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Cumulative Impacts
James SliderNovember 7, 2013
Overview• The challenge• Prioritization• Regulatory analyses
The Challenge• Since 2005, the U.S. nuclear industry has seen a
substantial expansion in workload• The challenge is to ensure management
attention and resources are focused on areas of highest significance to safety
• More 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 significance
Nuclear Utility Spending
Source: Electric Utility Cost Group
2005 2006 2007 2008 2009 2010 2011 2012$0
$500,000,000
$1,000,000,000
$1,500,000,000
$2,000,000,000
$2,500,000,000
$3,000,000,000
$3,500,000,000
$4,000,000,000
$4,500,000,000
$5,000,000,000Engineering and Equipment Reliability Regulatory CapEx Security O&M Licensing O&M Fuel O&M
Nuclear Utility Spending
Source: Electric Utility Cost Group
2005 2006 2007 2008 2009 2010 2011 2012$0
$200,000,000
$400,000,000
$600,000,000
$800,000,000
$1,000,000,000
$1,200,000,000
$1,400,000,000
$1,600,000,000
$1,800,000,000
$2,000,000,000
Fuel O&MLicensing O&MSecurity O&MRegulatory CapExEngineering and Equipment Reliability
Regulatory Cap Ex Spending
Source: Electric Utility Cost Group
2006 2007 2008 2009 2010 2011 20120
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
1,600,000
1,800,000
2,000,000
Fukushima Response CostsOther (Regulatory)Spent Fuel StorageEnvironmentalSecurityALARAPersonnel SafetyEmergency PreparednessNuclear Safety
Main Concerns• Company-initiated safety, security, and reliability
improvements are squeezed out- Attention and resources diverted to regulatory needs of
lower safety significance- Regulatory capital expenditures have increased and are
unstable
• NRC estimates of costs of implementation are off• Overlapping NRC actions cause rework
Examples of Plant Improvements Deferred
• Improvements to safety injection and feedwater control systems
• Reactor vessel internal replacements• Dry-cask fuel storage improvements deferred
because of unclear and evolving NRC requirements• Improvements in reactor coolant pumps
Addressing Industry-Imposed Actions• INPO reviewing key processes:
- Corrective action - Human performance - Work management
• Understanding the focus of supervisor and manager workloads and oversight
• Assessing effectiveness of industry initiatives, committees and organizations
Addressing NRC-Imposed Actions
• NEI offered 24 recommendations to accelerate, defer, amend or eliminate actions
• Improve regulatory process- Issue definition and closure criteria- Regulatory analysis, basis and cost-benefit
analyses- Prioritization and site-specific scheduling
consistent with safety significance
NRC Activities• Commissioners’ proposed initiative, Improving
Nuclear Safety and Regulatory Efficiency, using PRA insights and results to set the regulatory agenda
• NRC project for addressing cumulative impact of rulemaking
• NRC-industry working group meetings
12
Initial Scope of Applicability
• Rules and orders• Bulletins and Generic Letters
- 10 CFR 50.54(f) letters• New generic safety issues and regulatory
positions- Described in meeting summaries, correspondence
including inspection reports, regulatory issue summaries and guidance documents
Proposed Process & Template for Managing Cumulative Impact of Regulatory Actions
Issue Definition & Closure
Criteria
New Issue Identified
Assessment
· Regulatory Analysis· Adequate Protection
Determination· Cost benefit
Determination
Generic Prioritization
Initiate Regulatory
Action
Site Specific Prioritization & Integrated Schedule
Periodic Assessment
Against Original DefinitionEmerging Issue Assessment
Drop Reassess
Drop
Provisional Schedule• Tabletop exercises to test prioritization
guidance 4Q 2013 • Amend guidance and proceed with pilot field
implementation -- 1Q 2014• Input into July 2014 NRC SECY on cumulative
impact• Update guidance for NRC endorsement prior to
industrywide implementation by end of 2014
GSI - 191 NFPA - 805 10 CFR 73 Security Reg Guide 1.189 Rev 2*
Cyber Security*
100% 100% 100% 100% 100%
347% 343%
1449%
402%
1000%NRC Estimate
Actual Spend
Comparison of Estimated and Actual Implementation Costs
* Initial estimate was for no additional costs.
Case Studies on Variance betweenNRC estimates and Implementation Costs
• Studies confirm extreme variance between NRC estimates and implementation costs• Determine the causes of the high variance• Need for better and earlier definition and
implementation characterization• Industry will need to apply resources earlier to
provide more detailed comments on NRC estimated costs
Challenges & Issues
• Industry communication and coordination• Changing cultures
- What is perceived as important to specialist may be of low relative safety significance
- More robust questioning of new regulatory positions and requirements
• Disposition of low safety significant issues
Summary
• The number and complexity of new requirements demands a more integrated approach to managing plant improvements
• The goal is to do the right things, in the right order, once
• Industry and NRC must each do their parts to ensure the public interest in safe, reliable and economic nuclear energy is served
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