.54(f) letters. We understand 

that there's an expedited review schedule to get a batch of plants out by 

September of this year and another batch by the end of the year. But, 

quite frankly, we're skeptical about that given the track record that's 

been established here. So this is going to require a lot of focus and 

integration to get this done. 

And, finally, there's another handoff with not only when 

we complete the mitigating strategies assessment, giving that back to 

the staff. Some may have no actions to do after that assessment. 

Others may have several actions to do, but you want to get buy-in from 

the staff again before you move forward with those actions. We've 

always had a principle of do it once, do it right, with all the Fukushima 

activities. 

So I think what I've described is there's a synergism 

between what we do as the industry and what the NRC staff does. 

And we use an analogy like a relay race, a long relay race, where 

there's a lot of hand-offs of the baton. And, quite frankly, there's a lot 

of people who handed off in 2013 still waiting to get the baton back on 

flooding re-evaluation. So we've got to fix this problem to meet, I think, 

our common goal of getting most of these plants done by 2016. 

Next slide. During the seismic, both the NRC and 
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industry agreed that, after the initial screening against the ground 

motion response spectra that were completed in March of 2014, that 

several category one or several groups of plants were identified to 

conduct seismic PRAs, probabilistic risk assessment. But we didn't 

think, and I think the staff agreed, that just waiting another three years 

for a seismic PRA to be conducted was the right response to the new 

information that was received. So we developed the expedited 

seismic evaluation process and looked at the design basis level, 

doubled it, and looked at the equipment and the low frequency between 

1 and 10 hertz, the equipment you needed for AC power and for 

cooling, because part of the mitigating strategy involves permanent 

plant equipment that has to work if you lose all power and lose access 

to the ultimate heat sink. That's what that ESEP focused on. 

Thirty-two stations out of sixty were required to do that based on their 

GMRS review. Those were submitted in December of 2014. 

We've looked at the results of those, and we think it 

confirmed the robustness of the seismic designs. There have been 

some minor modifications identified, as well as some more significant 

modifications with respect to flat bottom tanks and how they perform in 

earthquakes. But all in all, we think the ESEP was, again, the bias for 

action to get the safety enhancement out in the field before you do the 

longer-term study of the hazard. 

Challenges going forward on seismic, what you do with 

the rest of the mitigating strategies beyond Phase 1. Is your Phase 2 

equipment still able to get to where it needs to be in a seismic event? I 

think they're still at the conceptual stage of the guidance on this, but 
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we'll have to develop guidance on how this is performed. 

So this is going to require a focused effort. And, 

really, our ultimate goal is to provide additional confidence and not wait 

for the longer-term seismic PRA that the mitigating strategy remains 

viable. 

So my final in less than two seconds. There's a 

substantial amount of work that remains to be done. And I guess, just 

from reaction to reading your SRM on flooding, just your first paragraph 

entailed a humongous amount of work to be done. So I don't want to, I 

want to make sure we're clear about, you know, how much work 

remains both for the staff and the agency. 

We will get the mitigating strategies as ordered done 

by the end of 2016 against the design basis levels. We will re-evaluate 

them, hopefully, with the goals to get them assessed against the 

re-evaluated hazards that have been submitted. But we do need to 

retain this focus and integration of these efforts in order to get to the 

goal line here. 

We think the rulemaking will help this because a lot of 

this stuff is codified in the proposed rule you're about to get from the 

staff. We've had good alignment on that rulemaking, with the 

exception of the regulatory basis on severe accident management 

guidelines. But other than that, I think we're pretty well aligned on what 

goes in the rule. 

I've gone over my time. Mr. Chairman, I apologize. 

Thank you for your attention. 

CHAIRMAN BURNS: Okay. Mr. Franke? 
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MR. FRANKE: Good morning. I'm Jon Franke. I'm 

the Site Vice President for Susquehanna Station, and I want to thank 

you for the opportunity to provide a single station's perspective on the 

discussion around Fukushima and industry's response. 

In general, what we've talked about today up to now is 

a lot of reams of paper associated with regulation and orders and 

responses by the industry. At some point, this turns into hardware and 

trained personnel ready to respond, and I think I can provide a 

perspective relative to that. 

If we go to my first slide, I think, in general, where we sit 

today as an industry, as Ms. Korsnick said, we've had a bias for action, 

and that has turned into a genuine improvement in the enhanced ability 

of the plant and staff to protect the health and safety of the public, which 

is our first job as stewards of this industry. We've got, both at the 

stations and in conjunction with the industry through the national 

support centers, we've developed simple standard compatible 

approaches to dealing with the mitigation strategies and the orders 

provided by the Commission to provide that cooling and power required 

to respond to any event that may happen at the station. And at the 

same time, not only have we taken a standard and compatible 

approach, I'd say that the approach to date, from my view, appears to 

have not only addressed an industry-wide response that can be used 

widely but also address individual needs of the stations relative to their 

seismic and flooding hazards and the technical requirements. Now, 

there's still a lot of work to complete in this area, but I think, even today, 

we're substantially better than we are before. 
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My next slide provides a little view as to what this 

actually looks like, what all these pieces of paper have resulted in. 

What I provided is a couple of photos of the facilities now installed at my 

station. You'll see a FLEX structure which houses the equipment 

available within the first immediate after-hours actions following an 

event. It's 10,000 square feet designed to withstand the worst hazards 

available, including a 300 mile-an-hour wind projected telephone pole, 

which drives standards along the lines of what ends up being a 39-ton 

swinging door to the 10,000 square feet of material inside. And we've 

got two pumper trucks. We have two one-megawatt turbine 

generators. We have trucks and debris-removal equipment, the food 

and water required for the staff, the cables, the material and tools 

required to implement the FLEX strategies at the station available at the 

station. 

If you go to the next slide, I would say that this visual 

commitment by the industry so far has matched the importance of the 

issue. And what this looks like when you get to a plant like 

Susquehanna, it's turned into a series of over a dozen plant 

modifications to address the ability to inject water supplied by pumper 

trucks into the vessel, into the fuel pool, into the cooling support 

systems required to be successful with that strategy. New 

instrumentation for our spent fuel pools, the temporary power 

connections to be able to provide power from external sources and the 

fuel supplies at the ready to be able to provide both power and cooling 

to the core, to the spent fuel pool, and provide the instrumentation and 

communications required to be able to both respond with the control 
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room staff and as the industry. 

This has turned into things like large numbers of new 

procedures. In the area of staff preparation, we've completed over 

5,000 man hours of training to date, and we continue to train our 

personnel. That includes both operation staff, around-the-clock 

maintenance staff ready to man the facility and to man the FLEX 

equipment. Our emergency response personnel have received 

hundreds of hours of training relative to the new strategies provided by 

the FLEX equipment and demanded by the orders, including as much 

as almost a thousand hours of training for the decision-makers that 

would be involved post-event. 

So I'd say that, to date, we have implemented 

significantly most of the mitigating strategies in a broad way, so that not 

only has provided the changes to the plant required but the training to 

the staff and the equipment available at the station to be able to 

respond. 

If I could go to my next slide, the one thing, as a single 

utility perspective, that I think is important to discuss is that this isn't just 

a single site or a single utility response but has been well coordinated 

across the industry. So, obviously, and it's very obvious with regard to 

the use of the strategic alliance for flexible equipment or the safer 

response centers, we've pre-positioned for the entire industry 

equipment available. What may not always be as apparent, however, 

is the equipment that I just showed you pictures of that are available at 

my station match the other equipment available for the nuclear plants 

around me. So a station that may be nearby that may not have 
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realized the same event that my station provided is available through 

our coordination with the Institute of Nuclear Power Operations, NEI, 

and EPRI to respond to my station with that same equipment. Since 

the equipment is substantially similar, the tools and requirements for 

hookup are similar, that equipment not only at my station and the safer 

stations that is available at stations not affected by the same event can 

respond to my station, as well. So we have layer upon layer of 

equipment ready and capable of being implemented to respond to an 

event at any one station. 

I also think that the open and collaborative method in 

which these new rules and orders have been implemented, working 

with the staff and working through NEI, has provided a stronger and 

more effective and efficient approach than might otherwise have been 

realized. And as the back-end of these regulations, the person in 

charge of implementing it, I've sincerely appreciated that collaborative 

response. 

Going forward, I'd say that the most important things to 

be able to implement are similar to statements stated earlier. I think it 

is important to do it once and do it right. We need to make sure that we 

have certainty going forward with the new requirements. I think that, to 

date, the response has been commensurate with the safety and 

substantially has answered the question as to what the industry needs 

to do in response to the Fukushima events. 

You know, as individual companies and stations, we 

take our responsibility relative to nuclear safety very seriously. We 

watched Fukushima, and we knew that our response needed to be 
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commensurate with the hazard that was represented there. Working 

closely with the staff and the industry, I think we've substantially 

implemented the safety functions needed in response to that. And 

going forward, I think we need to make sure that our response is timely 

and that the requirements from the staff are well understood and 

commensurate with the safety improvements that would be realized by 

any additional rules. Thank you. 

CHAIRMAN BURNS: Thank you. Dr. Lyman. 

MR. LYMAN: Good morning. And on behalf of UCS, 

I appreciate the opportunity to provide our views on this topic again. 

I think, overall -- may I have the first slide, please? 

Our main comments, overall, I think we have to acknowledge that 

there's been an enormous amount of work on behalf of the industry and 

staff to implement Fukushima lessons learned, and that can't be denied 

and we appreciate that. But as we've said before, the lack of a unifying 

framework for assessing safety improvements that might have been 

provided by fully implementing Near-Term Task Force recommendation 

one has been an impediment to our ability to assess exactly how much 

safety is going to be improved by the current enhancements that have 

been approved. And that's a problem for our ability to communicate 

what's been done to the public. 

With regard to FLEX implementation, I'd just like to 

advise that the Commission should keep a close watch on the schedule 

relaxations that have been approved and the potential for additional 

creep. So far, I believe there haven't been any that have actually 

asked for extensions beyond the end of 2016 and the endpoint three 
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apparently had requested one but has withdrawn it. So my mention on 

the slide there, that should be noted. We don't want to see a repeat of 

what happened after 9/11 where it took more than a decade before all 

the security improvements were finally completed at the sites. 

Next slide, please. So our overall view of FLEX, I 

think it has to be acknowledged that it does not fulfill the original intent 

of the Near-Term Task Force vision, and that's clear from the 

boilerplate language that the staff puts in every safety evaluation report. 

We think that diverse and flexible are good qualities, but they may not 

be sufficient. And what the French have done with the hardened 

safety core, one dedicated set of equipment that's fully qualified to 

events more severe than what the rest of the plant is subject to may be 

an important or a necessary compliment to that. And that's clear from 

the boundary conditions of FLEX that were established by the original 

Mitigating Strategies Order and the NEI guidance. It's an artificial and 

stylized event, and I think that the limitations of that original order are 

not evident in the fact that the flooding hazard re-evaluation issue has 

come to the fore and may end up causing additional delays. 

Next slide, please. So I think the industry position on 

evaluating FLEX has changed. I provide a quote from Mr. Ford from 

Entergy where he expressed the view also that the boundary conditions 

for FLEX were artificial and that you should try to evaluate, you know, 

real scenarios and success paths, and I think his point of view would be 

that the conditions may actually be less severe than the damage state 

in the order. But if you accept that philosophy, it's quite possible there 

may be conditions where the damage state exceeds what was in the 
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order and that would have to be followed through consistently. So it 

cuts both ways. 

Next slide, please. We think that any 

performance-based requirement needs performance testing-based 

inspections. So we think there should be an additional inspection 

protocol that would essentially be a stress test supplemented by 

performance testing where appropriate and that force-on-force security 

inspections could be a model, although, obviously, there are aspects of 

that which wouldn't be appropriate. But the goal is to really test 

whether FLEX will do what the industry says it will do, and that's 

essentially be able to cope with any situation that comes or a sufficiently 

broad spectrum that we can say there's confidence that the safety 

envelope is appropriately large. 

Next slide, please. There are some thunder clouds on 

the horizon that we're worried may cause additional delays, and I just 

note that NSAL-15-2, which only became public very recently, seems to 

call into question the timing for time of core uncovery for most of the 

Westinghouse plants, if not all of them, that it could actually be reduced 

to one and a half to two hours, which I don't think any of the current 

FLEX strategies could possibly cope with that short time line. So I 

don't think the current plans have addressed NSAL-15-2 yet, and we 

don't know but it looks like that could be a problem. 

Next slide, please. On flooding, pardon the pun, but I 

think the agency seems to be at sea with regard to its response. 

There's still a lot of questions to be resolved, but we do strongly support 

the Commission's vote on the COMSECY-14-0037. We think that that 
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is starting to correct some of the problems that we identified at the 

beginning with the limitations of the original order, and we think the 

simplest way to look at it is that, if you re-evaluate the hazard because 

you're using better information, more accurate methodology, and 

updated site conditions, that that's the true design basis and not a 

beyond design basis consideration. It's just correcting the wrong 

design basis. 

Next slide, please. And the issue of defense-in-depth, 

we still think this is a very important consideration in all the activities 

that we're talking about, and we don't think it's a qualitative factor like 

the others that have been discussed in the Commission's deliberations 

on this. Defense-in-depth is a key part of addressing severe 

accidents, and, in that sense, we think that it is certainly an important 

and valuable consideration when you consider post-core damage 

requirements, for instance SAMGs and CPRR, potential actions under 

a CPRR rulemaking. And we think you can't just evaluate the 

quantitative effectiveness of mitigating strategies for preventing core 

damage because they depend on uncertain manual actions. You do 

need some defense-in-depth considerations to consider post-core 

damage requirements. 

Next slide, please. So in that view, we strongly 

support that incorporating SAMGs as a regulatory requirement into the 

beyond design basis mitigation rulemaking is very important. We don't 

see how they can be effectively integrated with the other emergency 

procedures otherwise. And there are other potential ways where 

severe accident guidance may be required, for instance in the Phase 2 
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of the severe accident capable hardened event order. So we don't 

think CPRR should be simply limited to that but needs to evaluate the 

full spectrum of potential activities for reducing radiation releases, 

including the potential for filters. 

I'm running out of time. Sorry. Next slide, please. 

I'd like to just point out Dr. Stetkar has questioned the technical analysis 

supporting staff's analysis of CPRR and the lack of quantitative 

justification for SAMGs, and I'd refer you to the ACRS deliberations on 

that. 

And, finally -- next slide, please -- one of the activities 

that was not in a tier was re-assessing EPZ size and potassium iodide 

distribution. And even though the staff continues to maintain they don't 

see any evidence come out of the Fukushima accident that would call 

into question the 10-mile EPZ, I just provided some data which supports 

our view that an extension of the plume exposure EPZ to probably 20 or 

25 miles would be justified, according to the quantitative data that's 

come out, including the dose rates in the Iitate village which were about 

25 miles from Fukushima. We think those people weren't protected 

and they should have been in the aftermath of the accident. 

And I will stop there because I'm well over, and I 

apologize for that. Thank you. 

CHAIRMAN BURNS: Thank you all for your 

presentations. I'll begin the questioning this morning. Ms. Korsnick, 

on slide seven, you discussed a containment filtering strategy, and the 

statement on the slide is that extensive evaluations show no safety 

benefit for an external filter. It's a pretty strong statement. Is it that 
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there's no safety benefit or that, at least from the standpoint of the 

industry from a cost-benefit perspective, there's no benefit? 

