Nuclear Regulatory Commission: Natural Hazard Assessments Could Be More Risk-Informed
Released: 2012-05-29T00:00:00

Letter

Background

This section discusses U.S. commercial nuclear power reactors, NRC’s approach to natural hazard assessments, NRC’s endorsement of PRA, and actions NRC has taken on natural hazard assessments since the Fukushima Daiichi disaster.

Commercial Nuclear Power Reactors in the United States

Currently, 104 commercial nuclear power reactors operate in the United States. Together, these reactors generated almost 20 percent of our nation’s electricity in 2011. These reactors are located at 65 power plants across the country (see fig. 1) and are operated by 26 different companies. All 104 operating reactors received their construction permits in the 1960s and 1970s, with most receiving their operating licenses in the 1970s and 1980s. Many reactors are reaching or have reached the end of their initial 40-year license. As of March 2012, NRC had renewed 71 reactor licenses for an additional 20 years and was currently reviewing 11 license renewal applications.reactors in Georgia in February 2012 and two new reactors in South Carolina in March 2012 and is considering 10 applications for the building and operation of new commercial nuclear power reactors.

Actions NRC Has Taken on Natural Hazard Assessments Since the Fukushima Daiichi Disaster

In March 2011, NRC chartered a staff task force to review its processes and regulations in light of the Fukushima Daiichi disaster and to recommend whether NRC should make near-term improvements to its The task force issued its final report in July 2011. regulatory system.Among other things, the task force found that NRC regulations and guidance provide a robust approach for assessing natural hazards, but it noted that NRC’s processes for assessing natural hazards had evolved over time. As a result, the licensing bases, design, and level of protection from natural hazards differ among operating reactors depending on when the reactors were built and when they were licensed for operation. Based on these findings, the task force recommended, among other things, that NRC order licensees to reevaluate the seismic and flooding hazards at their sites against current NRC requirements and guidance and, if necessary, update their reactor design bases. The task force further recommended that NRC initiate rulemaking to require licensees to confirm seismic and flooding hazards every 10 years, address any new and significant information and, if necessary, update their reactor design bases. In addition, the task force recommended that, while these longer term actions are being completed, NRC order licensees to check their seismic and flood protection features to identify and address any plant- specific vulnerabilities and verify the adequacy of monitoring and maintenance for protection features such as watertight barriers and seals.

In response to the task force report, in August 2011, NRC directed agency staff to identify the task force recommendations that could and, in the staff’s view, should be implemented without unnecessary delay. The staff submitted a report to NRC in October 2011 with their proposed prioritization of the recommendations. In this report, the staff recommended that NRC move forward with requiring licensees to reevaluate the seismic and flooding hazards at their sites and to check their seismic and flood protection features. However, the staff recommended that NRC wait to initiate rulemaking requiring licensees to confirm their sites’ seismic and flooding hazards every 10 years in order to gain experience from the implementation of the initial reevaluation. In December 2011, NRC approved the staff’s proposals and supported actions on several recommendations. That same month, Congress passed, and the President signed, the 2012 Consolidated Appropriations Act, which included a provision directing NRC to require that licensees reevaluate external hazards at their sites, including seismic and flooding hazards, as expeditiously as possible. In February 2012, NRC staff proposed issuing a request for information that, among other things, would ask licensees to reevaluate the seismic and flooding hazards at their sites. The staff suggested PRA as one of two acceptable methods for licensees to use in reevaluating seismic hazards. The staff did not exclude, but also did not suggest, PRA as a method for assessing flooding hazards because, according to NRC officials, NRC currently uses a deterministic approach for assessing flooding hazards. NRC staff also proposed addressing other natural hazards, such as wind and missile loads from tornados and hurricanes, at a later date once sufficient resources are available for the reevaluations. According to NRC officials, it is not clear yet whether agency staff will suggest licensees use PRA or other methods to reevaluate those other natural hazards. In March 2012, NRC issued the request for information proposed by agency staff in February.

PRA Is Applied to Natural Hazards to a Limited Extent

Licensees and NRC apply PRA to natural hazards at operating U.S. nuclear power reactors to a limited extent, according to information provided by nuclear power industry representatives, NRC officials, and several experts in assessing nuclear reactor risks that we interviewed and data we obtained. While NRC has endorsed PRA as a means to enhance and extend traditional deterministic assessments, the agency has not conducted the analyses to determine whether or not it should require licensees of operating reactors to develop and maintain PRAs that address natural hazards.

Licensees and NRC Apply PRA to Natural Hazards to a Limited Extent

Nuclear power industry representatives, NRC officials, and several experts in assessing nuclear reactor risks we interviewed, as well as data we obtained, indicate that licensees and NRC apply PRA to natural hazards at operating nuclear power reactors to a limited extent. Prior to its response to the Fukushima Daiichi disaster, the last time NRC requested licensees to assess natural hazards was in 1991 when the agency initiated the IPEEE program. For the IPEEE, NRC requested each licensee to voluntarily identify and report plant-specific vulnerabilities to severe accidents caused by external events, including natural hazards. Although PRA was suggested by NRC as one of several possible methods for licensees to use in their examinations, most licensees opted to use methods other than PRA. Specifically, NRC received 70 IPEEE submissions from licensees covering all operating reactors. According to NRC’s summary of the 70 submissions, about 40 percent applied PRA to seismic hazards, and about 15 percent applied PRA to high winds, floods, and other external events. NRC reported that almost no licensees identified vulnerabilities with respect to seismic hazards, and none identified vulnerabilities related to high winds, flooding, or other external events. Nonetheless, according to NRC’s summary, 70 percent of the IPEEE submissions identified plant improvements related to seismic hazards, and about 50 percent identified plant improvements related to high winds and flooding. NRC performed a review of all IPEEE submissions to assess the technical adequacy of the methods and data used and noted that the quality of licensees’ submissions varied. NRC did not attempt to verify or validate licensees’ results. NRC staff proposed in 2011 that licensees reevaluate seismic hazards under the agency’s Generic Issue-199 program. Similar to the IPEEE, the proposal cited PRA as one—but not the only—possible method for assessing seismic hazards. The NRC staff has now proposed to pursue the reevaluation of seismic hazards as part of the implementation of the Fukushima Daiichi task force recommendations and has identified PRA as one of the methods that licensees can choose to use.

