U.S. Government and Nuclear Energy Industry Response to the Fukushima Accident

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1 October 2013 U.S. Government and Nuclear Energy Industry Response to the Fukushima Accident Summary The 2011 accident at Japan s Fukushima Daiichi nuclear power station had a profound impact on nuclear power operators worldwide. The policy discussion on nuclear energy changed from the benefits of this clean energy technology to safety and security issues that, informed by decades of safe operation, had been largely resolved in the minds of the public. Within one week of the Fukushima accident, operators at U.S. reactors were reviewing systems and components to ensure that the designed features and measures could mitigate the effects of a seismic event, flood or complete loss of AC power. The U.S. nuclear industry has pooled resources to ensure the lessons from Japan are systematically gathered, analyzed and implemented. This process has already identified near-term enhancements that will add further to the margin of safety F Street NW Suite 1100 Washington DC The industry will also take action to satisfy additional requirements that the U.S. Nuclear Regulatory Commission (NRC) imposes. The NRC is one of the world s largest independent regulators with approximately 4,000 employees and an annual budget of $1 billion. On March 23, 2011, while the accident in Japan was still unfolding, the NRC established a senior-level task force to review the NRC s processes and regulations to determine whether the agency should change its regulations governing nuclear power in the United States, and to make policy recommendations to the Commission. On July 12, 2011,

2 2 the task force, called the Near-Term Task Force, published its recommendations. The report also provided the basis for NRC development of regulatory actions to enhance safety. Since then, the NRC has repeatedly affirmed one of the Task Force s conclusions: continued operation and continued licensing activities [at nuclear power plants] do not impose an imminent risk to the public health and safety and are not inimical to the common defense and security. 1 Continued operation and continued licensing activities do not impose an imminent risk to the public health and safety and are not inimical to the common defense and security. Conclusion of Nuclear Regulatory Commission Task Force that reviewed the implications of the Fukushima accident. In the absence of any immediate threat to public health and safety, plant operators will incorporate enhancements to equipment and emergency plans in an organized, sequential and structured way. Plant operators are integrating new NRC requirements with existing regulatory and licensing activities consistent with their safety benefit and significance of the issue being addressed. The robust design of U.S. reactors, and their ability to manage severe natural events, was demonstrated in 2011 and U.S. plants maintained safety through severe tornadoes, historic floods, an historic earthquake and two hurricanes that wreaked havoc along the east coast. The reactor safety systems performed well during all of these events, while nearby infrastructure experienced billions of dollars in damage. NRC Study Confirms Nuclear Plants Are Safe A multi-year, multi-million-dollar severe accident analysis (State-of-the-Art Reactor Consequence Analyses (SOARCA)) conducted by the Nuclear Regulatory Commission and released on February 1, 2012, found that in the event of a total loss of electrical power and the failure of all permanent safety systems (similar to the accident in Japan), the public would be protected effectively with no significant near-term or long-term health effects. The report concluded that in all scenarios studied, even the unmitigated ones, events progress more slowly and release much less radioactive material than an extremely conservative 1982 siting study had found. Among its conclusions: the calculated risks of public health consequences from severe accidents... are very small. 2 Federal Government and Industry Actions to Enhance Safety Understanding fully the progression of events and the extent of the damage to the reactor fuel and major systems, structures and components at the Fukushima Daiichi reactors will take more than a decade. The industry has already identified issues that deserve attention, based on what is now understood about the events and their consequences. These issues include availability of 1 Recommendations for Enhancing Reactor Safety in the 21st Century: The Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, U.S. Nuclear Regulatory Commission, July 12, 2011, at U.S. Nuclear Regulatory Commission, State-of-the-Art Reactor Consequence Analyses (SOARCA) Report (Draft Report for Comment), NUREG-1935, January 2012, at xxiii.

