Good morning and welcome panelists today the NRC staff and the members of the public the purpose of today's meeting to discuss the status of Action is taken by the NRC in Response to and the industry in response to the lessons learned for the Fukushima Daiichi accident Including a discussion of progress on NRC's tier one activities and the status of open tier two and tier three recommendations We'll begin with presentations from the external panel which includes Anthony Petrangelo chief nuclear officer of the Nuclear Energy Institute Ken Canavan director of plant technology Technology electric power research Institute Randy Blunt from Southern Nuclear Country Company chairman of the BWR owners group Fukushima Response Committee and Paul Gunter Director of the reactor oversight project of Beyond Nuclear Following the external panel will have a brief break and then hear from the NRC staff I look forward to the presentations and discussions this morning before we begin to make my colleagues have any opening remarks Not We'll start with mr. Petrangelo with this the presentations on the external panel Chairman commissioners. Good morning In summary we continue to make good progress on implementing the Fukushima lessons learned I'll touch on a number of items in the presentation of we think we're very well aligned with Completion in 2016 and some issues. We're still trying to wrestle going to slide two We will be largely complete with flex implementation in the industry by the end of this year And with respect to the pool instrumentation orders completion by the end of this year With BWR mark one and two vents complete in 2018 and 19 as previously laid out We're continuing to focus on flexing flex inspections. I think we noted last time here that We want to make sure that all the work we've done in the previous five years to Get a common understanding of what it takes to implement the requirements and the orders Carries through to the field inspection and implementation by licensees We fully support the staff on the disposition of the tier two and three Actions made excellent progress there We are committed to completing the majority of the mitigating strategy assessments before the rulemaking That I think is consistent with our bias for action since the Fukushima event in 2011 And the rulemaking really aligns a lot of the significant activities that have been undertaken by us and the NRC There's a few issues to discuss which I'll touch on briefly next slide, please Here's the detailed implementation on flex status 58 units will be complete are already complete 29 are finishing up this year. There'll be an additional 13 that are substantially complete, but I'm still Dealing with the exception of severe accident capable of them That's a hundred sites including our hundred units including watts part two next slide, please Flex inspections The big thing with the inspection process, and I think we noted this last fall is there's a lot of work That's been done, but we've seen in the past Instances where a lot of that work is reinterpreted in the inspection process So we want to make sure that the knowledge transfer From the folks that have been working on it at the end the agency here as well as in the industry is transferred out to the field So what was maybe a couple a hundred people working on the? Implementation guidance and the rules and requirements etc now It's thousands of people who are expected to implement this going forward So there's a big knowledge transfer that has to take place. We're committed to doing that in the right way We've actually established a task force that'll meet with some of the folks here tomorrow on the inspection process We're trying to promote consistency and implementation in the industry. I suspect will will establish a frequently asked question Panel if you will on the industry side to share lessons learned if there's questions on Interpretations of the guidance in the field will have people who have already been working on these things for the last five years Ready to answer questions and share that with the staff. So we're trying to get out in front of this as best we can The industry task force does represent the entire fleet of plants So we've got every company playing on that and we want to make sure that we're learning from the inspections and Making adjustments as necessary. I also want to make a point about the use of flex equipment here We all know what it's beyond design basis functions are for for mitigation But we are starting to use and we'll use more frequently flex equipment as an additional layer of defense in depth for more traditional things We do we've actually submitted to white papers to the staff on Getting credit for the use of flex and notice notices of enforcement discretion and in the significance determination process I think that's just the tip of the iceberg of where we intend to apply The flex equipment. I think it's a win-win overall because it'll get this equipment hooked up and used and more familiarized with the plant Staffs and well as well as the inspector seen us use that equipment in different applications beyond waiting for the beyond design basis event To run out and do this. So again, I think it's a win-win overall next slide, please This is the projected schedule of the mitigation strategy assessments again before the final rule is issued Will have basically completed most of the MSAs for flooding this year And on path with seismic for about two-thirds by the end of 2017. You can see the rest there This is a this is the major part of the licensee work this year is conducting these mitigation strategy assessments against the re-evaluated hazards They'll get a lot more detail in the staff's presentation But we're well on our way to completing the bulk of these assessments this year next slide For the seismic SRAs the current focus is for those plants and what we call path 5 of the where their GMRS or the ground motion response spectra was greater than two times the safe shutdown earthquake We think the proposed rule has sufficient language in it to allow a risk-informed approach there We have to keep in mind that the we're utilizing the seismic PRA results to assess the potential Reduction for only the extended loss of AC power and the loss of ultimate heatsink. That's the focus of those For plants that are less than the two times the SSC or the safe shutdown earthquake We do think there's a limited benefit and we'll get out of those seismic PRAs and that If they're mitigating strategies assessments are done right it'll demonstrate the effectiveness of those using the deterministic approach there Next slide on the flooding integrated assessments We put a lot of time into the external flooding assessment guidelines and provided that last month to the agency for endorsement This looks at the methodology trying to reduce some of the conservatism in the initial methods again, we're utilizing the mitigating strategies for the local intense precipitation hazard and in this one again We don't see significant flood risk reduction expected by performing these integrated assessments given that the MSAs will have been done previously We are trying to strike some balance of protection and mitigation with this integrated assessment as we go through the process It's a limited number of plants will be using that full methodology Turning the next slide on the proposed rule. We think again the rule incorporates and All of the requirements from 2012 and beyond We are focused on the codification of the existing requirements and their integration. This is the beyond design basis framework regulatory framework I think this really did address recommendation one That the task force came up with initially we support issuance of the rule in 2017 We provide a comment in February. There's a couple issues on The implementation schedule, although I think we're on a good path to work those out We don't want to be in a position where we're asking for exemptions from the rule as these mitigating Strategy assessments are completed when we know how long they're going to take now So we'd rather have the rule reflect that versus go for exemptions later the change control process We believe it should be different from what we do for design basis materials so we're still working with the staff on that and there's a couple of Knits, I think in the reevaluated hazard methodology that we're still working through but overall I think there's a good alignment on what we thought was going to be in the proposed rule and final rule and what the Staff drafted so in summary we've had significant safety enhancements. We're well on our way to completing the Implementation of the Fukushima lessons learned we've had a focus on safety throughout and I'm very proud of the fact that the industry has maintained a very high safety record and performance both with reliability and safety as we've been Implementing the Fukushima lessons learned 2016 is critical year for completion of a lot of our Enhancements I said last fall and I'll say it again. We're still not done yet though There's still a lot of work to do with the mitigating strategies assessments some of the reevaluated hazard work So there's still work to do and and in particular focus on the inspection process we are committed to maintain a focus on Our equipment and these safety enhancements going forward and again We intend to utilize the flex equipment for other applications to improve defense and depth and safety. Thank you very much Thank you, Mr. Kahneman Good morning And thank you for having me here today to share some thoughts on both the lessons learned and some Perspectives on some of the future research that we see I'm going to sprinkle my lessons learned sort of around the presentation. Hopefully it's not too distracting So before I get into this the body of the slides Let me share one observation that I had in the in the in actually the hours and days after Fukushima Which was when Fukushima occurred as with most severe accident type Situations there was a scarcity of information And as that information started to become available. There was an interesting thing that I noticed that some folks Understood the severity of the events more than others and one community that understood those the severity is those events almost immediately was risk analysis people at the sites and and at other organizations throughout the nuclear industry and In the United States we have a large community of risk analysis practitioners, which is unusual And we have those because as a result of generic letter 8820 issued in 1988 in response to post TMI actions And that generic letter required each utility to perform an individual plan examination for severe accident vulnerabilities And and one of the stated goals of that generic letter was to develop an understanding of severe accident behavior These are actions that NRC took that I think Provided unique a unique benefit to the US nuclear industry when you think about it With that appreciation of severe accidents came improvements in the form of hardware modifications human performance improvements changes to procedures severe accident guides all came out of that effort and And you know in retrospect position the US nuclear industry Better to handle off-normal events Next slide so what's happened since Fukushima? Well since Fukushima Epri and others have performed a significant body of technical work too much to really talk about all of it today So I've summarized a few of it put it into categories in the blue Immediate actions short-term actions and sort of a longer term understanding And I'm going to cover some of the highlights the items in red. I have some slides on And like I said, I'll cover a few of the highlights my personal favorites actually so Without further ado, but before moving on One of the one other lesson learned from Fukushima Is that the spam fuel pool and in fact the nuclear plants are very rugged structures? And when we look at that that's supported by the fact that all available evidence currently indicates that after the seismic event which was the fourth largest recorded seismic event and Located just a hundred miles away all the safety systems I Operated as designed and research research activities to date continue to support the ruggedness of the both the fuel pool and the and the plant In the area of immediate response Epri assisted tepco a long-term every member and understanding severe accidents and analysis of the spent fuel pools looking at potentials for recratic criticality and quickly Helping to design a system to treat water The shorter-term actions Occurred in the months and years after the accident include updates as a severe accident Technical basis document which serves as one input to the severe accident guidelines that the owners groups will talk about in just a little bit As well as development of strategies to mitigate radiological releases and accelerated seismic activities And some of the long-term research activities were listed on the previous slide and we'll discuss them as we walk through the presentation but for seismic The post Fukushima Error we accelerated our existing seismic program accelerated and expanded To look at improving an understanding of the seismic hazard or the ground motion all the way from the seismic source through ground motion attenuation and Site amplification to understand the true seismic sort hazard at the site and then once understanding the Seismic hazard at the site evaluating a components both for the impact of high-frequency motions And to better understand component performance in seismic events sub commonly referred to as fragility analysis And all of that's to to better understand and then to mitigate seismic risk Again first is an understanding then there's a mitigation Next slide please So shortly after Fukushima TEPCO engineers were very interested in all the research performed After Three Mile Island as we can all understand another notable Accident and Epri had just completed a draft archive of the 30-year body of Scientific work that had been performed and the drafters were provided to TEPCO and that draft eventually became an EPRI report I'll cite it here 102 26 21 86 technical foundations of reactor safety revision one, but that contains Large body of that 30 years of scientific work And the reason why I mention that is because the Fukushima technical evaluation continues on a similar vein So work continues in that area now to collect that information again and to make sure that it's available both to develop a deep understanding of Fukushima to support sound technical decision-making in the future and One of the lessons learned in that document that I always find very Those documents because there are several a phase one and a phase two and several other supporting documents But one of the most interesting things I always find about that document. That's not well known is the fact that Unit two which is estimated to have the least amount of core damage And also had no hydrogen explosion is actually the largest contributor to the radiological release And so if you look at that Chart that we see a lot of that NNSA chart that shows the radiological release in a picture That's largely due to unit two Next slide, please So accident tolerant fuels so what would what would the nuclear industry be? Like if we had no zirconium in the core and while there are several definitions of accident tolerant fuel They all share a common element, which is an increased ability To tolerate a loss of active cooling for a longer duration than the existing zirconium system And a longer duration means more time for prevention and more time for mitigation It means less hydrogen and reduced or minimal fission product release So overall it would look a lot different. There's a lot of different strategies for fuel systems