I'm not trying to defend the industry or the NRC, but I think it's important to see the timeline here and understand the whys behind how long its taken to implement all the Fukushima stuff.
From a pure construction standpoint, it is taking my plant 1 year to install all the Fukushima plant modifications. We have 3 full time construction crews right now (and a full time engineering crew for just Fukushima), and have installed generator pads for a generator to be airlifted onto (with portable connections), portable pump skids in bunkered reinforced domes. New fixed piping along with equipment storage areas, all using standardized fittings so that connections can be made easily. So right now we are on track for full FLEX implementation to be complete 4 years after Fukushima. The physical construction work is taking us 1 year. So that leaves 3 years for planning, regulation, design, contracts/bidding, along with needing to share construction firms with other plants (there are limitations on how many nuclear qualified construction firms there are).
3 months after Fukushima, INPO put a "Level 1 INPO Event Report" to all plants, detailing that they had 90 days to put together their plan to deal with a Fukushima like scenario. It had some extreme limitations that were well beyond the existing b.5.b program about where you could get water and fuel from, what systems and supplies worked, what power worked, etc. Each plant put their plants together 3 months later, and the industry started formulating those plans. If there were no regulations, and this was a non-nuclear field, all of this could have been done in another 1.5 years (1 year for construction, 1/2 year for design and bidding type stuff). And if you look in England and France, the countries where the regulatory structures are more about qualitative safety factors rather than deterministic ones, those countries got their Fukushima safety improvements installed much faster.
But the NRC doesn't operate that way. They have to make a technical basis for determining what actions they feel they need to take, which get challenged on multiple levels. Then they need to determine what things they think need to be done. Then they have to make a regulation or order for it. Then they have to determine how to determine whether or not a plant adequately met the requirements. Then that has to get issued. I mean, the NRC will literally put together the paperwork to determine how they are going to determine something. And all of this adds a lot of time and overhead. Just like with the extensive damage upgrades (post 9/11, known as b.5.b), the physical security regulations and upgrades, and cyber security regulations and upgrades, the Fukushima regulations by the NRC are going to take up to a decade to fully implement. The most important ones (FLEX) are going to be done in the next year or two. This is not the industry trying to hold it up, but rather its the strict rules based regulatory process slowly trudging along. In all of these cases, the industry wanted to spend 1-2 years actually doing the upgrades and be done with it, because it costs a LOT of money to have all of these things going on for up to a decade. The industry tried to get ahead of the NRC and get their FLEX plan approved and get it done early on, and the NRC was not moving at that pace. The NRC didn't even fully determine what the FLEX requirements were until late 2012/early 2013 I believe. Until early to mid 2013, the NRC was still trying to figure out if FLEX should be just severe site damage, or if it should also include extended loss of AC power (ELAP).
Think about that, it took the NRC several years just to decide if post-Fukushima requirements should have included ELAP.
Even if the US nuclear industry was ready to build all the FLEX upgrades in 2012, the NRC wouldn't have known how to even regulate it. Until the NRC issues their regulatory guides and standard review plans, the industry is very likely to be told that any upgrades they make are no good, causing substantial rework. The way nuclear plants in the US work today with the regulator, is they want to know exactly what the NRC is looking for before they issue a license amendment request, because they do not want to go back and re-do stuff. (Lets also remember major plant stuff like many Fukushima changes cannot be physically installed until approved, because they involve potentially significant changes to the plant's licensing basis). The industry tried to get FLEX moving early on, but it didn't, and then they basically slowed the pace down until the NRC figured out how they were going to be dealing with it.
Anyways...moving on to EOPs (emergency operating procedures).
You do not just change EOPs or make changes to your emergency response. When you are in EOPs, they supersede many of the conditions of your operating license, and authorize or even require you to defeat safety functions, perform high risk evolutions, use plant systems in ways they were not designed for, in order to prevent core damage, preserve the integrity of the containment, prevent unmonitored/unfiltered releases, and stop release rates to the public. Some of the EOP changes for FLEX are actually pretty extreme, the biggest one being that we are now required to halt an emergency blowdown to maintain RCIC injection capability, and maintain the reactor pressurized (albeit at a reduced pressure). But because of this directive, it puts us into a position where we are going to be making an active choice to potentially destroy the containment in order to preserve the reactor core. This required extensive engineering analysis, testing, risk analysis, all to demonstrate that this is in fact the best action to take with respect to the health and safety of the public. This is just one item of many many items in the FLEX EOP changes that is fundamentally changing the way we respond during an ELAP.
Needless to say, getting EOPs approved takes months to years. There's a reason my plant has only had 3 revisions to our EOPs since we started up, because the engineering and analysis behind them is rock solid (thanks to the work upfront), and because they are very hard to change. The last thing anyone wants is a flawed EOP that actually causes a more dangerous situation than you originally had. Right now we are working out the kinks in the new procedures before we get them approved. (For comparison, the procedure on starting up the reactor has been updated over 300 times in the plant's life).
That's my wall of text.