national standards response to fukushima lessons … · national standards response to fukushima...

NATIONAL STANDARDS RESPONSE TO FUKUSHIMA LESSONS LEARNED

Presented to: U.S. Nuclear Regulatory Commission

Public Meeting, November 30, 2012

Washington D.C.

By: Donald J. Spellman, Chairman Prasad Kadambi, ANSI Policy Committee Liaison

American Nuclear Society Standards Board

AMERICAN NUCLEAR SOCIETY

NUMBERS • Total number of standards setting bodies in the U.S. today

estimated in hundreds of “traditional” standards development organizations (SDOs).

• The 20 largest SDOs produce 90% of the standards - hundreds more “non-traditional” standards development bodies, such as consortia, exist.

• Individual experts committees comprise groups addressing the technical requirements of standards within their specific area of expertise.

• About 200 standards developers accredited by ANSI; with more than 10,000 American National Standards.


ANSI PROCESS ASSURES • Consensus reached by representatives from interested

parties • Standards undergo public reviews • Comments must be responded to in good faith • Provides an appeals process • Due process requirements • Approval verifies • Openness and due process principles have been

followed, and • A consensus of all interested stakeholder groups has

been reached • Participation of all stakeholders represented fairly through

balance of interest

ANS Balance of Interest (BOI) Categories*

Owners Vendors

Architect-Engineers Consultants

Government Agencies National Laboratories

Universities Societies

Individuals

*no single interest category constitutes more than one-third of the membership of a consensus body dealing with safety-related standards


Typical Organization Structures of an ANSI Accredited SDO (e.g., ANS)

• Standards Board (ANS Standards Board) • Consensus Committees (e.g., N16, N17, NFSC,

JCNRM) • Subcommittees (e.g. Design, Operations, Emergency

Preparedness, Fuel Cycle, Computations, Analysis, Waste Management, Physics, Criticality Safety, PRA)

• Working Groups (Standards Writers)


ANS Standards Committee STANDARDS BOARD

(17 voting members)

Nuclear Facilities

Standards Committee

N16

Nuclear Criticality

Safety

ANS/ASME Joint

Committee on Nuclear Risk Management

Nuclear

Criticality Safety

Research Reactors, Reactor Physics,

Radiation Shielding & Computational

Methods

Subcommittees

Working Groups

Subcommittees

Working Groups

Subcommittees

Working Groups

Subcommittees

Working Groups

Between 800 and 1000 active committee members

Risk & Performance Based Principles Policy Committee

(Approved 11/13/12)

NRC/DOE Interface Management Standing Committee (Approved 11/12/13)

Policy & Procedures Standing Committee

(Approved 11/13/12)

LIST OF ANS SUBCOMMITTEES ANS-1: Conduct of Critical Experiments (N17) ANS-6: Radiation Protection & Shielding (N17) ANS-8: Fissionable Material Outside Reactors (N16) ANS-10: Mathematics & Computation (N17) ANS-14: Fast Pulse Reactors (N17) ANS-15: Operation of Research Design (N17) ANS-19: Physics of Reactor Design (N17) ANS-21: Maintenance, Operations, Testing & Training (NFSC) ANS-22: System Design Criteria (NFSC) ANS-24: Modeling & Analysis (NFSC) ANS-25: Site Characteristics (NFSC) ANS-26: Emergency Planning (NFSC) ANS-27: Fuel Cycle, Waste Management & Decommissioning (NFSC) ANS-28: HTGR Design Criteria (NFSC) ANS-29: Advanced Initiatives (NFSC)


ANS Standards Overview

Development Process

Work Group established PINS approved by SB

Written comments

WG drafts standard & evaluates comments

Subcommittee reviews standard & votes

BSR ballots certification

SB certifies process

Consensus Committee reviews & ballots

Public review

American National Standard

Consensus Committee agrees with

ballot resolution

ANS Standards Committee Discussion Regarding

Fukushima


Flooding Standards • ANS-2.8, “Determining Design Basis Flooding at Power Reactor

Sites” (historical revision of ANSI/ANS-2.8-1992 – new standard) Applicability to NRC Fukushima efforts: This standard will provide

a means of establishing design bases for numerous hydrological events inclusive of tsunamis. Additionally, it will provide a means to conduct flood hazard walkdowns at existing and new nuclear power plants.

Status: The working group anticipates completing a first draft by the end of 2012.

• ANS-2.30, “Assessing Capability for Surface Faulting at Nuclear

Facilities” (new standard incorporating portions of historic standard ANSI/ANS-2.7-1982)

Applicability to NRC Fukushima efforts: This standard will address seismic walkdown and seismic design requirements. It will provide a compilation of techniques to evaluate fault offset potential in site characterization studies.

Status: The working group anticipates completing a first draft by the end of 2012.

