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Industry Moves Closer to Pilot on Prioritizing Plant Activities

Oct. 3, 2013—The nuclear energy industry has submitted preliminary draft guidance to the U.S. Nuclear Regulatory Commission to begin discussions on a process that ultimately would help plants make safety improvements more quickly.

The guidance’s basic concept is to determine the relative safety contribution of various activities—both regulatory and plant-initiated—and place those with greater impact higher on facilities’ to-do lists. The industry approach is consistent with a regulatory initiative proposed by two NRC commissioners as part of the agency’s efforts to improve regulatory efficiency and safety focus.

“We believe the process outlined in the guidance provides an important opportunity for plants to focus work activities consistent with the plant-specific risk profile,” Adrian Heymer, NEI’s executive director of strategic programs, said in an Oct. 1 letter to the NRC.

NRC Commissioners George Apostolakis and William Magwood have proposed an initiative in which licensees would prioritize regulatory actions using probabilistic risk assessment (PRA) insights. “Such prioritization, if approved [by the NRC], should both speed a licensee’s completion of the most important new safety measures and also address … the cumulative effects of regulation,” they said in a November 2012 memorandum to their fellow commissioners.

The draft guidance, Heymer said, will help plant operators manage the cumulative impact of regulatory activity and prioritize regulator- and industry-initiated actions consistent with safety and reliability significance. The industry’s approach is modeled on previous risk-informed activities such as the NRC reactor oversight process, the maintenance rule and the Severe Accident Mitigation Alternatives approach for license renewal, he said.

Several companies are assessing whether to participate in a pilot program that would start with tabletop activities followed by field implementation using the guidance, provided the NRC deems it suitable.

The pilot plants would use individual risk and hazard information to categorize regulatory and plant-initiated activities into broad bins of high, medium, low and very low significance, using a plant-specific expert panel. “Public safety is the primary basis for prioritization,” Heymer said. “These bins will form the basis for development of a safety-focused schedule.”

Licensees would use existing plant-specific PRA and risk information to prioritize regulatory actions. “We do not believe extensive verification of PRA technical adequacy is appropriate or necessary for this binning application,” Heymer said. Requiring such verification “would delay plants’ ability to achieve improved safety-focused work schedules.”

Heymer said the scheduling part of the guidance is still in development and will be informed by the pilot activities.