And a lot of things to consider when designing new fuel But two of Epri's favorites are the molybdenum cladding concept, which is actually a zircoly Cladded molybdenum both on the inside and outside because if you think about it If you take molybdenum and you clad it with zirc on the inside and outside very thin layer You don't have a lot of zirc But you do have the water and the fuel still seeing zirconium so you don't change chemistry or physical properties as much and Silicon carbide fuel channels which again replaces zirconium with a silicon carbide both have higher melting points both have higher resilience and strength There are other concepts But this is part of the longer-term research that we see Being potentially a game changer for the nuclear industry Epri's role in this is to accelerate the collaboration in the development not one entity will not develop new fuel on its own It's quite an endeavor But the goal would be for test assemblies to be available in the early 2020s Next slide, please so in summary There's a significant body of research and development that's been completed since Fukushima by Epri and others and much has been learned and Implemented in the global nuclear industry is is safer as a result. I did want to close with with one additional thought that As we look at future research and development it falls into two bins really one is the continuous improvement type of work And through improved understanding and implementation of those learnings We we get better performance in terms of both safety and economics But also and the items in this bucket are things like severe at learning on severe accidents External hazard analysis in other areas, but there's a second bin that provides a more significant step change such as the accident tolerant fuel We just discussed As well as things like severe accident prognostics that would allow us to faster than real-time simulate accidents and be able to both prevent and mitigate better and things like a New reactor technology such as molten salt reactors, which I'm hoping is a subject of a future commission brief and That's the end of my prepared comments Thank you, Mr. Yes, thank you for allowing me to present today and present on behalf of the beat of our owners group and our Chairwoman Lisa Hill who's not able to be here Do you want to go over a few topics if you go to the next slide talking about the lessons learned and where do we stand and What's remaining for the BWR fleet going forward? So we'll give you a brief status of where we stand from our flex strategies Then go over severe accident hardware and containment vent systems our procedures both the severe accident and the mercy operating procedures and our AIDS of the TS technical support guideline documents going forward And then what are we doing in support of what Tony had already mentioned about the mitigating strategies? Rule and the other elements associated with that so next slide please So Updated status of where we stand with the strategies industry-wide BWR fleet has followed the industry lead and we are very close to being finished by the end of this year in the Primary elements that make up the flex strategies We will have a few outstanding items for the vent to enhance that going forward after the summer of 16 And that will take us into the 18 time period many units will be coming in in 17 and the early 18 in Accords with that rule to enhance their venting associated with that Approximately about a third of the fleet of the BWR will submit their final integrated plans for documenting their closure of flex By in 2016 the remainders will be submitting those after their enhancements to the vents per the schedule that's outlined We expect two plants to have their flex inspections in the 2016 time period which will lay the the foundation for where we're going forward for the inspections for the BWR fleets in The future years most of those inspections will come after their FIPs are done So they will be a little the tail end of those inspections where the PWRs will be the main focus with that also looking to establish how the mitigating strategies assessments both for flooding and seismic are working and the BWR fleet is in line with the schedule that Tony had already presented for the most of the floodings to be done in 2016 and in the seismics to be spread out 16 and 17 Next slide please To go into the order the 109 for the mark one and mark two units that are specifically out there with the Hardware part which was the phase one part of that order complete by the 2018 time period and then the phase two It's the strategy complete by 19 many sites will be be doing the strategy Earlier than that, but their commitment is in the 19 time period The impacted has said that will have their hardware installed by mid 2018 with In compliance with that order and the agreed to schedule The strategy part is the water addition and the water management that will see We expect to see the staff evaluations for that integrated plans By the summer those integrated plans were submitted last year at the end of the year in December very concentrated effort between the staff and the industry to have a Consolidated are a very typical submittal on that so this all the sites followed the template Very good was done for across the industry and having the templates and trying to look like an industry when we submitted our reports as a independent so We expect to see closure when we go forward with these activities Through inspections that'll happen in the 18 to 20 time period Following the compliance with that we expect to see the integrated plans and the Safety assess are the staff assessments to be the basis for those inspections Going forward. So that's how we see this hard and Vince activity going forward. So next slide, please So this is a brief status of where we stand with the in the procedure suite of activities for the owners group Broken into the three categories of the procedures the emergency operating procedures The bulk of those lessons learns have been submitted. They're out there in the current revision revision 3 a Full implementation of that revision is expected by mid 2017 the majority of the lessons learned required for the flex support from the direct application Will be have already been implemented at the majority of sites into further compliance of their 2016 flex material complete For the severe accident guidelines The owners group committed in their letters last year to be upgraded by the middle of 17 for the rev 3 and there also most units are complying to have to have that done for their vent order the 109 order compliance also so their schedule is in that ahead of their Compliance for a few plans when the majority of plants are there Several plants that a couple plants have already had that implementation done as of 2016 For our technical support guidelines, these are the calculational aides that allow the TSC staff the technical support center staff to to have more tools and also the operating crews to have more tools into how to evaluate Those are outside out have been issued and Workshops have been held in the US this year and there'll be more next year and they also were held internationally for the BWR fleets In 2015 so that's an example of where we're spreading the lessons learned those were enhanced Through activities and also support from both epory and from DOE and some of the activities that support that from a Code standpoint and the valuations that go forward Next slide please For the proposed rule out there the BWRs are In line with the rest of the industry following the same industry schedule We don't anticipate any changes or any delays that will happen because of the BWR fleets in complying with the rule Language and a very supportive that so we do expect, you know Our documentation enhancements needed for the mitigating strategies as we do that work in Advance of the rule coming out across the industry Also, how will the demonstrations and procedures be impacted from flecks going forward and then what is the full Documentation required for the rulemaking going forward being that most of the compliance will have already taken place prior to the rule coming out So those are where we see very consistent with the rest of industry the BWRs are just where you ask for the information Next slide please And in summary we feel that the BWR fleet will be materially complete with flecks so that we will be able to cope with the mitigation of any external event Currently the bulk of the fleet are there also the enhancement Through the added wet well venting capability and the water addition and water management strategies Will be implemented starting in 2016 Through the agreed to schedule and then we expect to as mentioned before comply with the mitigating strategies rulemaking Along with the rest of the industry in a consolidated approach Then it might come up comments. Thank you. Okay. Thank you. Mr. Gunter I'd like to Thank you for the invitation and open my comments today with an observance that Yesterday Michael Marriott with nuclear information resource service passed away at his home in Maryland Surrounded by his loving family. I'm sure a number of you know and knew Michael and Certainly we in the public interest community are going to miss him Our concern today turns to some examples of the Fukushima lessons that have been unlearned in the United States Defense in-depth is being whittled away and Sacrifice to the US nuclear industries industries increasing fragile economics I will focus on the example of the post Fukushima regulatory treatment of containment and emergency planning Components as it pertains to one Specific biological hazard generated in a severe nuclear accident radioactive iodine next slide, please Quite simply the pressure suppression containment system for the GE mark one and mark two boiling water reactor is too small To contain the dynamic energy of a severe accident this inherent design flaw has been known since 1972 yet we continue to see piecemeal approaches and voluntary Industry initiatives to allow operators the option to deliberately defeat the containment design function in hopes of saving it In from permanent rupture during a severe accident Fukushima demonstrated a 100% containment failure rate For the same containment venting system that is currently deployed on nearly one-third of the US nuclear reactor fleet next slide, please Radioactive iodine is one of the more manageable radioactive isotopes generated by a nuclear accident It's a it's a relatively short half-life of eight days constitutes a biological hazard for about 80 to 160 days It can be effectively retained and contained along with other radioactive isotopes by state-of-the-art engineered Radiation filters on hardened containment vents to reduce the uncontrolled radioactive releases to the environment and population exposures emergency planning can be Enhanced by providing safe and effective doses of prophylactic potassium. I died as is used in common table salt Predistributed in advance to saturate the thyroid gland particularly in young children for protection from radiogenic diseases of the thyroid however in the aftermath of the Fukushima Catastrophe the public interest community has witnessed both of these beneficial aspects for defense in-depth Dismantled and obstructed by the nuclear industry and the Nuclear Regulatory Commission next slide, please on January 9th 2013 senior management for the NRC staff presented his broad-based Consensus to recommend that the Commission order the installation of external engineered Radiation filters on sphere accident capable hardened vents on the G mark 1 and mark 2s in The staff study judgment using established regulatory practice and guidance the The use of filter vents when used in conjunction with containment spray and reactor cavity flooding as Already added by the NEI guidance that reactors in response to the September 11th attacks represented a cost-beneficial and substantial safety improvement the nuclear industry lobby and its champions in Congress vehemently opposed Adding the filters to the containment vents maximizing decontamination in the small containment By increased water spray and reactor cavity flooding was preferable and sufficient However, the NRC staff focused their defense in-depth concern without the benefit of the external filtration on the uncertainties regarding the effectiveness of internal decontamination in the Extremely cramped containment that still needed analysis and provided performance requirements in anticipation of the Commission vote on adding filters in March 2013 UBS the global Swiss banking giant that handles nuclear corporation finance is predicted quote We increasingly believe that the NRC may not require these added precautions Given the added stress this places on the incumbent portfolio as well as the fragile state of affairs among existing units UBS concluded that while not overwhelming the Additional cost would add insult to injury for an industry in difficult economic and environment The Commission report majority vote rejected its staff's recommendation for engineered filters and issued an order for just the containment vent and Directed staff in industry to develop other non-specific severe accident confinement strategies such as the industry-favored adding and managing of more water and containment the Commission directed staff to pursue proposed public rulemaking to solicit further stakeholder comments on radiation filtration and develop the performance requirements for what industry now describes as severe accident water addition and management that proposed rulemaking renamed containment protection release reduction would never happen There would be no public comment or independent expert opinion on the benefit of engineered filters And as a result as the NRC staff had described in its earlier concerns No NRC or independent vetting of performance requirements on industry severe accident water addition Next slide, please in our view The protection of the management now the protection of the American public from the GE containment design vulnerabilities is A least-cost base case scenario in favor of industry's hands-off approach to its fragile economics next slide, please In the meantime the Japanese reform nuclear Nuclear regulation authority essentially adopted the NRC staff recommendation For external engineered filters as a prerequisite for restart of the boiling water reactors there by August 2015 a Riva had announced delivery of its 14th filtered Containment vent system for installation in Japanese reactors initiated by Hitachi GE tepco is Since completed installation of redundant filtration units on it's Kaja wasaki Kiroa nuclear power plant that are both above grade For flood qualification and redundantly below grade for seismically qualified backup systems next slide Moreover, it's our concern that even an NRC order doesn't constitute what the public might think an order should the NRC can in fact The order can be undone with a request for an extension to comply without a single public meeting Ironically, New Jersey's oyster Creek nuclear station the first mark one in the world Fukushima Fukushima's prototype as well as the first unit in line for compliance with the order also Received the first waiver from compliance following this summer's scheduled fueling outage and restart for fall 2016 the NRC staff Waved oyster Creek's compliance until after Exxalon plans to permanently close the reactor on December 31st 2019 None of Exxon's pro offered compensatory actions Addressed the post fuel damage requirement in the order based on this precedent other industry waiver requests are now anticipated next slide please Though recommended by the Kemeny Commission in October's 1979 the NRC would not propose optional voluntary stockpiling a potassium iodide within