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