3 back-up power sources and protection of primary and back-up components from flooding or seismic risks. 3 The industry and the NRC are in general agreement on the topics to be considered in the near term, including assessment of earthquake and flooding hazards and an assessment of plants ability to cope with the extended loss of electric power. The Nuclear Regulatory Commission has identified a number of new requirements in response to the Fukushima accident. These requirements are organized into three tiers. Those in Tier 1 will be implemented without unnecessary delay and have the highest priority. Tier 2 actions depend on the resolution of Tier 1 issues, technical resources or further technical assessment. Tier 3 recommendations will be evaluated later based on the availability of additional information from Japan, the types of regulatory actions required, and the outcome of Tier 1 activities. (See page 9 for the tiers and their recommendations.) There are eight Tier 1 recommendations that are considered to have the highest priority and the greatest safety benefit. The Commission has directed the NRC staff to engage stakeholders communities, states, and nuclear plant operators to develop the scope, approach and acceptance criteria for these items. Given the technical complexity of some of the issues, some of the Tier 1 recommendations will take several years to complete. NRC Response to Fukushima On March 12, 2012, the NRC issued the first regulatory requirements for the nation s operating reactors on the eight recommended actions in Tier 1. The NRC issued three orders requiring safety enhancements related to: mitigation strategies to respond to extreme natural events resulting in the loss of AC power ensuring reliable hardened containment vents enhancing used fuel pool instrumentation. The NRC has required that plants begin implementation of these safety enhancements immediately and complete implementation within two refueling outages or by December 31, 2016, whichever comes first. In addition, the NRC issued formal Requests for Information to plant operators asking for their specific plans for how they will: re-evaluate their earthquake and flooding hazards using present-day methods and information conduct walk-downs (inspections) of facilities to ensure protection against the hazards in their current design basis, and re-evaluate their emergency communications systems and staffing levels. Companies submitted plant-specific plans to NRC in February 2013 describing how they intend to comply with the NRC orders for responding to beyonddesign-basis events like those experienced at Fukushima. (Those orders covered mitigation strategies, reliable hardened vents and spent fuel pool instrumentation.) Seismic Hazards. The NRC has endorsed the industry s proposed approach to re-evaluate the seismic hazard at nuclear plants. The industry approach in-

4 4 cludes an expedited seismic evaluation to demonstrate sufficient seismic margin, implementing plant modifications where appropriate to increase seismic margin, and (in the longer term) comprehensive seismic probabilistic risk analyses (PRAs) of the entire plant. Reactors in the central and eastern regions of the U.S. must complete their expedited evaluations (and any modifications necessary) no later than two refueling outages after 2014, using an updated ground motion model. Reactors in the West have until two refueling outages after Known as FLEX, for diverse and flexible mitigation capability, the industry will position emergency equipment at diverse locations onsite, supported by reserve equipment prestaged elsewhere. Flooding Hazards. The first group of 22 nuclear power plants required to conduct flooding re-evaluations either submitted their evaluations, or rescheduled their submittals, by the NRC s March 12, 2013, deadline. Ten of the 22 sites found that their flooding re-evaluation results exceeded their design basis, and they are required to perform integrated assessments of their responses to various flooding scenarios identified by the NRC. These assessments could lead to plant modifications e.g., watertight doors for certain compartments, or moving essential equipment to higher ground. In addition to this first group, 24 sites have flooding re-evaluations due in March 2014, and 20 sites have flooding re-evaluations due in March FLEX: The Industry s Initiative The nuclear industry is implementing a response strategy called FLEX which will provide the greatest safety benefits in the shortest period of time. FLEX will mitigate those extreme, unexpected scenarios that are beyond the plants design parameters. Linked directly to the lessons learned from the Fukushima accident, the strategy: addresses one of the major problems encountered in Japan: the loss of power to maintain effective cooling builds on existing safeguards to protect the fuel and reduce the likelihood of severe-accident scenarios maintains cooling of reactors and used fuel pools if normal systems fail, by stationing additional pumps in multiple locations to provide cooling water to the reactors maintains continuous backup power after an extreme event by prepositioning emergency equipment generators, chargers, pumps in multiple locations around the plant site maintains safety even after a catastrophic event by stationing emergency equipment in secure regional locations for use if onsite and offsite reserve equipment is insufficient, and coordinates sharing of backup equipment among the 62 nuclear sites. The FLEX approach adds equipment pumps, generators and chargers located in diverse locations throughout the plant site. The equipment will be commercial-grade with engineered specifications, with requirements for equipment testing and maintenance subject to NRC oversight. The strategy is flexible: It does not mandate installation of permanent equipment. Instead, it requires that the plant sites obtain, prepare and maintain portable equipment that could be used for any catastrophic event. The equipment will be able to connect to a variety