Nuclear Energy Institute representatives told us that, if data were to be collected on licensees’ current application of PRA to natural hazards, they believe the data would likely show little difference since the IPEEE in the 1990s. They also stated that they believe few of those PRAs developed for the IPEEE would have been updated since then. Likewise, senior NRC officials told us that were NRC to obtain current data on licensees’ application of PRA to natural hazards, the results would likely show limited application, substantial variability, and few new or updated assessments since the IPEEE. According to several experts in assessing nuclear reactor risks we spoke with, few of the nation’s operating reactors currently have PRAs in place that address natural hazards. For example, one expert stated that some reactors have PRAs that address seismic hazards, and a few have PRAs that address external floods, but the rest do not have PRAs that address natural hazards at all.

NRC does not collect comprehensive data on the extent of licensees’ voluntary application of PRA to natural hazards at operating reactors. NRC officials stated that, because PRAs are not required for operating reactors, NRC does not have comprehensive data on their use. NRC officials told us that where licensees voluntarily undertake risk-informed applications or license amendments, the information licensees submit to NRC may include results on natural hazards. For example, when a licensee chooses to use a risk-informed approach to request a change to its licensing basis, the licensee must determine whether natural hazards are a significant contributor to risk and provide that information to NRC. To make this determination, the licensee may use a PRA. Apart from these circumstances, however, NRC does not have data on operating reactor licensees’ PRA use. NRC officials could not tell us, therefore, which licensees of operating reactors have voluntarily undertaken PRAs that address natural hazards, what natural hazards are addressed, when existing PRAs were first developed and last updated, or the extent to which they meet NRC-endorsed quality standards. Nuclear Energy Institute representatives similarly told us that they do not collect data on PRA use and do not have a plant-by-plant listing of which reactors have PRAs in place that address natural hazards. NRC officials said that they do not collect comprehensive PRA information because licensees of operating reactors are not required to have a PRA. Further, they told us that, if NRC decided to collect this information, the agency would likely issue a “generic communication”––NRC’s primary method of communicating information to licensees and interested stakeholders or requesting information from them. NRC officials told us that a generic communication to obtain comprehensive PRA information would take NRC a significant amount of time to develop and issue.

According to representatives of five licensees we interviewed, 12 of the 25 reactors those licensees operate have PRAs in place that address seismic hazards, and none have PRAs in place that address high winds or external floods (see table 1). The representatives told us that, in some instances, a reactor does not have a PRA in place for a given natural hazard because a screening analysis indicated that the hazard’s contribution to risk was sufficiently low that it could be eliminated from further consideration; in other instances, licensees have performed margin studies instead or rely on traditional deterministic assessments of the hazard. Of the seismic PRAs in place at 12 of the 25 reactors for which we obtained information, 10 have not been updated since they were first developed. The seismic PRAs at 6 of the 12 reactors were developed in the 1990s under NRC’s IPEEE program. The seismic PRAs at the other reactors were developed between 1983 and 2010 for a variety of reasons. For example, two were developed as part of voluntary licensee efforts to better understand seismic risk. Another was developed as part of a plant’s long-term seismic monitoring program created as a condition of its operating license due to discovery during construction of a new fault line.

NRC has also applied PRA to natural hazards to a limited extent. For example, NRC officials told us that the agency has developed 16 external event risk analysis models of limited detail that address some natural hazards at 19 operating reactors.staff for internal use in providing risk insights to various agency initiatives such as NRC’s inspection and incident investigation programs. According to NRC officials, NRC staff use the models to a limited extent. The models rely on licensee information, such as that derived from the IPEEE, that could be out-of-date. NRC officials told us they have plans to validate These models are available to NRC the models in the future to improve confidence among agency staff in their use. According to the officials, there has also recently been renewed interest in the agency in resuming development of these models for the remaining operating reactors. The officials told us NRC is finalizing the first in a series of such models that include more recent plant information and improved validation. In a separate initiative, according to NRC documents and officials, NRC has plans to perform a new full-scope PRA for a single operating power plant that will calculate off-site risk and its contributors, including natural hazards. NRC staff identified several reasons for doing so, including technical advances that had taken place since the last similar NRC effort in the late 1980s, scope considerations that had not previously been addressed such as multiunit site effects, and potential future uses for these models such as verifying or revisiting regulatory requirements and guidance and developing NRC’s in-house PRA technical capability.