MS. KORSNICK: Yes, I understand the question 

relative to the containment filtration. I think you'll see that, all along, 

the industry's position has been very much one of protecting 

containment, and the idea of ensuring that we have severe accident 

water addition was, in fact, a stronger solution to ensuring that you kept 

containment intact. And that water addition, through our 

demonstration and analysis, provides equivalent filtration as water filter. 

So since our solution involves involving this water, in 

addition to that, there's no additional safety benefit that a filter would 

provide. 

CHAIRMAN BURNS: Okay, thank you. Mr. 

Pietrangelo, one question. If you would discuss perhaps the industry 

view -- we've had a little bit of discussion between your slides and Dr. 

Lyman's, regarding severe accident mitigation guidelines. But if you 

could explain, from the industry standpoint, what the concern is with 

respect to the justification of those guidelines in the upcoming rule that 

we'll be looking at. 

MR. PIETRANGELO: Let me start with saying that 

the industry has had severe accident management guidelines in place 

since the mid 1990s. That commitment was looked at after Fukushima 

occurred. There was a request by the Near-Term Task Force to look 

at the status of SAMGs in the industry. The summary said that every 

licensee had SAMGs available. They weren't in all the locations they 

expected them to have. Not all of them were consistently updated or 
 24 

maintained. Nevertheless, they were in programs that the owners 

groups kept to maintain the SAMGs. 

So the question is not whether to have SAMGs or not. 

It's solely about the regulatory treatment of SAMGs. Our 

understanding, based on the interactions we've had on the proposed 

rule, is the staff-cited qualitative factor solely is the basis for requiring 

SAMGs in the rule. We thought the Commission direction on that was 

pretty clear. We're not adverse to a docketed equipment to have, 

improve, maintain SAMGs over the longer term. We think that's the 

right touch for the regulatory footprint on SAMGs. But we're 

concerned about the precedent-setting nature of citing qualitative 

factors only as the basis for that requirement in the rule. We think that 

sets a bad precedent. It goes back to a lot of the discussion that the 

Commission had at the time of the filter vent decision. So that's where 

our concern is, Chairman. 

CHAIRMAN BURNS: Dr. Lyman, any comment you'd 

like to make? 

MR. LYMAN: Yes. As I said first, we think that, in 

addition to the industry just having SAMGs, and I think we all know 

where the desire for regulatory requirement came from was the fact that 

the inspections of those SAMGs after Fukushima found some 

problems, but we think that the rule should be regarded as a coherent 

whole and that you can't really assess mitigating strategies before core 

damage under regulatory, proper regulatory treatment and then 

continue to have voluntary actions. First of all, at Fukushima, they 

didn't even know where core damage started. So it's an artificial 
 25 

distinction, and the operators may not actually know. 

So we think that those procedures have to be fully 

integrated and the agency should be able to evaluate them from 

beginning to end whether they would be effective. And I don't think 

they can do that without having the same regulatory treatment before or 

after core damage. 

CHAIRMAN BURNS: Okay. And, obviously, the 

rulemaking is coming before -- we'll continue the debate in that context. 

One other thing, Tony, in terms of you described for, you know, there's 

a desire, I think, to move forward and get the endorsement on the 

particular NEI guidance document, the 12-06 Appendix G. 

MR. PIETRANGELO: Correct. 

CHAIRMAN BURNS: What do you see right now as 

the push points where, in terms of staff review or evaluation of that, 

where do you think things need to come together? 

MR. PIETRANGELO: Yes, the staff has been aware 

of the document that we've been working on for a while. We formally 

transmitted it this past Monday, so we're ready to engage on it, 

incorporate any staff comments, and move forward with the mitigating 

strategy assessments. So this takes the re-evaluated flood hazards 

and says this is how you would look at your mitigating strategies to 

provide assurance that it's still viable under those kind of flood 

conditions. 

So I think if we can get that guidance endorsed before 

the letters of adequacy on the re-evaluated flood hazards, we'll be in 

good shape to conduct those assessments with confidence. 
 26 

CHAIRMAN BURNS: Mr. Franke, you talked about 

support or input from other organizations in terms of, you know, your 

own on-site implementation of some of these strategies. And in 

particular, you mentioned INPO. What's INPO's role in this context? 

MR. FRANKE: Well, INPO, and I don't speak for the 

institute but as a member, they have several roles, actually. One, they 

do do assessments of our own strategies against a response. They 

provided their own, as you likely know, their own event reports with 

recommendations to respond to the Fukushima disaster. We've had a 

series of those. And as an industry, we police ourselves through the 

institute. They come in and evaluate us against the recommendations 

provided by INPO. 

In the case of an event, our processes and procedures 

would require us to contact INPO very promptly after the event, and 

they would coordinate the response from other member utilities to our 

station. So an event at Susquehanna, through coordination with 

INPO, would get response in both equipment, personnel familiar with 

that equipment, not only from the safer sites but from member stations, 

as well. 

CHAIRMAN BURNS: Okay. Thanks very much for 

that. One question I had, Dr. Lyman, I think on one of your slides, I 

think, speaking of the Commission's SRM on the flooding issue, it 

seems that, on slide seven, it seems to take issue with the SRM 

because we direct the staff to be risk informed, and the SRM says risk 

informed in performing its base to the extent practicable. And I was 

trying to understand what your concern was, again, as reflected in the 
 27 

slide and your comment. 

MR. LYMAN: Yes, thank you. I think the issue is just 

that I think one of the problems with being able to do the flooding hazard 

re-evaluations and incorporate them appropriately is the lack of having 

probabilistic risk assessment methods for flooding, and risk informed 

generally refers to having such tools available. And I think without 

having that, it's hard to assess what, you know, what are the most 

safety-significant issues in a quantitative sense. And I think that may 

be, that may cause problems as the industry tries to address the issue 

of flooding hazard re-evaluations in the context of both FLEX and 

installed equipment. 

So we think that a more conservative approach may be 

needed at the beginning, more deterministic, and then, as methods 

improve, the industry could try to secure, you know, some risk-informed 

modifications to what they're doing. But there may not be time to come 

up with a credible methodology for judging what's risk significant, you 

know, or what's highly risk significant on a quantitative basis. 

CHAIRMAN BURNS: On another topic, could you 

elaborate, you suggested in terms of sort of testing FLEX strategies as 

a stress test type approach, it reminds me of your opinion the EU did in 

terms of looking at the post-Fukushima. Could you elaborate on what 

your concept is there? 

MR. LYMAN: Yes. I mean, I envision that there 

would be a, you know, a red team of analysts who would come up with a 

set of scenarios. And then through a combination of analytical work, 

tabletops, and performance testing where appropriate, they would 
 28 

actually see if there are success paths that are plausible. So in other 

words, you would stress the system with a certain boundary condition 

and then evaluate the equipment that, you know, if it's qualified to a 

certain seismic or flooding hazard, you evaluate the manual actions. 

You just try to assess it in a more realistic way. Instead of just saying 

we've met the battery of conditions in the mitigating strategies order, 

you do this, you know, actual scenarios. And, of course, you can't 

cover everything, but, if the idea of FLEX is it should be able to deal with 

pretty much everything, you can test that with a certain set of scenarios. 

So that's sort of my idea. 

CHAIRMAN BURNS: Okay. My time is up. 

Commissioner Svinicki? 

COMMISSIONER SVINICKI: Well, I thank each of 

our four presenters for your presentations today. I'll give you some 

warning that I'm not sure I'm going to find a question anywhere in what 

I'm about to say, so that allows all of you to either tune out or do 

whatever you'd like. 

I was preparing for this meeting last night, and it 

caused me to really pull back and reflect on where we are right now 

because, in looking at what the staff is going to present, they're going to 

both talk about status but give a forward look on other of NRC's 

Fukushima activities that are underway. And I began to get into kind of 

a deeply philosophical train of thinking, which is a little curious because 

I've been here for all of this, and Commissioner Ostendorff and I share 

that so I apologize for my two colleagues who, you know, weren't here 

for the journey all along the way. But you would think that I would have 
 29 

great clarity, therefore, on everything that the staff is about to present. 

And it's not that I'm confused by the activities or don't remember their 

origins, it's just -- well, maybe this will give you a sense of my mind set. 

I texted a friend and said, "What's that science fiction movie we like 

where they spin that top on the table?" and, if a friend knows you well 

enough, that's enough that they go, "It's the movie 'Inception." 

So my thoughts were, as confusing as some of the plot 

lines of that movie were, I think, you know, I spoke at the Regulatory 

Information Conference that I think the United States can take a lot of 

pride in the very measured both political and technical and public 

reaction to the accident in Japan. I commented, you know, that 

President Obama had asked us to do a quick look at what were the 

relevant learnings and asked the nation's safety regulator to come 

forward with any near-term actions that needed to be taken. And there 

are other countries that were perhaps not as structured in how they 

reacted to events. Yet, here we are, this many years later, and we 

have those who very sincerely believe that we've done nothing. I 

appreciate that the U.S. industry provided an opportunity for me to bring 

my counterpart from Japan, a Japanese commissioner from their 

nuclear safety agency and a number of Japanese technical staff to a 

U.S. nuclear power plant -- that happened to be Palo Verde -- to look at 

what's been done. And, you know, that's meaningful to me. 

I know that when I was here the orders that were 

issued on the one-year anniversary seemed like a very substantive 

body of actions. The U.S. industry is deep into implementation of 

those actions right now. 
 30 

And I wondered that there are events where the peril of 

overreaction or imprudent action I think comes early after the event. 

But I'm beginning to think to myself that there are events where the 

danger of engaging in actions that go beyond what is needed actually 

comes much later after the event, and I think that can be because 

you're so deep into what you're doing that maybe you lose some 

perspective on all that you've already done. 

So as I look -- and our Commission will have a 

separate meeting on the mitigating beyond design basis proposed rule 

that the staff I think is delivering to us today. But as a Commission, of 

course, we've been following their work along the way, and I think about 

some of what's creeping into the analysis now and I worry that it is 

reflective of some loss of perspective. Yes, the SAMGs were 

inspected under a temporary inspection instruction after the events in 

Fukushima. And if we reflect upon the fact that, historically, it is a 

voluntary program, and voluntary initiatives have a place in NRC's 

regulatory framework, they do not take the place of things for which you 

have a basis to require compulsory action. 

But as I reflect on the proposed rule, I wonder what it is 

that arose from Fukushima that causes us to say that there was not a 

basis for compulsory action but there is now? If it's enhanced 

defense-in-depth, although I agree with Dr. Lyman that that has a very 

unique role in our regulatory framework, defense-in-depth does, and 

does need to be looked at as a special case, other than qualitative 

factors, at the end of the day, if it's not quantified, it is definitionally a 

qualitative consideration or whatever you want to call it. 
 31 

So, you know, there were issues with the SAMGs, but 

when I look at the actual writeup of what were the observations it says 

in some cases the procedures were not available in all locations, didn't 

reflect the proper control designations. It says while personnel do 

appear to be properly trained and knowledgeable, exercises at some 

sites were not conducted or were not recorded as being periodically 

conducted. 

So, you know, if you're a regulator of communications, 

you have to decide what it is is so objectionable that it can't be aired. 

So the parlance there is we know it when we see it. If you're a safety 

regulator, the adequate protection is kind of your version of you know it 

when you see it. So we do have the authority, as a commission, to 

deem things matters of adequate protection. But if four years after an 

accident we have a fundamental view of what is necessary under 

adequate protection, you know, was there error in our thinking early on 

that there were not a set of strong and additional actions that were 

needed? So this is maybe more for the NRC panel, but I think we need 

to look at that. 

I also agree with Dr. Lyman that there, you know, if 

there isn't a framework for something, it is very difficult as the years go 

by to say how do each of these discrete considerations of actions fit into 

the totality of the regulatory response? But the truth is, the 

Commission has acted on a number of the Near-Term Task Force 

recommendations here. Here, May 19th, 2014, the Commission has 

disapproved the staff's proposed improvement activity one: establish a 

design basis extension category of events and associated regulatory 
 32 

requirements; has disapproved improvement activity two: establish 

Commission's expectations for defense-in-depth; and it has 

disapproved improvement activity three: clarify the role of voluntary 

industry initiatives in the regulatory process as written. 

And it said for activities one and two, the staff should 

re-evaluate them in the context of the long-term risk management 

regulatory framework. I believe that work is due to us in December of 

this year. And for improvement activity three, the Commission has 

only approved the proposal to evaluate the current status of 

implementation of the most risk or safety-significant type two initiatives, 

which are a type of voluntary initiative. 

So we've had a lot of turnover on our commission. I 

don't know if that is another factor in not having a consistency in the 

overall framework or approach to issues. But it does concern me on 

something like the mitigating beyond design basis rulemaking, if we 

take the set of actions that a commission three years ago established 

and take that direction, if we constantly revisit these threshold issues, I 

don't think you ever achieve the kind of harmony, coherency, or stability 

in acting on the Tier 2 and Tier 3 or even the fidelity on the 

implementation of Tier 1. 

So I sit here today, I will say, somewhat concerned 

about where this drifts from here. And, again, I don't mean to keep 

talking about Dr. Lyman's presentation, but I think embedded in there is 

that some concern, maybe from a different vantage point, about drifting 

a bit and kind of losing your purpose and direction that you set out on 

now. 
 33 

I do believe that, in working on the Near-Term Task 

Force recommendations, we have shaped those significantly. So I 

acknowledge totally that we are not implementing that set of 

recommendations as they were published in the months following the 

events. But still, in all, whatever direction we have set and whatever 

policy judgments we have made, I think if we're going to, in the more 

detailed implementation of actions, depart from those, then I think it 

needs at least to be done consciously. 

And so I wish I had a kind of thumbs-up and all's clear 

this many years after this accident, but I am a little bit concerned at 

looking, when people in the future look at the set of actions that were 

taken five to seven years, you know, after Fukushima, it would be nice if 

they were able to see a kind of coherency and approach throughout 

them. And I'm a little worried not so much in what we've done to date 

but some of the proposed things on the horizon that we may drift away 

from that. And I've been here, so, to the extent it's happening, I bear 

some responsibility for it. But I think, unless we have the basis of new 

knowledge to depart from the threshold calibrations that the 

Commission has set to date, I would hope that we would only do that on 

the basis of new facts and new information and not constantly be 

re-setting the standards and making new judgments about what needs 

to be done after Fukushima. I think there's peril for the regulator and 

the industry in that. 

So, gosh, I rambled on. It's a lot like my speeches, 

isn't it? I just hit go. But I appreciate the opportunity to reflect on that. 

I appreciate the indulgence of my colleagues, some of whom have 
 34 

traveled the journey with me and others who are going what the heck is 

she talking about? But with it, I yield back. 

CHAIRMAN BURNS: Thank you, Commissioner. 

Commissioner Ostendorff? 

COMMISSIONER OSTENDORFF: Thank you, 

Chairman. Thank you all for being here today and for your 

presentations. Perhaps like Commissioner Svinicki, my good friend 

and colleague, I'll provide some perspectives, as well, as the better part 

of comments because I think you've made some very important points 

since you and I have been the Commission continuity here since the 

Fukushima action items. 

Let me start out, I'm going to make a couple of 

comments and I'm going to have one question for Mr. Pietrangelo, but 

let me start out with Ms. Korsnick. And I appreciate the perspective 

you've provided on the 15,000 discrete actions that are approximate 

70-percent complete. This is a public meeting. Because we have 

been criticized in the public by members of Congress with respect to 

lack of action, I think it's helpful to get the facts out on the table. 

Along with Commissioner Svinicki, I worry that there 

are inaccurate statements being made in the press by some members 

of our oversight committees. And I personally, along with other 

commissioners here, see a lot of effort and actual discrete actions that 

have occurred by the NRC staff and by industry. And so I thank you for 

providing that perspective. 

