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NRC, Industry Continue Discussions on Cumulative Impact of Regulations

Nov. 7, 2013—The NRC has expressed interest in being part of tabletop exercises on easing the cumulative impact of regulation, but the agency said the potential prioritization of regulatory actions needs to be discussed in greater detail.

“The cumulative effect of regulation is a large effort that will continue and prioritization could be something we pursue also,” Tara Inverso, NRC project manager, said at a Nov. 6 meeting on the issue with industry representatives.

Over the years, the amount of regulatory activity and industry-driven requirements have increased, requiring nuclear energy facility operators to devote more resources to compliance efforts, some of which the industry believes do little to enhance safety. The industry supports adoption of a coordinated approach to regulation—informed by safety insights and cost-benefit analysis—to help ensure that high-priority actions are taken before those that would have less of an impact on safety and that there are no conflicting requirements or regulatory gaps.

At the meeting, industry representatives underlined the importance of reducing the cumulative impact of regulatory actions and urged NRC staff to give the issue the highest priority.

“This initiative is vitally important to us,” said John McCann, Entergy’s vice president of nuclear safety, emergency preparedness and licensing. “There is clearly a real issue here both in terms of being able to assign priorities and to assure that limited resources—on  both sides of the regulatory divide—are being applied properly.”

Adrian Heymer, the Nuclear Energy Institute’s executive director of strategic programs, said that the industry is proposing tabletop exercises during the weeks of Dec. 9 and 16.

“We have the outline of the process and issues, and we have something to build on [for a tabletop exercise],” Heymer said.

Heymer added that the industry also intends to complete pilot projects on cumulative impact at plant sites next year to determine how sites can more efficiently prioritize the implementation of regulatory requirements and plant initiatives. The industry then hopes to roll out the program industrywide in late 2014. The NRC commissioners would have to be involved in any decision to conduct pilots at plants prior to wider implementation.

Heymer explained that the tabl top simulations would allow industry and the NRC to work through scenarios, while the pilots would allow them to see what would happen when actual processes are implemented at plant sites.

NRC staff said in the meeting that it plans to submit to the five-member commission a staff paper on the commission’s proposed initiative for improving nuclear safety and regulatory efficiency next July. The NRC staff also is developing another paper on cumulative impact for March 2015. Inverso said that this did not mean that dialogue on the issue would stop.  

“I did not want to imply that we wouldn’t have any feedback or results until two years from now,” Inverso said.

Industry slides from the Nov. 6 meeting are available on NEI’s website here and here. The NRC slides are on the agency’s website