NRC Has Not Analyzed Whether It Should Require PRAs That Address Natural Hazards

While NRC has endorsed PRA as a means to enhance and extend traditional deterministic assessments, the agency has not conducted the analyses to determine whether or not it should require licensees of operating reactors to develop and maintain PRAs that address natural hazards. NRC’s “backfit rule” generally requires NRC to assure licensees that requirements placed on them will change only when warranted from a public health and safety standpoint. As such, to require that licensees of operating reactors apply PRA to natural hazards, NRC officials told us NRC would have to determine that the advantages of doing so are necessary to ensure that protection of the public health and safety is adequate or that the added increase in overall protection is at least substantial and justifies the cost of implementation. Senior NRC officials told us that it may be difficult to meet either of these criteria in order to justify the imposition of a new PRA requirement on licensees of operating reactors.determinations by the agency regarding whether or not requiring PRA of operating reactors meets the backfit rule or exceptions thereto. Additionally, an official from the agency’s Office of General Counsel told us that the NRC has the authority to “administratively except” a new NRC officials we spoke with were unaware of any formal requirement from the backfit rule. NRC officials stated that it generally takes several years to conduct and document the regulatory analyses to determine whether a new requirement should be implemented and then to complete the rulemaking process necessary before a requirement can become law.

Experts Offered a Range of Views on NRC Assessment Processes

The 15 experts in assessing natural hazards and/or nuclear reactor risks that we interviewed offered a range of views on (1) the adequacy of NRC processes for assessing the threats that natural hazards pose to operating U.S. nuclear power reactors and (2) what, if any, changes to those processes are warranted. Experts had varied views on the overall adequacy of NRC natural hazard assessment processes and identified a number of strengths and limitations of those processes. More than half of the experts we interviewed suggested expanding the use of PRA for assessing natural hazards as a complement to traditional deterministic analyses, and several experts cited a number of challenges to doing so. Some experts we interviewed suggested other changes to NRC processes for assessing natural hazards. Appendix II lists the names and affiliations of the 15 experts we interviewed.

Experts Noted Strengths and Limitations of NRC Assessment Processes

The 15 experts we interviewed had varied views on the overall adequacy of NRC processes for assessing the threats that natural hazards pose to operating U.S. nuclear power reactors and identified a number of strengths and limitations of those processes. Several experts said they believe NRC processes are generally adequate. One of those experts noted that, in his view, NRC’s processes for assessing natural hazards work well due to the conservative approach NRC takes to assessing and designing against natural hazards. Another expert who agreed that NRC processes are adequate overall explained that natural hazards are well accounted for in reactor designs and that NRC does as good of a job as any other federal agency in ensuring that its regulated community protects against natural hazards. Several other experts expressed mixed views on the adequacy of NRC processes. Some of these experts stated that they had more confidence in NRC’s approach for assessing the threats that natural hazards pose to proposed new reactors than its approach for operating nuclear power reactors because the former requires licensees to use PRA in addition to traditional deterministic assessments when assessing natural hazards. Two experts stated that NRC processes for assessing natural hazards are inadequate. One of those experts noted that NRC and licensees need to consider other possibilities that may affect natural hazard assessments, such as the potential effects of climate change on the natural hazards a reactor may face over its operating life.

Experts we interviewed identified a number of strengths of NRC processes for assessing the threats posed by natural hazards to operating nuclear power reactors. Four strengths were identified by more than two experts. First, about half of the experts identified as a strength the structured and thorough process NRC follows in reviewing licensee assessments of natural hazards. A few of these experts noted the stringency of NRC’s review of licensee assessments, and a few others said that the agency has done an effective job defining a comprehensive set of natural hazards that licensees are responsible for assessing. Second, several experts identified as a strength what they said was NRC’s conservative approach to licensee assessments and reactor designs for natural hazards, including NRC’s emphasis on (1) defense-in- depth principles, (2) engineering safety margins, and (3) reactor designs based on the worst credible natural hazards a site is expected to face. Some of these experts said that, because NRC’s approach to assessing natural hazards is conservative, they believe that U.S. nuclear power reactors are well-designed and well-protected from natural hazards. Third, a few experts pointed to the expertise of NRC’s staff in assessing natural hazards as another strength of the agency’s processes. These experts said that NRC staff are diligent in trying to understand natural hazards and are proactive in identifying new information for assessing natural hazards. Several experts indicated that NRC is effective at identifying and considering new natural hazard data, although one of those experts also noted that it can take the agency time to incorporate new data into agency regulations. Fourth, a few experts identified as a strength what they said was NRC’s global leadership in developing the latest tools and methods for assessing the threats posed by natural hazards to nuclear power reactors.

Experts we interviewed also identified a number of limitations of NRC processes for assessing the threats posed by natural hazards to operating nuclear power reactors. Three limitations were identified by more than two experts. First, about half of the experts identified as a limitation that NRC has not required licensees of operating reactors to assess natural hazards using PRA and that licensees generally have not done so. One of these experts noted that while NRC generally has good information on natural hazards, the use of PRA would allow NRC to better quantify the adequacy and uncertainty of that information. Another of these experts stated that deterministic assessments of natural hazards alone can provide a false sense of security with regard to the certainty of the information that has been assessed. Second, several experts identified as an additional limitation of NRC processes for assessing natural hazards that some existing assessments are not as robust or up- to-date as they could be. One of these experts noted that NRC generally does not require licensees of operating reactors to systematically reevaluate their natural hazard assessments, and some experts highlighted external flooding and high-wind hazards in particular as warranting further review. Third, a few experts identified as a limitation that NRC’s processes for assessing natural hazard threats are overly bureaucratic and slow and can lead to overly conservative results. One of those experts noted that NRC’s conservatism can potentially lead to the costly overdesign of nuclear power reactors. Another of these experts stated that NRC processes are bureaucratic and time-consuming and undermine the agency’s ability to identify actions that need to be taken promptly in response to new information.