I'll come back to Mr. Pietrangelo later on. Mr. Franke, 

I appreciate your discussion on the training. You know my 
 35 

background. I've done hundreds, if not thousands, of drills and have 

fought real fires and dealt with real flooding on a submarine and I've 

dealt with some very significant damage control measures, so I'm big 

into the training operator piece. 

And so your comment of 5,000 man hours of training, 

to put it into perspective, for one site was very helpful, as well as the 

hundreds of hours in training in emergency preparedness type actions. 

I believe that the NRC staff, as well as the industry CNOs, when they 

went to both Dai-ichi and Daini, saw the strong importance of proper 

command and control and training. And so highlighting that in your 

presentation is extraordinarily helpful for us. Thank you for doing that. 

Mr. Pietrangelo, with respect to -- the Chairman had 

commented on this. I wanted to make sure I just pull one string. The 

Chairman had led off in two. On your slide three, you made a 

comment associated with the need to expedite reviews so the 

mitigating strategies assessment can be completed by the end of 2016. 

Does the NEI 12-06 guidance, does that go a long way towards your 

view providing some more granularity to help us get through those 

reviews? 

MR. PIETRANGELO: Absolutely. 12-06, Appendix 

G, is taking the re-evaluated flood hazard and assessing your mitigating 

strategies for viability under those conditions. And you'll either come 

up with verifying that your mitigating strategy is still fine. You know, for 

FLEX, we assume the initial condition where you lost all AC power and 

lost access to the ultimate heat sink. Now that you have an actual 

re-evaluated hazard, you may find that permanent plant equipment is 
 36 

still viable, like your diesel generator, so you wouldn't have to employ. 

That might be an alternate mitigating strategy that you would identify for 

that condition. 

And then if you get to a condition where you're 

completely flooded up and you're doing more extraordinary measures, 

that's the targeted hazard mitigating strategy that's referred to. So our 

guidance would encompass all three of those different potential 

scenarios, report back to the staff on the results of the assessment, and 

then, if there's any actions necessary, also try to -- this is the other 

handoff we were talking about before is, one, to get the flood level 

acceptance; and then another one, once we complete the assessment, 

to say we agree with it, as well as any actions you need to take 

post-assessment. But that guidance contains all we think we need to 

do for flooding. 

COMMISSIONER OSTENDORFF: Okay. I'm going 

to make a comment, I think also is triggered, I think, by one of Dr. 

Lyman's points, and I know you suggested table tops to a certain 

extent, and you discussed this in response to Chairman Burns' question 

on the stress test, and maybe we did not provide -- maybe the NRC 

maybe industry has not provided you the opportunity to see this. 

I'm going to give you one example I saw just last 

Tuesday. I visited four plants in the month of April, Arkansas Nuclear I, 

Grand Gulf, Monticello and Davis-Besse. Two of those plants are on 

the Mississippi River. I spent a lot of time in particular last Tuesday at 

Monticello, looking at their flooding strategy, because they're right there 

on the river. There's an intake channel that comes in. 
 37 

It kind of goes to the point about a stress test type 

event, and it goes Mr. Petrangelo's comment on targeted strategies. 

So that licensee had constructed a bin wall 40 feet tall. So it's about 

twice the size of maybe -- twice the height of this building, and the linear 

length of that was perhaps two to three times the width of this building. 

What that had done was constructed reinforced 

aluminum with rebar in there. But it was designed as a site-specific 

strategy to deal with the fact they could not have passed the time 

requirement to construct this wall and a earthen levy in the time that we 

required them to. 

So I think some of that may be happening. I want to 

encourage our staff to communicate that, because I think that as we go 

through this on a site-specific basis, some of what you're asking for and 

suggesting, which I don't necessarily disagree with, I believe in the 

context of targeted strategies, there are significant examples of what's 

happening around the U.S. nuclear fleet. So thank you for your point 

on that. 

I found the visit very helpful, because that strategy was 

X number of days to build this bin wall and Y number of days to build an 

earthen levy, but that was greater than what we required. So they 

went ahead and built the bin wall now, so that in a rising flood scenario 

in the Mississippi River, the bin wall's done. 

So now we turn to some of your comments. Now I'm 

going to preface this by saying I think the Commission in my five years 

here, and Commission Svinicki's eight years here, we have benefitted 

significantly from the Union for Concerned Scientists' participation in 
 38 

this, in these sessions, and I have a lot of respect to Dr. Lyman, for you 

and your colleague David Lochbaum. I think you're knowledgeable 

and engaged in a very constructive, and I think we benefit significantly 

from your interface with the Commission as well as the staff. 

That said, I perhaps will highlight maybe some different 

viewpoints. I'm not saying that I'm right and you're wrong or anything. 

But I just want to highlight again, because we have a public meeting. I 

think it's important for people to hear if there's a differing view on 

something. 

I do want to highlight a couple of different views that I 

personally have. I'll speak just for myself on some of the points you 

made, and your presentation was very thoughtful. Commissioner 

Svinicki has already dwelled a little bit in a constructive way on 

Near-Term Task Force Recommendation 1, and I understand your 

point about the lack of unifying framework. 

I am not going to sit here and say that in a conceptual 

way I disagree with your comment, nor did Commissioner Svinicki 

disagree. But I think since the two of us are involved in 

decision-making on this, you know, in the last four years since 

Fukushima, we saw that trying to get the closure on taking some safety 

actions in a fairly expedient manner would be significant delayed by 

waiting for a Recommendation 1 type effort, to go through and do a 

wholesale review of our entire framework. 

So I respect your position. I think we took that into 

account, decision-making back in 2011, and came to a different point. 

I've been blessed with Amy Cubbage. Amy, raise your hand there, 
 39 

who's on my staff, and she was on the Near-Term Task Force report. 

So I got a lot of indepth knowledge about their thinking. She was one 

of the authors of that report. 

I'd say that since that report, which was a really 

Herculean effort in 90 days, at the same time there was that amount of 

time and the amount of time, I can't spread my arms wide enough, for 

the staff efforts since that report came out. So I just have a different 

view on the FLEX comment you made, whereas the FLEX does not 

fulfill the original intent of the Near-Term Task Force. 

I think there's no -- I don't agree with that comment. 

Again, I'm not saying I'm right and you're wrong, but I just have a 

different viewpoint. But I believe that from a pragmatic standpoint, that 

trying to get some -- move down the path to address the station 

blackout scenario in particular, and provide backup means for power 

and moving cooling water to remove decay heat, those are smart steps. 

I saw analogous fairly quick actions taken in my time in 

the Navy, in response to different events. The last comment I would 

go to is your comment about the true design basis on the flooding piece, 

and again, I have a different view. I don't think that the original design 

basis is wrong. 

I think we are the beneficiaries of new knowledge and 

new data, and I believe that this new information that has been 

captured by the flooding hazard reevaluation is being acted upon, 

responded to by our staff, and that's part of the Commission SRM 

guidance on the individual assessments. 

So I think at the end of the day, we'll get to a proper 
 40 

place on that, and I want at least to comment on your thoughtful 

presentation, and I thank you for listening to that. Thank you, Mr. 

Chairman. 

CHAIRMAN BURNS: Thank you, Commissioner. 

Commissioner Baran. 

COMMISSIONER BARAN: Thank you, and I'd like to 

express my thanks for all of your thoughtful presentations. Marie, I 

want to start by asking about implementation of Phases 1 and 2 of the 

hardened vent order, which are targeted for completion in 2018 and 

2019. Can you just take a minute and walk us through the work that 

needs to be done to comply with that order? 

MS. KORSNICK: I understand your question is 

around the Phase 1 and Phase 2 for the -- 

COMMISSIONER BARAN: Hardened vents. 

MS. KORSNICK: --hardened vent, and yeah. Just to 

step us through, actually Steve Kraft, who's sitting behind me, might be 

a better one, Steve, to answer the details for Phase 1 and Phase 2. 

CHAIRMAN BURNS: And if you would, Mr. Kraft, 

identify yourself and your affiliation. 

MR. KRAFT: Yes thank you, Mr. Chairman. Steven 

Kraft, Nuclear Energy Institute. I'm the industry lead for the vent order. 

In answer to Commissioner Baran's questions, Phase 1 is the wet well 

vent. First, I should just say 29 plants that are affected by the order. 

It was 31, but two have dropped out. One shut down and one will shut 

down. 

So Phase 1 wet well vent, guidance was approved 
 41 

about a year ago. The plans were submitted to the Commission staff 

at the end of last year. They are in process now. What's left there are 

the traditional design engineering installation modification testing 

verification steps, very much like what's going on in FLEX. Just about 

a two-year delay on that, because the order was later. 

The second phase is a bit more complicated. The 

order requires either a severe accident-capable dry well vent, or water 

strategies to allow you to operate under ELAP (phonetic) conditions, to 

manage water that's being injected, as has been discussed here today, 

to cool core and protect containment. 

That's a very complex set of procedures. To do that, 

you can imagine the idea of not wiping out a wet well vent, controlling 

water flows, things like that if a plant should elect to do that. We have 

just yesterday received an endorsement on the guidance that we wrote 

to implement that, and then you move forward with that. 

It is less about modifications, or there will be some 

modifications to assure water injection to containment or the reactor 

vessel under ELAP conditions reliably. That's a lot of words there that 

drive a lot of requirements. But there's also analysis required. 

So it's not just the engineering design steps. There's 

some analytical steps involved, and some more NRC reviews. The 

plans for that from the industry are due by the end of this year, and then 

it's like another year longer to the end of 2019. So it runs very much 

like FLEX did a couple of years out, but there's more complicated 

analyses when you get to Phase 2. 

COMMISSIONER BARAN: And do you see any 
 42 

challenges in completing this work by the 2018 and 2019 -- 

MR. KRAFT: Not at this time. 

COMMISSIONER BARAN: And I guess, I think for 

folks who are just kind of not following everything very closely, or are 

following it closely, this has -- you know, the hardened vents are kind of 

the long pole in the tent on Tier 1, right? I mean we have so much 

that's going to wrap up by I think 2016. This is all the way out to 2018, 

2019. Do you see any opportunities for accelerating the schedule? 

MR. KRAFT: The schedule is tight as it is, and I have 

to tell you it took some Herculean efforts on the part of industry staff and 

NRC staff, to meet the schedule we have been meeting in terms of a 

document review, document approval. The guidance for the vent is 

well over 300 pages long, with any number of appendices and white 

papers. 

Let me compliment Raj Auluck here, the project 

manager handling that. We have worked very closely on schedules. 

So to suggest that we might be able to shorten that time frame 

Commissioner, I'm not seeing that. 

COMMISSIONER BARAN: Okay, thanks for that. 

Do you have any thoughts about implementation on hardened vent 

order? 

DR. LYMAN: Yes, thank you. Well, we think that 

the -- especially the Phase 2 -- well first of all, the fact that some of the 

FLEX strategies depend on completing that, and so they had to 

be -- the FLEX compliance deadline had to be relaxed to allow 

completion of the vent. 
 43 

That makes sense from our point of view, because if 

they need the severe accident capable hardened vent for their strategy, 

then that's something that might have been sorted out sooner if there, I 

think, had been this more coherent or holistic view at the beginning. 

But I won't press that point. 

On the issue of the Phase 2, we think that there's 

been a kind of -- this is an example of draft. So instead of simply 

requiring a severe accident capable dry well vent, the Commission is 

allowing the industry to pursue these alternative strategies, which 

depend on manual actions. We don't think that a piece of 

hardware -- we don't think that that's necessarily an appropriate 

tradeoff, because you lose something if you rely on manual actions to 

replace what an installed piece of equipment could do, and it's sort 

of -- it's similar to the -- what's down the pike with regard to the external 

filters, and the fact that the idea was perhaps there are manual 

strategies that would accomplish the same as actually installing a filter. 

Now the staff's judgment is that maybe there's no 

justification doing any of that. We think that's inconsistent with the 

philosophy of perhaps requiring this post-core damage manual actions 

as part of the hardened vent order. So we think again there's some 

incoherence there that would be sorted out, only if the whole package 

were evaluated consistently, again with regulatory, proper regulatory 

treatment of all the post-core damage manual actions that are being 

discussed. 

COMMISSIONER BARAN: And so on the 

containment protection and release reduction proposed rule, I don't 
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know where they come up with these names, but so your view is that 

filtered vents should be -- we should take comment on their requiring 

filtered vents as part of that rulemaking? 

DR. LYMAN: Yes. I think the original deal, as it was, 

the Commission approved severe accident-capable vents, but then 

said take more time to evaluate whether you need to filter those vents, 

or whether there are these alternative manual actions that would 

adequate substitutes. 

It doesn't make sense to have severe accident capable 

vents if you are not also addressing the potential for enhanced 

radiological releases from those vents after core damage. So we think 

the Commission's -- there's a commitment to go forward with the 

rulemaking, and to fully evaluate what it said should be considered, 

including the option of external filters as well, and there shouldn't be any 

attempt to walk that back, in our view. You're locked into that. 

COMMISSIONER BARAN: Maria earlier expressed 

the view that water addition strategies would provide an equivalent 

safety benefit to external filters. What are your thoughts about that? 

DR. LYMAN: Well, I'm not completely familiar with all 

the technical analysis, but I think there are questions about again, we're 

talking about defense indepth and there's always going to be some 

uncertainty about the efficacy of that and those kind of management 

strategies, and those could be -- that uncertainty could be reduced with, 

you know, with passive approaches like upgrading hardware as 

opposed to these active approaches. 

And but I'd also just point again to Dr. Stetkar's 
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questioning of the technical analysis that's supporting that -- the 

regulatory basis, and we'll see if the ACRS elevates that a letter. But 

at least his concern is that he doesn't think the technical analysis is 

adequate to support those conclusions. 

COMMISSIONER BARAN: And Maria, just following 

up on that, what further technical analysis, if any, remains to be done 

regarding water addition? 

MS. KORSNICK: In the water addition, I guess let me 

just comment. I appreciate that Dr. Lyman said he wasn't familiar with 

the analysis. Just the work that was done relative to the filtration 

strategy was done through EPRI and through some other external 

engineering firms. I would say it was very robust, very regressed, and 

there's a lot of documentation and we invite his review of that. 

And in terms of severe accident water addition, you 

know, each plant needs to have a view of the particulars for their plant. 

In other words, where things tap off, at what heights things tap off would 

then tell you basically how much volume of water that you would be 

able to add, what flow rate that you would want that water. 

So whereas the filtration strategy analysis that was 

done was on a more, I'll just say broad, maybe more generic basis, 

when you get down to severe accident water addition, each station is 

going to have to make sure that they have a station-specific look, so 

that you know exactly what you want designed. 

So as we said, I think there's 29 plants that this applies 

to. So that would be on track on what would be required for Phase 2. 

COMMISSIONER BARAN: I'm a little over on time, 
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but I just want to ask one final question, which is given the research that 

has been done there and what it's shown, why do you think some of our 

foreign international counterpart regulators have acquired filtered 

vents? 

MS. KORSNICK: I guess, you know, just my opinion, 

but I can just conjecture that really going back to what Commissioner 

Svinicki said, I think in some cases people made some calls very early 

on to make certain requirements, maybe didn't do the depth of analysis 

that others have taken time to do. 

We have done a very indepth analysis of the BWR 

Mark Is and Mark IIs. So there might be other containment types that 

they had a view that that was a better answer for. I feel very confident 

in the rigor of the evaluation that was done for the statement we've 

made, and recently attended an IAEA conference where the NRC 

themselves responded to some questions there, in support of the 

decision that we were going forward for. 