5 5 of locations for injecting coolant and providing a continuous supply of electricity. The objective of FLEX is to ensure plant-specific capability to cope for an indefinite period through a combination of installed plant capacity, portable on-site equipment and off-site resources. The FLEX concept was informed by the industry s response to the September 11, 2001, terrorist attacks, in which additional security precautions such as portable generators, water pumps, hoses and batteries were put in place to mitigate the effects of large fires and explosions. The FLEX approach provides a further layer of mitigation for events that are beyond what a plant is designed to withstand. Multiple means of obtaining power and water fulfill the key safety functions of reactor cooling, containment integrity and used fuel pool cooling that would prevent damage to nuclear fuel and protect the public and the environment. By September 2013, U.S. nuclear plants had already procured more than 1,500 Workers at the Monticello nuclear plant test its new portable pumps. pieces of equipment, including portable generators, diesel-driven pumps, fire trucks and portable ventilation units. The additional equipment needed to implement FLEX will vary from site to site. The post-fukushima safety enhancements are part of the industry s continuing investment in the operational safety and efficiency of U.S. reactors. FLEX Concepts Effective at Fukushima Daini Six miles south of Fukushima Daiichi lies the four-reactor Fukushima Daini nuclear station, also owned by Tokyo Electric Power Company (TEPCO). On March 11, 2011, the Daini plant, which also sits on the Pacific shoreline, experienced the same earthquake, tsunami, and flooding as its larger sister plant to the north. Yet the outcome at Fukushima Daini was very different. At Fukushima Daini, all four reactors shut down automatically as a result of the earthquake, but water damage from the tsunami resulted in the loss of cooling capability to remove decay heat in three of the reactors. The one reactor retaining core cooling capability was brought to cold shutdown in less than a day. Core cooling capability was re-established for the other three reactors over the subsequent three days, allowing operators to bring them to cold shutdown. Conditions at Fukushima Daini were not drastically different than at its sister plant six miles up the coast of Japan.

6 6 In a period of 30 hours, plant staff replaced residual heat removal pump motors and laid and energized 5.5 miles of heavy-duty electric cables. Core cooling was restored at all reactors, and they were brought to cold shutdown. TEPCO s response to the events at Fukushima Daini resembles U.S. industry s diverse and flexible coping strategy (FLEX), with one significant difference: At Fukushima Daini, there were no pre-planned procedures and training and no portable or replacement equipment staged at the site. Nuclear stations in Japan had not implemented measures similar to the capability U.S. plants added after the 2001 terrorist attacks. Nonetheless, there are several elements of TEPCO s response at Fukushima Daini that match the U.S. FLEX approach, including steps taken by control room operators, use of equipment from other nearby sites or suppliers and the use of government assets to assist with transportation or other logistics. Regional Response Centers The March 11, 2011, tsunami inundating the Fukushima Daini nuclear power facility. The Daini station is six miles south of Fukushima Daiichi and managed a different outcome. Photograph courtesy Tokyo Electric Power Company. The nuclear energy industry is adding another layer of safety and public protection by developing regional centers for critical equipment that could be needed to maintain safety in an extreme event at a U.S. nuclear energy facility. All companies that operate nuclear energy facilities have joined to develop and operate two regional response centers managed by Pooled Equipment Inventory Co. The regional response centers will be located near Memphis and Phoenix and capable of delivering supplemental emergency equipment to any of America s nuclear energy facilities within 24 hours, enabling them to manage an extended loss of electrical power and/or cooling water supply. The equipment and materials provided by the regional response centers supplement the additional portable equipment purchased at all 62 nuclear energy facilities, which can also be utilized and shared during a site emergency. The regional response centers will be capable of delivering another full set of portable safety equipment, radiation protection equipment, electrical generators, pumps and other emergency response equipment to an affected site within the first 24 hours after an extreme event. The regional response centers near Memphis and Phoenix are expected to be operational by August 2014.

