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
• 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
$5,000,000,000
Engineering and Equipment Reliability
Regulatory CapEx
Security O&M
Licensing O&M
Fuel O&M
$4,500,000,000
$4,000,000,000
$3,500,000,000
$3,000,000,000
$2,500,000,000
$2,000,000,000
$1,500,000,000
$1,000,000,000
$500,000,000
$0
2005
2006
Source: Electric Utility Cost Group
2007
2008
2009
2010
2011
2012
Nuclear Utility Spending
$2,000,000,000
$1,800,000,000
$1,600,000,000
$1,400,000,000
$1,200,000,000
Fuel O&M
Licensing O&M
Security O&M
Regulatory CapEx
Engineering and Equipment Reliability
$1,000,000,000
$800,000,000
$600,000,000
$400,000,000
$200,000,000
$0
2005
2006
Source: Electric Utility Cost Group
2007
2008
2009
2010
2011
2012
Regulatory Cap Ex Spending
2,000,000
1,800,000
1,600,000
Fukushima Response Costs
1,400,000
Other (Regulatory)
1,200,000
Spent Fuel Storage
Environmental
1,000,000
Security
ALARA
800,000
Personnel Safety
Emergency Preparedness
600,000
Nuclear Safety
400,000
200,000
0
2006
2007
2008
Source: Electric Utility Cost Group
2009
2010
2011
2012
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
Periodic Assessment
New Issue
Identified
Against Original Definition
Emerging Issue Assessment
Assessment
Issue
Definition
& Closure
Criteria
·
·
·
Regulatory Analysis
Adequate Protection
Determination
Cost benefit
Determination
Drop
Reassess
Generic
Prioritization
Initiate
Regulatory
Action
Site Specific Prioritization
& Integrated Schedule
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
Comparison of
Estimated and Actual Implementation Costs
1449%
NRC Estimate
1000%
Actual Spend
347%
100%
GSI - 191
402%
343%
100%
NFPA - 805
* Initial estimate was for no additional costs.
100%
10 CFR 73 Security
100%
Reg Guide 1.189 Rev 2*
100%
Cyber Security*
Case Studies on Variance between
NRC 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