And so again, not only has the industry done very 

rigorous evaluations, the NRC staff also has done very rigorous 

evaluations, and they compliment each other well. 

COMMISSIONER BARAN: Okay, thank you. It 

looks like Commissioner Ostendorff might want to jump in. 

CHAIRMAN BURNS: Commissioner Ostendorff. 

COMMISSIONER OSTENDORFF: I do want to just 

maybe provide one thought in response to Commissioner Baran's 

question on the European approach. I'll just say, and others will have 

experiences as well at the table, so they might want to chime in too. 
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But when I visited Sweden in October 2012, to specifically look at the 

filtered vent installations at Oskarshamn, south of Stockholm, and to 

discuss with the Swiss regulator, excuse me the Swedish regulator, 

why they'd install this. 

I asked what was the analysis from a regulatory 

standpoint that was done to support the filtered vent installation, and 

they said very bluntly there was none. It was done strictly as a 

response to Chernobyl, and it was not pursuant to a scientific or 

engineering regulatory analysis. So that's just one data point for you. 

CHAIRMAN BURNS: Thanks. Any other 

comments? I thank again the panel for your presentations this 

morning and answering our questions. With that, we'll take a brief 

break and try to reassemble at 10:25. 

(Whereupon, the above-entitled matter went off the 

record at 10:18 a.m. and resumed at 10:26 a.m.) 

CHAIRMAN BURNS: If we could take our seats 

again, please, we'll start with our second panel, the NRC staff panel. 

Joining us this morning are Mike Johnson, the Deputy 

Executive Director for Reactor and Preparedness programs, and the 

Fukushima Steering Committee chairman; Bill Dean, the Director of the 

Office of Nuclear Reactor Regulation; Jack Davis, the Director of the 

Japan Lessons Learned Division in NRR; Scott Flanders, Director, 

Division of Site Safety and Environmental Analysis; and Ray Lorson, 

Director, Division of Reactor Safety, NRC Region I. So welcome and 

Mike, please proceed. 

MR. JOHNSON: Thank you. Good morning 
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Chairman and Commissioners. As we sit here today, we're pleased to 

report on the progress that's been on translating the learnings from the 

tragic accident at Fukushima into plans and actions that have, as you 

heard in the previous panel, and will continue to make plants safer. 

The scores of NRC staff that have been working on 

these activities have exhibited great dedication, great determination 

and technical competence, and I think as a result of that, have 

significantly been able to advance what was proposed in the Near Term 

Task Force in the right direction. Of course, the staff's work was 

benefitted greatly by valuable interactions with stakeholders, including 

the industry, including the public and including the ACRS. 

We have continued to maintain our focus on the 

guiding principles that we established shortly after we formed the 

steering committee, that is to not distract ourselves from safety, to be 

disciplined streamload of things that we would be adding under the 

auspices of the Near-Term Task Force, the Steering Committee and 

the JLD. 

We don't want to displace from higher priority work, 

greater safety significance work. We want to make sure that we do it 

right the first time, and we certainly want a sound basis for decisions. 

This is a complex effort, and it does continue to demand our continuous 

attention, to ensure that we get things done in a high quality manner. 

We're seeing plants come into compliance, and with 

respect to the orders, and at least for me, I think that's very exciting. 
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Most importantly, in spite of all of the work that's going on, licensees 

and the NRC have been able to maintain their attention and to ensure 

that plants continue to operate safely and securely. I think that's 

particularly important. 

We do have work to do, as we will continue to discuss 

in the panel. We're confident that we'll be able to reach resolution on 

the 301 items with continued work and focus, and also to move forward 

in terms of serving up for resolution the Tier 3, Tier 2 and Tier 3 

initiatives in a highly effective and efficient manner. 

Bill Dean, the Director of the Office of Nuclear Reactor 

Regulation, will begin our presentation. 

MR. DEAN: So thanks Mike, Chairman, 

Commissioners. Pleased to be with you this morning. Mike's not all 

that happy about the fact that I'm just getting over some bronchial stuff, 

so he's probably not pleased to be sitting next to me. But I'm pretty 

sure my voice will hold out for this presentation. 

Chairman, thanks for introducing the panel. That will 

save me this slide. We can move on to the next slide. So this slide is, 

I think, a pretty nice graphic that shows on one page a pretty good state 

of affairs relative to our Tier 1 implementation. 

We are on or ahead of schedule of everything, except 

for the flooding hazard analysis, and we'll be talking about that a little bit 

more later this morning. I was very pleased that Dr. Lyman noted in 

his opening remarks the fact that there has been great progress by 
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industry and the NRC, relative to pursuing Tier 1 actions out of the 

Near-Term Task Force recommendations. 

I'm very proud of what our staff has accomplished to 

date. It's been almost four years solid of some pretty substantial effort. 

I think the staff has shown a lot of resilience, a lot of creativity and 

innovation, as things have progressed and we've learned more as 

we've gone through this. 

So I'm very proud of the staff, as represented not only 

by the people in the divisions at this table, but also offices like Nuclear 

Security Incident Response, the Office of Research, Office of General 

Counsel have all had major roles on certain aspects of the Tier 1 

activities. So it's a true collective effort on the part of the agency in the 

progress that we've made thus far. 

Relative to the flooding, I do want to point out that part 

of the slide where it shows current projection going into 2019. That 

would be if we were staying the course with the path that we had been 

on. Clearly, we haven't made the progress that we, I think, anticipated. 

I think we overestimated or underestimated the challenges that would 

be before us relative to doing the flooding hazard evaluations. 

I give the credit to -- a lot of credit to Scott and his staff, 

for taking a pretty hard look at themselves and how they can be doing 

these reviews in a more effective and efficient manner, and borrowing 

from a lot of the insights that we've garnered from the SRM we received 

from the Commission on SECY 14-0037, relative to being, you know, 
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more crisper and focusing more on those plans, where really we could 

see some more benefits to safety from doing a flooding hazard 

evaluations. 

Scott will talk more about this a little bit, but the gold bar 

in their enhanced schedule for mitigating strategies reflects what they 

believe to be the progress that they can make in getting information to 

licensees by the end of the year. Mr. Petrangelo talked about some 

skepticism that industry has, given past performance. 

But I have confidence that Scott and his team will be 

able to be successful in meeting the projections that they're putting 

forth. Next slide please. 

So the key message on this slide is that there are 

substantial safety enhancements in place, and substantial safety 

enhancements that are being put in place. So for example, relative to 

the mitigating strategies, the slide before noted that were six plants that 

are currently in compliance with the mitigating strategies order. 

By the end of the year, we anticipate 50 percent of the 

facilities in this country being in compliance with the mitigating 

strategies order. The previous slide noted 18 plants were in 

compliance with the order on spent fuel pool instrumentation. By the 

end of this year, we anticipate 75 to 80 plants will be in compliance with 

the spent fuel pool instrumentation orders. 

So that's real progress, that's real safety enhancement 

that's taking place, and then I appreciate your comment, Commissioner 
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Ostendorff, about some of our external stakeholders that's sitting there 

promote a message that nothing's being done. There's a lot being 

done and is being put in place that's enhancing safety. 

Relative to the reevaluating hazards, the flooding and 

seismic, while there's still a lot of work being done in terms of looking at 

those evaluations, what sometimes gets lost in the dialogue is that all 

the plants were required to put in interim compensatory measures, both 

for seismic and for flooding, and we've evaluated, at least for the Tier 1 

and Tier 2 flooding plants, the interim actions that have been put in 

place, and have found those to be satisfactory, and then the same thing 

for seismic. 

So we're talking about things in seismic like 

anchorages of pumps and tanks and things like that. Relative to 

flooding, we're talking about enhanced protective measures for spaces 

or components utilizing barriers, inflatable barriers, sand bags, things 

like that. 

But it is providing enhanced safety and compensatory 

measures, so that we complete, can complete the longer-term 

evaluations. Relative to other activities, the Tier 2 and Tier 3 activities, 

really the majority of the Tier 2 have either been done or integrated into 

the mitigated beyond design for that rulemaking. 

So really there's not much in terms of Tier 2 that 

remains to be done, and Tier 3 is either on ahead of schedule. We did 

dispose of one Tier 3 action, that being the expedited transfer of spent 
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fuel. That's something that the Commission help disposition earlier or 

last year. So we have actually done some of the Tier 3 work already. 

Next slide, please. So relative to improve deficiencies 

for threat hazard reevaluations, again Scott will talk some more about 

that. But I think it's important to point out that we pout ourselves in bit 

of a conundrum when we embarked on our Near-Term Task Force 

activities, by doing the mitigating strategies order in parallel with the 2.0 

seismic and flooding hazard reevaluations. 

So as the Commission is well aware, and as we tried to 

demonstrate in SEC 14-0037, as it pertains to flooding, it's a very 

complex interrelationship between what's going on in mitigating 

strategy space and what's going on in the reevaluated hazards space, 

both flooding and seismic. 

And so I think the Commission certainly appreciates 

the challenges that we face, in our efforts to try and bring some 

coherence to these sort of multi-path activities, and trying bringing them 

together. 

We do appreciate the support that the Commission 

provided us relative to Recommendation 1, which I thought really was 

the most important recommendation out of that SECY paper, which was 

that the intent is that the mitigating strategies be protected to the 

reevaluated hazard. 

To me, that was the most substantial piece of that, and 

then the Commission affirming staff's belief that that is indeed the case 
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will, I think, help us move forward with a greater degree of clarity, and 

also the recognition by the Commission relative to Recommendation 2, 

that there will be some sites out there because of some very complex 

environmental conditions for those plants, that will need to rely on 

targeted strategies to be able to deal with the reevaluated hazards. 

So we appreciated that endorsement, and even though 

our Recommendation 3, which looked to merge the mitigating 

strategies with the flooding hazard reevaluation integrated assessment 

activities was not agreed to. I think the Commission really gave us a 

lot of great guidance and direction, in terms of how to be able to pursue 

our future endeavors in that regard. 

So all in all, I thought that the Commission direction on 

that SRM was quite positive and very beneficial for the staff. Next 

slide, please. 

So over to the action plan, one of the actions out of the 

SRM for that SECY was to develop an action plan relative to the Phase 

1 and Phase 2 reviews. I'm very pleased to say that we formed a 

working group that consists of branch chiefs and senior staff from both 

Scott's division and Jack's division, working hand in glove to be able to 

develop a plan. 

They've had the opportunity to get insights from Mike 

and I relative to some executive level guidance, and so we're looking 

forward to the plan that they're going to develop. I think it will meet -- 

It will meet all the things that the Commission directed 
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us to do, relative to providing a more efficient and effective approach 

towards achieving meaningful safety benefits out of those processes, 

and I know in talking to many of the Commissioners, there was some 

disappointment in sort of the lack of information we gave you relative to 

what the Phase 2 approach will be. 

So we will certainly reflect on that guidance as to 

what's in the SRM, and provide you in our plan our approach to putting 

a Phase 2 guidance document into place. So with that, that completes 

all of my remarks. I'd like to turn it over to Mr. Davis. Jack? 

MR. DAVIS: Thanks Bill. Good morning Chairman 

and Commissioners. I'm pleased to report out to you on NRC 

Fukushima activities and certainly seek your continued insights and 

guidance and move forward on this work. So with regard to the 

mitigation strategies and the spent fuel pool instrumentation orders, as 

you've heard from the previous panel and Bill as well, plants are coming 

into compliance on schedule, again using existing hazard information, 

as Tony had pointed out. 

I think that while implementation of these two orders 

certainly provides a substantial increase in the safety margin of the U.S. 

fleet, against again unknown and extreme natural phenomenon, that's 

the real thing there. 

The magnitude of this investment is extremely sizable, 

in terms of just safety resources being used by the NRC and by 

industry, as well as the capital improvements, the modifications and so 
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on. It's a sizable effort. 

To ensure an efficient and timely regulatory review of 

such a large magnitude and undertaking, the NRC adapted its review 

processes by instituting an electronic and on-site audit process in place 

of the traditional RAI process that we typically use for licensing actions. 

The audits have proven to be extremely beneficial to 

the NRC, in terms of gaining a solid understanding of what the licensee 

are planning on doing with mitigation strategies, their time lines, the 

feasibility of the strategies, and also early understanding of any of the 

barriers or concerns that they were having as they start to implement 

these particular strategies. 

Likewise, we found that the audits have been 

extremely beneficial to industry, in terms of regulatory risk reduction, 

because they're hearing from us earlier in the process. It helps with 

timely and efficient reviews, because you can have a more continuous, 

if you will, back and forth dialogue on some of the issues. 

And then of course the sharing of knowledge and best 

practices between utilities, and understanding what the NRC has 

looked at from other plants and how you apply that to the plants going 

forward. So it's been a huge success, I think, on both parts. 

I've personally observed and participated in several of 

the audits, and I can tell you that each time there was an efficiency 

improvement in the one from before. 

We continue to learn from them as we move forward 
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and apply that knowledge going forward. Regional staff have also 

been actively involved in the audit process, and they have -- not only 

providing the valuable plant knowledge that they have, but also this is 

very helpful as we start to move from, you know, the licensing if you will, 

and going into the oversight, and Ray's going to talk a lot more about 

that in his presentation here in a little bit. 

We've also participated in industry workshops that 

were designed to share knowledge with the plants that already have 

come into compliance, with those that are scheduled to come into 

compliance over the next several outages, and there was a lot of good 

information sharing, not only from a regulatory perspective but also 

from licensee to licensee. 

So if we talk about specifics, Bill mentioned a few of the 

numbers there. Specifically, we have six units already in compliance 

at the start of the spring 2015 outages. Approximately 25 percent will 

be done by the end of the spring outages. More than half are expected 

by the end of this year. 

The entire U.S. fleet will be in full compliance with both 

of these orders by the end of 2016, with the exception of the 12 plants 

that were -- where compliance is tied to the EA-13-109 order. But 

even with those plants, all of the mitigation strategies requirements 

need to be in place, other than just the piece related to vents. 

And we obviously in accordance with Commission 

direction on COM-SECY-14-0037 SRM, the staff and industry are 
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diligently working towards completion of the mitigation strategy orders, 

that would also be able to protect against the reevaluated hazard by the 

2016 date. You know, as I mentioned the strategies will be in place for 

the design basis piece, but we think that we'll have a good number of 

plants that also could have the reevaluated hazards as well. 

There may be a few plants, just depending on the 

complexity of the analyses, depending on if there had to be any mods 

made or if there's changes that have to be made to their strategies, that 

likely could go beyond that date. But again, we're striving. We 

recognize how important this is as a goal, to make that happen. 

And Scott's going to report out to you briefly also on 

that effort, on what we're doing to accelerate those reviews. 

If I can have my next slide, please. I think it's 

important to note that while good progress has been continuously 

made, there's a sizable amount of work yet to be done, to bring these 

two orders to appropriate closure. Obviously, we're going to continue 

to do the obvious to the plants coming into compliance. Staff will also 

be documenting and completing their safety evaluation reports and 

making those publicly available. 

Then of course staff is -- has been and will continue to 

be supporting the transition of these plants from our licensing effort, if 

you will, over to regional oversight. We had a pilot temporary 

instruction which received diverse stakeholder input. That typically 

doesn't occur, but we felt in this case it was important to do so. 
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We used that TI this past March at Watts Bar to gain 

some insights. Ray again will talk to you about a lot of the insights 

that came out of that. Then we have our next inspection is now 

planned for this fall with the North Anna plant. 

