Cumulative Impacts. James Slider November 7, 2013. Overview. The challenge Prioritization Regulatory analyses. The Challenge. Since 2005, the U.S. nuclear industry has seen a substantial expansion in workload - PowerPoint PPT Presentation
Cumulative Impact of Industry and Regulatory Actions
Cumulative ImpactsJames SliderNovember 7, 2013
Cumulative burden comes from two main sources: industry- and regulatory-initiated actions.1OverviewThe challengePrioritizationRegulatory analyses2The ChallengeSince 2005, the U.S. nuclear industry has seen a substantial expansion in workloadThe challenge is to ensure management attention and resources are focused on areas of highest significance to safetyMore than ever before, NRC and industry need to work together to weigh, prioritize and implement regulatory and industry actions in an integrated manner consistent with safety significanceThis is one of the most important issues facing the industry
This is not a new issue it was identified by the industry and NRC in 2010 but work was suspended following Fukushima. Regulatory interactions restarted in May 2012.
With the Fukushima lessons learner workload, the issue is now more acute.
Industry and NRC resources are finite and as the workload increases it is important that we continue to focus on the most safety-significant issues, to maintain and improve the high standard of safety and reliability at US plants
The focus of regulatory and industry actions should be consistent with safety significance, the protection and reliability of critical equipment and the protection of the environment.
It is evident that some regulatory actions are not as safety significant as company or plant initiated improvements, Example RCP seal upgrades
3Nuclear Utility Spending Source: Electric Utility Cost Group4Nuclear Utility Spending Source: Electric Utility Cost Group5Regulatory Cap Ex Spending Source: Electric Utility Cost Group6
7Main ConcernsCompany-initiated safety, security, and reliability improvements are squeezed outAttention and resources diverted to regulatory needs of lower safety significanceRegulatory capital expenditures have increased and are unstableNRC estimates of costs of implementation are offOverlapping NRC actions cause reworkIn the current regulatory environment, it is becoming increasingly difficult to develop outage and modification schedules because the regulatory guidance and expectations keep changing, causing rework and unnecessary expenditure of resources.
Its not just deferment of high significant work but also inaccurate regulatory analyses and basis including cost-benefit determinations.
Over the last four years overlapping NRC actions have resulted in rework with often accompanied by additional and more complex requirements and interface considerations.
8Examples of Plant Improvements DeferredImprovements to safety injection and feedwater control systemsReactor vessel internal replacementsDry-cask fuel storage improvements deferred because of unclear and evolving NRC requirementsImprovements in reactor coolant pumps9Addressing Industry-Imposed ActionsINPO reviewing key processes:Corrective action Human performance Work managementUnderstanding the focus of supervisor and manager workloads and oversightAssessing effectiveness of industry initiatives, committees and organizationsFor the industry actions, INPO has the lead and is focused on the impact of industrys work processes and on ensuring that supervisors and managers are correctly applying their time to monitoring, mentoring and managing work to maintain our high safety standards.
INPO and senior industry executives have performed a review of plant and support activities and have identified three work processes to focus on as a first step.: corrective action, human performance and work management
Cap Example: We should not be processing minor deficiencies or deficiencies of low safety significance in the same way as those that have high safety significance.
First line supervisors and middle managers are spending too much time on administrative paperwork and in meetings rather than managing, monitoring and mentoring plant staff and work activities. That needs to change.
INPO, EPRI and NEI are also looking at their own processes with the aim of making them more efficient10Addressing NRC-Imposed ActionsNEI offered 24 recommendations to accelerate, defer, amend or eliminate actionsImprove regulatory processIssue definition and closure criteriaRegulatory analysis, basis and cost-benefit analysesPrioritization and site-specific scheduling consistent with safety significanceImprove regulatory efficiency close issues earlier, eliminate duplicative actions and reworkThe industry recommended 24 actions that could be taken to improve safety, resource loading and regulatory efficiency and predictability. One third of these recommendations are to increase priority on resolving the issue and proceeding with implementation.Common understanding of problem statement and what it is going to take to close the issue and understand the basis (justification)Criteria for closure must be identified earlier to enable more accurate cost estimates and cost benefit determinations difficult to develop accurate cost estimates when there is no common understanding on what needs to be accomplishedMore detailed engineering and regulatory interactions earlier in the processGeneric prioritization based on safety significance NRC activityCharacterization of generic prioritization Industry/NRC activity what are the important attributes? A feed into site specific prioritization High generic significance could be low at a specific site11NRC ActivitiesCommissioners proposed initiative, Improving Nuclear Safety and Regulatory Efficiency, using PRA insights and results to set the regulatory agendaNRC project for addressing cumulative impact of rulemakingNRC-industry working group meetings12Actions are already being taken
In November 2012, the commission proposed an initiative that would use PRA insights and analyses to prioritize regulatory actions and dictate regulatory requirements. The industry generally supports this initiative
Regulatory interactions have started and there is a common understanding between NRC and industry management on the need for addressing cumulative impact and taking action to manage this facet going forward.
12Initial Scope of ApplicabilityRules and ordersBulletins and Generic Letters 10 CFR 50.54(f) lettersNew generic safety issues and regulatory positionsDescribed in meeting summaries, correspondence including inspection reports, regulatory issue summaries and guidance documents
13Proposed Process & Template for Managing Cumulative Impact of Regulatory Actions
This depicts the process with the exception of the top right there is nothing new there just needs to be greater emphasis on the processes that are in place with and more objective, safety focused prioritization scheme
If we keep to the established processes with emphasis on safety prioritization and add the reassessment element so that satellite issues do not unnecessarily prolong and complicate issue closure the cumulative impact will be reduced and managed, going forward 14Provisional ScheduleTabletop exercises to test prioritization guidance 4Q 2013 Amend guidance and proceed with pilot field implementation -- 1Q 2014Input into July 2014 NRC SECY on cumulative impactUpdate guidance for NRC endorsement prior to industrywide implementation by end of 2014
Proposed schedule is aggressive yet achievable.15Comparison of Estimated and Actual Implementation Costs* Initial estimate was for no additional costs.16Case Studies on Variance betweenNRC estimates and Implementation CostsStudies confirm extreme variance between NRC estimates and implementation costsDetermine the causes of the high varianceNeed for better and earlier definition and implementation characterizationIndustry will need to apply resources earlier to provide more detailed comments on NRC estimated costs
17Challenges & IssuesIndustry communication and coordinationChanging cultures What is perceived as important to specialist may be of low relative safety significanceMore robust questioning of new regulatory positions and requirementsDisposition of low safety significant issues18SummaryThe number and complexity of new requirements demands a more integrated approach to managing plant improvementsThe goal is to do the right things, in the right order, onceIndustry and NRC must each do their parts to ensure the public interest in safe, reliable and economic nuclear energy is served19