the 10 mile EPZ until 2001 next slide please as of today to a 25 of 34 eligible states participating in NRC's voluntary initiative for Voucher distribution and within the 10 mile EPZ However, according to public health surveys the current Ki emergency plan is ineffective as only 5.3% of residents respond to the voluntary pickup next slide please The American Thyroid Association has repeatedly appealed to the NRC to expand the distribution of Ki by direct delivery to all residents within 50 miles and wider stock piling out to 200 miles next slide please Moreover the Canadian Nuclear Safety Commission required that by December 31st 2015 Predistribution of Ki by direct delivery to every resident within the six mile primary Evacuation zone around Canadian nuclear power plants would be completed The Canadian the Canadians have further expanded public awareness for Ki out to 31 miles from their nuclear power stations Next slide please the chief lesson from Fukushima From Fukushima for us according to the Japan's national diets Fukushima Dichi Nuclear accident independent investigation committee determined that the catastrophe was profoundly man-made and the results of regulatory capture The combination of willful negligence the collusion of government Regulator industry to advance corporate production and financial agendas over public safety and regulatory deferral of enforceable standards To voluntary industry initiatives adds up to a recipe for the next disaster. Thank you Thank you. I will begin the question this morning with Commissioner Baron. Well, thank you all for being here. I appreciate your comments In the last few years five US Reactors have permanently shut down and three more have announced plans to close Licensees are actively considering shutting down additional four units of Clinton Quad Cities and Fort Calhoun in the near term I want to get the panel thoughts about how these announcements will affect compliance with post Fukushima safety requirements Paul noted just a couple minutes ago that Oyster Creek Which plans to shut down in 2019 was granted an extension on implementing phase one of the order requiring severe accident-capable Harden vents essentially Oyster Creek got an exemption from the requirement to install wet well event by fall of this year Recently Enter G submitted a request for an extension for Fitzpatrick to comply with the mitigating strategies and spend fuel pool instrumentation orders Paul let me start with you if if NRC gets similar requests for other plants in the future related to vents or another requirement How do you think NRC should evaluate such a request? Well, you know, thank you for that It's our concern that the NRC has to draw a line in terms of what an order means and You know clearly in the case of Oyster Creek When the order was issued the the agency had provided X line with an opportunity to address the NRC's calendar date schedules for compliance and then they took a pass on that and It wasn't till later They announced that they would seek an extension to comply on a schedule change that you know Dissingenuously puts the react you know takes them through an exemption process without any public oversight or Transparency and I think that You know clearly in terms of the severity of the Fukushima disaster and its consequences The we're asking the NRC to hold a line on the orders that it issues and it's and it's scheduled and I think that's reasonable Well, let me let me explore that a little bit with you So what do you think the standard should be in the situation like that? How do we weigh or how do you think NRC should weigh the length of time? The plant will be open and would be benefiting from a safety enhancement with you know with the benefit of the safety enhancement How do how do we weigh that you know if it's a if if the Plant would close a month or six months or a year after a Particular safety enhancement came online. How do you think we should weigh that? I think one clear guideline would be no more refueling cycles. I mean we're right now. We're looking at Oyster Creek You know going through One plus fuel cycles and I don't think that it's reasonable to extend That kind of undue risk to public health and safety I'm interested in what the rest of the panel thinks about this issue Tony or Randy Do you have thoughts about how NRC should approach extension or exemption requests? Related to post Fukushima requirements at plants that are shutting down on a case-by-case basis Anything beyond that I mean so that's I think that's I think that's basically the approach right now It's a the NRC staffs taking a case-by-case look at it I think that's appropriate because the circumstances are different for each site You have an exemption process specifically to deal with case-by-case things like that So I would exercise that process. Do you think there are any and I want to hear Randy's thoughts of this too if he has any Are there key factors you think the NRC staff should be looking at when they're evaluating these on a case-by-case basis I think you have to look at the magnitude of risk and the time exposure In time exposure, you mean how long the plant will be yes operating. Yep Ken I didn't mean to exclude you. Yeah, I just wanted to add to Tony's comment So all forms of electrical generation have some form of hazard associated with them So if we assume moisture creeks replaced by coal burner or or another Generation of like gas unit carbons produced There are there are health effects from other Sources of Electrical generation and you can do trade-offs with period of time and exposure to the hazard and and other health effects from other forms of generation To address your question. I think you do have to consider the the time constant here and The total time constant of the activity that was being requested So if you look at the end date for this particular application of the 109 order the end date was summer of 18 Which had already been evaluated from a risk standpoint So the extension time then has to be looked at the consequences of the event and also the Mitigating actions that were put in place and what were there those all have to be factored in on a case-by-case basis It's Tony mentioned along with the risk the impact and other economics that Ken had mentioned as well as other hazards that are Dominant by having a plant shut down or have something prematurely done like that Any any closing thoughts from any of you on this on this topic us the staff about this too, and we'll get their thoughts Randy and Ken both discussed the development of accident tolerant fuel In this question for both or either of you what when do you think it's likely that these technologies would be ready for NRC review? There's been discussions Well accident tolerant fuels a wide area. There are several different systems That are being discussed all have pros and cons difficulties in manufacture these things haven't been done all those caveats in in place it looks like Early 2020s so sometime in that time frame test fuel assemblies or test pins would be available for insertion Currently that's the thought Prior review would be submitting something to the NRC in the 18s or 19s I would assume And do you anticipate any challenges for NRC and being prepared to review those? Yes, and talk a little bit about that please Well with all new technology You know this is a system and one of the things I missed in my notes was it's a cradle of the grave type of thing Which is one of the reasons why molybdenum with coated zircaloi is is a preferred System Every time you change something you'll move other dynamics So you'll have other chemistry effects if you use different materials Most people don't know that silicon carbide is actually soluble in water Only a little bit but Still soluble and and what are those long-term impacts? So I think You know careful review will be required and it's first-of-a-kind technology which always creates some challenges for the regulatory environment Do you think it and I know this is a little bit of prognostication But would you anticipate that the first technologies we received here for review would be ones where you didn't have a change in chemistry Or not a very significant change or not necessarily coming in that order as a researcher I would hope that that regulatory Thoughts didn't play too significantly in the technology chosen, but in reality it does So again the molybdenum concept that's coated with zircaloi on both sides is a very positive one because it doesn't change those Chemistry it changes things less and so one of those things I think when making a submittal one of the considerations would be things that don't Change the regulatory regime as much Randy do you have any thoughts you want to add? Okay, Commissioner. Can I just add one more comment to your your original question? I Think it's important to recognize that an order modifies the operating License of these nuclear facilities and and that's a that's a critical legal question and You know it needs to be redressed through the legal process. So I think it's disingenuous to to essentially avoid an order on a schedule change When in fact there is this obligation to meet the modified operating license Thanks. Thank you. Mr. Chairman Oh, thank you Commissioner bearing covered in an area I was interested in begin to beginning with respect to the process that Mr. Gunter and and others spoke to I'm going to turn first Mr. Canavan I was interested in your comment and With regard to the contribution to radioactive release from the Fukushima accident. It was mostly unit 2 and Yet unit I think what I understood you to say unit 2 relatively speaking Was less That's the right way to say the relapse damaged or More integral. What could you just refresh me? Is it to what what the reason or what the understanding of that is? Why that was I can I can walk you through some of the statuses very quickly and and Again, no one has seen where the cores are so this is all based on modeling and simulation Although to date we're fairly confident in that Simulation unit 1 1f1 Lost core cooling very early. It's expected that about 10 to 12 hours into the accident the melted core exited the vessel and and Is in the containment? unit 3 Similarly lost cooling late, but also for a sustained period of time and and again Some of the core is expected to be exited the vessel. However for unit 2 While again, this is all based on modeling it would appear that the core is would be in the vessel according to modeling So it hasn't exited the vessel Yet the timing and releases Correspond with the largest a radiological contamination actually line up with that and an essay Diagram that we all see Largely that's probably a result of extremely high core temperatures at the same time that drywall headlift Occurred so it suspected that pressure in a containment The hardened vent or the vents were not utilized at that time containment exceeded twice design at that point the drywall bolts stretched and the head relieved vision products were relieved out the top of the structure and That resulted in the contamination that we see combined with adverse Weather conditions it was raining. Okay. Thank you. Let me stick with you for a moment Can you tell me a little bit more about the international? benchmarking efforts and analysis activities that are going on to with respect the evaluation of the accident and What the nature your participation is for every is? well a various Organizations have done their own simulations using their own codes or other predictive Methodologies and EPRI participates through a number of forums IAEA and some others WG risk in Europe To discuss some of the outcomes of our analysis and compare and contrast. I think largely Benchmarking efforts have been between in the US between the map code, which is an EPRI owned severe accident code and melcore Which is a US DOE code And those comparisons have been The subject of much effort and a lot of work the international ones are really in their earlier stages Alright, thanks, so I want to turn to you with respect to a couple issues with respect to the the rulemaking effort that's underway One of the things you noted and I appreciate a little more granularity on this is that You noted that you believe that the change control process with respect. I think the flex equipment of the beyond design basis Strategies ought to be different and I'd like to explain that a little more and I compare that to for what I'll call the normal process or What I would call the norm or what I can at least conceive of the norm for operating reactors So for operating reactors we have 10 CFR 50 59 changes tests and experiments You do a licensing check basically of the change or experiment you're making to determine if you have an unreviewed safety question Okay, there's criteria established in that rule if you exceed the criteria you come in for a license amendment You ask for prior NRC Approval before you implement the change so that's what we do for the traditional design basis material This is beyond design basis, so I think it's wrong to apply the same test to it We think it should be something less than that One idea was to say that the licensee evaluate the change keep the record at the plant for inspection Such that when the NRC is conducting its baseline inspections, they can see whatever changes were made and whether They agree with the evaluation that there's still compliance with the rule. So it's very very simple. There is no submittal made It's just an evaluation that the plant staff does the licensee does that's available for inspection So that's kind of the other end of the spectrum. Is there a 50 59 light like process? I haven't heard of one yet, but I think for the kind of safety significance of these beyond design basis things I think the approach where the licensee evaluates it and keeps the record for inspection is Probably appropriate for this category. Okay, and how What is it that? assures that maintain the fidelity of In effect the the equipment or processes that we're We're intended to implement. Yeah, I think design base. There's um, it's 50 59 the same way There's not a requirement 50 59 that those The process is 50 59 and licensee does the evaluation and we know I think Historically on close calls and may be submitted to the NRC even though that 50 59 doesn't require that but I think that would still be in place for the areas where the interfaces with the safety systems Where the connections are made for the flex equipment? Those would still be subject to 50 59 But for all the rest of those things on the mitigation strategies I think the licensee can evaluate that and keep a record of the change We could submit like we do for FSA our updates for 50 71 e a record of those changes that were done in a Short basis for why we think we're still in compliance and that could be subject to inspection So it should be a much less burdensome process for this. Okay, mr. Gunjee. Do you have any thoughts on that? I think there I think there's a real Foggy situation here between license amendments and intensity for 50 59 That we would appreciate more clarity by providing public withstanding One other thing Tony I want to talk about is the the process and had some discussions and in Some of my plant visits on this is a question of the credit for use of a flex equipment and other And other applications or and I know there have been a couple instances where hadn't worked out Well, it hasn't isn't the credit but in the terms the application or in invocation of the flex equipment if you will hasn't worked out as well as is probably intended or thought so I would appreciate it says what give me an idea of what it is that we're crediting or how does that? How would that work and again? Ensuring this overall the fidelity in terms of the undertaking activities at the plant right