And of course we have a good amount of work to 

achieve Commission direction, again on the COM-SECY-14-0037, not 

only related to the reevaluate hazard for flooding, but also to look at are 

there -- how do we adequately treat some of the plants that may 

require additional amount of regulatory scrutiny, right? 

We have to work ourselves through that process in an 

appropriate way, and then of course there's ramifications to seismic, as 

Bill had mentioned. And then for the Tier 3 items, which talks about 

other hazards, we'd have to look at those underneath this position of 

Tier 3 items. 

And then finally on this slide, we continue to work with 

our colleagues in the Division of Inspection and Regional Support. We 

work with the regions as well on developing an oversight program, that 

appropriately treats the beyond design basis nature of the mitigation 

strategy and spent fuel pool instrumentation orders. 

It's going to be informed by the pilot TI. It will be 

informed by a few additional TI inspections that would go on after the 

Watts Bar one. The general thinking at this point is that the significance 

determination process that we develop needs to be informed by the fact 

that it is a beyond design basis postulated scenario, and of course the 
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large amount of redundant equipment that's available and the diverse 

way in which they can accomplish safe shutdown of the reactor. So 

we think that has to be factored in, and folks are working in that regard. 

Likewise, we're also looking at developing appropriate 

regulatory oversight for the national response centers, and primarily to 

ensure that not only the equipment remains available, but that it's also 

reliable, all right. So you're talking about maintenance and testing, 

those types of things there. 

So if I can have my next slide please? Similar to the 

progress being made on mitigation strategy and spent fuel pool 

instrumentation orders, we are also on schedule for the vents order. It 

was originally issued, as you know, in March of 2012 as EA-12-050, 

and that required hardened vents be installed on all boiling water 

reactors using Mark I and Mark II containments. 

The Commission superseded that order on EA-13-109, 

and they added an additional piece that said it had to be severe 

accident capable. So the additional direction that was provided by the 

Commission dealt with both pre-core and post-core damage scenarios, 

and to make sure that those were adequately treated. So it was a 

good addition. 

As part of that Commission direction, the staff was also 

asked to assess the need for filtering those vents as the previous panel 

was discussing, and we will directly develop either regulatory basis and 

associated rulemaking, if it was needed, and then I'll talk about that in a 
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little more detail on a later slide, and certainly I'm sure you'll have 

questions after that that we can discuss. 

As part of the EA-13-109 order, the Commission did it 

in two phases. Phase 1 requires the installation of the reliable severe 

accident capable hardened wet well vent, and then of course Phase 2 

was for any of their installation reliable severe accident capable dry well 

vent, or strategies that suggest that the dry wall vent is not necessary 

underneath the severe accident conditions. 

The phased approach was really in recognition of the 

relative effectiveness of the wet well vents. You heard Maria talk 

about the fact that that provides a lot of scrubbing of the radionuclides, 

and there was also, I think, to minimize the delays, if you will, in 

implementing some of the requirements that were already in the 

EA-12-050 order, so that we didn't really cause unnecessary delay to 

getting that part installed. 

So licensees submitted their Phase 1 plans in June of 

last year. Staff then did its review. We issued all interim staff 

evaluations for all plants, and that's several months ahead of schedule. 

The ahead of schedule piece is both an indication, I think, of an efficient 

staff review, as well as high quality submittals from the industry. 

The Commission directed schedule, as you know, for 

full Phase 1 compliance has a backstop date of June of 2018. 

However, I think it's important to note that the NRC and industry are on 

track to have nearly 30 percent of the plants done by 2016, more than 
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two-thirds by early '17, and then the remainder by 2018. 

So it's not just we'll all wait until the end. I know you 

had that comment before, Commission Baran, so I think it's important 

to point that out. 

Next slide, please. For Phase 2, the Commission 

established backstop date of course is June 2019 for full compliance. 

We have been working with interested stakeholders to develop 

acceptable criteria to meet that order. In fact as you know, we issued 

the interim staff guidance for Phase 2 earlier this week. 

There are three alternatives in Phase 2 compliance. 

One is that you just have a stand-alone dry well vent that's capable of 

dealing with severe accident conditions. You could also do something 

where you have a dry well vent and then a combination of water 

addition, and then of course there's a third option that just has water 

management, that extends the capability of the wet well vent for a 

longer period of time. 

So they can -- any licensee can pick one of those 

options, and the obviously they have to develop the analysis that Steve 

Kraft had mentioned, to show that they have an acceptable path 

forward. Al indications at this point are that we are on schedule to 

meet the Commission-directed compliance date. 

Once again, Phase 1 and Phase 2 are done. Staff 

will then have to do its safety evaluations and inspections will follow in 

the regions afterwards. We don't feel at this point, unlike mitigation 
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strategies, that there's any need to do onsite audits for Phase 1 or 

Phase 2 of compliance. 

It's just what they have to do onsite is not as complex, if 

you will, of looking on a strategy from, you know, mitigation strategies 

standpoint, where we benefit from the onsite audit portion. I'm now 

going to turn over my presentation to Scott. He's going to give you a 

status of flooding and seismic, and then he'll return it back to me and I'll 

talk more about the rulemaking activities and the Tier 2 and Tier 3 

status. 

MR. FLANDERS: Good morning. Good morning, 

Chairman, Commissioners. Today I'm going to focus on the schedule, 

progress to date and the next steps for the flooding and seismic hazard 

reevaluation activities. As Bill mentioned, we've completed the interim 

action reviews for the Group 1 and 2 plants, and we've determined that 

they are all in fact acceptable for their intended purpose. 

Again, as Bill mentioned, the purpose for the interim 

actions is to provide staff with additional confidence that the sites can 

cope with the reevaluated hazard, while the remaining 2.1 flooding 

activities are completed. For the 16 Category 1 sites that submitted in 

March of 2013, we've issued ten staff assessments, and we're near 

final on two others. 

The other four sites that submitted in March of 2013 

have recently submitted or plan to submit revised hazard evaluations as 

a result of RAIs from the staff, or feedback from the staff or other federal 
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agencies on certain aspects of the originally submitted hazard 

evaluation. 

The review of the Category 2 plants are progressing. 

For the 12 that submitted in March of 2014, the staff has issued RAIs for 

all but two. Those two had self-identified errors and recently 

resubmitted significant portions of their flood hazard reevaluations. 

We expect the RAI responses to be submitted within 

the next few months for most plants, and we anticipate reaching closure 

on the remaining issues by the end of this summer for most of the 

Category 2 plants. 

For the Category 3 plants, we just received them last 

month, all but three, and we're actively redoing the interim actions at 

this time. Of the sites that have been granted extensions over the 

years, nine have not submitted their hazard reevaluations as of yet. 

Most of these are awaiting reports, dam failure 

evaluations from the Army Corps of Engineers, and are expected to 

submit in late 2015 or, in some cases, in 2016. 

In light of the SRM, and Bill had touched on this a little 

bit, in light of the SRM for the COM-SECY-14-0037, that directed the 

staff to ensure that plants address the reevaluated flood hazards 

within their mitigating strategies, we had modified the flood hazard 

reevaluation activities to include feedback on the reevaluated hazards 

for most sites by December of 2015. 

To achieve this goal, we are employing some different 
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approaches that will facilitate closure of the remaining technical issues 

as soon as practical. These approaches will allow us to get access to 

information needed to reach technical conclusions in a timely way, and 

we believe that providing this feedback by December is achievable, 

when we consider the significant portion of the review is already 

completed for a lot of the Category 2 sites, and we are focusing on -- 

primarily on those issues that remain open. 

For the Category 3 sites, we are leveraging 

experiences gained by the Category 1 and 2 sites, to focus our efforts 

on the most critical issues. We also have the opportunity for the 

Category 3 sites to carry out some preparatory review activities, which 

should allow us to reach closure on technical issues a little bit sooner. 

If you flip to the next slide please. This slide shows 

the schedule for the reevaluation activities. If you focus on the 

checkmarks on the slide, those do note the time we anticipate providing 

feedback on the adequacy of the reevaluated hazards on to industry or 

to the sites. 

We will issue letters to them, informing them of -- that 

their site hazard reevaluations are acceptable for use in evaluating 

mitigating strategies. However, for this process to be effective, we will 

need industry to support technical meetings and audits, in order to 

expedite the sharing of information with the staff. 

We'll need the industry to respond in a timely way to 

RAIs, and we will also need licensees to limit changes to their current 
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submittals to only correcting staff or licensee-identified errors. Based 

on the input from industry, providing feedback on the hazards by 

December 2015 would allow licensees in most cases sufficient time to 

identify and implement any necessary changes to the mitigating 

strategies equipment installed in response to the order. 

These letters we intend to issue in two batches, one in 

August and the second in December. However, for the sites that have 

not submitted their hazard reevaluation reports, we estimate that about 

a half a dozen will not submit in time for us to provide feedback by 

December of 2015. However, we'll try to provide feedback to them as 

soon as possible. 

If I can have the next slide, please. This slide is a high 

level schedule for the seismic reevaluation activities. The seismic 

hazard reevaluation activities continue to be completed on schedule. I 

want you to focus your attention again on the time line to provide early 

feedback on the adequacy of the seismic hazards, again denoted by 

the checkmarks. 

The original plan for the seismic reevaluations always 

included providing early feedback. But for the purposes of supporting 

the seismic PRA, information for the seismic PRAs. For the central 

and eastern United States plants, the staff provided feedback on the 

adequacy of the seismic hazards in 2014, and we intend to provide 

feedback for the western U.S. plants no later than December of 2015. 

This feedback should not only support the seismic PRA 
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schedules, but it can also be used to assess mitigating strategies. We 

are currently working to develop guidance that will describe the 

analyses that are needed beyond what was done solely for the 

expedited approach, to demonstrate that the mitigating strategies can 

protect against the reevaluated hazard. 

May I have the next slide please? We are making 

significant progress on the seismic hazard reevaluation reviews. For 

the central and eastern United States plants, we've issued -- we issued 

last May a letter summarizing the results of our screening and 

prioritization, and our review of the interim evaluations. From the 

results of the interim evaluations, the staff concluded that there were no 

immediate safety issues, allowing us to take the time we needed to 

complete our 2.1 activities. 

We've completed our review of the ground motion 

response vectors for all central and eastern United States plants, and 

we've completed and issued several staff assessments ahead of 

schedule. We plan to issue all of the staff assessments for the central 

and eastern United States plants by the fall of 2015. 

The expedited seismic plant evaluation program 

reports were submitted on time by the industry. Staff is actively 

reviewing these evaluations. A few licensees did identify minor 

modifications, such as adding anchor bolts or supports to further 

enhance seismic safety. 

The expedited seismic evaluation program calls for 
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these modifications, if the capacity of certain Phase 1 installed 

equipment cannot withstand up to two times the design basis hazards, 

and that these modifications will need to be completed by the end of 

2016, unless it's needed -- a plant outage is needed to implement the 

modification. 

For the western United States plants, we received the 

reports last month with some additional information this month. The 

hazard reports and supporting submittals are thousands of pages long. 

Unlike the central and eastern United States plants, industry and staff 

did not have the benefit of fully developed seismic source and ground 

motion models. 

So the level of effort is significantly higher for both the 

licensees and the staff. We have completed our interim evaluation 

reviews, and concluded that there are no immediate safety issues. We 

intend to issue a letter summarizing the results of our screening and 

prioritization and the results of our interim evaluation reviews by 

mid-May. 

Next slide. In addition to completing our work on the 

western United States plants and also completing the staff 

assessments for the central and eastern United States plants, we are 

also working with industry on further guidance for the high frequency 

and spent fuel pool evaluations. 

Good progress is being made on both of these issues, 

particularly the spent fuel pool evaluations, where the staff and industry 
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are working together to develop additional guidance which meets the 

original intent of the evaluations. The additional guidance will build off 

of previous spent fuel pool studies, and likely utilize review methods 

that can be applied to groups of plants, and focuses on the most 

risk-significant aspects of the spent fuel pools. 

This helps reduce the effort on the part of licensees 

and the staff, while maintaining our safety focus. Consistent with our 

May 9th, 2014 letter, we're evaluating certain plants that screen in for 

further risk evaluations, need to conduct a seismic PRA to inform our 

regulatory decisions. 

We are considering several factors to help assess the 

likelihood that a cost beneficial safety enhancement would be identified 

for those plants with relatively minor differences between the design 

basis and the reevaluated hazard. For sites to screen in for further risk 

evaluation, the Group 1 plants are expected to submit by June of 2017, 

and we're actively working with industry to develop a supplemental 

template to support high quality submittals. 

After completion of the seismic PRAs, of course the 

plants will enter into Phase 2. The staff has identified Phase 2 

preliminary decision-making criteria for seismic, and we recently 

initiated outreach to stakeholders on these criteria. Although 

stakeholder interactions have been limited and the discussions on the 

topic has just begun, the interactions have been positive, and it appears 

that alignment could be achieved relatively quickly. 
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With that I'll stop, and turn it back over to Jack. 

MR. DAVIS: Thanks Scott. So moving on to 

rulemaking activities, here again we are on schedule for this activity. 

The draft rulemaking package will be submitted to the Commission 

actually today, and it was certainly a significant undertaking by staff of 

many different offices. It's benefitted from extensive interactions with 

external stakeholders, as well as the Advisory Committee on Reactor 

Safeguards. 

And we often refer to it as mitigation strategy 

rulemaking, but it goes well beyond just codifying EA-12-049. The rule 

includes lessons learned since the Fukushima accident, and then also 

other regulatory initiatives that I'll address on the next slide. 

And I'm not expecting anybody to be able to read this. 

It's really -- it depicts the scope of the mitigation strategy rulemaking. I 

acknowledge that it's busy, but it's in large part to the significant number 

of post-Fukushima regulatory initiatives that are actually included in this 

rule. 

The combination of many of these initiatives, I think 

was appropriate because a lot of the emergency response type of 

activities, by necessity, had to be a part of the mitigation strategies, if 

you will. So I mean that just had to be incorporated, and then there 

was other efficiencies and effectiveness reasons for combining some of 

these things. 

In addition to the EA-12-049 that it's going to codify in 
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EA-12-051, just to point out a few other things. It will also include 

integrated response capabilities, consisting of strategies and guidelines 

to go for beyond design basis external events. Large areas of the 

plant, due to explosions and fires will be included, severe accidents of 

course. 

It does have the requirements for SAMGs, which is 

currently a voluntary initiative, and then the integration of those 

SAMGs, which I think is the important part, with existing emergency 

operating procedures. It also includes enhanced emergency response 

capabilities that address the multi-unit, multi-source events in a reactor 

and spent fuel pool at a single site. That's an important piece to it. 

It includes training, drills and exercises. You've heard 

a lot about that in the first panel there, with the concern there. It has 

change control, a process for new requirements, and then of course it 

includes issues on decommission activities, just to name a few. 

If I can have the next slide, please. Another 

post-Fukushima rulemaking activity is the containment protection and 

release reduction rulemaking. This is formerly known as the filtered 

vents rulemaking. The staff will be submitting an information paper to 

the Commission here in the near term. We think it's somewhere 

around the end of May, with the current status and plant path forward 

for that activity. 

The paper won't be seeking Commission approval, but 

it will notify the Commission that at least our current analysis indicates 
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that there is an adequate justification to impose a requirement to install 

filters on the dry well vent. Again, we talked a lot about the fact of the 

scrub being with the wet well and so on, and how much benefits you get 

from that, and I think that's important to recognize. 