Emergency Planning Standard • ANS-3.8.3, “Properties of Radiological Emergency Response

Plans and Implementing Procedures and Maintaining Emergency Response Capability for Nuclear Facilities” (historical revision and consolidation of ANSI/ANS-3.8.3-1995 and ANSI/ANS-3.8.4-1995 – new standard)

Applicability to NRC Fukushima efforts: Its future revision will address all emergency preparedness equipment and planning requirements that have been identified in the FLEX program, etc.

Status: Project Initiation Notification System (PINS) forms were approved and submitted to ANSI for historical revisions/consolidations to seven emergency preparedness standards. A decision was made to initiate ANS-3.8.7 first as a risk-informed, performance-based standard. Once further along, a path forward for completing the remaining emergency preparedness standards will be determined.


Fuel Related Standards • ANS-57.3, “Design Requirements for New Fuel Storage Facilities at

LWR Plants” (historical revision of ANSI/ANS-57.3 -1983 – new standard)

Applicability to NRC Fukushima efforts: This standard will contain applicable requirements identified by the NTTF associated with spent fuel pool level monitoring and SSCs.

Status: A working group was reformed and a PINS prepared. Work on the draft has just begun.

• ANSI/ANS-57.10-1996; R2006, “Design Criteria for Consolidation of LWR Spent Fuel” (revision of ANSI/ANS-57.10-1987)

Applicability to NRC Fukushima efforts: If revised, this standard will contain applicable requirements identified by the NTTF associated with spent fuel pool level monitoring and SSCs.

Status: Reaffirmation received ANSI approval 7/6/2006. No current activity.

ANS Responses to NRC NTTF Tier 3 Recommendations

Prasad Kadambi


NRC-ANS Standards Interactions • ANS (together with ASME) has been engaged with NRC on PRA

standards for more than six years. • NRC has provided a grant that enables ANS volunteers to travel

to meetings. • ANS has learned many lessons in consensus building through

this experience. • NRC has sought ANS engagement on Integrated Safety

Assessments for 10 CFR Part 70 implementation. • ANS proposed post-Fukushima engagement regarding guidance

documents on Tier 1 issues. • Tier 3 issues offer more time to build a stronger working relationship

between NRC and ANS on standards.


Standards Process for Tier 3 Issues

• Experience from PRA standards shows that achievement of consensus can be arduous and time-consuming when dealing with technology under development. ▫ It can be done. ▫ It saves NRC resources.

• PINS process analogous to ANPR relative to some Tier 3 issues • Standards process allows TUPA (Trial Use and Pilot Application). • Standards process can be performance-based to deal with

incomplete Fukushima or other information. • Focus efforts where policy clarity obtains.


SECY-2012-0095 on Tier 3 Issues • Characterization of Tier 3 issues ▫ require further staff study to support a regulatory action, ▫ shorter-term action that needs to be completed to inform the long-

term action, and ▫ availability of critical skill sets.

• Eleven issues identified with program plans and staff assessments. Some not related to NTTF recommendations.

• Significant research needs identified in addition to Fukushima-related information.

• Policy issues clearly identified. • Generally represents more information than is typically available at

the start of standards projects.


Potential Standards Approaches • Work with NRC staff to make maximum use of program plans

for each Tier 3 issue. • Work with other SDOs to constitute one or more working

groups. Negotiate balloting rules to fulfill balance-of-interest and due-process considerations.

• Create project plans to be consistent with research studies or information gathering.

• Address critical skills issue by exploiting broad volunteer base. • Frame consensus issue in performance-based manner to

enable experts to use qualitative and quantitative information to the maximum extent possible.

• Ensure that important boundary conditions are captured in “shall” statements.

Preliminary Issues Analysis 1) Periodic Confirmation of Seismic and Flooding

Hazards a. Issue definition

i. Confirm seismic, flooding and other hazards periodically ii. Address new and significant information

b. Regulatory challenge i. Incorporate systematic approach to update hazards, and response to

new and significant information, as part of regulatory practice c. Potential consensus action

i. How to treat information gathered in updates? ii. What constitutes new and significant information?

d. Related standards i. Seismic standards ANS-2.2, 2.10, 2.26, 2.27, 2.29, 2.30 ii. Flooding standard ANS-2.8 under revision

Preliminary Issues Analysis-continued

2) Enhancements for Prevention and Mitigation of Seismically Induced Fires and Floods

a. Issue definition i. Evaluate potential safety enhancements for seismically induced fires

and floods ii. Implement regulatory response

b. Regulatory challenge i. Work with JCNRM to develop PRA methodology standard ii. Work with ANS to apply PRA for evaluation

c. Potential consensus action i. Consensus on methodology standard ii. Criteria for determining safety value of proposed enhancements

d. Related standards i. ASME/ANS RA-S-2008, ANS/ASME-58.24,58.25 under development ii. TBD for application standards