More Than Half of Experts Suggested Expanded Use of PRA

More than half of the 15 experts we interviewed suggested expanding the use of PRA for assessing natural hazards at operating nuclear power reactors as a complement to traditional deterministic assessments, and several experts cited a number of advantages, as well as challenges to doing so. The experts’ suggestion was similar to a lesson learned from the Fukushima Daiichi disaster identified by a team from the International Atomic Energy Agency, which found a need for the nuclear power community to increase efforts to develop PRAs for external events.the experts who suggested expanding the use of PRA, more than half Of noted that such risk assessments should not be the sole basis for decision making but should be used to complement traditional deterministic assessments in order to provide a more robust approach to assessing natural hazards. A few experts noted that NRC has already moved in this direction by requiring that licensees of new reactors develop and maintain PRAs that address natural hazards. Some experts emphasized the importance of NRC better integrating PRA into agency processes for assessing natural hazards, and others said that such risk assessments of natural hazards should be comprehensive, periodically updated, and integrated with licensees’ PRAs of internal events.

The experts who suggested expanding the use of PRA for natural hazards cited a number of advantages of using it to complement traditional deterministic assessments, including the following:

PRA takes a broader look at hazards than traditional deterministic assessment by systematically examining all potential causes of an accident for any particular hazard, including events beyond those accounted for in a reactor’s original design.

PRA considers and quantifies the likelihood of events and can help inform regulatory priorities by identifying more significant contributors to a reactor’s risk profile.

PRA provides a structure for explicitly addressing and presenting uncertainty and attempts to account for unknowns.

PRA can help identify design vulnerabilities that might otherwise be overlooked by relying on traditional deterministic assessments alone.

PRA can support improved safety decision making by providing risk insights.

Several experts also identified challenges to expanding the use of PRA for natural hazards, including the following:

More than half of the experts we interviewed noted that uncertain knowledge about natural hazards, particularly the frequency of large hazards, presents a challenge in evaluating those hazards. Some experts noted the difficulty of identifying the frequency of large natural hazards for use in a PRA given the limited data resulting from the brief historical record and rarity of the hazards. One of these experts said he believes the uncertainties associated with low-probability, high- consequence natural hazards are too large for a PRA to produce an accurate risk estimate, and two other experts said the information generated by a PRA would be useful to inform but not determine decisions.

About half of the experts said another key challenge is the limited number of experts qualified to develop PRAs for natural hazards. One expert noted the number of practitioners that can do this type of risk assessment is small and that it is important that more people be trained to conduct them. Another expert said that finding people to do these analyses, more so than the cost involved in conducting them, represents the primary challenge to expanding the use of PRA. He further noted that this is even more the case now given the actions NRC and industry are taking in response to the Fukushima Daiichi disaster. In June 2008, we noted a similar challenge to NRC’s efforts to transition to a risk-informed approach to fire protection. At that time, numerous NRC, industry, and academic officials we spoke with expressed concern regarding the limited number of personnel with the necessary skills and training to design, review, and inspect against PRAs. Those officials told us that the shortage of skilled personnel was due in part to an increased demand for individuals with critical skills under NRC’s risk-informed approach. We have reported on this challenge of the limited number of PRA practitioners as far back as 1985.limited number of experts qualified in PRA remains a challenge today.

NRC and industry officials we interviewed agreed that the

A few experts identified other challenges to expanding the use of PRA for natural hazards, including the cost of developing those risk assessments, the regulatory hurdles to NRC requiring licensees of operating reactors to use PRA, and the care that must be taken when deciding which natural hazards to include in a PRA and which to screen out of the analysis.

Some Experts Suggested Other Changes to NRC Assessment Processes

Some of the 15 experts we interviewed suggested changes to NRC processes for assessing the threats posed by natural hazards to operating U.S. nuclear power reactors that were unrelated to expanding the use of PRA. Five such changes were suggested by at least two experts as follows:

Several experts suggested that NRC should have licensees revisit their existing natural hazard assessments to incorporate current knowledge on natural hazards or ensure that the assumptions used in the assessments have not changed. Some of these experts noted that the state of knowledge on natural hazards such as earthquakes, floods, and high-wind events had changed since licensees completed their assessments. More than half of the experts we interviewed said the NRC Fukushima Daiichi task force’s recommendations that NRC require licensees to reevaluate their seismic and flooding hazards and confirm them on a periodic basis in the future were useful, and some of those experts suggested that the reevaluation should include all natural hazards, as it will, according to NRC officials. One expert said it would be better if NRC required licensees to perform a comprehensive assessment of natural hazards rather than a reevaluation of existing assessments against current requirements. A few experts said the reevaluations proposed by the task force would be of only limited utility. Two of those experts indicated that resources would be better devoted to having licensees enhance their reactors’ abilities to mitigate natural hazards and to reevaluate natural hazards as significant new information becomes available rather than on a set periodic basis.

A few experts suggested that NRC should examine the criteria that licensees use to decide whether to assess a natural hazard or screen it out of their assessment. One expert suggested that NRC create a special category of assessments to consider low probability, high- consequence natural hazards that otherwise might be screened out.