so The I put them in two categories. The first category is What you can use the flex equipment for I'd say in a qualitative way not modeling it in the PRA or anything like that So it's just kind of another layer of defense in depth that you could apply to Whatever the situation is two white papers. We've submitted to the staff for consideration and discussion our Notices of enforcement discretion and the significance determination process That's the more short shorter term applications longer term. I think there is discussions already underway on how you would model flex in the PRA we believe that's going to take longer to work through to determine what's acceptable for that But in the interim we think we can use a lot of these qualitative applications They're not like regulatory guide one one seven four where it's an amendment you submit and none of that This is using flex equipment. I think one of the cases you may have heard of chairman Is it a specific licensee used it as defense in depth during an outage using the flex equipment? I think that's a terrific application and allows the plant staff to get that equipment out in the field hook it up get familiar with it In addition to the normal surveillance is going to get so the more familiarization you can get with equipment That's not going to be used very often I think is a win-win and for the staff and the residents and the regions to see the licensee utilize that equipment is a good thing Okay, thanks, and my last question mr. Bundt regarding mitigation strategy said that for the US BWR fleet is expect to be materially complete by the end of 2016 so for Give me some flavor for BWR mark ones and twos what will be in place at the end of 2016 Understand what we will be in place is their procedures their equipment their Connection points for those equipment the thing that won't be in place is their enhancements to their wet-well venting The majority of these sites already have hardened wet-well vents that they installed as part of their generic letter Back in the 90s They all have venting capabilities and procedural compliance on how to do that So what wouldn't be done is the material or the equipment and the enhancements that are done under the 109 order Which would come in a later date Okay, thank you. Okay. Thank you. Make sure it's a bit Thank You mr. Chairman, and I want to thank all the presenters for being here today My colleagues have covered a number of issues that I was interested in exploring I think I'll begin by turning to The two questions that chairman burns asked but I Am having some difficulty in bringing the two concepts together. This is for mr. Petrangelo On the one hand the chairman asked about change control and these are my words not yours So I'm paraphrasing seems that the industry is setting an expectation that they would like to have some kind of Graded regulatory treatment for change control on some of the mitigating strategies measures and equipment But at the same time then he the chairman's next question was about Perhaps crediting for the existence of some of these strategies and and equipment I know you mentioned that as further defense in depth But it seems to me a reasonable person could hear that as on the one hand I want a lighter regulatory footprint and on the other hand I want to have some kind of underlying acknowledgement of this equipment For fundamental issues within the design basis So and do you acknowledge that it could be heard that way? And if so, why is it not that that you're advocating for? I think you characterize it very very well I think we have a new rule that requires us to have these mitigation strategies in place with all this equipment Backed up by the nationals response centers We want to leverage that equipment to improve safety in certain situations during normal operations. So The lighter regulatory touch I think is For any changes in the mitigation strategies that the rule requires is I think appropriate for the beyond design basis Part of the framework, but for the existing framework. We're just simply using the equipment as additional Safety measures. So I don't see a conflict there myself But I could understand how it could be construed that way Well, I suspect and I can explore this with the nrc staff, but in some of the discussions you're having with them I suspect that this is a core issue for them and that's something that is going to be Credited although I don't like that term maybe acknowledged in underlying or incorporated into underlying risk analyses I think That it is likely that that will bring with it then a heavier regulatory treatment of whatever it is that you're crediting In other risk analysis So I think that's gonna I think a lot of this Resolution is going to turn on that question of how much is enough And I think if it were that, you know, the the equipment exists. Don't get me wrong I've been to a lot of plans. I've gone and look at it and it's it's substantial and it's physical And you can go look at it So I would understand a mindset that said but it is here and it would be usable and used in the event But on the other hand, I know this sounds Profoundly bureaucratic to say but If it is credited in certain analyses, I think that will Have to be a consideration in the regulatory treatment for change control and Configuration management and other other measures knowing that it is beyond the design basis And I understand that but I think it gets a little murky, you know Once we start kind of having it's not design basis It's beyond design basis and yet for some fundamental Analysis of risk and hazard. We're going to credit its use and existence. I don't know. It's just tricky It's uncharted territory and that's really all I'm saying. I don't know the answer I don't think the staff has made up its mind one way or another. My only caution is don't make it harder to improve safety I think it's likely we can begin with that as a mutual objective for the nrc and the industry Since we can't solve that one. I'll turn to mr. Canavan One of one of the things that We have an opportunity to do here is to do a validation of modeling and simulation You had a slide. I think it was slide four That talks about embarking on a long depth long term in depth technical understanding of the accident A lot of our severe accident codes and the chairman touched on this are based on Our expectation of the behavior of materials and systems Does this long term tech in depth technical understanding is this it seems to me this could be a multi-decade kind of research plan Is it taking that kind of shape? um, I think uh, there are There's there's Probably a multi-decade research plan, but there's also on ramps and off ramps to that that are sooner um, so there have been some I mentioned that the technical evaluation project if you if if you go to the first report of that Which is publicly available by the way, and you flip through the executive summary. You'll note that there's a simulation line that matt that has what we think occurred during the event Via simulation and then there's the actual data points that are plotted and when the data fits well We know the conclusions that are modeled in the code are probably accurate So we can we we have an understanding already of how to model and simulate we have a very good match actually of the of the Core dynamics that occurred there are some things we don't know yet that were that we Make educated guesses on based on the prevalence of data For example, did a safety relief outfell at a certain time did the head of the dry well lift to produce the The consequence that we talked about earlier in radiological terms so Improving that understanding and refining those models and getting higher fidelity Is part of the process and as we learn more about fukushima and as The japanese do more and more work to get into the containment and then into the vessels and then eventually remove Quarter break we will continually learn lessons that will continually refine those models Are those models good enough now to do quite a bit of work? Yeah. Yes. So I believe so. I believe that they're Substantially the containment and the core models are very good in terms of the core if refinement comes through having physical data points When does one begin to draw physical data out of Fukushima and I'm reflecting on the fact that the three-mile island damage core ended up in Idaho I did work out there not on the core, but I had a chance to see detailed video surveys and things that were produced and If you really want to validate a model being able to have access to the physical thing is How you can know whether your models are at all close When might the nuclear Science and technology sector begin to draw any Type of data like that from fukushima. I guess that's what I mean by a multi tech Adel saying it will take a long time to ever Be able to have access to that. Well, since you're familiar with tmi It took many many years to get all the way into the core And if you're if you're familiar with tmi and you go to the site in the control room of unit two there's actually a cutaway mock-up of the core and You can see how it melted and relocated It wasn't until they actually physically saw that and mapped it. They actually mapped it with with a laser To get that to get that model and that provided a lot of insight so I think it's a discovery process if you and We don't we don't normally like those but it is a discovery process where as we move in as Radiation dies down and we're able to get closer into the containment and then eventually the cores We'll learn more and more as we go For example, we'll learn if the head relieved When we can inspect the head bolts we'll learn more about whether a safety valve failed when we can see it So for now, we strongly believe that that the safety valve failed due to severe accident loads in unit two But we're not positive So we will have to and I meant unit three, but We will eventually see so I think it's a journey Well, I I I think that for The community of practitioners there will be a tension dynamic between our desire To have access to data and information with The need of those who are doing the decommissioning will seek to have a timely decommissioning and proceeding along however An opportunity to inform our knowledge about something like this is rare. We hope never again So I think it would be deeply regrettable if we couldn't Begin with a very conscious plan of what are those key opportunities to glean glean these kinds of accident insights and if Those can be somehow communicated to those who have the primary responsibility for Decommissioning like I said that will be in some tension And so I think that I would hope that the international r&d community would come together to realize that There will be some very significant opportunities here and if that that should be communicated I would hope to those who are Planning and executing the decommissioning at the site. Yes tepco is very interested in that and they pursue Capturing that information and sharing it as they go As well as participating in the international communities that are trying to capture data and model and simulate Thank you. And um, mr. Bond if I have a moment, I was just going to ask you provided A fairly detailed status on a number of implementation activities But specifically on severe accident hardened containment vent systems What would be the the key schedule uncertainty or if you will the long poll in the tent and completing those Activities on the schedules currently projected. Sometimes it's design. Sometimes it's procurement Is there anything there that you would identify as having the greatest association with schedule uncertainty for completing those plant modifications is currently projected? Thank you for the longest poll for Half the plants is design uh, believe the Other half the plants are really modifying what they already have to some degree So are going in and air going forward Design is uh well underway. We're sharing the lessons learned from the early design plants to the later ones So we are beneficial. It strikes me at the plants. I've gone to that. It's extremely plant specific and They have to look at the impact of the integrated system and things like that So is there much benefit in sharing design lessons between the plants or are they so plant specific? There is several elements that are Good for the sharing from the missile capability to some of the structural Impacts for where people are putting their vents to the procurement of radiation monitors or the indication systems. So we have periodic Every two weeks or every monthly calls within the industry to share their issues or their concerns But there is a lot of plant specific Design elements that go into when you run the codes for your particular design of your plant site But to create the overarching guidance on how you would address some of the Ununknowns or some of the other areas within the design process. We're doing that collectively as a bwr fleet Okay, thank you. I'm sorry. Mr. Chairman. I went over by bit. Thank you commissioner commissioner Austin. Thank you chairman Thank you all for being here and for your presentations Very helpful. I appreciate the questions of my colleagues. Very thoughtful Um, I want to start out just by reacting to a comment. I think mr. Petrangelo made And I think you're talking about the use of flex equipment during an outage. Is that that's one example? Yeah, so I just every now and then there's a something that resonate with me for the following reason Um Early on the s5w Westinghouse submarine reactor plants had emergency cooling system in that emergency cooling system was routinely used Well, the design of the system was provided flow via natural circulation in the event of loss of all the ac power Yet that system was also used routinely when the plants are cooled down during an upkeep or refit period and the operators got experience Um, I think I'm looking at pat cast them back there. You're an s5w submarine your first uh back and yeah So we use this a lot just during the upkeep periods And I think it enhanced the operator awareness of how the system operated. You actually operated the valves to the temperature indications And I had to have my over my 16 years in sea duty I had to use a system once for real life casually and I know that I was Glad to have had the actual routine operating experience of having used it Under non emergency situations before I was presented as engineer directing is used in a very critical situation. So I just I'm not sure what it's worth, but it's an analogy that I personally from operating and Not maintaining submarines think that's a good thing to enhance operator awareness and familiarity to the system Yeah, just to add a little bit. I think the arena we're talking about here is compensatory measures or something that's going on in the plant This equipment's all the same across the industry We've got every collecting data failure data on the surveillance. We're doing on this equipment so that we can later on Start to model it in the pra's with some actual data and not just on assumptions Um, and I think you know to your point getting your hands on it using it hooking up Is very very positive thing And I don't want to get hung up on the treatment. It's it's required by a rule We have a every develop the bread of maintenance templates for these Pieces of equipment. So we've already got a pretty good program in place for that I don't I don't see why it should be different to support comp measures and some of these other areas. Okay. Thank you Uh, I want to say there's a potential here on your slide for inflexing inspections I think your last bullet you indicated there's a concern with potential for growth and inspection scope without careful management oversight Uh, do you need details or specific there