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Industry, NRC Identify Need to Improve Cost Estimates of Regulations

Sept. 25, 2013—The industry and the NRC must work together to provide better cost estimates of regulatory changes, industry representatives said last week at a meeting with the NRC.

Adrian Heymer, NEI’s executive director for strategic programs, said the purpose of the effort is not just to collate the cost data but to determine the reasons for the variance between the NRC’s estimates and actual implementation costs.

“We need to drill down and have a better understanding on both sides [of cost estimates],” Heymer said.

David Bradish, NEI’s manager of energy and economic analysis, presented data to demonstrate how the cost estimates between industry and regulator often vary widely.

Using the example of the costs of regulatory analyses for transitioning to risk-informed fire protection regulations (NFPA 805), Bradish said the NRC had estimated the one-time, plant-wide analyses to cost $1.68 million per facility. Based on data from five reactors, however, the actual average cost of the analyses was $10.5 million per reactor.

“One of the reasons the costs were about $10.5 million per unit was because the amount of documentation was quite large,” Bradish said. “What we heard back from the volunteer sites was that they had to have thousands of pages of documentation just to support the modeling software and the 1,200- to 1,400-page licensing amendment request.”

Bradish added that industry wanted to share more detailed costs with the NRC in a timely as well as a “blinded” manner, which would withhold the name of the plants providing the data.

“It will be important for the industry to share our cost estimates with you sooner as well as when the regulatory analysis is developing,” Bradish said.

The industry is working on a paper that would provide aggregated data on cost estimates and suggestions for improving them. However, there is not yet a timeline for its completion, Heymer said.


The meeting participants also discussed the importance of developing a pilot program to address the cumulative impact of regulation.

“The cumulative effect of regulation is an agency priority,” said Michael Johnson, NRC deputy executive director for reactor and preparedness programs. “We have a common interest and that interest is that we focus on those things that have the greatest safety benefit.”

Heymer said that the industry is discussing a cumulative impact pilot project that will use five to six volunteer plants. The pilots will help determine if regulations and processes can be enhanced or made more efficient.

“Are the actual regulatory processes we have established sufficient or do they need to be enhanced? We think we’ll get that information out of the pilots,” Heymer said.   

The industry hopes to have the tabletop pilot activity wrap up at the end of the year and move to field implementation in 2014, in time to provide the NRC with insights to support a July 2014 commission paper.

Heymer added that if conducted correctly, the pilot programs should demonstrate how to enhance safety while reducing distractions on plant personnel.

“The whole intent here is not just focusing on the right stuff at the right time, but to do so in a more efficient manner so that we close issues out earlier and make safety enhancements sooner,” Heymer said.

NEI’s slides from the meeting are available online.