Two experts suggested that NRC should devote additional resources to researching natural hazards in order to inform agency assessments and guidance relating to those hazards.

Two experts suggested that NRC should do more work to assess how natural hazards might affect sites with multiple reactors. One expert expressed the view that there has not been a systematic enough examination of the potential consequences of a natural hazard that might affect multiple reactors.

Two experts suggested that NRC should consider how potential future changes in natural hazards are addressed in assessments. One expert noted, for example, that climate change could potentially lead to changes in natural hazards over reactors’ operating lives.

In addition, two experts said that they do not believe NRC needs to make changes to its processes for assessing the threats posed by natural hazards beyond what NRC is already undertaking in response to the Fukushima Daiichi disaster. One expert said that NRC and licensees should focus on enhancing reactors’ ability to cope with and respond to natural hazards rather than devote those resources to further assessing natural hazard threats.

Conclusions

Operating a nuclear power reactor is never entirely free of risk, but comprehensive assessments of that risk and various contributing risk factors—including natural hazards—can help identify vulnerabilities that might otherwise be overlooked. Actions taken to mitigate such risks could decrease the chance of an accident that could have serious public health, environmental, and economic consequences. NRC documents and most experts we spoke with indicate that PRA offers NRC and licensees a number of advantages that, as a complement to traditional deterministic assessments, can provide a more robust approach to assessing natural hazards.

Because NRC and licensees of operating reactors continue to rely primarily on deterministic assessments of natural hazards, they are realizing PRA’s advantages to a limited extent. We recognize that NRC must undertake a thorough review to require licensees of operating reactors to develop and maintain PRAs that address natural hazards. In particular, we acknowledge the difficulty that NRC officials anticipate in reaching a determination that a PRA requirement is warranted for operating reactors under existing regulations. Further, we understand there are a limited number of experts qualified to develop PRAs for natural hazards, and that there is a cost to developing PRAs. However, we also note NRC’s overall endorsement of the use of PRA to enhance and extend traditional deterministic assessments, as well as the significant advantages cited by the experts we interviewed who suggested expanding the use of PRA for assessing natural hazards at operating nuclear power reactors. Moreover, we note that a team from the International Atomic Energy Agency has identified a need to increase efforts to develop PRAs for external events as a lesson learned from the Fukushima Daiichi disaster. While NRC suggested PRA in the 1990s as one potential option for licensees to use to assess natural hazards, most licensees opted not to do so, and agency officials and industry representatives told us they believe that licensees today have only applied PRA to natural hazards to a limited extent. Given all this, PRAs’ potential benefits in the natural hazard context may not be realized without efforts by NRC to promote its use. Without conducting the analyses necessary to determine whether a PRA requirement is warranted for operating reactors, however, NRC does not have a strong basis to judge whether or not such a requirement should be implemented.

Recommendation for Executive Action

To improve safety decision making by NRC in carrying out its responsibility under the Atomic Energy Act to ensure that the operation of nuclear power plants is consistent with the common defense and security and public health and safety, we recommend that the NRC Commissioners direct agency staff to conduct and document any needed analyses to determine whether the agency should require licensees of operating reactors to develop and maintain PRAs that address natural hazards.

Agency Comments and Our Evaluation

We provided a draft of this report to the NRC Commissioners and the Secretaries of Commerce, Defense, and the Interior for their review and comment. The Secretaries of Commerce, Defense, and the Interior had no comments. NRC provided written comments on April 13, 2012, which are reproduced in appendix VI, and technical comments, which we incorporated into the report as appropriate.

NRC agreed with the report recommendation. The agency stated it would conduct and document the analysis recommended by GAO in the context of follow-on actions for related ongoing agency initiatives after sufficient information has been gathered from those activities to better inform the analysis. In addition, NRC asserted that it will continue to evaluate its processes and policies regarding the enhanced use of PRA and risk insights as part of its overall regulatory framework. As we noted in our report, NRC documents and most experts we spoke with indicate that PRA offers NRC and licensees a number of advantages that, as a complement to traditional deterministic assessments, can provide a more robust approach to assessing natural hazards. We also noted that officials we interviewed and data we obtained indicate that NRC and licensees apply PRA to natural hazards at operating nuclear power reactors to a limited extent. We continue to believe that until NRC completes the analysis necessary to determine whether a PRA requirement is warranted for operating reactors, NRC will not have a strong basis to judge whether or not such a requirement should be implemented, and PRAs’ potential benefits in the natural hazard context may not be realized.

As agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies to the Chairman of the NRC, the Secretaries of Commerce, Defense, and the Interior, the appropriate congressional committees, and other interested parties. In addition, this report will be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please contact me at (202) 512-3841 or ruscof@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix VII.

Appendix I: Objectives, Scope, and Methodology

Our review provides information on: (1) the extent to which probabilistic risk assessment (PRA) is applied to natural hazards at operating U.S. nuclear power reactors and (2) expert views on and suggested changes, if any, to Nuclear Regulatory Commission (NRC) processes for assessing natural hazards at operating U.S. nuclear power reactors. To address both of these objectives, we reviewed relevant literature and NRC documents and met with officials from NRC, the nuclear power industry, public interest groups, and others to understand NRC processes for assessing natural hazards at nuclear power reactors.