or things that are of concern? Not at this point commissioner. It's just a based on experience and I think I used the maintenance rule example last time I was here that you know that where we got our rule. We had five years to implement it Tremendous industry effort along with the nrc to get ready to implement it And then when it went to the field for the baseline inspections the average was Four level four violations after all that preparation work The concern is really based on if there's a whole different set of people that's going to have to implement now And interpret the new rules and guidance etc that weren't engaged with the front end of this We're keeping around this task force just to maintain that knowledge level I know uh nrr has plans to do the same thing with the all the lessons learned uh with within jld So it's just a big effort. It's a new piece of the regulatory framework Subject to interpretation. So I don't have any specific examples for you at this point it's just We want to make sure that we capture the operating experience And and let let all the other licensees in on it and share it with the nrc on a regular basis for the implementation smooth Well, I encourage you that if there are issues that come up that that'd be raised to our staff Does anybody else want to comment on that? Okay, mr. Canavan, let me ask uh on the epri experience here. I set the clock back to 2012 at this table We can mr. Svendiki and I are here with the number of Fukushima Uh Issues that they come out of uh seki 11 0 1 3 7 Looking at the tier 1 tier 2 2 3 seismic were Some of the hardest issues that time there was discussions four years ago at this table about concerns on being able to Conduct the size or seismic hazard reevaluations based on lack of seismic human capital expertise What can you say about how do you characterize the health and welfare of the seismic expert? Community at this point in time. They are very tired To be in all frankness that's that's actually not uh that far from the truth My my uh staff and I know the nrc staff puts a lot of work into Continuing to solve some of the More difficult seismic research issues It's time consuming It's a process that tends to evolve. So for example, we look at hazards We determine that hazards may have increased in certain areas But only in a certain part of the curve. They're high frequency motion. So we go into a high frequency motion Testing program that's quite extensive and you know expressed delivery. So we're working very hard to get that research completed The research gets completed. We understand the impacts on equipment very well But then we start looking at structures and because there's a the models originally built for analyzing structures Don't handle high frequency motions very well. So now there's another so it's a discovery process that that has continued Uh till recently and it's been it's been since Fukushima that we've been looking so I would say that um the burden the demand is remains high and We continue to work very hard on on the next set of issues Do you think as a result of Fukushima and I'll also throw in there the dominion resource august of 2011 earthquake at in southern virginia Do you think that In 2016 there is greater consensus on the approach for seismic than there was before Fukushima Look at seismic hazards I think so I think we're moving in the right direction and I think we're we're we're getting better understanding about seismic motion However, it it is an evolving area. It continues to move one of and actually a I'm going to answer a different question if I might which is what one of my worries is that We continue to analyze issue after issue and and we generally just just position those issues to an understanding of higher capacity or or significant robustness of the structures and There's a lot of resource spent in Evaluating what seems to be a smaller hazard now. I know we we need that understanding to uh to to understand our The risk from seismic events. However, there are other hazards as well So we need to balance resources with what we uh with the with what we think the commensurate risk is with the hazard And uh in seismic. We probably put a lot of resource in right now for um a hazard that's Sort of lower Okay, right or it has been shown in past to be lower. I should be more clear. Okay Mr. Bunt From the experience of the bwr owner group arena Has nrc kept up With promulgation of guidance and a time period to facilitate Implementation of the various orders Yes, we've worked very diligently with the staff on getting guidance out and getting uh frequently asked questions for the bwr fleet We've issued Several guidance documents and position papers to support the order. We have Had a lot of professional conversations some uh candid discussions And come up with a reasonable working element realizing that the where each one of the groups come from And just recently as part of the phase two worked with the 109 order issued a revision one that got endorsed and had a very concise and The documented template for the implementation of that that I believe is speeding up the nrc's review of that So that we'll get the evaluations in a timely manner to support our design elements. Okay Thank you all for being here. Thank you chairman Thank you. I want to thank the panel again for their presentations and the discussion this morning And uh, we'll take a brief break. Uh, we'll reconvene it about 10 25 and hear the staff presentations at that point Meeting back to order and uh, we'll now have a presentation with the nrc staff We'll discuss progress on implementing tier one recommendations and overview of the Staff's assessment on some tier three recommendations as well as a status update on uh, the remaining tier two and three recommendations and uh, Staff will also discuss plans for nrc oversight of post fukushima safety enhancements And i'll turn over to deputy executive executive director for operations mike johnson might Thank you. Good morning chairman commissioners We appreciate the opportunity to report on report to you on the status of our fukushima lessons learned activities As a result of the march 2011 accident of fukushima We began a race And at that time we recognized that it wasn't a sprint And it wasn't a solo activity or individual sport It was really a long distance relay And we anticipated that at times the terrain would be rough We anticipated that sometimes we would see adverse weather We knew fatigue would set in due to the length of the race and the struggle Associated with it. We knew there'd be distractions and we'd need to persevere if we were going to be successful Well five years into that race and here we are We've come quite a distance We've made uh, the industry has made numerous safety improvements That have been implemented at the facilities Plants are safer because they are better prepared to deal with extreme natural hazards And they're better prepared for other design basis beyond design basis events and as a previous panel discussed I think they're safer because they're margin associated with being able to deal with design basis events We've made substantial progress the progress that we've made Is really a testament to the dedicated and capable folks on the staff and in the industry And through active stakeholder engagement external stakeholder engagements And engagement for example with the advisory committee on reactor safeguards I would note we keep count at this point. We've had over 250 public meetings So we've had an active engagement with those stakeholders We've also benefited greatly from our collaboration with our international partners In a variety of interactions We've had active engagement in the international atomic energy agency And through nuclear energy agency activities as well And so I would say we're on the final leg of the race And the end is within sight Most of the safety enhancements, uh, directed by the commission will be realized by the end of 2016 Of course, we'll give you a detailed description of where we are in each of those individual enhancements And so we've made great progress But I want to emphasize that there's still work that remains And we'll talk about that work that remains as well And it remains that we need to be focused and provide leadership both on the part of the nrc And the industry in order to be ultimately Successful slide two, please Our approach in addressing the lessons learned from the accident has evolved substantially I would say from the issuance of the near term task force report in 2011 For every box on this slide starting with the near term task force We learned from the efforts that preceded it When it was appropriate We modified our actions based on new information And based on lessons that we learned from performing our activities For example, the original hardened vent orders With those orders we expanded to address severe accident conditions And to acknowledge the importance of water Addition and containment during those circumstances Ultimately, we added nine additional recommendations from the near term task force report And expanded the scope of several others In some instances we combined issues and in other instances We looked at what was recommended we did an evaluation We considered actions that were planned or implemented based on tier one and tier two items And we decided not to pursue additional action And of course at the end the commission put its you put in place Made a decision on each of those actions as we move forward and we've been implementing those actions We continue we will continue to learn as we complete our post flu kashima actions And we'll continue to make changes proposed changes as appropriate as we go forward Next slide, please This slide is really intended to provide On a single picture if you will The the the work that we've done and the work that remains As we move forward on implementing the near term task force recommendations again as modified by the staff approved by the commission Our focus today really is on the actions that remain where that remain to be closed We're going to discuss the progress made thus far and the pathway our pathway for closing those items But I don't want to lose sight of the fact that a number of the items many of the items on this slide is indicated in blue Have already been closed next slide, please And so I want to turn to uh the folks at the table uh introduce them briefly Starting with jack davis who is the director of the japan lessons learning division In jack will provide an update on the status of lessons learned activities, particularly the tier one activities Mohammed shams all the way to my right as a chief of the hazard management branch He'll provide an overview of the status of flooding and hazard flooding and seismic hazard reevaluations Greg bowman who is the acting deputy director for the jld We'll discuss the status of tier two and tier three recommendations And last but not least troi pruitt who was the director of the division of reactive projects in region four We'll discuss the regional regional activities and in particular transition to long-term oversight. And so with that i'll turn to jack Thanks mike. I'm good morning chairman and commissioners Um happy to be here again to report out to you the status of where we're at with these activities since we have Last met a several months back Um as mike said we continue to be on our ahead of schedule on all the activities And we have a clearly defined path forward for the remaining items that go beyond the 2016 time frame If can I have the next slide? Yeah, thank you. So starting at the top there Just i'll run through some of the stats for you just so you know we're at As you heard from the industry from mitigation strategies. We're approaching 75 in compliance We'll have the remainder coming due this year And in fact, we've already started verification inspections On several of the facilities that troi's going to talk to you in more detail to give you a flavor of the things We've been finding out there The um spend fuel pool instrumentation order about 85 percent are in compliance now And again what the remainder do the end of the year And we're also doing the verification inspections of those in conjunction with the mitigation strategies and inspections the hardened vents If you heard randy talk about almost a third we'll have phase one which is the wetwall vent this year We're expecting about 75 percent next year and then the remainder by The 2018 backstop date and likewise for phase two. They're coming in on a staggered Schedule but again most plants will be in compliance with that order about a year ahead of the backstop date of 2019 that the commission set With regard to the reevaluated seismic and flooding work again by design this goes past the 2016 time frame We're making good progress in that area Majority of the plants will have completed Their mitigation strategies assessments as we call them by the end of this year And again, mohammed is going to go into a lot more detail give you the breakout of some of the areas that we We're having somewhat of a challenge with On emergency staffing and communications the assessments and upgrades are in place for most licensees And again the few that are remaining will be done by the end of the year We see no problem with them making that that date On rulemaking We recently published the proposed rule for comment. We received a lot of comments We're in the process of looking at those comments trying to address those comments We are on track to deliver the final rule to the commission by the end of the year We don't see any problem with making that date on the next slide I'll I'll talk a little bit more detail about some of the comments that we that we had In 2015 we took the insights as you had instructed us to do on the tier one And we started applying those to the tier two and tier three Items and we were able to adjust our schedules to get to an earlier disposition of those items And following the commission's approval We've closed all group one items now and just recently closed group two And again, we're on track to close the remaining group three items by the end of this year And again, greg will provide you more information on that So really what we have left with Fukushima now What our real focus is is the seismic the flooding the vent work. We're completing our Safety evaluations for all of this work. So we have a durable record From our regulatory standpoint And then of course, we've been over the last couple of months Perhaps even a year of transitioning some of the activities back to the line and of course transitioning to oversight And I would mention, you know, you heard Tony talk about he's concerned about inspections We've been doing a lot of lessons learned a lot of knowledge management with the regions They've been hand in hand with us throughout this process So if I can have the next slide, please So just a little bit of detail on some of the comments we got We received about 20 comment letters and these included hundreds of individual comments Many of the comments are going to help us further improve the clarity of the rule and get a higher quality product That can get approved The four common areas that I've that I've shown here It's really to give you a flavor of some of the comments that we're receiving And also some of the ones that perhaps have a little bit of a Stickiness and that we have to take pause and and think about Before we move forward with so starting with the loss of all ac power There's a bit of a disagreement, I guess between commenters on the concept of the loss of all ac power In mitigation strategy We talked about it in terms of you lost offsite power concurrently with losing emergency diesel generators But we allowed them to take credit for inverters for motor control centers and so on