Industry Challenges NRC Resource Estimates for Post-Fukushima Re-Evaluations

The following story originally appeared in NEI’s Nuclear Energy Overview.

The industry estimates it will take each nuclear plant site between 30,000 and 45,000 hours to respond to the U.S. Nuclear Regulatory Commission’s post-Fukushima request for information on seismic risk and other issues—more than three times the NRC’s estimate.

In March the NRC issued a request asking reactor operators to perform a detailed re-evaluation of their plants’ seismic and flooding hazards and to provide information on sites’ communications and staffing capabilities during emergencies affecting multiple reactors at a site. The NRC estimated the total level of effort, or resource burden, required to respond to the requests would range from 8,840 to 14,660 hours per site.

The industry believes those figures “significantly underestimate the burden that will be imposed on licensees,” said Adrian Heymer, executive director of Fukushima response at NEI, in a June 29 letter to the agency.

The biggest discrepancy between the industry and NRC estimates involves the seismic hazard re-evaluation, which includes two steps. First, licensees will re-evaluate the seismic hazards for their sites. The NRC estimates these initial evaluations will require 1,420 hours for sites in the eastern and central United States and 2,850 for western sites.

Heymer said the industry has too little information to develop accurate resource estimates for this part of the request because the NRC is still working out the requirements. He said the industry has no basis for challenging the NRC’s figures but questions the accuracy in light of the limited information available.

Depending on the results of the seismic hazard re-evaluations, licensees may have to proceed to the next step and perform additional studies to calculate the seismic risk profiles for their sites. The industry projects that up to 70 percent of nuclear plant sites may have to perform such studies. Industry experience with new plants indicates this step will require 15,000 to 30,000 hours per site. However, the NRC assumes that only about one-third of the sites will need to perform these studies and would be able to do so in a fraction of that time—2,020 to 6,410 hours per site.

The portions of the information request dealing with flooding and emergency preparedness are less resource-intensive, but even here the gap between industry and NRC resource estimates is wide, with the differences ranging between a factor of two and seven.

The only point of agreement in the two sets of estimates concerns the seismic inspections, which both industry and the NRC estimate will require 2,000 hours per site.

The discrepancy between the NRC and industry resource estimates has significant implications for the NRC’s timetable for completing this work, Heymer said, particularly in the seismic area. Given the large number of sites likely to perform seismic risk studies and the limited number of seismic experts available to assist with this work, he said some licensees will find it difficult to complete this part of the information request by the NRC’s deadline.