Specifically, to address the first objective, we reviewed relevant documents and data obtained from NRC and selected licensees on the extent to which PRA has been applied to natural hazards. We interviewed knowledgeable officials about the data and found the data to be sufficiently reliable for the purposes of our report. We reviewed NRC policies and procedures, as well as NRC initiatives related to the assessment of natural hazards. We also reviewed the NRC near-term task force’s report on insights gained from the Fukushima Daiichi disaster and documented the actions taken by NRC on recommendations related to the assessment of natural hazards. In addition, we visited a nonprobability sample of five nuclear power plants to interview licensees about the actions they have taken to assess natural hazards. The five nuclear power plants we visited were the Browns Ferry Nuclear Plant in Alabama, the Diablo Canyon Power Plant in California, the North Anna Power Station in Virginia, the San Onofre Nuclear Generating Station in California, and the Turkey Point Nuclear Plant in Florida. We selected these sites to capture a variety of characteristics, including reactor and containment vessel type, operating license issuance date, license renewal status, and natural hazard activity level.

To address the second objective, we summarized the results of semistructured interviews with experts in assessing natural hazards, risks to nuclear power reactors, or both. We first reviewed NRC documentation about processes used to assess natural hazards at nuclear power reactors and confirmed our understanding of those processes with NRC. Then, we identified 43 experts from our review of the literature, prior GAO reports, congressional and NRC hearings, and recommendations from NRC, the Nuclear Energy Institute, the Union of Concerned Scientists, and experts in assessing risks to nuclear power reactors. From this list, we selected 15 experts based on (1) the relevance of their expertise as reflected in publications, testimonies, and their biographies; (2) the relevance and extent of their publications; (3) the relevance and extent of their testimonies before Congress and NRC; and (4) recommendations from others in the field. Finally, to ensure coverage and a range of perspectives, we selected experts who came from academia, government, industry, public interest groups, and other affiliations; provided perspectives from both those inside NRC or the nuclear power industry and from those outside of those two groups; and provided perspectives from those publicly supportive, publicly critical, and those without a public position on nuclear power. Appendix II lists the experts we interviewed. We conducted a content analysis to assess experts’ responses to a standard set of questions and grouped responses into overall themes. The views expressed by experts do not necessarily represent the views of GAO. Not all of the experts provided their views on all issues. We did not independently evaluate the quality of NRC processes for assessing natural hazards and the threats they pose to nuclear power reactors.

During the course of our review, we interviewed NRC officials from the Office of General Counsel, Office of New Reactors, Office of Nuclear Reactor Regulation (including the Japan Lessons Learned Project Directorate), Office of Nuclear Regulatory Research, and Risk Management Task Force in headquarters, as well as NRC officials in Region II and Region IV and the resident inspectors at the five nuclear power plants we visited. We also interviewed officials and reviewed documents from the National Oceanic and Atmospheric Administration, the U.S. Army Corps of Engineers, and the U.S. Geological Survey on the current state of knowledge on natural hazards, how that knowledge has changed over time, and the related uncertainty. Further, we interviewed representatives from American Nuclear Insurers, the Nuclear Energy Institute, and the Union of Concerned Scientists to discuss their views on NRC processes for assessing natural hazards and the threats those hazards pose to nuclear power reactors.

We conducted this performance audit from May 2011 to April 2012 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: List of Experts

Dennis C. Bley, Buttonwood Consulting, Inc., Member of NRC’s Advisory Committee on Reactor Safeguards

Biff Bradley, Nuclear Energy Institute

Robert J. Budnitz, Lawrence Berkeley National Laboratory

Thomas B. Cochran, Natural Resources Defense Council

Karl N. Fleming, KNF Consulting Services LLC

B. John Garrick, U.S. Nuclear Waste Technical Review Board

Michael W. Golay, Massachusetts Institute of Technology

N. Prasad Kadambi, Consultant

William Leith, U.S. Geological Survey

William Levis, PSEG Power LLC

Stuart Lewis, Electric Power Research Institute

David A. Lochbaum, Union of Concerned Scientists

Mohammad Modarres, University of Maryland

Ali Mosleh, University of Maryland

Doug True, ERIN Engineering & Research, Inc.

Appendix III: Key Developments in NRC’s Approach to Probabilistic Risk Assessment

According to NRC documents, NRC is moving toward a risk-informed, performance-based approach to decision making that is being implemented in phases. This approach extends the traditional deterministic approach in part by incorporating PRA—a systematic method for assessing what can go wrong, its likelihood, and its potential consequences to determine quantitative estimates of risk. The timeline below describes some of the key developments in NRC’s approach to PRA, including its application to natural hazards.

NRC publishes the first PRA of nuclear power reactors. According to an NRC document, this study marks the first U.S. attempt to systematically evaluate a large spectrum of accidents and to use quantitative techniques to evaluate severe accident probabilities and off-site radiological consequences in an integrated manner to obtain a more realistic estimate of public risk. The study challenged the concept that conservative safety analysis of design-basis accidents could establish an upper limit of public risk.

An accident occurs at the Three Mile Island nuclear power plant, resulting in a partial meltdown of a reactor core. According to an NRC document, the accident substantiated risk insights generated through the 1975 study and led to the increased use of PRA to identify vulnerabilities in the nuclear industry.

NRC issues its Safety Goal Policy Statement in which it broadly defines an acceptable level of radiological risk that might be imposed on the public as a result of nuclear power reactor operations and calls for the use of PRA to measure achievement of the agency’s individual and societal safety goals.