as long as those items Couldn't be protected from the external hazards The language that we had in the orders we carried through it in a rule So some people have challenged us to say that Well, that's not a strict interpretation of the loss of all ac power right because you're using inverters You really haven't from the dc buses and you're turned into ac We feel that you know the strict interpretation of that and we can still deal with we still have contingencies for that Where they have portable equipment that they can take readings from and they have alternate means of Powering these equipment if those particular centers weren't available and again as I said before that We specifically looked to make sure that for instance have had flooding and you were going to flood out your your distribution center Well, that's not acceptable To us so I think We can just clarify the rule language Somewhat more and I think we're we would be okay in that area A multi-source term dose assessment We received a comment from industry that the backfit justification that We had for that was not sufficiently developed to justify the backfit We went back we took a look at what they had Provided to us and we feel that the initial look perhaps there's some validity to that concern Um, if if that stands if that conclusion is substantiated Um, then perhaps a voluntary regulatory approach may be appropriate because we still feel as there's significant safety Added by having these particular multi-source term assessments. We received Regulatory commitments from all licensees back in 2014 that they were going to do this So we don't really see an issue with relying on a different regulatory tool if we need to go the voluntary route On reevaluated hazards, uh, we received comments that the rule language could be improved to better reflect The means of how we're addressing reevaluated hazards and then also to incorporate risk-informed approach for these hazards We feel it We're very receptive I guess to the risk-informed approach we've done risk-informed approaches with the mitigation strategies order and really we believe that it's already there In the rule, we think it's just another way for them to to be saying that What we're already currently allowing Nevertheless, we think that maybe the best approach here would be to put in the statements of consideration to have better clarification That risk-informed approaches would be acceptable Way of dealing with some of the hazards and then on the clarification Points, we would just take those comments and put them into the rule language itself With change control and I heard a lot of discussion from the with the previous panel on change control Um, we received comments suggesting that our c should include some more rigor of some more specific requirements in the rule Currently we have it set as you heard tony talk about that. Um, the plans can do an evaluation They would keep that on site. It's certainly inspectable by the agency at any time it wants to look at those things Um, and we felt that that was the best way to deal with the beyond design basis nature The fact that it's a very uh flexible approach so that It's really at the highest level of the strategy. Did you really concern about that they not change? And then the other things that they can change down below if they follow their normal processes would be acceptable to us There's certainly our pros and cons to putting more detail into the rule that say that here's some more explicit criteria to use And we're going to have to go through that. We haven't even had a chance really yet to Work this up the chain of leadership to get some different ideas about how we might do this We have some options and we're going to present those and then we'll figure out how it goes before the uh, we owe you the rule at the end of the year Finally, um, unimplementation. It's another key area. I think for consideration of the rule We have a lot of moving parts right now a lot of different schedules with things coming into compliance so to uh, the more that we can anticipate that and the more that we can um Design in if you will the flexibility in the rule the better off we're going to be where we can Avoid unnecessary burden in the end of having people come and asking for an exemption when we already know that they're going to be on a certain schedule So we're trying to build that into the rule as well with the language With that i'll i'll turn it over uh to my next speaker Thank you jack, uh, good morning chairman commissioners It is my pleasure to be here today reporting on seismic. I'm flooding in and what we're doing in these activities My first slide i thought to to put up a flow chart to describe The the overall picture of how we're proceeding with flooding at seismic It is more for the benefit of someone that might not be as familiar as the commission is with with this activity So last year the commission directed the staff to develop an action plan To to ensure that the mitigation strategies address both The the the the timely completion of the 5054 f letters and the the assurance that the mitigation strategies address the reevaluated hazard This slide provides the overview for that plan The action plan consists of two as you can see for two two parallel path One associated with ensuring that the mitigation strategy is developed in response to order ea 1249 Can be implemented under the reevaluated hazard conditions the the other path Um is associated with completing the 5054 f letters to identify opportunities for further safety margins The nrc and the and the industry are proceeding aggressively along those both uh paths developing the necessary guidance and completing the associated assessments Um, I would say that the nrc staff has clear well defined approaches for completing both actions I also want to take an opportunity to indicate that as the commission directed us In carrying out the 5054 f letter assessments We always seek opportunities to focus the scope on those plans that would benefit from the safety enhancements for example last year we rescreened the The the plans doing SPRAs and the staff informed the industry that only 20 sites need to complete these detailed uh seismic probabilistic risk assessment Also with the revised guidance and flooding We anticipate that fewer than 10 plans would need to do integrated assessments Original count with more like 50 plans would be doing that The remaining sites will either screen off from further evaluations or perform limited scope evaluations to complete the The the information request next slide please So so getting to the specifics and and the statistics of what we've done What we can see on the slide is that the staff and industry have made substantial progress In completing the flooding in the seismic hazard reevaluations In the seismic areas as we can see all licensees completed The hazard reevaluation and the staff provided feedback on the adequacy of the reevaluated hazards Licensees with an increase in hazard Completed an interim evaluation known as the expedited approach and it's intended to ensure adequate seismic margin existed While the detailed risk assessments are underway We've issued staff assessments for all central and eastern united states Sites and we are unscheduled to issue the remaining three staff assessments for the western u.s. Sites And that should be completed by the end of this year In the in the flooding review area with the exception of two sites Requiring assistance from the u.s. Army Corps of Engineers All sites have submitted the reevaluated flood hazard information and the staff is providing feedback on the acceptability of of that hazard To date we've issued 51 letters Asserting the acceptability of the of the hazards submitted by the licensees The remaining 10 sites needed additional time to implement the u.s. Army Corps of Engineers information or to finalize calculations or licensee initiated site Layout changes the staff expects for the remaining 10 sites We expect to provide feedback letters for the majority of them by the end of this year. There may be one off by in next year We can also see on the slide At the bottom right corner that work remains In documenting the flood reviews and staff assessments to date We've issued only 15 staff assessments for 25 percent of the sites and I should say that this was done by design As part of our recovery plan for for the flood reviews Over the past nine months We have directed the staff's efforts to focus on issuing hazard letters in lieu of staff assessments To provide the licensees with the needed information to proceed with their mitigation strategies assessments and As a result of this Movement the vast majority of licensees are now able to and are on track to complete their mitigation strategies assessments In the coming months, we will shift our focus back to issuing the remaining staff assessment and we will do so in an expedited manner next slide please As I indicated we're proceeding down two parallel paths for the for both the seismic and flooding reviews This slide captures the ongoing activities In the in the flooding review area to support both the mitigation strategies and the closure of the 5054 f letter In addition to the progress in the hazard as I indicated on the previous slide the staff And the industry have made significant strides In developing the guidance necessary to complete the remaining assessments And the staff recently endorsed their revision to the industry's guidance for mitigation strategies NEI 1206 in order to provide guidance to the licensees for performing the mitigation strategies assessments or msa's At the reevaluated hazard level All licensees will perform this evaluation And the majority of them will complete it by the end of 2016 In fact, mr. Patrangelo indicated this morning that 50 of them will be completed by the end of this year Um, I should say that and last april We've actually received the first submittals of the msa. So licensees are not waiting to the end of the year They've already been submitting to us and we're in the process of reviewing them right now To support the 5054 f letter the other path The industry submitted a revised integrated assessment Guidance also known as the phase one guidance As directed by the commission this guidance provides a graded approach For performing the integrated assessments such that the integrated assessments are focused on those plans Where there is the greatest opportunity for additional safety enhancements This graded approach will enable most licensees to demonstrate An effective plan response to the reevaluated hazard by submitting a focused evaluation The the limited number of sites needing to submit integrated assessments will complete them by the end of 2018 Um in terms of endorsing the phase one guidance the staff has issued a public document It's a draft. It's a draft guidance to endorse this phase one guidance The staff also met with the acrs and discussed the guidance and received feedback a couple of weeks ago After addressing the public comments and acrs The staff will finalize its endorsement Of the guidance and will inform the commission in june prior to implementation Another guidance document that we've been working on is the so-called phase two guidance. That's the guidance on Carrying out additional actions as necessary based on the the integrated assessment results We're progressing well on this guidance as well. We're on track to Complete it in october and again and inform the commission of of its completion big slide, please This slide outlines the steps in the seismic hazard reevaluation process to support again the two activities mitigation strategies assessments and the 5054 f We're taking an approach. That's similar to the flooding reevaluation approach Again in support of the 5054 ladder closure since we met with the commission Last time the staff has endorsed the industry's guidance for performing high frequency and spin fuel pool Confirmation and the industry is proceeding to complete these confirmations on schedule With respect to the mitigation strategies again similar to flooding all licenses will complete This assessment to ensure that the strategies can be implemented under the reevaluated hazard In january of this year The staff endorsed appendix h to nei 1206 which provides guidance to most licensees on performing the strategies assessment And as we've seen this morning on a chart that mr. Pretend you presented the majority of licensees will be done by the middle of next year completing this assessment I should indicate that a number of licensees are Aiming to leverage insights from their probabilistic risk assessments into their mitigating strategies assessment The guidance for those sites are under development. It has been a focused area for the staff in the industry over the past few months NEI plans to submit this guidance to the staff in the third quarter of Of this year and that's intended to support the schedule for the final mitigation of beyond design basis events rule Also in terms of phase two the staff is it's also working on the seismic Guidance in that area and we plan to submit it to the commission along with the flooding guidance In october with that I'll turn the briefing over to greg to talk about tier two and tier three recommendations. Thank you moe As we discussed at our last commission meeting in november coming to resolution on the open tier two and tier three recommendations Has been a high priority for the staff over the last year We provided secchi 150137 to the commission back in october with proposals for resolving each open item And our goal in developing that paper was to identify disposition plans for each open recommendation In a timely and efficient manner while ensuring a strong technical and regulatory basis exists for our ultimate disposition approach As we discussed in secchi 150137 The majority of the open tier two and tier three recommendations were evaluations To determine if there's a need for specific regulatory action like issuance of an order of 50 54 f letter Rather than a recommendation or excuse me There were evaluations determined if there was a need to take regulatory action rather than a recommendation to actually take a regulatory action So given that our focus has been on completing those evaluations and identifying whether additional regulatory action is needed beyond what's already been done When we briefed you on secchi 150137 We discussed that the recommendations fit into three groups group one recommendations were those that we believe could be closed Group two recommendations were those where our initial assessment identified what we felt was a sufficient closure basis But where we felt that would be benefit to additional interaction with stakeholders before finalizing that assessment And then the group group three recommendations were those That we felt required additional evaluation or development before we were ready to provide the commission with our closure recommendation As you know, the commission approved our the staff's plans for the open tier two and tier three recommendations earlier this year Including the closure of the group one recommendations Since that time we've completed our evaluation of the group two recommendations Incorporating insights from our interactions with acrs The public and the ongoing state of the art reactor consequence analysis We provided our final assessment to the commission At on these recommendations at the end of march and they're now closed In the next few slides, I'll discuss our basis for closing the group two recommendations And then I'll provide a brief status update and next steps for the group three recommendations Before that before I do that I did want to take a minute to highlight The fact that we completed an evaluation of these to modify our potassium iodine