The staff then will subsequently seek stakeholder input 

on the draft regulatory basis, and then plans to finalize that by 

September of this year. We then also plan to codify the severe 

accident capable hardened vents order, the EA-13-109, including the 

provisions for water addition, which is a very important piece. Then we 

plan to provide that proposed rule to the Commission in September of 

next year. 

If I can have my next slide. Now just transitioning 

quickly to Tier 2 and Tier 3 priority Fukushima activities, I'd like to 

discuss the progress we've been making here. Again, another busy 

slide, but the color coding kind of gives you a quick visual on the status 

of these activities. 

I want to remind the Commission, there was a reason 

why we tiered these things, right. Tier 1 was something that we 

needed to do without delay. Tier 2 and Tier 3 was either because we 

didn't have resources available to address those, because they were 

working the Tier 1, or we might be able to benefit from international 

activities or we needed some more early insights, if you will, through a 

couple of studies and so on like that, to determine what their 

appropriate path would be. 
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So staff developed project plans for these activities 

and provided them to the Commission in SECY-12-0095. Progress 

has been made on many of the recommendations consistent with that 

schedule that we provided, and in fact some cases we accelerated the 

schedule, by either combining some of the lower-tiered items with Tier 1 

activities, or actually just accelerating the schedule on certain ones. 

You know, for example, the one that you see at the top 

there, which is on expedited transfer of spent fuel from pools to dry 

cask, that was done ahead of schedule and pulled up early. So that's a 

complete item. The blue items that you see on the slide, those have 

been subsumed into the higher-tiered activities, such as mitigation 

strategies. 

The pink items that are in progress, to some capacity 

there's a number of components that go along with those things. We 

just listed the highest item there. And then of course the black items 

that you see at the bottom, they're still being developed. But they're 

still consistent with the existing project plans that we provided the 

Commission previously. 

Next slide, please. So over the last couple of months, 

staff has been actively going back through those project plans, and 

considering the remaining items that have to be developed, looking at 

the lessons learned that we have to date. We have had evolved 

thinking. I've heard Commissioner Svinicki talk about that many times, 

about how our thinking has evolved over these many years. 
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So we're relooking at those things, and determining 

whether we have adequate information to disposition those, or whether 

we could take an action sooner, or whether we need more work to be 

done. And staff expects that we'll have many opportunities for 

stakeholder involvement, and we know a number of those items are 

important to a number of our stakeholder. 

As we move forward with engaging the Steering 

Committee internally and the EDO and so on, we'll have opportunity for 

them to comment on that. And then staff plans to obviously engage 

the Commission, to either inform you of the results of our evaluations 

and receive your feedback on our conclusions. 

Although not included in the slide that I showed 

previously, there was an item that we looked at other regulated 

facilities, to determine if there was any post-Fukushima lessons learned 

that should be applied to those. These are fuel cycle facilities, 

irradiators, RTRs, things like that. 

There's a paper that's being finalized and we plan to 

submit to the Commission in the next month or so, to talk about what 

we think needs to be done there. I'll now turn over the presentation to 

Ray, and he's going to give you a regional perspective on how 

Fukushima's been going. 

MR. LORSON: Thank you, Jack. Good morning, 

Chairman and Commissioners. 

As you know, the Regions play an important role in the 
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NRC's response to the Lessons Learned from the Fukushima accident. 

Inspectors are the Agency's eyes and ears for verifying plant safety and 

operational readiness. We have and continue to inspect 

post-Fukushima requirements to insure that these requirements have 

been properly implemented. Our insights and oversight in these areas 

plays a key role to insure the importance of these programs. 

Regional involvement also facilitates effective and 

efficient communications with external stakeholders. We're often the 

first point of contact for members of the public who want to know what 

has been done, and what can be done. Our continued involvement in 

the post-Fukushima activities allows the Regions to provide timely, 

up-to-date information to all of our stakeholders. 

The Regions have been involved in a number of ways, 

including we participate in many of the audits that Jack had mentioned 

previously. We've also been involved with the development of key 

program documents, such as Temporary Instruction, or TI-191 that was 

issued in October of 2014 to inspect the compliance with the NRC 

orders. 

While these post-Fukushima modifications or activities 

are ongoing, it's important to recognize that if they're not conducted 

properly, they can have an impact on operating plant safety. To that 

extent, our inspectors in the field implementing the Reactor Oversight 

Program play a continued key role to insure the safety of these 

modifications as they're being implemented. 
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For example, implementation of these modifications 

involves heavy industrial activities that can involve lifting heavy loads, it 

can involve the movement of large vehicles, and it can involve 

breaching or modifications to existing systems. As these activities are 

occurring, through our Reactor Oversight Program we're insuring that 

they're being conducted safely. 

We have identified some issues as these modifications 

have been implemented, including a case at one facility where a piping 

modification led to the exposure of a section of piping to a missile 

hazard. And another case where installation of a pipe modification led 

to the partial drain down of the refueling water storage tank. We insure 

that the propre actions are taken for issues as these, when they're 

identified. Next slide, please. 

As I just mentioned, TI-191 was issued to provide 

inspection guidance to insure that the NRC orders have been 

effectively implemented. The TI focuses on three main areas, including 

verification that mitigating strategies are in place to protect against 

large-scale events. Secondly, to verify that the licensees have installed 

reliable instruments to measure the level in the spent fuel pools. And, 

lastly, to insure that communications, equipment, and staffing have 

been developed to insure the response to multi-unit and to events that 

involve an extended loss of AC power. 

An important aspect of implementing any Temporary 

Instruction is to insure that the inspectors are adequately and 
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appropriately trained. We have received training from our Headquarters 

Subject Matter Experts on the implementation of the TI. 

In addition, the pilot TI was conducted at Watts Bar 

back in March of 2015, and we observed that with inspectors from all 

four of the Regions participated in that TI to understand the inspection 

requirements, and also to gain insights on any areas where the TI could 

be further improved. 

The last thing I would like to mention in this area is that 

to insure a consistent reliable assessment of any findings that are 

identified from the TI, we plan to conduct cross-regional assessment 

panels so that all findings will be commonly reviewed from inspectors 

from all four Regions, and from NRR to insure consistent reliable 

treatment of findings. Next slide, please. 

As I noted just a minute ago, the pilot inspection of this 

TI was completed just a little over a month ago, and while the final 

inspection report has not been issued, the results are considered to be 

pre-decisional and I cannot go into great detail in this forum regarding 

the results, but I can mention a few highlights. 

First off, the overall assessment is that the licensee 

conducted an effective program for implementing the mitigating 

strategies that were required by the order. Having said that, there were 

a few items or issues that were identified involving things such as 

consistency between plant labeling and some of the procedures, and 

also a question was identified related to how the post-Fukushima 
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requirements and mitigating strategies were going to be implemented 

for all modes of plant operation. 

In the picture in this slide we see Jeff Hammond, who is 

the Resident Inspector at Watts Bar, and he was also a member of the 

pilot TI Team. Here he's conducting a walkdown to verify that 

equipment, labeling, and procedures are adequate to support 

implementation of the mitigating strategy. 

As I mentioned, a key benefit by having inspectors 

from all of the Regions participate in the Pilot TI was to gain insights 

regarding implementation of the TI. We'll take the Lessons Learned out 

of the pilot to make the procedure even better. One of the early 

questions or findings we've got in that regard was should we provide 

more guidance in the Temporary Instruction to inspect the civil 

structures, the structures that are used to house the FLEX equipment, 

so that's something that we're looking at as a method or potential 

enhancement to the procedure. 

Last point I'd like to make is that implementation of the 

FLEX TI will be completed here in the next few years, but the need to 

maintain the equipment in a robust and reliable state will continue. To 

that extent, we will be integrating the TI inspection requirements into 

our Reactor Oversight Program so that this will become a routine part of 

how we do business. 

And with that, I will turn it back over to Mike Johnson to 

talk about international involvement. 
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MR. JOHNSON: Thanks, Ray. 

So, I want to just turn for a minute to provide an 

international perspective. I would say that based on a lot of interactions 

that we've had with our international partners, we do believe that the 

actions that we're taking are generally consistent with the actions that 

have been taken by other regulators around the world. The world 

community of regulators and the industry are insuring protection from 

beyond-design-basis external events, they're strengthening mitigation, 

and they're strengthening emergency response capabilities. 

Of course, the actual specific changes that are being 

made in any individual country do vary based on the country-specific 

factors, such as to what extent, for example, they had safety initiatives 

in place, already in place, I guess I should say, before Fukushima. 

The NRC's views are routinely sought by our 

international partners with respect to how we are proceeding on the 

Fukushima Lessons Learned, and we also through active engagement 

with those international partners learn from our international partners, 

and that informs what we do with respect to our posture going forward 

as it relates to the Fukushima Lessons Learned activities. Last slide, 

please. 

So, in conclusion, I just wanted to point out that while 

we are implementing post-Fukushima safety enhancements, we are 

continuing to maintain a strong focus on operational safety and 

security. That continues to be our mantra. 
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As we've noted, we do continue, we have continued to 

make continuous progress and safety improvements are in place. We 

are realizing those safety improvements in the plants today. 

We continue to look for ways to, as we go forward to 

continue to integrate, to continue to improve our efficiency and 

effectiveness as we move through the remaining activities, and 

continue to not lose sight on pushing to completion on these very 

important activities. 

That completes the Staff's presentation. We're ready to 

take your questions. 

CHAIRMAN BURNS: Well, thank you. I want to thank 

the Staff for the comprehensive presentation. Commissioners Svinicki 

and Ostendorff have been on this journey the last few years. I sort of, as 

counsel, was involved very early on in terms of helping to advise the 

Commission in terms of dealing with the Near Term Task Force, and 

then took my brief sabbatical, but tried to watch from afar. But what I 

want to express appreciation for to the Staff is for really getting me back 

up to speed as I re-entered the NRC; because, again, as much as I tried 

to maintain sort of an awareness while at OECD, you know, it's difficult 

to do. And, also, you know, sort of the thinking is how the Commission 

and how the Staff has worked through the various aspects of the 

recommendations, reformulating thought, and you've given a lot of 

good thought. 

COMMISSIONER SVINICKI: We were busy while you 
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were gone. 

CHAIRMAN BURNS: I think --- yes. I was, too, but in a 

different way. But, no, I do appreciate that, because a lot of times, I 

think --- and don't get me wrong. I think, again, with the extraordinary 

work that the Near Term Task Force did in those 90 days is something 

to be commended. But then I think going the next step is thinking 

through how we proceed, how we look at the various aspects, in some 

cases adding ideas, or thinking about we need to look at this issue. So, 

that's been very helpful for me from the Staff in terms of getting me 

refamiliarized, and also preparing me --- had the opportunity, 

particularly with the FLEX equipment, to see, go down to North Anna 

which happened to be the first nuclear power plant I ever went to in 

1978, and the first one I did when I returned late last year. But to see it 

also at North Anna, and also at Watts Bar, it was very valuable for me. 

And one of the other reflections again from --- I'd have 

from sort of my past experience; and, again, most of my experience as 

counsel to the Staff here and there, is --- and I think it's a real credit to 

the Agency, to the Commission, and to the Staff in terms of the focus on 

moving through wisely and smartly on this. I know I worked early in my 

career on implementation of the TMI Action Plan with the Staff, and 

there's a --- I'll call it an apocryphal characterization of sort of 

--- perhaps chaos is the wrong word, but such a bulk of items, and 

whether --- in terms of the time it took, and the thoughtfulness in terms 

of some of the things that were added on. And that's something that the 
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Staff and the Commission did here, and it is one of those things which 

is, I think, one of the great things about this Agency in terms of learning 

lessons from its prior experience, has been very focused in terms of 

moving through and committed to bringing resolution to the various 

issues. So, again, I think that's a good appreciation on my --- I want to 

express my appreciation again for the --- I think the focus particularly 

the Staff has had on that. 

And I know, to echo what Mike said, certainly, you 

know, one of the things I saw in the three years in Paris with OECD is 

the real engagement that our Agency has had with our foreign partners 

through the Committees both through the NEA, but also through the 

IAEA in terms of working through these issues. Certainly, I mean, that 

engagement I think has been very valuable. And I think as Mike said, I 

think we've learned from it, but there's a keen interest in terms of what 

the United States is doing, why we do it. And I think a very healthy 

dialogue from --- you know, for example, what I could observe through, 

for example, the Committees at NEA, the Committee on Nuclear 

Regulatory Activities, and the Committee on Safety of Nuclear 

Installations in terms of the --- and the particular projects. 

I think Mike may have mentioned a particular project 

through NEA on hydrogen, which will help inform us in terms of the 

--- some of our Tier 3 activities. So, again, you know, my own 

observation, this is, you know -- both our own activities here in the 

United States, but internationally have been very important. And I think 
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really, while we may have differences with some of our foreign partners 

about approaches, I think the commitment and engagement on safety 

issues has been really top notch. So, I just wanted to express that as I 

began. 

Mike, since I mentioned the international activity, are 

there other particular --- you might describe, if you would, some of the 

other things that we've been doing in that regard. 

MR. JOHNSON: Well, I think, Chairman, you hinted at 

them. We are actively engaged, as you indicated, through the Nuclear 

Energy Agency, and those activities with respect to the Steering 

Technical Group in looking at Fukushima, I would say Near Term 

activities that were Lessons Learned for Fukushima. We continue to be 

engaged at the committee level in those various committees and 

working groups moving through those activities. 

In a similar fashion, we are engaged in the IAEA 

activities, both from an understanding of what's going on with the 

standards from a perspective of participating in missions, for example, 

and looking at sharing through peer review activities, looking at other 

countries, so that's an area of active engagement for us. 

We are engaged in research that is going on 

internationally and all of those important activities to make sure that we 

continue to partner, garner insights, and move forward. So, again, there 

really is a healthy engagement in the international community to make 

sure that we move along, all of us, in terms of putting in place real 
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lessons. 

CHAIRMAN BURNS: Okay, thanks. 

I sort of asked this question to Tony Pietrangelo on the 

last panel, but from the Staff's standpoint, it can be any one of you, what 

would you say are the really --- the hard points or push points in terms 

of your continued progress? What --- if you'd highlight for me that. Jack 

can do it, or actually Scott, or Ray, as well, from your own perspective. 

MR. DAVIS: I'll take a first shot at it. Certainly, I think 

getting the Reevaluated Hazards into mitigation strategies is a 

challenge going forward. I don't think it's insurmountable, but I certainly 

think it will take some focused effort, as Tony had mentioned. 

The other things that we have ongoing are all on 

schedule. But, certainly, as you go into implementation you sometimes 

run into situations you didn't anticipate, and that's why you saw some of 

the relaxation requests that were coming through later on as we were 

moving along. So, in those two areas, but we're well aware of those, 

and we're continuing to watch them, so I think that's probably what I 

would say. And I would welcome anyone else's comments. 

MR. FLANDERS: Yes, I would second Jack's view in 

terms of the challenge associated with now considering the 

Reevaluated or mitigating strategies against the Reevaluated Hazards 

for both seismic and flooding. I mean, a lot of the attention has been 

focused on flooding in terms of the need to finish the completion of the 

hazard reviews which has its own set of challenges associated with 
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that, which we've discussed and can talk more about. 

Also, on the seismic side in terms of demonstration that 

the licensees' mitigating strategies can actually cope with and address 

the Reevaluated Seismic Hazard; for certain plants, I think is going to 

be --- is going to require some level of effort to come up with that 

guidance in a timely way, and then to actually execute the guidance in 

terms of doing it on the part of the industry and in the Staff's review, as 

well, on the timeline that we're looking at. 

CHAIRMAN BURNS: Okay. Ray, anything from the 

Regional perspective? 