NRC initiates the Individual Plant Examination program and requests that each licensee perform an examination to identify plant-specific vulnerabilities to severe accidents that could be fixed with low-cost improvements. One of several program objectives is for each licensee to gain a more quantitative understanding of the overall probability of core damage and radioactive material releases. NRC identifies PRA as one acceptable approach for licensees to use in conducting their examination but limits the scope of the effort to internal events.

NRC publishes a follow-on study to its original 1975 study that advances the state of the art in PRA, particularly the analysis of uncertainty.

NRC initiates the Individual Plant Examination of External Events program and requests that each licensee identify and report to the agency all plant-specific vulnerabilities to severe accidents caused by external events, including natural hazards such as seismic events, floods, and high-wind events. NRC suggests PRA as one possible method for licensees to use in responding to NRC’s request.

NRC develops a PRA implementation plan that aims to ensure PRA is implemented in a consistent and predictable manner in regulatory activities.

NRC issues a policy statement regarding the expanded use of PRA. In its approval of the policy statement, the NRC stated its expectation that “the use of PRA technology should be increased in all regulatory matters to the extent supported by state-of-the-art in PRA methods and data and in a manner that complements the NRC’s deterministic approach and supports the NRC’s traditional defense-in-depth philosophy.”

NRC requires new nuclear power reactors licensed after January 1997 to be sited and designed with respect to geological and seismic determinations based on an appropriate analysis, such as a probabilistic seismic hazard analysis.

NRC establishes a structure for risk-informed decision making to improve consistency in regulatory decisions where PRA results are used to supplement traditional deterministic and defense-in-depth approaches.

The structure consists of five key principles: proposed changes must (1) meet current regulations, (2) be consistent with the defense-in-depth philosophy, and (3) maintain sufficient safety margins; (4) when proposed changes result in an increase in risk, the increases should be small and consistent with the intent of NRC’s Safety Goal Policy Statement; and (5) the impact of the proposed changes should be monitored using performance management strategies. The structure acknowledges that assurance of adequate protection of public health and safety encompasses more than simply demonstrating an acceptable level of overall risk.

NRC develops a strategy for implementing risk-informed regulation in response to a GAO recommendation.

NRC issues regulations requiring that applicants for combined licenses for new nuclear power reactors submit a description and the results of a reactor-specific PRA to NRC as part of their license application. NRC also requires licensees of new nuclear power reactors that will operate their reactors under a combined license to develop by the scheduled date of their initial fuel loading a Level 1 and Level 2 reactor-specific PRA that covers, among other things, initiating events for which there are NRC- endorsed consensus quality standards 1 year prior to the scheduled date for initial fuel loading. Licensees are required to maintain their PRA and upgrade it every 4 years over the operating life of the reactor, as well as when the licensee submits a license renewal application. Also, NRC develops its risk-informed and performance-based implementation plan.The plan provides guidance and direction regarding activities the agency undertakes to integrate risk information and performance measures into its regulations, regulatory guidance, and oversight processes.

NRC issues a regulatory guide that provides guidance to licensees to use in determining the technical adequacy of a PRA for regulatory decision making and endorses certain American Society of Mechanical Engineers and American Nuclear Society national consensus standards for PRA quality. Among other things, those standards address the application of PRA to natural hazards.

The Chairman of the NRC charters a task force to develop a strategic vision and assess options for a more comprehensive and holistic risk- informed, performance-based regulatory approach, with one option being better incorporating risk management concepts into NRC’s regulatory programs. Later that year, in response to the Fukushima Daiichi disaster, NRC charters a staff task force to review its processes and regulations and to recommend whether NRC should make near-term improvements to its regulatory system. The task force makes several recommendations in its final report, including requiring that licensees reevaluate the seismic and flooding hazards at their sites against current NRC guidance and requirements. With policy direction from the NRC, the agency staff moves forward with actions to implement the task force recommendations.

NRC issues three orders and a request for information in response to lessons learned from the Fukushima Daiichi disaster. As part of the request for information, the staff asks licensees to reevaluate the seismic and flooding hazards at their sites and suggests PRA as one possible method to address the seismic hazard reevaluation.

Appendix IV: Information on Developing a Probabilistic Risk Assessment

Probabilistic risk assessments are used to evaluate several categories of initiating events––that is, events that can lead to a reactor accident— including internal events, which start inside the nuclear power plant or the electric system serviced by the power plant (e.g., random hardware failures and operator actions), and external events, which typically start outside the nuclear power plant, such as natural hazards (e.g., earthquakes, external floods, external fires, and high-wind events). According to NRC documents, external events are of significant concern since they can both initiate core damage accidents and negate or compromise the safety systems or procedures used to prevent or mitigate such accidents.

According to NRC documents, PRA can estimate three different levels of risk—one focused on reactor core damage, one focused on containment release, and one focused on radiological consequences to the public. Specifically, Level 1 PRAs evaluate events that can lead to plant accidents and examine reactor systems and operators’ responses to calculate “core damage frequency”—the frequency of the combinations of initiating events, hardware failures, and human errors leading to the uncovering of the reactor core such that reflooding of the core is not imminent. A Level 1 PRA consists of six major steps: (1) identifying a comprehensive list of events that can lead to accidents and grouping those events into categories based on their potential impact on accident response systems; (2) establishing success criteria based on traditional engineering analyses; (3) modeling accident sequences; (4) estimating parameters for the analysis such as initiating event frequencies and the failure rates of particular components; (5) quantifying accident sequences; and (6) documenting and evaluating the results. To accomplish these steps, a PRA employs several specific techniques, including event trees, fault trees, human reliability analyses, and Monte Carlo methods (see table 2). Analysts use these methods to estimate the core damage frequency for each accident sequence. Those frequencies are then totaled to calculate the total core damage frequency for a reactor.

