Periodic Briefing on New Reactor Issues Training for new procedures costs too much - really! ASTM Pressure codes sufficient -- for new materials? for composites? for new design? Current guidelines use 10 to the negative nine for risk are not appropriate for new plants -- are fewer people at risk? Early release frequency for new plants -- current operating practice (COP) Milestone schedules for reviews -- ITAC hearing -- NRC moderator OK Rulemakings - Limited Work Authorization in advance -- been there, need very specific processes defined and approved and less room for deviation - Aircraft impact should be part of the design certification - Industry peer review group has been established to provide consistency in interpretation of results - Rule 7355 design center working group -- adjusting designs to meet unambiguous language Critical Industry Tasks - Lessons learned from recent construction -- previous construction in US, project in New Mexico, Brown's Ferry, developing ties with Korea and Japan - Supply Chain -- 28 reactors under construction world-wide now and 120 are in planning so international markets may take talent and USA base has shrunk with shortages in forgings, speciality valves, and batteries, and most other components to some extent. -- Counterfeit and substandard parts are a problem -- validate integrity at receiving inspection (no vertical integration?) - Workforce -- a national issue primarily focusing on skilled craft. In the next 15 years electrical infrastructure needs a lot, projected a shortage of 20,000 people in the southeast over the next five years for just maintaining the existing infrastructure and does not include the building of new. -- Southern Governor's Association headed by Governor of Mississippi next week on how to attract people into the building trades -- Last week a job fair in Joilette Illinois suggested a training school in Missouri - Preparation and review of COL and design certification applications -- Part 52 - Construction Inspection Program -- Defining the ITAAC closeout process -- need by end of 2008 - Improving environmental reviews -- Need quality submittals and documenting the meeting reviews -- but who selects the stakeholders? -- Prototypes and other first efforts -- ESPWR -- 30-month cycle for standard process -- but what about design changes as they occur and as other threats emerge? -- Continue workshop process - New phase of regulatory updates should not require new QA standards or inspections but if changes are needed then they should be in effect for existing plants as well as new -- safety experience -- technology advances - Predictable open communicatons -- dynamic predictability Four Major Priorities - High quality COL - Work with NRC on design process - Focus on inspection closeout process -- may need signoffs defined - Rulemakings are needed -- impact statement on an 1800 page rule takes time - Waste confidence Matagorda County, Texas, Impacts - Good soil for rice, etc, and mostly flat with canal irrigation - Impacts -- Housing -- Schools -- Traffic -- Infrastructure -- new waste water treatment plant in 1990's, rehabilitating elevated storage tank -- Wireless broadband mesh network to be installed - Benefits -- Education -- Midcoast Educational Alliance -- High paying jobs for new generation as current employee median age is 49 so they will be retiring -- Clean industry -- Economic Growth -- Emergency Preparedness -- EOC opened for Hurricane Dean this week, but not needed, and evacuations have gone smoothly -- Where do you evacuate to? -- Corporate Support -- STP executives are great corporate citizens -- Wharton County Junior College Extension Center opened two weeks ago -- Power Technology Curriculum Q&A - Transit workforce -- numerous apartment complexes are being renovated and ordinances on trailer parks - Training for skilled crafts -- not yet, but these classes will be built up probably at the Extension Center as we come out of the duldrums - Part 26 to be published in December? -- Conforming changes to site visits and expect approval from OMB in March 2008 - Hearing process in the COL process to be modified? Why do you want an environmental hearing? -- New Plant situation has changed because we are planning on building plants now whereas before COLs occurred without the intent of building plants -- or buy power -- How to shorten the approval process for Industry -- Once the environmental hearing is done then filing for the new LWA rule can occur prior to the COL -- How do we build quicker ... and still stay within the rules -- ESP process may not work for others -- necessary condition for the transition from testing the COL process to planning for building -- But does not the first plant affect the second? Why would the first ESP apply when the second plant is planned? -- Early Site Permits -- these have required delays on the part of the applicants because the seismic analysis was lacking, open items with responses to REI's, amendments submitted and were incomplete, Environment Report lacked hearing notice, Coastal Zone Compliance needed supplemental EIS, ... problems on the applicant side -- Tier I and Tier II design changes slowing process -- NRC needs high quality submittals, not incomplete, etc., in order to process applications in a timely manner -- Waste Confidence needs Rule Making petition -- geologic repository for spent fuel - Industry response: -- Low Quality issues -- Growing Pains -- a Lot of People doing a lot of