MR. LORSON: The only thing I would add is that it's 

important as we do these analyses and as we do these audits that we 

develop a well-founded licensing basis. You know, the field inspectors 

when they go out, it's important that we know what the criteria are, and 

we have clearly defined criteria. And I think we've been successful with 

that. I think the audits that Jack's group has been doing has been 

helping --- very helpful in that regard. 

CHAIRMAN BURNS: All right, thanks. 

One issue Dr. Lyman raised was this issue on the 

Westinghouse reactor coolant pump seal issue. Could you let me know 

what the Staff's thinking is on that issue? 

MR. DAVIS: Yes. Certainly, he raises a legitimate point 

that it can impact upwards of 13 plants. Actually, it's somewhat less 

than that because some folks have taken action already to put in an 
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additional seal package, like a shield seal, or something like that. But, 

certainly, the NSAL, the 14.1 and the 15.2 NSAL that was put out by 

Westinghouse certainly does, or could potentially impact the strategies, 

particularly the timelines in which they're doing something. And we're 

actively engaged with the Owners Group right now, we're actively 

engaged with Westinghouse to try to understand it better, and then 

understand what viable paths are forward other than just changing a 

mitigation strategy at this late stage. 

Certainly, it would even impact some of the plants that 

are already in compliance, so it's a legitimate issue. We're working 

through it. We think that there's a resolution path for it. And, again, I can 

go into a lot more detail if you want on the specifics of what it involves 

with the over-pressurization and leak, but I think probably I've given you 

enough for right now. 

CHAIRMAN BURNS: My time is up. Commissioner 

Svinicki. 

COMMISSIONER SVINICKI: I want to thank all of you 

for your presentations and all the hard work that your presentations 

represent done by both you and others on Staff. So, again, we have 

done a lot, and I appreciate Chairman Burns' reflection on that, having 

stepped away from it and then coming back. I'm sure the magnitude of it 

is even more significant having had that perspective of stepping away 

for some period of time. 

Mike, I appreciate --- I think we haven't really focused 
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on you. You started with one of the most important things that was 

discussed today, which is the Guiding Principles that the Staff uses in 

focusing on this work. Since they weren't on the PowerPoint, I'll repeat 

them just really quickly; do not distract from safety, be disciplined in the 

screening of additional issues, do not displace work of greater 

safety-significance, do it right the first time, and establish a sound basis 

for a decision. So, it is really important, I think, to keep those principles 

in mind. 

As an outgrowth of what I said to the first panel, I might 

actually say to you those principles are more important than ever now, 

this many years out from the event. I actually am developing that view, 

that it is important what you do initially, but it's very, very important that 

you keep that perspective all along the way. Otherwise, I think you can 

find yourself on a bit of a hamster wheel, so I think it's important that we 

focus on that. 

Some specific topics, on the flood hazard reevaluation, 

the Commission Majority not having adopted --- as a matter of public 

record, I voted for the Staff's recommendation, but that was not the 

outcome. But in today's presentation, the statement was made, so for a 

new process for the integrated assessment going forward that Staff is 

developing as an outgrowth of the Commission's Staff Requirements 

Memorandum, the statement was made, "For the process to be 

effective, we will need industry to support technical meetings and 

audits. In order to expedite, we will need them to share timely 
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information with the Staff, we will need industry to limit changes to 

current submittals to only correcting errors." 

So, please assure me that the Commission having 

elected the more prolonged of the options in front of us, we do not now 

make it industry's problem to make up the time difference. 

MR. FLANDERS: Yes, I think there's a couple of 

points. I'll start, Mike, and then you can certainly jump in. 

Those statements were relative to completion of the 

Reevaluated Hazards. Completion of the Reevaluated Hazards is 

necessary regardless --- it would have been necessary regardless of 

the outcome of the Commission vote on the COMSECY. So, those 

statements go really to this desire to actually complete the evaluation of 

the mitigating strategies against the Reevaluated Hazards before 2016. 

That desire has now created a need for us really to try to get the 

hazards in the hands of the licensees, or agreed upon hazards in the 

hands of the licensees as soon as possible. That's a fair request on 

their part in terms of needing that in order to be evaluated. 

So, in order for us to accelerate some of these 

activities, there are certain things that have been a constant challenge 

as part of completing the hazard review. And those statements go 

directly towards the things that have been a constant hazard ----a 

constant challenge in completing the hazard reviews. 

For many plants, we've had situations where the 

licensee would come in and would have used one approach in their 
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original submittal. Staff spends time reviewing it, sends a Request for 

Information, and then gets a new, entirely new analysis. That creates 

challenges. It pretty much puts you back to square one for reviewing 

certain pieces of information. 

There have been times where, and recognizing if you 

think about it from the licensees' perspective, there's a number of things 

that they're working on, so when you send them a Request for 

Information, they may say I can't get around to answering this for three 

months, six months, whatever period of time. And, of course, that also 

creates a challenge in terms of when the Staff will get responses. So, 

those comments really go to the need for both of us --- both --- not only 

those are for industry, but also for ourselves, to really agree that we are 

going to make this a priority to complete these reviews as timely as 

possible. So, I don't think that's intended to put --- 

COMMISSIONER SVINICKI: Okay, and I appreciate 

that assurance. As I said, contextually, it could sound different. So, as I 

said, please assure me --- 

MR. FLANDERS: I appreciate the question. 

COMMISSIONER SVINICKI: --- that that's not the 

purpose of those statements. So, I appreciate that. 

MR. JOHNSON: Commissioner, can I also just add? If 

we've been successful, and I think Maria made this point, actually, in 

the first panel. If we've been successful at anything, I think, in terms of 

working with the industry on these items it's been to jointly put our 
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heads down and do the work that it takes to move forward. 

I think I heard in the first panel, what I've known about 

the industry, and that is they're committed to do that. We are also 

committed to working through these items. You didn't hear any 

difference on us with respect to milestones and desires to meet those 

milestones, so we will, in fact, move forward. 

COMMISSIONER SVINICKI: Okay. Well, it is --- I 

mean, it's a significant body of work on both sides, so we do also need 

to be able to take the requisite care and attention, again, for both us and 

for the submittals to be of quality. So, I am a little worried always when I 

see well, we've got to limit changes, and we've got to do this, and we 

also have to do it right. That was one of your principles that I began 

with, so I appreciate keeping that front of mind. 

In the Staff's six-month status, the fifth six-month 

status update on Response to Lessons Learned from Fukushima, that 

was a Notation Voting Paper for the Staff. This goes back to the middle 

of last year. In there, there was Combined Rulemaking that was 

proposed. It was approved by the Commission. It was described in 

Enclosure 6 to the SECY Paper, but in that enclosure about this 

consolidated rulemaking, the Staff made the following commitment. 

And, again, this was approved by the Commission. So, the Staff made 

the commitment that, "The Staff understands that different portions of 

the consolidated rulemaking will have different backfitting justifications 

under 10 CFR 50.109. And, accordingly, portions of the consolidated 
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rulemaking may not be supportable in accordance with the provisions of 

10 CFR 50.109." 

"The Staff," again, this is the Staff's commitment. "The 

Staff will also need to determine whether the consolidated rulemaking 

will be inconsistent with any applicable issue finality provisions in 10 

CFR Part 52. As such, the Staff intends to construct the consolidated 

rulemaking with this in mind, and enable any requirements that do not 

meet the backfitting or issue finality requirements to be bifurcated from 

the consolidated rulemaking at the final rule stage." 

Can you assure me that in the development you have 

fulfilled that commitment in that when the Commission receives 

consolidated rulemaking language to vote on, it will be possible to 

excise, if the Commission should not join the Staff in some of its 

backfitting, or in terms of its look at the technical, or regulatory basis, or 

justification for requirements. Is it possible to have these bifurcated 

things excised out of the proposed language? 

MR. JOHNSON: Yes, Commissioner. I can assure you 

that was our approach in developing the proposed rule. I think as we 

move through the proposed rulemaking stage and engage in public 

comments, for example, we will, and the Commission ultimately 

decides, will be able to either move forward with that entire package as 

it's proposed, or we'll be able to separate out pieces. The discussion 

--- harken to the discussion on SAMGs, for example. It's entirely 

possible that we can, because of their differences in terms of how they 
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were --- the status, I guess I would say, they had, as we move forward 

into putting these together we'll be able to partition them out, if you will, 

as we go forward. 

COMMISSIONER SVINICKI: And, again, it was the 

Staff's commitment, but I commented very favorably on it in my vote on 

that particular paper, because what it allows the Commission to do is 

not set back the entirety of an effort, which is a very significant 

undertaking. And I think where you can do that -- you know, 

Congressional staff often in proposed statute has what we call 

bracketed text, meaning it can be dropped out if there's not support for 

it. And it's a little more work, but to the extent you can structure for 

decision makers to say if you don't join me in this conclusion, then it's 

kind of modular. So, again, I was favorable on it. I think it's extremely 

helpful so that we can keep decision making going forward in a 

structured way. 

So, we have --- I've just a minute left, and we have a 

meeting that I believe we'll be noticing specifically on the proposed rule, 

itself. I think we're doing that in July, so I don't want to --- I look forward 

to what will be delivered to me today. I don't know if I'll take it home over 

the weekend or not. I'm kind of behind on some other things. I hope it's 

that thick, because you've got your work --- 

MR. JOHNSON: It's thick. 

COMMISSIONER SVINICKI: --- cut out for you. But, 

you know, I think you have a sense, I've telegraphed a bit, that we need 
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to look really closely at a justification, which if the descriptions are 

accurate, reads to me like well, Commission, take this thing that there 

was never a basis. It was a voluntary initiative because there was not 

--- we could not substantiate a basis to make it compulsory. Make it 

compulsory now, Commission, as part of regulations. I'm talking about 

the SAMGs; because you get more safety. I think enhanced 

defense-in-depth is at the highest level saying well, you'll enhance 

safety, and you'll add more measures of safety. 

You know, Mike, your time here at NRC makes my 

eight years look like nothing. You know, that's a big, big ask, because 

that's your asking someone to take a real leap with you. I may not be 

able to take it, but it certainly, I'm sure, will engender a really, really 

significant debate back and forth. 

And I take as a very sober thing the Commission's 

ability under law to have the authority to say I deem this a matter of 

adequate protection. It sounds almost regal, you know, like a royal 

proclamation of some kind. But with that kind of authority comes the 

need to be extremely prudent in using it. So, we have a lot of authority 

to compel, but the reason we're the gold standard is the quality of work 

that we have historically done. And I'm not sure if this is the kind of level 

of substantiating a basis for something that is the kind of work that 

earned us the gold standard label. I'm just being really, really candid 

with you, but I'll be taking a very close look at that. And I yield back. 

Thank you. 
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CHAIRMAN BURNS: Thank you, Commissioner. 

Commissioner Ostendorff. 

COMMISSIONER OSTENDORFF: Thank you, 

Chairman. Thank you all for your presentations. I want to add my 

thanks to that of my colleagues to not just you at the table, but all the 

Staff behind you, and the Staff throughout the NRC in support of other 

offices, such as OGC, for your strong adherence to our principles of 

good regulation throughout this entire process. Has it been completely 

smooth? No, nothing hard like this will ever be completely smooth. 

There will be bumps and hurdles, but I think you've maintained a focus 

on principles, as Commissioner Svinicki has talked about, in Mike's 

opening statement. And as important as those individual principles are, 

but the broader principles of good regulation. 

I'm particularly impressed with the extent and scope of 

continued and ongoing stakeholder engagement, public meetings, et 

cetera. I won't ask what the last count is on this, but I know it's been 

very significant. 

I was thinking about Mike Johnson, to thank you for 

your continued leadership with this effort. I know that continuity is so 

important to have a strategic leader guidepost for the Staff, so thank 

you for what you've done in that area, Mike. 

Bill, I want to talk to you real quick just to comment on a 

comment that you made that I thought was important. You mentioned 

the conundrum of direction four years ago, four and a half years ago to 
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proceed for the External Hazard Assessments under Recommendation 

2.1, in parallel with addressing what started out as Station Blackout, but 

then morphed into FLEX, and morphed into Mitigating Strategies, and 

the rulemaking we'll see, as Commissioner Svinicki discussed, later on 

today, I guess. 

So, just to kind of keep the historical context in place, 

the Commission recognized that at the time, recognized there were 

perhaps going to be some challenges with this parallel effort, but similar 

to the comment in the first panel that I made to Dr. Lyman about Near 

Term Task Force Recommendation 1, if you wait to get all that done 

and then looked at individual plant safety enhancements, we'd be 

waiting a long time. The same thinking applies, I believe, to the 

conundrum you've raised, but thank you for bringing that point up. I 

think we recognized it at the time. 

I told Mike Johnson this in more than one meeting. I 

think I've told Bill Dean and Glenn Tracy, I think I told Scott Flanders 

this, but will continue to highlight the importance of keeping the 

Commission informed as you go forward in the Flooding Hazard 

Reevaluations of challenges. I think we found a couple of times prior to 

last fall where there were perhaps challenges that the Staff was facing 

that were not fully communicated to the Commission. It's so important 

to keep us informed of those efforts, and I think you understand what 

I'm talking about. In that note, in the last week I've had periodics with Bill 

Dean and Glenn Tracy where I've communicated the value of getting 
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out in the field and seeing the in situ application of various strategies. I 

talked about the Monticello visit. I think Bill is going out there soon. But I 

think that for Scott's group it's so important for people looking at 

especially the targeted strategies on a site-specific basis, it's so 

important for your team to have the ability to get out and see what it 

means on site. There's just no replacement for that, because we see 

significant variations from one location to the other. 

Scott, on Slide 11, I do want to ask you one question. 

The last bullet, it says, "To support the mitigating strategies timelines, 

the Staff is identifying alternative approaches to provide earlier 

feedback on Reevaluated Hazards." Is there any comment you can 

make, or maybe an example or two that you can talk about in that 

context? 

MR. FLANDERS: Sure. So, there are some --- in order 

to reach our closure on certain issues, for some reviews that have 

recently been submitted, as I mentioned, there are some Category 1 

plants had resubmitted their hazard. In an effort to try to accelerate our 

completion of those reviews, we are engaging the licensee in a different 

way, where we have more interactive discussions, and we intend to 

implement additional audits which will allow us to get a better 

understanding of the models and the information to use right there with 

the expert who actually prepared the models in use. It allows us to 

answer questions in a much faster way, as opposed to getting a partial 

submittal, and then a lot of the detail that you really need to look at and 
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putting on an electronic reading room, and then Staff has to sift through 

that and try to find the information. So, we're trying to get to access to 

the information in a much faster way. 

For these closing reviews in many cases the fastest 

way really to see what's going on is really to get an opportunity to look at 

the model and the input and output files and the interface, and seeing 

that allows the experts really to dial in on the things that are most 

significant, and the things that may be in question the most. And I think 

by doing that in an audit fashion, it's even faster because you also have 

the licensee's experts there. They can explain what they were thinking, 

and what they were doing. So, to do that is going to be a little bit more 

resource-intensive, but we do think it's a way that will effectively allow 

us to get to the end point much faster. That's one example. 

While I have just a second --- 

COMMISSIONER OSTENDORFF: Sure. 

MR. FLANDERS: --- in terms of getting out into the 

field, I couldn't agree more with you in terms of the comments. We have 

tried to do that on many occasions supporting the Regions on a lot of 

activities. For example, on the Monticello case where our Staff actually 

supported and participated in those inspection activities to get out in the 

field, so that is critical, also to provide context. We appreciate that 

comment. 