Level 2 PRAs start with Level 1 core damage accidents and assess the frequencies of various categories of containment releases. The results for operating reactors are typically reported in terms of “large early release frequency”—the frequency of those accidents leading to significant, unmitigated releases from the reactor’s containment in a time frame prior to effective evacuation of the nearby population such that there is a potential for early health effects. Level 3 PRAs start with Level 2 radiological release accidents and assess the public health consequences of a radiological release in terms of injury to the public and damage to the environment.

Appendix V: NRC Actions on Natural Hazard Assessment in Response to the Fukushima Daiichi Disaster

NRC has taken a number of actions in response to the Fukushima Daiichi disaster. The timeline below describes actions that relate to natural hazard assessments.

March 2011

A 9.0 magnitude earthquake and subsequent tsunami lead to a prolonged loss of alternating current electrical power at several reactors at Japan’s Fukushima Daiichi nuclear power plant. As a result of the loss of power, plant operators are unable to keep three of the reactors cool, which leads to fuel melting, hydrogen explosions, and the release of radioactive material into the environment. Among several actions, NRC charters a staff task force to review its processes and regulations in light of the Fukushima Daiichi disaster and to recommend whether NRC should make near-term improvements to its regulatory system.

July 2011

The NRC task force issues its final report.regulations and guidance provide a robust approach for assessing natural hazards but notes that NRC’s processes for assessing natural hazards have evolved over time. As a result, the licensing bases, design, and level of protection from natural hazards differ among operating reactors depending on when the reactors were built and when they were licensed for operation. Based on these findings, the task force recommends actions to, among other things, clarify and strengthen NRC’s regulatory framework for protection against natural hazards. Three of these recommended actions relate to the assessment of natural hazards. Specifically, the task force recommends that (1) NRC order licensees to reevaluate the seismic and flooding hazards at their sites against current NRC requirements and guidance and, if necessary, update their reactor design bases; (2) NRC initiate rulemaking to require licensees to confirm their seismic and flooding hazards every 10 years, address any new and significant information and, if necessary, update their reactor design bases; and (3) NRC order licensees to check their seismic and flood protection features to identify and address any plant-specific The task force finds that NRC vulnerabilities and verify the adequacy of monitoring and maintenance for protection features such as watertight barriers and seals.

August 2011

The NRC directs agency staff, among other things, to engage stakeholders on the task force recommendations and to identify and prioritize the recommendations that in the staff’s view can and should be implemented without unnecessary delay.

September 2011

Agency staff report to the NRC Commissioners on the task force recommendations that in their view can and should be implemented without unnecessary delay.that the NRC move forward on requiring licensees to reevaluate the seismic and flooding hazards at their sites against current NRC requirements and guidance. The staff also recommends that the NRC move forward on requiring licensees to check their seismic and flood protection features.

October 2011

Agency staff propose a prioritization of the task force recommendations to the NRC Commissioners and describe the actions necessary to The staff suggests deferring the task implement the recommendations.force recommendation that NRC initiate rulemaking to require licensees to confirm their seismic and flooding hazards every 10 years until the related recommendation for licensees to reevaluate seismic and flooding hazards is implemented. Later in the month, the NRC approves the staff’s proposal on the task force recommendations that can and should be implemented without unnecessary delay and says that the agency should strive to complete and implement the lessons learned from the Fukushima Daiichi disaster by 2016.

December 2011

The NRC approves the agency staff’s proposals on implementing task force recommendations and supports actions on several, including the recommendations that licensees reevaluate their seismic and flooding hazards against current NRC requirements and guidance and check their seismic and flood protection features. Later in the month, Congress passes and the President signs the 2012 Consolidated Appropriations Act, which includes a provision directing NRC to require that licensees reevaluate external hazards at their sites, including seismic and flooding hazards, as expeditiously as possible.

January 2012

NRC announces that it is accelerating its plans for implementing the task force recommendations. According to NRC officials, agency staff will propose expanding licensee reevaluations beyond seismic and flooding hazards to include all natural hazards that are relevant to a site, but they expect to recommend that the reevaluation of seismic and flooding hazards take priority over other natural hazards.

February 2012

The NRC staff proposes issuing three orders and a request for information in response to lessons learned from the Fukushima Daiichi disaster. The staff’s stated goal is for the orders and request for information to be issued before the first anniversary of the earthquake and tsunami that led to the Fukushima Daiichi disaster. As part of the proposed request for information, the staff plans to ask licensees to reevaluate the seismic and flooding hazards at their sites. NRC staff propose addressing other natural hazards, such as wind and missile loads from tornados and hurricanes, at a later date once sufficient resources are available for the reevaluations. The staff also plans to ask licensees to check their seismic and flood protection features.

March 2012

NRC issues the three orders and the request for information proposed by agency staff in February.

Appendix VI: Comments from the Nuclear Regulatory Commission

Appendix VII: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above, Kimberly Gianopoulos, Assistant Director; David Marroni; Emmy Rhine; and Ashley Vaughan made key contributions to this report. Important contributions were also made by R. Scott Fletcher, Cindy Gilbert, Jonathan Kucskar, Alison O’Neill, Timothy Persons, Kiki Theodoropoulos, and Jack Wang.