7 7 The layers of protection at nuclear energy facilities were tested, and proved the effectiveness of training, procedures and planning in the face of major floods, tornadoes, earthquakes and hurricanes. Industry Performance Demonstrates Readiness for Natural Disasters Nuclear stations across the country are challenged periodically by extreme weather, and always manage these events using their emergency response procedures and guidelines, protecting worker and public health and safety throughout. The layers of protection at nuclear energy facilities were tested, and proved the effectiveness of training, procedures and planning in the face of major floods, tornadoes, earthquakes and hurricanes. Tornadoes On April 16, 2011, an EF3-rated tornado touched down in the switchyard of the Surry nuclear power station in Virginia, damaged equipment and severed offsite electric power. The station shut down automatically and back-up diesel generators started immediately to provide electricity to maintain both units in a stable condition. Also in 2011, three waves of storms in the Southeast U.S. on April 26 and 27 generated an unprecedented 226 tornadoes in a 24-hour period. These tornadoes killed approximately 330 people, obliterated entire towns and devastated the Tennessee Valley Authority (TVA) transmission system in this region. TVA s Browns Ferry reactors in Alabama suffered a loss of off-site power when the storm damaged the station s transmission lines. The layers of protection for nuclear units ensure that even though Browns Ferry had diverse off-site power feeds, the next layer of defense, the emergency diesel generators, were available when the unlikely combination of storms occurred. Due to the extensive damage to the transmission system (337 damaged structures, 96 lines out of service) off-site power was not restored for five days. All three reactors shut down safely and were maintained in safe shutdown condition during this period. Major Floods Historic levels of flooding in the Midwest along the Missouri River occurred in the summer of The flood devastated homes, businesses and many square miles of farmland in Montana, North Dakota, South Dakota, Iowa, Nebraska, Missouri and Kansas. The Fort Calhoun and Cooper nuclear stations are located in the flooded region. Both plants took precautions to implement and bolster flood protection measures and ensure safety would be maintained as water levels rose. Fort Calhoun had shut down for a scheduled refueling outage before the flood. It remains in a safe shutdown condition pending NRC permission to restart. Flood protection measures included sandbags, aqua berms and additional testing of emergency diesel generators and loss of off-site power procedures. Cooper station used more than 5,000 tons of sand to create additional flood barriers. The plant monitored the flood waters continuously and coordinated with the Army Corps of Engineers but was not required to shut down since flood waters did not exceed technical specifications.

8 Earthquakes 8 On August 23, 2011, a 5.8-magnitude earthquake in central Virginia was felt from Georgia to Maine. The two nuclear reactors at the North Anna Power Station in Mineral, Virginia, automatically shut down as a result. The epicenter was approximately 11 miles west-southwest of the station. There was only minor cosmetic damage to the plant and the reactor and safety systems were not damaged even though the earthquake exceeded the design specifications. Storm damage to TVA high-voltage transmission tower, Stevenson, Alabama, April 27, Photograph courtesy Tennessee Valley Authority. The North Anna staff "responded to the event in a manner that protected the public health and safety," an inspection team from the U.S. Nuclear Regulatory Commission (NRC) reported on October 3. Although the ground motion at the site during the earthquake exceeded levels for which the plant was originally licensed, the NRC team report said "safety system functions were maintained" and "reviews of the plant equipment, systems and structures did not reveal significant damage." The condition of the reactors following the event demonstrates the robust seismic design and construction of nuclear facilities. The NRC authorized the restart of both reactors in November 2011 after extensive analyses and inspections. Hurricanes A few days after the earthquake, on August 27, Hurricane Irene made landfall in the Outer Banks of North Carolina as a category 1 hurricane. Irene pounded the east coast with high winds and rainfall and caused particularly severe floods in upstate New York and Vermont with total damage estimates for the U.S. as high as $7 billion. Twenty-four nuclear plants in affected states monitored the storm and all were maintained in a safe condition. On October 29, 2012, Hurricane Sandy hit the East Coast, destroying property and knocking out electricity to seven million customers in 13 states. Of the 34 nuclear facilities from South Carolina to Vermont in Hurricane Sandy s path, 24 continued to operate safely and generate electricity throughout the event. Seven were already shut down for refueling or inspection, and three in New Jersey and New York shut down safely, as designed. Indian Point 3 and Nine Mile Point 1 in New York shut down October 29 due to grid disturbances and Salem 1 in New Jersey shut down October 30 because of storm conditions affecting circulating water pumps. The three units returned to operation on November 2. These events demonstrate the robustness of U.S. commercial nuclear plant designs and the effectiveness of operator and emergency response training programs and plant knowledge. These attributes will be strengthened with the additional measures being taken in response to the accidents at Fukushima.

