Nuclear Plant Journal, May-June 2016 NuclearPlantJournal.com
35
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more deterministic, and I think a lot of
mechanisms for flooding that had a lot of
strong conservatisms in them. I think the
big change in the past year (2015) was that
we had gotten to the point, where we were
going down two parallel paths. One was
the evaluation as required by the orders to
put in place mitigating strategies to deal
with the flooding and seismic hazards.
And at the same time, we were going
through a process to look at reevaluated
flooding and seismic hazards. And what
we came to the realization was that in
some respects, they’re working at cross
purposes. And we had to make a decision
as an agency, what was the most important
thing to do? Ultimately, the mitigating
strategies would need to be able to be
protected against the reevaluated hazard.
And so, the conundrum that we were in
was that we have to move industry in
a direction to focus on the mitigating
strategies equipment because the goal
was to have, by the end of 2016, all the
mitigating strategies in place. When the
orders were written, however, we didn’t
know what the reevaluated hazards were.
Well, as they’ve done the reevaluated
hazards, some plants have found that
the reevaluated hazard may exceed their
design basis, but they’ve been marching
along to get their mitigating strategies
to only meet design basis requirements.
And so we had to basically have a course
change that allowed both us and the
industry to focus our attention on the
mitigating strategies and the ability to
meet the reevaluated hazards, and then
push back the effort and streamlined
the effort on looking at sort of the more
integrated assessment picture for all the
plants and flooding.
That was a big change, I think, in
flooding. We had to send a paper to the
commission. Commissioner Baran’s
presentation talked about this very issue
as being an important area where we
had non-concurrence. We had staff
that felt we ought to pursue a different
direction. And all that information
came up to the Commission, and the
Commission ultimately gave us some
direction that basically said go forth,
focus your major attention at this point
in time on the mitigating strategies, and
oh, by the way, look to eliminate some
of the conservatisms, and let’s give us a
more focused effort on looking at other
facilities in terms of sort of an integrated
flooding picture. So that’s where we are
now. There are still a handful of plants
that have not yet gotten affirmation from
us that we agree with their reevaluated
flooding hazard, for example. Some
plants are relying on Army Corps of
Engineers analyses which have yet to be
delivered, so clearly they can’t get theirs.
Some licensees have made decisions that
they want to do a reevaluated flooding
hazard assessment, which means we
haven’t reviewed their final results. So
there’s a handful of plants that, as you go
into 2017, will, may be need to make some
adjustments either to their procedures or
processes, or in some cases, maybe some
of their equipment protection, because of
the reevaluated flooding hazard effort, but
the important thing is that the mitigating
strategies and the equipment will be in
place for all plants by the end of 2016.