things -- see comment about need for strict mature process control -- Petition for Waste Confidence will extend the time period so recommending that the NRC save 60-90 days by initiating it - NRC rebuttal: -- Building staff to handling these expected applications -- Safety focus must stay regardless of the need for speed -- A tremendous amount of trust goes into the application reviews - Emergency Planning - Waterford Plant in the path of Katrina had a well-exercised emergency plan which minimized damage - Engaging with local stakeholders in the vicinity of new plants -- let industry be involved in local politics ... well, can we bring in some expertise from the outside? Or the local professors? Or the local legal community? Let us get the locals trained by involving them in the public meetings. - NRC does not want to be blind sided by agitators - Notice of Hearing and Docket of Application - how do we decide what to docket? Docketing of smaller pieces have to cross reference into the Safety which would not yet be done -- This leads to imcomplete hearings -- Industry response: -- Maybe just use this for the first round and industry will work with the staff to provide standards for a partial submittal -- Environmental is part of the bigger risk for industry and can be stop issue -- From an investment view knowing the results of the environmental can reduce the risk and thereby the cost of financing - Open issues that need closure need scheduling for closure and continued dialogue - Shifting workshop dates -- attendees will also be reviewing -- no independent review? - Participation should be fully involved not just attendance -- Remember the hen is involved but the pig is committed - FEMA review and Paulsen involvement -- Industry response: -- Adding another unit at an existing site will already have preparedness plans and minimal change would be needed because 64 site plans are already approved by FEMA -- NRC rebuttal: -- Underlying system should be one that works, but NRC takes a different tack than FEMA - Waste Confidence needs rule making - non-proliferation should not be addressed by several licensing boards even though instability in the DOE and the politcal arena - The first three ESP using the plant perimeter approach subsidized by DOE were complete failures - When industry identifies the Lead Plant in a Unit at a site then the NRC can prioritize its reviews and forstall budget restriction problems because NRC cannot work on all the plants simultaneously - Docketing partial applications seems unwise even if you smoke out contingents early because you should get the same information from the Environmental Impact Statement meetings - Digital I&C provides a possibility of a more national approach (standardized) with multiple agencies and multiple companies -- Meeting in Atlanta in September -- Industry Response: -- Across national laboratories and national industries -- NRC rebuttal: -- What is not going on in our national universities may be more important - Standardizing the applications across the industry should include even the companies that are not represented by the Big Boys --Industry Response: -- Taskforce meeting with suppliers and independent peer evaluations with the three companies and design-centered working groups -- Growing Mode means OJT learning mode -- Lack of quality components is a world-wide problem such as those coming from China -- we used to have a Government clearing house that issued problem reports, even from subvendors - Need national program to get the universities and people involved because the pickings are slim -- Pickings are harder for analogue than for digital, but digital is hard - People who are working the current applications should be walled-in to keep them from diverting to the new plants -- Industry Response: -- Hiring 100 engineers a year and moving them into the main engineering office where the mature engineers mentor them for a couple of months -- Not hiring engineers or draining (cannabilizing) engineers because we subcontract out the COL and ESP engineering - Workforce issues because even the NRC takes the well-qualified, long-serving folk from industry -- so we need to build a 15-year-experience engineering base fast? We did not see this nuclear rennaisance coming. How do we retain people? - Lawyers seem to be produced adequately but are there enough engineers?1 -- Industry Response: -- Bind them with health benefits that tenure only occurs after five years ... but then you get someone who works hard for five years, burns out, and coasts -- Leadership academy to provide for the leadership needs for the future -- Operators will be in short supply. Training Engineers as operators takes seven to eight years and robbing Peter to pay Paul occurs - Status of the Operator Pipeline may be the best indicator of industry preparedness and having "good" operators in the pipeline may be the indicator of industry performance -- Industry Response: -- We hire 100 operators a year and do not forsee a problem in hiring what we need Periodic Briefing on New Reactor Issues - Steep learning curve for both NRC and industry - Review by NRC to be done by outside contractors - Training on Project Management Tool to NRO staff and contracting for space outside - Safety Evaluation Report Templates - standard format and consistent approach across the design centers - Public Outreach Meetings - Quality Assurance Audits of the status and content of the applications so the