9 9 Tier Tier 1 Safety Enhancements Recommended by the NRC s Fukushima Task Force Mitigating strategies for beyond-design-basis events Reliable hardened vents for Mark I and Mark II containments Spent fuel pool instrumentation Seismic and flood hazard re-evaluations Seismic and flood walk-downs NRC Action Order Order Order Request for Information Request for Information Tier 2 Emergency preparedness regulatory actions (staffing and communications) Station blackout (SBO) regulatory actions Strengthening and integration of emergency operating procedures, severe accident management guidelines, and extensive damage mitigation guidelines Request for Information Advanced Notice of Proposed Rulemaking Advanced Notice of Proposed Rulemaking Spent fuel pool makeup capability (dependent on Tier 1 spent fuel pool issues) Rulemaking in 2013 Emergency preparedness regulatory actions Re-evaluation of other external hazards (e.g., tornadoes, hurricanes, drought) Staff plan to subsume into Tier 3 but was denied by Commission due to more information needed Request for Information (as resources are available) Tier 3 Ten-year confirmation of seismic and flooding hazards Potential enhancements to the capability to prevent or mitigate seismically-induced fires and floods (long-term evaluation) Reliable hardened vents for other containment designs (long-term evaluation) Hydrogen control and mitigation inside containment or in other buildings (long-term evaluation) Emergency preparedness enhancements for prolonged station blackout and multiunit events (dependent on availability of critical skill sets) Emergency Response Data System capability (long-term evaluation) Additional emergency preparedness topics for prolonged station blackout and multiunit events (long-term evaluation) Emergency preparedness topics for decision-making, radiation monitoring, and public education (long-term evaluation) Reactor Oversight Process modifications to reflect the recommended defense-in-depth framework (dependent on recommendations for establishing a new regulatory framework) NRC staff training on severe accidents and resident inspector training on severe accident management guidelines (dependent on recommendations for strengthening and integrating onsite emergency response capabilities) Basis of emergency planning zone size Pre-staging of potassium iodide beyond 10 miles Transfer of spent fuel to dry cask storage Program plans based on resources required, information needed, and resolution of Tier 1 and 2 issues.

10 The ABCs of Filtered Containment Venting 10 Why Venting is Important The accident at Fukushima Daichi focused attention on the issue of containment venting, and how best to ensure that containment pressures do not exceed safe levels. At Fukushima, three of the six boiling water reactors (BWR) were operating at the time of the March 11, 2011, earthquake and tsunami. The tsunami flooded important electrical gear, causing a loss of AC power (sometimes called station black out ). This power loss meant the loss of instrumentation and the ability to cool the reactors. Without adequate cooling, the fuel in the three reactors that were operating overheated and melted, releasing steam, radionuclides and other gases, notably hydrogen. The steam and gases built up pressure in the containments. The power failure prevented the operators from opening valves and reading instruments so venting to relieve pressure was delayed. The operators also delayed venting the containments out of concern for the local population who had not yet evacuated. Although attempts at venting were underway, on the second day hydrogen that had collected in one building exploded. This was followed by hydrogen explosions in two other units on succeeding days. These explosions resulted in uncontrolled releases of radionuclides to the surrounding countryside. That contamination has prevented tens of thousands of residents from returning to their homes. If the operators at Fukushima had had access to equipment, systems and procedures that allowed them to perform controlled venting of the containments at an early stage of the accident, they could have maintained the containment pressures at acceptable levels and also vented the hydrogen. This could have prevented the explosions and the uncontrolled release of radionuclides. NRC s Path Forward NRC has decided (and the industry agrees) that control of radioactive materials produced during a severe accident is imperative. With input from the industry and other stakeholders, the NRC has analyzed the options and developed a two-track strategy for enhancing venting and filtering in BWRs with Mark I and Mark II containments: In mid-2013, the NRC ordered operators of Mark I and II-type boiling water reactors to install enhanced, hardened vents capable of operating even in the event of a severe accident, with the elevated temperatures, pressures and radiation levels associated with a damaged core. This will ensure that plant operators have the ability to perform controlled vent-