distribution practices As part of secchi 150137 Since that issue came up in the previous panel As part of that evaluation we considered the radiological impacts in japan from the fukushima accident Um as documented in a number of recent studies We ultimately included that insights from the accident Uh did not call into question the ki distribution practices in the us And so we recommended in the commission approved closure of that recommendation Next slide, please So this is the first group two recommendation and it came from acrs Acrs recommended that we assess the need to upgrade certain reactor and containment instrumentation Such that it can survive the conditions that might exist during a beyond design basis event In secchi 150137 we discussed that based on the results of our initial assessment There will be only a small additional safety benefit from imposing new requirements in this area The primary factors in that in that conclusion included insights from the mitigation of beyond design basis events rulemaking And post fukushima safety enhancements which in addition to providing New capabilities to prevent core damage also help ensure continuity of important instrumentation from the onset of an event at least until core damage begins Our initial assessment also considered existing guidance for treatment of instrumentation that may be impacted by severe plant conditions This guidance includes provisions for the use of alternate instrumentation if primary instrumentation becomes unavailable treatment of instrumentation uncertainties that may exist due to environmental conditions The use of computational aids when direct measurement of plant parameters can't be obtained In actions to take if if conditions in the plant degrade such that there is no reliable instrumentation Our more recent interactions with acrs and other stakeholders have further supported our initial assessment and led to our final assessment which closed the recommendation The primary change from the initial to final assessment was the addition of further discussion Of the approaches the licensees would use in the event installed instrumentation is unavailable due to environmental conditions Including the use of analytical techniques It also reflects recent developments associated with the severe accident management guidelines Including the submittal of sam g related commitment letters from power reactor licensees and the staff's progress in developing the oversight program for sam g's Our recent paper also notes that will continue with ongoing work to update guidance That could be used on a voluntary basis by the industry if they choose to make instrumentation enhancements Next slide, please The next group two recommendation came from near term task force recommendation 5.2 And it involved an evaluation of the need for hardened vents on contaminants other than mark ones and mark twos Secchi 150137 provided a containment by containment initial assessment of this recommendation Along with plans to obtain input from external stakeholders and the acrs before finalizing that assessment Our initial assessment considered the substantial information that was available Pre-focus shame of studies on containment performance such as the containment performance improvement program from the 1980s We also consider that post-focus shima mitigating strategies order ea 12049 Includes requirements for maintenance of the containment function under extended loss of ac power conditions This order applies to licensees of all containment types and addresses the primary objective of the initial mark one and mark two containment Vent order specifically to remove heat and pressure from the containment For example for mark three containment types Compliance with the mitigating strategy order requires Licenses to put in place measures to remove heat from the containment Generally through repowering suppression pool cooling equipment using portable power supplies Finally insights from the draft containment protection and release reduction regulatory bases from mark one and two Contamines supports the finding that any risk benefit resulting from enhanced venting capabilities For other contaminants would likely be orders of magnitude below the quantitative health objectives Meaning that we would not be able to justify such action as a cost beneficial substantial safety benefit under the back fit rule Since providing the commission with our initial assessment, we've enhanced that assessment Based on interaction with the interactions with the acrs and the public And we've also incorporated insights from the ongoing SORCA study for sequoia and ice condenser plant and additional analyses We've done for mark three containment As with the previous recommendation the work we've done on uh since completing our initial assessment further supports the staff's initial conclusion The further regulatory action on this recommendation is not warranted Next slide, please The final group two recommendation recommendation six came from the near-term task force And it recommended that the staff evaluate the need for enhancements for control and mitigation of hydrogen inside Containments and an adjacent structures based on insights from the accident In evaluating this recommendation We were able to take advantage of significant information available from previous studies as well as from a recent international effort to study hydrogen control practices As with the previous recommendation the october sake paper provided a containment by containment Initial assessment of this recommendation and we concluded that that additional study is unlikely to identify the need for further regulatory action That conclusion was based in part on existing requirements in 10cfr 54 5044 for containment hydrogen control And the fact that the mitigating strategy in order provides provides a layer of defense against core damage And the resulting hydrogen generation that didn't exist before the Fukushima accident Our initial evaluation also considered a number of containment specific factors For example in the case of mark 3 and ice condenser containment types Compliance with the mitigating strategy to order includes provisions for repowering hydrogen igniters from portable power supplies The analyses we've done have shown that availability of the hydrogen igniters can significantly improve performance of the containment under severe accident conditions Finally as with the previous recommendation Studies completed for the containment performance and release reduction rulemaking So that imposition of additional requirements in this area beyond those already in place Wouldn't be justified under the backfit rule So we've enhanced our initial assessment based on interactions with acrs in the public And we've also incorporated insights from the ongoing sorca analysis for sequoia and some additional analyses for mark 3 containment As with the previous two recommendations the work we've done Since our october paper further supports the staff's initial assessment that this recommendation should be closed Next slide, please So in addition to our focus on the group two recommendations We've also been working on completing our evaluation of the group three recommendations which are listed on this slide In our october seckey paper, we described a four step screening process for evaluation of external hazards other than seismic and flooding We're nearing the completion of a paper that will provide the commission with the results of the second step of that process Which will identify a list of hazards that require additional review We held a public meeting on that subject in early april and we recently met with the acrs full committee and subcommittee We plan to provide our paper to the commission at the end of this month and then our overall assessment of that issue at the end of the year We've also been working on developing an approach that can be used Going forward to systematically assess new information related to external hazards This project is related to near-term task force recommendation 2 2 Although it's been expanded to include more than seismic and flooding hazards as it was originally envisioned We've begun developing a proposal to address this recommendation And we're planning to engage with stakeholders including the public the industry other governmental organizations and the acrs in the coming months Our approach for resolving this recommendation is due to the commission at the end of this year The final group three recommendation involves an assessment of the need to for real-time Radiation monitoring in the emergency planning zones and onsite We've been actively evaluating this recommendation since october and we're on schedule to have the final assessment completed by the end of this year So in summary we're on track to complete our evaluation of all the group three recommendations later this year consistent with the initial plans We've provided it to the commission and with that I'd like to turn I'd like to thank the commission first for the opportunity to brief you on this important activity And turn the presentation over to chore to discuss oversight activities Thanks, great. Good morning chairman and commissioners today. I'll be discussing the region's role in oversight The nrc staff conducted onsite audits to review technical issues and observed modifications to the plan Following notification by a licensee that compliance has been achieved The nrc staff will complete a safety evaluation to document its assessment of licensee's final integration plan for compliance The safety evaluation will be used to provide regulatory assurance and support completion of the nrc inspection activities ti 191 is being used to verify compliance staff from jld who are responsible for the safety evaluations will be assisting the region's In the initial inspections Additionally headquarters staff may also assist in the inspections Cross-regional teams are being utilized during the initial inspections in each region The staff is using cross-regional panels along with established processes such as the significance determination process To disposition any performance issues identified with these inspections A draft manual chapter o 609 appendix o is out for industry comment in its current form Appendix o would have a detailed risk evaluation performed if one of the three safety functions of core cooling Spent fuel pool cooling or containment is unavailable for more than 72 hours. So what that'll do is kick you out to a phase three analysis Next slide, please Inspections will be scheduled shortly after the staff issues the safety evaluation for each plant and just as a side note that's About four to six months from the time we get their safety evaluation in-house that gives us time to Will notify the licensees through traditional processes that we're planning an inspection activity A pilot inspection was completed at watts bar in 2015 More recent inspections have been completed at north anna robinson and cook The majority of inspections conducted under ti 191 will be completed in 2017 Inspection issues to date have involved the adequacy of procedures for story and testing flex equipment Calculations for room heat up following a loss of ventilation And labels marking deployment locations or hall paths All of the observations have either been minor or of very low safety significance or green With more plants coming into compliance with the new requirements inspection and oversight activities will increase from this point forward The staff has developed a transition to oversight plan the transition plan outlines roles and responsibilities and ongoing activities The plan assures consistent implementation through engagement and alignment of management For example cross regional panels and cross regional participation and development of programmatic tools The plan provides for enhanced knowledge transfer opportunities For example visits to sites and the response centers training at regional counterpart meetings and bi-weekly calls And the plan also provides for development of knowledge management tools Those involve training modules and the development of a share point site to exchange knowledge knowledge items Once all initial inspections have been completed a longer term inspection process will be developed using ti 191 As the basis in incorporating any lessons learned normal processes will be used for long-term oversight Such as the baseline inspection program under the reactor oversight process The staff is currently conducting training and creating a conduit for sharing information among the regions and other nrc staff We are also working with industry representatives to prepare for our on-site activities A number of related activities are ongoing with long-term oversight For example, the staff is developing the oversight program for the national safer response centers using the inventor inspection program Findings at the safer response centers Are expected to be dispositioned by issuing notices of nonconformance to the vendor overseeing the facility The staff plans to develop the inspection approach for the hardened vent order And for any changes made to the mitigation strategies in response to the reevaluated flooding or seismic hazards All licensees submitted commitment letters in 2015 to integrate severe accident management guidelines or samg's Into emergency response procedures The nrc staff will review the generic bwr and pwr samg's Implement the necessary training for staff and revise inspection guidance Changes to inspection guidance for site specific samg's should be completed by december of 20 That's all my comments mike i'll turn it over to you Thanks choice slide 19, please So as you can see we have achieved significant progress On implementing the safety enhancements as a result of the Fukushima accident As outlined in the presentation we're on track To ensure that the majority of those safety enhancements are in place by 2016 the end of 2016 Uh as as we uh finishing with the point that I made at the start our work's not done Hopefully we've re-emphasized the importance that we Pushed to to the finish line those activities and seismic and flooding for example that we do the transition to oversight That we capture knowledge as we go forward We're going to continue to monitor research activities and work that might be coming from other Lessons learned activities as they have been in our country and around the world We'll continue to engage effectively with stakeholders as I think we have in the past To solicit their input and consider them in our activities We're going to continue to stay attuned to what happens in the international Community and and make adjustments proposed changes should they be warranted So again, I think we've made good progress. We'll continue to stay engaged As we go forward result as a result of the items that have been raised as a result of the lessons Associated with the Fukushima lessons learned to ensure that we Do in fact make plants safer This concludes the staff's briefing and we look forward to the questions that you may have Thank you, Mike and well again, we'll begin questioning with the commissioner baron Well, thanks everyone for your work and for your presentations One of the ongoing tier three efforts is focused on developing a system for proactively evaluating New external hazard information on a routine basis. The goal is basically to actively seek Out new scientific information that may deepen and refine our understanding of external hazards I think it's an important effort particularly in light Of the expected impacts of climate change on some hazards like flooding extreme temperatures and drought Greg provided a brief update on the status of this work But I'd be interested in hearing a little bit more about where we are on that I know you have all year to do it, but I'm curious about where we are Yes, so we are aware in the sort of the early phases of developing the process And we don't have internal alignment yet on how it would look our thoughts right now We have a framework put together that would consist of essentially three components The first being knowledge management where we take the lessons learned from recommendation 2.1 and 2.3 We take the things we've learned about plant response to those hazards and incorporate them into You know sort of a sort of memorialize them so we can use them going forward The second component would be to sort of either establish new or re-establish You know re-establish relationships with Other federal agencies and with the industry that are involved in hazard assessment things like groups like NOAA The core army core of engineers epri to support Us going forward in that initiative. We would as part of that we would be looking to Establish routine interactions with those organizations so that we can gain insights from the work they're doing and then the third component of it would be You know the sort of the implementation component of the process where we take new hazard information in we screen it against established criteria We decided further regulatory action is needed So those are the three main components we're looking at we do have some work left to do Sort of to align internally and then to get input from external stakeholders before ready to propose An approach to the commission. Okay. Well, thanks for that update It I think there are at least two approaches One could take to assessing external hazards One is to do a periodic re-evaluation after a set number of years Another approach is what you are looking at right now, which is is there a way to do it on a more ongoing basis It sounds like based on the work you've done at date that Well, just asked as a question.  