COMMISSIONER OSTENDORFF: Thank you, 

appreciate that. 
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Jack, I want to comment on two of your slides, on Slide 

18. This is the second bullet, "Analysis indicates an installation of filters 

is not justified." I would just remark, since Commissioner Svinicki and I 

were here during the time period of that decision making, there will be 

folks that will accuse the --- and I know this Information Paper is going 

to come to us at some point in time. 

MR. DAVIS: Right. 

COMMISSIONER OSTENDORFF: Not for 

Commission decision, but for information. I would just comment, there'll 

will be folks who'll say well, you know, you said this two years ago. Why 

aren't you going forward with this? Well, we didn't say that two years 

ago. We said we were going to direct the Staff to proceed upon the 

rulemaking process, and that process involves development of 

regulatory analysis that looks at scientific engineering principles as to 

what's the right thing to do here. So, I think it's a real strength of our 

process that the Staff has fully investigated whatever, you know, the 

topic is, in this case the filtering strategies piece. And I'll look forward to 

seeing the paper, but I think that there will be folks that don't understand 

that external to the organization. But thank you for highlighting that. 

MR. DAVIS: I appreciate it, Commissioner Ostendorff. 

In fact, that's also why you look at the name change from filtering 

strategies to containment protection and release reduction because it 

more accurately reflects what's actually --- what we're trying to achieve. 

So, thank you. 
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MR. DEAN: And if you don't mind --- 

COMMISSIONER OSTENDORFF: Please, Bill, yes. 

MR. DEAN: Yes, I'm sorry. There's a couple of 

aspects, too, when you look at things in moments in time. Right? So, at 

the time that the Staff came forward to the Commission with its 

recommendation, we had not yet had Commission direction, for 

example, on economic consequences. That came out shortly 

thereafter, which perhaps if we had had that before we made the 

recommendation, it maybe could have affected some of --- at least 

some of the qualitative factors. 

Clearly, you've indicated we've had the opportunity 

over the last several years to do a much more substantive quantitative 

analysis, which sort of reinforces what Jack said in terms of where our 

analysis is taking us. And then, also, just consideration of all the things 

that have been done relative to mitigating strategies, relative to severe 

accident capable hardened vents, and so. So, the landscape is different 

than it was several years ago, so hopefully our paper will be able to 

describe all of those things. 

COMMISSIONER OSTENDORFF: Bill, thank you. 

That's a very helpful point to make. 

Jack, I'll also tell you, your Slide 19, the progress made 

in Tiers 2 and 3, I found that to be a very helpful, informative slide to put 

it in perspective, so thank you for presenting that. Again, it goes to our 

responsibility as a regulator to communicate externally. I think that's 
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very helpful, so thank you. 

Ray, thanks for being here. I think the role of the 

Regions is so important in this. And also comment for all of the Regions, 

I've been extraordinarily impressed with the level of knowledge that the 

Residents, the Senior Residents have had in all things Fukushima, and 

the whole approach. Their grasp of the flood level, the strategy, the 

--- just the whole gamut of issues, I think is a real pride of the Agency. 

So, thank you for representing the Regions here today in that context. 

MR. LORSON: Thank you for those comments, 

Commissioner. 

COMMISSIONER OSTENDORFF: I also want to 

comment, just last Wednesday, Davis-Besse, very quickly, I was 

looking at their --- they have a construction site to build a new building 

basically to house a new emergency feedwater system that will be 

associated with mitigating strategies. And that building is right next to 

the plant, the existing plant. So going back to Commissioner Svinicki's 

comment about getting it right the first time, they're taking their time to 

make sure that they fully understand the impact on the operational unit 

of this construction project, because if you drill down or you excavate 

something you could have a miniature seismic event, for instance. So, I 

think that the level of focus to that by the licensee and by the NRC 

Resident and Region III personnel is impressive. 

I'm out of time. Thank you all for your presentations. 

CHAIRMAN BURNS: Thank you, Commissioner. 
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Commissioner Baran. 

COMMISSIONER BARAN: Thanks. Thank you to all of 

you for your presentations, and more importantly for all the work 

described in those presentations. I know it's been an enormous effort 

over a sustained period of time. 

The April six-month status update to the Commission 

on the Lessons Learned from Fukushima provided the Staff review of 

the National Academy of Sciences Report on Improving Safety in the 

U.S. Post-Fukushima. And the Staff's conclusion was that ongoing or 

planned NRC and industry activities address all of the 

recommendations. And I wanted to ask Michael, really anyone on the 

panel, whether you thought there were any new insights that the NAS 

report provided? 

MR. JOHNSON: I guess I'll start and, Jack, if you want 

to, or anyone else wants to weigh in. 

I think we were thoughtful in terms of our review. Your 

conclusion that we repeated in the paper is accurate. We didn't find that 

there were recommendations that we hadn't already --- aren't captured 

in our current plans or activities that we were already taking, so we were 

comfortable with respect to that. We recognize that there are a few 

aspects of things that were provided by them that we'll continue to 

consider along with all the other insights from various assessments and 

work that we do in wrapping up the Tier 2 and Tier 3 items. So, I don't 

have --- nothing comes to mind in terms of a significant insight that we 
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might have, but we certainly will continue to consider that body of work 

as we go forward. 

MR. DAVIS: Yes, if I can just add, also. As you 

remember, the National Academy of Science wasn't critiquing, if you 

will, the NRC's program. Right? They were taking a fresh look at it, and 

then when we looked at our program it was fairly consistent with the 

comments that they're making. 

I'd also add that we have ongoing work with the 

National Academy of Science right now on spent fuel pool, so we wait to 

hear more information from them, and there may be some insights that 

they give us from that. 

COMMISSIONER BARAN: Are there any particular 

findings or recommendations that the NAS had that going forward, you 

know, Mike, you mentioned that there are areas where what they came 

up with should inform our decision making going forward. I mean, are 

there any particular examples of that where you think yes, that's a really 

good point we need to keep in mind as we go forward on this? 

MR. JOHNSON: Again, I don't --- I wouldn't point to 

anything, necessarily, specifically. I know there was work, there was a 

recommendation related, for example, to emergency planning and 

EPZ, those kinds of things, would that work, or you've still that item out 

there related to that, so again that's one area we'll continue as we plow 

through all of the areas to just be mindful of what they said. 

COMMISSIONER BARAN: The Commission recently 
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received the ACRS letter on the proposed rule on mitigation of 

beyond-design-basis events, which I guess we'll be getting later today, 

looking forward to it. The ACRS suggested that the Severe Accident 

Management Guidelines, or SAMGs as we call them, be implemented 

through voluntary compliance. We talked a little bit about this earlier, 

rather than becoming mandatory through rulemaking. 

Mike, what are you --- we're going to likely have a 

Commission hearing on this going forward. We're all going to delve into 

the proposed rule probably starting like 5 p.m. today. But what are you 

--- but I have you here now, so what are your thoughts on this 

recommendation? Walk us through your reasoning, the Staff's 

reasoning for including SAMGs in the proposed rule. 

MR. JOHNSON: Thanks, Commissioner, and I'll start. 

I'll give you my perspectives, and then to the extent someone at the 

table wants to weigh in, we can go more. And we will, obviously, have 

an opportunity to talk more about this. 

I think there's widespread agreement among all of us, 

the NRC, the ACRS, external stakeholders, the first panel, I think you 

heard widespread agreement regarding the importance of Severe 

Accident Management Guidelines, and what that can bring in terms of 

enhancement in defense-in-depth, for example, the benefit of SAMGs 

in terms of their being able --- providing an ability to preserve the 

containment, to minimize/reduce releases, for example, the sort of 

indirect benefit that has in terms of the emergency response. And 
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really, again, bolstering that capability to provide --- to adequately 

protect people who live near the plant. So, there's widespread 

agreement about the benefit of SAMGs. 

I think the only difference is whether or not to require 

them, or whether or not to continue to rely on them as a voluntary-type 

initiative. And I know Tony Pietrangelo's perspective is that the glass is 

half full, for example. My perspective was that the glass is half empty. 

Having said that, I think we do have to offer up a recommendation, an 

analysis that ACRS, for example, thought could be broader with respect 

to the quantitative analysis and the damage states that we considered, 

and the way in which we did our regulatory analysis, to the insights that 

we gleaned from that as it related to the quantitative benefit of SAMGs. 

We --- certainly, they'll appreciate the fact, the 

importance of SAMGs from a defense-in-depth perspective, for their 

reasons that I talked about. So, we've offered all of that up in the 

proposed rule. Ultimately, it will be up to the Commission to decide 

whether or not it's voluntary, or what the regulatory footprint is, I guess I 

should say. 

Again, finish where I started, we're all in agreement 

that SAMGs are important, an important part of the fix, if you will, the 

improvement, if you will, that we're making in terms of the Fukushima 

items. 

MR. DEAN: And if I could weigh in, and Mike was quite 

on target with his comments here relative to the Staff's perspective on 
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SAMGs. 

I would just offer that when I think historically about 

some of the things said in the days after Fukushima that the NRC was 

kind of trumping, as well. We've got these SAMGs in place. Right? 

We've got these hardened vents at BWR Mark I and Mark IIs, and then 

when we dig into it a little bit further we find well, maybe not every plant 

followed that voluntary initiative for hardened vents, and not everybody 

was maintaining the SAMGs, you know, in an available or up to date 

manner. So that certainly points to, I think, weaknesses in the NRC 

regulatory approach towards dealing with voluntary initiatives. 

And I know, Commissioner Svinicki, you talked about 

the paper relative to Recommendation 1, and the things that the 

Commission basically said disapproved. And there was a good 

dialogue, a good discussion in there about treatment of voluntary 

initiatives. And I think one of the things that if we had, perhaps, a more 

substantive approach towards the treatment of voluntary initiatives, you 

know, maybe a better regulatory hook, then maybe we wouldn't have to 

rely on rulemaking. So, I think that's part of it. I think in the proposed 

rulemaking we want to seek some feedback on that particular issue. 

COMMISSIONER BARAN: And Commissioner 

Svinicki talked a little bit about what some of the findings were of the 

Staff when Post-Fukushima the Staff took a look at the SAMGs and 

assessed their status. Talk a little bit more about that. I mean, what did 

the Staff find there that led you to conclude that we need to require this? 
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MR. JOHNSON: I was waiting for any minute Jack to 

jump up and say something. 

 (Simultaneous speech) 

COMMISSIONER BARAN: Commission, can I as a 

part of our preparation for the next Commission meeting on this subject, 

can I offer to go back and do a more exhaustive look at the specific 

findings, and try to draw a connection as it relates. I think you'll find a 

robust discussion and regulatory analysis that undergirds the Staff's 

recommendation with respect to SAMGs. We don't talk a lot about what 

came out of that inspection except in the level of detail that we talked 

about today almost. Well, we can do that for you to supplement going 

forward so that we don't have to get all that today. 

MR. DAVIS: Yes. The only thing I would add, too, is 

this notion about how you integrate your emergency response, if you 

will. Right? If you know how they're going to integrate FLEX into it, they 

have FLEX support guidelines, so they go down their emergency 

operating procedures and they find points where they --- they 

determine that they're in a beyond-design-basis thing, and then they go 

into FLEX. So, that sounds nice when you put it on paper, but let's all be 

honest, right? In a real accident that's very hard to determine. Well, it's 

the same notion when you carry that forward all the way to you're now 

into post-core damage. How does all that come together and integrate 

well? So, I think part of us saying that hey, maybe we should add a little 

bit more rigor to that adds to that, making sure that it works cohesively. 
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COMMISSIONER BARAN: And, Jack, when I first 

arrived in October, there was a lot of discussion at that time about NRC 

oversight of the Regional Response Centers, which are now 

operational. What's the latest thinking on how we can ensure the 

availability and reliability of that equipment going forward? 

MR. DAVIS: So, we're in the process of working with 

the Regions, and working with the Division of Inspection and Regional 

Support, also NRO on how best to oversight the Regional Response 

Centers. Latest thinking is that we would use the Vendor Inspection 

Program, and we're working through that, looking at what would the 

right frequency be, and so on, given, again, the redundant nature of the 

equipment and so on. 

But what gives us confidence, if you will, today? We 

have participated in numerous amount of V&V activities, tabletops with 

them. We've reviewed their documentation, and specifically looking at 

maintenance and testing, and how they're going to maintain the 

equipment reliable and capable to respond. 

We actually went out and watched as they took pieces 

of equipment from there and actually got them over to the airport, and 

got them on the aircraft to simulate you're going somewhere. And we 

followed that all the way through, and there were a number of 

observations that were made that made the program better. So, we feel 

fairly confident that given what we found, given what we looked at that 

we can take the time to put the right program in place going forward. 
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COMMISSIONER BARAN: Okay, thank you. 

CHAIRMAN BURNS: Commissioner Svinicki. 

COMMISSIONER SVINICKI: There's been a number 

of references to some of my statements, so I'd just like to close with this 

comment; that the ACRS is very telling to me, what they said about 

SAMGs. It says, "We consider how the requirement is imposed to be as 

important as how the requirement is implemented." 

And while it's interesting to me that the members of the 

ACRS find that important, let me tell you who else finds that important. I 

find it very important. The people sitting on this side of the table have to 

take that very, very seriously, because I talked about the powers and 

authorities granted to the public office I occupy. It's a hair's breath 

between exercising the impressive authorities I have under law to 

require things, and abusing my discretion by having reliance on 

something that states make this compulsory because it increases 

defense-in-depth. 

With more, some could view that as not enough of a 

basis to compel action. So, you know, whether or not we looked at a 

voluntary industry initiative --- and I think many of you would accept the 

stipulation that the standards for inspection of voluntary industry 

initiatives are not the same as regulatory requirements, so 

post-Fukushima having gone and found issues, I don't think there's a 

single gentleman on the other side of the table that was surprised by 

that outcome, because it was voluntary industry initiative. But making 
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things compulsory is a sober power to have, but there's obligations that 

come along with it. So, I look forward to looking at --- Mr. Dean's 

indicated the stack of reg analysis is this high, so I look forward to 

looking beyond the one sentence that says "this enhances 

defense-in-depth," which I hope all of you would also agree might be a 

basis to make a regulation of pretty much anything. And that was a 

question I got asked in my last Congressional hearing; is there a level 

where it's abusive? I was asked that question, and I said, "Yes, there is 

a level that is abusive, but you have to look at it case by case," which is 

what we'll do. Thank you. 

CHAIRMAN BURNS: Thank you. 

MR. JOHNSON: May I just add, one of the things that 

you'll find in that package is we go into a little bit of detail about what we 

would do --- how we would implement a requirement and it is scaled. 

So, I know you've got to look at the package and arrive ----the 

Commission needs to arrive at a decision. We did recognize that given 

the fact that it's --- we're talking about beyond-design-basis situations, 

we're talking about a situation where you have, for example, a core 

damage frequency event, extremely low-frequency event, situations 

where you would be needing these SAMGs. So, we tried to right-size 

the requirement, but all of that is in the package, and we look forward 

to the next opportunity to meet with you on this. 

CHAIRMAN BURNS: I want to thank the Staff, as well 

as our first panel, again, for their presentations, for giving us a 
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comprehensive view of where we stand with respect to the efforts that 

the Agency and industry have done since the Fukushima Daiichi 

accident. 

We, obviously, had a foreshadowing of an important 

paper and an important meeting we will have later in early summer, in 

July, and we look forward, again, to the engagement of the Staff, the 

industry, and our stakeholders as we continue on. So, with that we are 

adjourned. Thank you very much. 

(Whereupon, the above-entitled matter went off the 

record at 12:01 p.m.)