11 11 ing to relieve high pressure in containment and reduce potentially explosive hydrogen. Second, the NRC commissioners decided to examine (through its rulemaking process) the appropriate strategy for mitigating radioactive releases during venting. NRC staff had recommended installation of vent filters to reduce the radioactive particles released to the environment during an accident that requires venting the containment. The NRC commissioners decided instead to develop the technical bases and technical acceptance criteria for operators to consider all options that could be more effective, such as suppression pools, containment sprays and separate filters. The NRC will develop the technical bases for such a regulation by March 2014, the proposed rule in two years, and the final rule in four years (March 2017). The rulemaking process will include substantial involvement, review and comment by all stakeholders, including the industry. This approach is largely in line with industry recommendations for a performance-based approach to venting and filtration issues i.e., define first the results to be achieved, followed by plant-specific assessment of the best approach to achieve that result. Extensive industry analysis has shown that a one-size-fits-all approach (e.g., simply adding filters) would not be an effective or efficient way to proceed. Other techniques containment sprays, for example may be more effective. In simple terms, containment venting filtration systems consist of large tanks of water outside containment. The gases generated during an accident are routed through the vent and associated piping into the water, which scrubs out the radionuclides exactly what happens inside containment with flooding and water sprays. As a general principle, the industry thinks it makes more sense to scrub out the radionuclides generated during an accident inside containment rather than outside. The Technical Basis for a Performance-Based Approach In 2012, the Electric Power Research Institute (EPRI) conducted a study of what happens inside BWR Mark I and II containments during severe accidents. EPRI found that substantial reductions of radioactive releases can be achieved. EPRI evaluated several approaches including water injection by flooding and sprays. Flooding removes heat from the debris (melted material), reducing the amount of airborne radionuclides created. Water sprays strip radionuclides out of the containment atmosphere (like rain knocks dust out of the air during a storm). Other scenarios evaluated included controlled, unfiltered venting; filtered venting, and combinations of water injection and venting. Insights from the analysis included:

12 12 No single strategy is effective. Containment vent filters are ineffective when water injection is not used. The most effective strategies involved combinations of water injection and containment venting. Active core debris cooling is required. If debris cooling is not provided through water injection or spray, containment failure is likely. Existing severe accident management guidelines (SAMGs) for plant operators provide substantial benefit. Flooding or spraying is addressed in the SAMGs and is an essential element of a strategy to reduce radioactive releases. Spraying the containment atmosphere is beneficial. The amount of fission products removed is higher when sprays are used. Venting prevents uncontrolled releases and manages hydrogen. Flooding or sprays produce a large amount of steam, which increases pressures, possibly to the point of containment failure. Venting maintains the containment pressure below the design pressure and removes hydrogen and other gases. Control of the vent provides significant benefit. Opening and closing the vent at the most opportune times (e.g., venting right after sprays have reduced airborne contaminants) is essential. Filters may further reduce radionuclide releases. Several of the combined water injection and venting strategies could reduce radiological releases significantly. This could potentially be enhanced by adding a vent filter, but additional research is needed to determine its effectiveness. The research concluded that viable methods exist for reducing radiological releases and the potential for land contamination. Combinations of water injection approaches and various containment venting approaches appear to provide the greater benefit. Plant-specific analyses are necessary to determine the most effective approach. Position of the NRC s Advisory Committee on Reactor Safeguards NRC s Advisory Committee on Reactor Safeguards (ACRS), a group of seasoned technical advisers, was asked to provide an independent evaluation of the possible approaches. Based on its review of studies by both the NRC and industry, the ACRS concluded: Additional defense-in-depth measures should be added in response to Fukushima lessons learned; a no-action response is not appropriate. Severe accident-capable vents are an essential part of any controlled venting strategy; they would allow both opening and closing vents during the accident. For certain accident sequences, additional filtration systems could reduce the cesium or iodine release from containment by a meaningful amount.

13 13 For other sequences, however, the existing filtration systems of the plant (flooding and sprays) operated efficiently and little additional radioactive material would be removed by an external filter system. ACRS recommended a plant-by-plant, performance-based approach as the most effective means to reduce radioactive material releases. At certain plants, installation of external filtered vents could result from this performance-based approach. Industry Position The industry believes the decision by the NRC to examine the venting issue in detail is the wise path. The approach to mitigating release of radionuclides in the unlikely event of a severe accident should be developed around the findings of the EPRI study. This is consistent with the recommendation of the ACRS and is based on the following: A filter-only option will not be effective in several scenarios, and therefore its benefits do not support the costs. Initial cost estimates are tens of millions of dollars per reactor. A performance-based approach to filtering focuses the response to a severe accident on those actions best able to manage the accident and mitigate potential radiation releases. It protects public safety and the environment better than other options by providing greater defense-indepth for the containment function. The performance-based approach is an integrated response that maximizes the retention of radionuclides in containment, reduces radionuclide release to a greater degree than external filtering systems alone, and provides plant operators with additional tools to manage a severe accident effectively. A performance-based approach to filtering would take advantage of the required addition of reliable vent valves to allow operators to control the venting process. Finally, using a performance-based approach allows licensees to tailor filtering and venting strategies to their plants appropriately, taking into account the unique circumstances of each facility.

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