I think it is feasible. There are a number of challenges though. I mean, we I give one example in a moment have additional examples, but The tools that we have available to us to assess hazards are not fully developed for all types of hazards You heard that the site that our work in seismic Has benefited greatly from the fact that that was a very well developed field Flooding is not quite the same at the same place. And so going forward. We're going to be challenged. I believe in The the maturity of those tools and applying them going forward. So that'll be a challenge I think it's a feasible. I think it's feasible for us to develop an approach But you know, we want to make sure That that approach is consistent predictable and not overly resource burdensome So I think it's feasible. I think there are there are challenges that are going to require attention from the management team at the NRC Well, I'm looking forward to seeing what you come up with over the next several months. I really appreciate that you're doing this work I think it's important and I think it's an interesting approach. That's You know a little different than what people were originally suggesting here, but you know may have Several benefits of going that way Mike, I also wanted to follow up on the discussion I had With the with the first panel about how announcements of plant shutdowns will affect compliance with post fukushima safety enhancements or requirements On the first panel we talked a little bit about the example of oyster creek essentially gaining an exemption From the requirement to install wet well vent. We I just mentioned Fitzpatrick recently Submitted a couple requests. Are we expecting to receive more exemption or extension requests of this type either for the vent requirements or for other post fukushima requirements Thanks, misha. I I don't really know whether or to what extent we might get additional Request for relaxations. I would say certainly it's possible or feasible that we would But we don't know of any today But if I can just go forward then with that With that notion One of the things that I want to point out as I was listening to the discussion in the previous panel Is that for the majority of plants that we know about between now and 2018? The majority of those will be in compliance With the mitigating strategies order for example with spin fuel pole instrumentation order So so those plants we know about For plants that have to put in vents hardened severe accident capable hardened vents Those orders become effective around or those implementation dates are around 2018 2019 Which is when those plants would be shutting down. So we have a good understanding about the folks who are Sort on the plate if you will with respect to their intentions And I think because we for example have built into the mitigating strategies rulemaking Actually provisions for plants and decommissioning once that rule is effective will be in a in a stable place from a regulatory perspective dealing with those should they happen after that fact Right now in the absence of having gone final on on the mitigating strategies rule Um Can you talk to us a little bit about how the staff evaluates these these exemption or extension requests? Sure commissioner if I could I'm going to ask jack to do most of that discussion I did I do want to point out that uh, as you are aware, uh, because you made this point actually in the earlier panel It is a case by case Evaluation um when we look at what is requested it's often plant specific when we look at what we would consider in fact, it is specific case specific and so Because plants give us lots of leeway typically for those requests we have enough time to look at what What their rationale is what their justification is What compensatory things they might be doing and that enables us to be very thoughtful and deliberate about making a decision So jack do you want to add to that? Sure. Thanks Yeah, and I think it's important to point out too that there's really we've had two sets if you will of of different kind of exemptures For the mitigation strategy order the majority of those All of them and I take back all of them have been just to extend some time for them to complete It's still meeting the backstop date the few that that go beyond they're related to the plant shutting down Right, so for the you mentioned oyster creek. I think it's important to recognize we We look at those very seriously We expect them to have compensatory measures in place to essentially accomplish the same thing they would have Accomplished with with the order in oyster creeks case in particular The wet well vent that they currently have they still have to be able to operate those valves open and close that vent Without any motive force without any ac power So they had to have additional commitments put in place to have like nitrogen bottles for instance Those questions that we asked of them were all done in the public's eye So the reis that went out their responses they came back were all public publicly available So we take it very serious We do it on a one-off basis and we and we have to make it some engineering judgment as to as mike said They're shutting down right around the time that the plant would have to be in compliance. Anyway, does it really make sense to have them Do that upgrade or is it better to go with a compensatory measure? And some of these requirements including the vent requirement were determined by the commission to be necessary for adequate protection of public health and safety How does that affect play into The staff's evaluation of an extension or exemption request? Well, so this is another one. I'll start and then and then if you guys want to join in please do So even at the time when the orders were effective At a protection basis, we recognize that there would be time necessary for Licensees to come into compliance with those Because they needed to do designs if you will or or purchase equipment do training and all of those things So we always recognize that there would be some amount of time needed Um relaxation requests are adjusting that period of time based on what they might encounter on a plant specific basis And so we think it's reasonable actually if it can be justified To to grant those adjustments So we're not determining whether or not they come into compliance We're we're determining how long it takes and as someone mentioned I think on the earlier panel We'd be looking at for among other things that the risk And the exposure period compensatory actions and a number of things that we've considered In in granting those Yeah, I would just add commissioner that in the case of oyster creek They still have to comply with the order just because we extend at the time right So let's say they shut down and they need to come in with a recension request And we need to evaluate that to determine whether we would allow that to occur in in other plants similar to that Um if they're shut down they still have a component right that they'd have to protect and that's suspend fuel So it's not just that we're allowing them to not have to comply with the order It's the timing of when they would comply with it and we look at that in a case by case basis Well, you know, I don't want to get in spend a lot of time on the kind of semantic element of it But you know if if um if we have a plant oyster creek just take as example the plant that's Planned to shut down in a certain year 2019 And they get an extension on the wet well requirement until after the point they're shut down You know whether we call that a an extension or we call it an exemption I mean practically speaking it's going to be the same thing, right? I mean they've they're going to have shut down by that point I don't think anyone thinks at that point we're going to require them to put in a wet well after the plant shut down, right? I mean it's But you wouldn't need it at that point either right, but you still have you still have other components of practical purposes The extension is an exemption It's it's saying that for this plant shutting down a few years. You don't need to do a wet well vent If they were if they chose to stay in operation they would have to they would be required, right? If the announcement turned out not to Right be effectuated and that and then there's other components So that I think is the key point like for instance on the mitigation strategy And so and they still have certain pieces of the order that they would still have to comply with Even though they're in a shutdown state because they still have fuel on site So it's not a complete again That's why it has to be looked at and they have to ask for Resension or relaxation of certain components. I'm a little over on time, but I just want to ask one thing You know came up as a A little bit. I think maybe on the first panel If additional requests for an exemption or extension or relaxation, however talking about it are submitted for other plants That are shutting down Will the staff consider seeking public comment on those? So we don't as you well know as a part of that process Seek public comment. I would I would hasten to add that we've provided and I try to Illustrate the The high level of a stakeholder interaction that we've had from the time the orders were issued From the time we were crafting guidance for how those orders would be implemented through Interactions that we've had with licensees as we've tweaked guidance to based on lessons learned and in fact When we as someone made the point when we issue an RAI those are publicly available. So there's good public visibility There's not a formal way or in our process today by which we would go beyond that There is a 2206 process that could be used By individuals who want to request action of the agency We've seen that used in a number of instances and and would encourage folks to continue to use that if if they seek that Well, I you know I'll wrap up I you know these are pretty significant decisions and I would imagine that For many of them. They'd be pretty significant stakeholder interest Even if we're not required to seek public comment Even if we haven't done so as a matter of practice in the past Is is there any reason we shouldn't think about doing that going forward in cases of significant Exemptions that would have significant stakeholder interest So I would I would just say in response to your question that We will look we look to try to provide as much visibility as we can to the process There there are downsides. There are there are concerns that we would have by engaging in sort of a protracted interaction As a part of the decision process on some of these actions, so I personally i'm comfortable with where we are We we could do We could make sure through additional actions that would provide greater visibility if if there were a concern that that's not the case Okay, well somebody to think about we could talk about down the road. Thanks, mr. Chairman. Okay. Thank you One of the questions I would have is and we talk about The first panel and as well as in the staff presentations talk about Ongoing engagement in the international community in terms of research other types of activities you're going Ongoing that contributed to further understanding of the Fukushima Daiichi accident and as well as strategies to Basically respond to it or to prevent Or mitigate such actions Are there particular deliverables I would say over the next few years we're looking at obviously, you know, I think and Commissioner Saminiki talk in the discussion had on things like looking at Some of the research on the fuel will obviously of necessity have to extend out A number of years But are there particular deliverables we're looking for from IAEA or from the NEA or or even Bilaterally that might be in form us. We need to go on Thanks, just identify yourself for the record Richard me from officer research Uh, first is that I want to say the melko code is an NRC code. It's not a DOE code In terms of international efforts the star brand the NEA just finished us What Steve was was participate in the so called us I have to read it is the senior expert group on safety research opportunity post Fukushima The report would be coming out sometime in june And they have identified two issues that in the near term between three to four years that they will look into That will have a bearing on how to advise the The government of japan on the forensic those two activities has to do with the Study the fuel debris Using simulated Debris and analysis that is to help them. How do you develop tools for decommissioning? That will be useful for them because When we do the analysis the predictions of the few behavior is different But when they cool down is completely different. It's a very difficult material to cut as we have learned from tmi Another one has to do with the second activity has to do with Getting rid of the contaminate water in the buildings, especially the turbine buildings In all the three units so they can stage the recovery That the staff can work and a reasonable dose environment So those two activities are proposed for the next three to five years during that period they would also try to How do you call it fine-tune what type of information that doing the decommission that the The TEPCO can look for that can help us to validate our survey accident analysis called worldwide So those are the two activities near term that NEA will propose by the Recreatory agency from japan okay, another thing is that the US DOE also established a bilateral So-called similar nuclear working group that we do track and one of the activities has to establish an international framework for doing the forensic and Just like the tmi international efforts Okay, thanks very much. That's helpful one of the other things i'll ask with respect to You know international evaluations. I think it was you know At last year. I think around the time of the general conference at th