3) Hardened Vents for Other Containments a. Issue definition

i. Reaffirm existing regulatory position on other containments ii. Evaluate new information

b. Regulatory challenge i. Priority of other containments relative to filtering Mark I & II vents ii. Interaction with hydrogen gas control and mitigation

c. Potential consensus action i. Criteria for determining adequacy of containment capability under

severe accident conditions ii. Criteria for determining safety value of proposed enhancements

d. Related standards i. TBD


4) Hydrogen Control and Mitigation Inside Containment

a. Issue definition i. Identify insights about hydrogen control and mitigation from

Fukushima information ii. Evaluate new information

b. Regulatory challenge i. Evaluate adequacy of existing requirements and practices (some of

which are voluntary) in light of Fukushima information c. Potential consensus action

i. Convert voluntary practices in Mark III and ice condenser containments into voluntary consensus standards that can be endorsed by NRC

d. Related standards i. TBD


5) EP Enhancements for Prolonged SBO and Multi-Unit Events

a. Issue definition i. NTTF recommended rulemakings for specific enhancements

b. Regulatory challenge i. What new regulatory requirements are justified given that the existing

set of requirements provide reasonable assurance of adequate protection?

c. Potential consensus action i. ANS standards sub-committee ANS-26, “Emergency Planning” is

undertaking revisions of its suite of historical standards. Some Tier 3 EP enhancements may be candidates for inclusion

d. Related standards i. ANS-3.8.1, 3.8.2, 3.8.3, 3.8.6, 3.8.7


6) ROP Modifications to Reflect NTTF Recommendation1

7) Staff Training on Severe Accidents and SAMGs 8) Basis of Emergency Planning Zone Size 9) Prestaging of Potassium Iodide 10) Transfer of Spent Fuel to Dry Cask Storage

These issues involve significant policy

considerations and so may not be amenable to consideration in a consensus process.



11) Enhanced Instrumentation for BDB Conditions a. Issue definition

i. Adequacy of current instrumentation to cover full range of BDB conditions suggested by Fukushima events

b. Regulatory challenge i. Determine survivability with adequate capability of instrumentation

qualified to address the guidance of RG 1.97 ii. Modify regulatory requirements as appropriate consistent with new

information c. Potential consensus action

i. Joint ANS and IEEE activity to establish criteria to determine adequacy of instrumentation for BDB conditions

d. Related Standards i. TBD

Fuel Cycle Facilities’ ISA Standard • SECY-2012-0091, “Completeness and Quality of Integrated Safety

Analyses” recommended that the staff request ANS to develop an ISA standard.

• The Commission approved this recommendation stating that the diversity of fuel cycle facilities should be addressed and a peer review process be considered.

• The underlying requirements in Subpart H of 10 CFR Part 70 identify risk-informed performance requirements.

• Although unrelated to Fukushima, the time scale and technical skills needed for fulfilling this request from NRC would be similar for ANS.


ANS Actions on ISA Standard • A PINS (Project Initiation Notification System) form

has been prepared and balloted. • A Working Group has been formed. • The consensus building process has begun with the

need to resolve negative ballots. • A consensus PINS will be published under ANSI

rules providing public notice of work on the standard beginning.

• A project plan will be prepared with the involvement of all stakeholders including NRC.


Summary and Conclusions Standards Development Cost *

• Chair(s) annual hours 127.9 • 1 WG members annual hours 61.7 • # of WG members 11.0 • # of years (initiation to ANSI approval) 6.0 • Chair(s) annual travel expense $2,178 • 1 WGM annual travel expense $1,935 • Annual cost per standard $17,657

* Average for 23 standards


Summary and Conclusions • Major impacts on time to produce a standard ▫ Members time is generally on a volunteer basis and

conducted after regular work hours. ▫ Approximately 30% of committee members are not funded

(retired, etc.) and travel at their own expense. ▫ ANS information system inadequate to allow conduct of

comment resolutions, balloting, etc.. online (funding need).

▫ ANS members database on volunteers inadequate to support selection of WG members by skill sets.

▫ Required review period times rather long to allow adequate and balanced responses from experts.


Summary and Conclusions • Never pose a problem without a potential solution ▫ NFSC task group reviewed the process and noted a

number of potential improvements. ▫ Additional secretarial support at ANS HQ has improved

turn around times. ▫ Greater attention from ANS management is helping with

committee focus and planning. ▫ Better communications with NEI has greatly improved

cooperation and feedback from industry. ▫ Convert NEI quick response documents into national

standards.


Summary and Conclusions • What else is needed? ▫ Grant support for ANS computer software and working

group travel would greatly shorten the ANS response time and improve the products.

▫ Better direct communications between SDOs and regulators and industry to identify areas where standards would benefit and those where they would not be needed. Start with the list of all historical ANS standards. Small task group to weed out the needs and set priorities.

▫ Major volunteer recruiting campaign supported by NRC and NEI.


national standards response to fukushima lessons … · national standards response to fukushima...

Documents