The United States utilities started preparing for external events that could lead to a loss of all ac power in the 1980’s, when the Station Blackout (SBO) rulemaking was first introduced by the United States Nuclear Regulatory Commission (USNRC). Following the events at the Fukushima Dai-ichi nuclear power plant on March 11, 2011, the USNRC established a senior-level agency task force referred to as the Near-Term Task Force (NTTF). The NTTF was tasked with conducting a systematic, methodical review of Nuclear Regulatory Commission (NRC) regulations and processes to determine if the agency should make additional improvements to these programs in light of the events at Fukushima Dai-ichi. As a result of this review, the NTTF developed a comprehensive set of recommendations, documented in SECY-11-0093, “Near-Term Report and Recommendations for Agency Actions Following the Events in Japan,” dated July 12, 2011. Documentation of the staff’s efforts is contained in SECY-11-0124, “Recommended Actions to be Taken without Delay from the Near-Term Task Force Report,” dated September 9, 2011, and SECY-11-0137, “Prioritization of Recommended Actions to be Taken in Response to Fukushima Lessons Learned,” dated October 3, 2011.

To satisfy some of the NRC’s recommendations, the industry described its proposal for a Diverse and Flexible Mitigation Capability (FLEX), as documented in Nuclear Energy Institute’s (NEI) letter, dated December 16, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11353A008). FLEX was proposed as a strategy to fulfill the key safety functions of core cooling, containment integrity, and spent fuel cooling.

The events at Fukushima Dai-ichi highlight the possibility that extreme natural phenomena could challenge the prevention, mitigation and emergency preparedness defense-in-depth layers. At Fukushima, limitations in time and unpredictable conditions associated with the accident significantly challenged attempts by the responders to preclude core damage and containment failure. During the events in Fukushima, the challenges faced by the operators were beyond any faced previously at a commercial nuclear reactor. NRC Order 12-049 (Ref. 1) and NRC Interim Staff Guidance JLD-ISG-2012-01 (Ref. 6) provided additional requirements to mitigate beyond-design-basis external events. These additional requirements impose guidance and strategies to be available if the loss of power, motive force and normal access to the ultimate heat sink to prevent fuel damage in the reactor and spent fuel pool affected all units at a site simultaneously.

The NEI submitted document NEI 12-06, “Diverse and Flexible Coping Strategies (FLEX) Implementation Guide” in August 2012 (ADAMS Accession No. ML12242A378) to provide specifications for the nuclear power industry in the development, implementation, and maintenance of guidance and strategies in response to NRC Order EA-12-049.

The US utilities are currently proposing modifications to their plants that will follow specifications provided in NEI 12-06. This paper presents some of the NEI 12-06 requirements and some of the proposed modifications proposed by the US utilities.

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