staff can help industry complete them - Pre-application site visits -- pre-empt visits by FEMA and Safety and DOT - Meetings with design center working groups ... initiative from NRC - Simultaneous reviews of design certification and COL applications ... one issue - one decision - one time - One project management branch for each design center working group Reviewer Tools - Add request for more information to review process - Combined license application - Issue Resolution Protocol - WIZARD desktop tool - Useful knowledge management tools for future too - Critical Skills Hiring - electrical and digital instrumentation control engineers - Contract work to be used during periods of peak work -- collecting statements of work now - OJT being provided in soils - Use of technical staff in closures Comment: Why do I not hear of staff reviews being done now? What about Lessons Learned? Security - Department of Homeland Security MOU - Public - Industry - Vendors Outreach - Start with an Open House with a Poster Session and Q&A one-on-one - We try to get out to every site to hold a public outreach meeting prior to the environmental impact statement -- try? What is the metric? - Multinational Design Evaluation Program Steering Committee Questions - Can you meet the expected workload? -- Staff: -- Grown organization in a very short period of time and some skill mixes are of concern -- Changing the way the NRC does project management -- Difficult challenge -- Dampen peak workload with contractual labor -- NOTE: This requires a different skill set - Why did the regulatory guide not require a complete application? -- The first time the regulation was used -- What! Who defined the process? Do you know what a process is? -- Regulation will probably need to be changed -- Split application was not seen by people who although knowledgeable had not been through it before - Are delays expected in limited work authorization by OMB -- NRC is ready and we are at the cusp of that happening -- Efficiencies if the same person does both reviews -- Huh? Better to serially review or team review - Are we creating the application through reviews? - ABWR - Will GE submit a design certification amendment for South Texas? Design amendment better than through the COL process. -- Staff: -- GE considering this and NRC will consider them through their joint license request -- GE thinking other orders may come in and is waiting to consider the need for a design amendment - Unified Approach: One issue - One review - One resolution - One decision - One time - How can something be scheduled overlapping the end with the beginning. The start of the end of the review process begins with the start of the project -- Staff: -- Project Management Server software provides the model and may not allow minion to look at the final "revision" - If we have contentions filed during the design process, then we do not have resolution prior to the hearing. ... Leaving the public out of the design process. -- Staff: -- Resolve on the basis of the staff position and take some risk with the public comments. - FEMA coordination? -- Staff: -- FEMA wants 40 people to support these NRC reviews as a central organization within DHS then some dispersed to the FEMA regions -- FEMA can hire contract workers until fully staffed but this may not be adequate -- FEMA Lessons Learned -- latest ESP review on time and of "good" quality Security and Fingerprint requirements for construction? -- Staff: -- Not everybody, but a critical group to provide "fitness-for-duty." A tiered approach. Public Outreach Meetings? -- Staff: -- Attended recently by over 200 persons with questions. -- Most interaction with Environmental Impact Statements. -- Hispanic TV and Japanese TV Next round will not be so mysterious -- Staff: -- Greenfield site vs Brownfield site Another inspector? Go back to the site at another stage and concentrate on another aspect, such as electrical, and get another Lessons Learned. -- Staff: -- Probably not because we are aware of the seismic concerns. In depth look at AP1000? -- Staff: -- Difficult coordination issue. -- What! You get paid to interface! Only you! So do it. - Is standardization in programatic areas lacking? -- Staff: -- Operational programs need to be enhanced and we should not build new reactors to the older operational program standards. -- Industry wants consistency and backward compatibility - Technical challenges in review process? -- Staff: -- Need new analysis codes to meet seismic sensitivity studies and soil testing results in a timely manner. Maybe start COL without complete soil testing results. -- Standard Review Plan resolves some of the new technical issues -- clarification of seismic standards between NRC and industry -- Clinton ESP Risk or Performance Based Methodology has evolved. -- SWAG Scientific Wild-Ass Guess should be accepted by NRC but this prevents a thorough review prior to issuing operating license. -- How much back fill? Soil sampling at construction needs to be back tracked into SWAG. You do not know what you have until you start to dig. - Design Center Working Group - Should the staff be reviewing an application that probably will not result in construction? -- Staff: -- According to budget we have identified the site that the industry wanted -- Hand-in-Glove relationship between NRC and industry. - Re-examine priority if staffing crunch occurs -- Staff: -- We are not shy. - Focus on existing reactors and make them run safely