The Nuclear Regulatory Commission and New Nuclear Power
On Tuesday, October 25, 2011 I had the opportunity to attend part of the 3rd Nuclear Energy Insider Conference in Charlotte, NC at the Ritz Carlton. As a media partner, we had promoted this event to several hundred nuclear energy leaders.
The NRC is charged with guaranteeing safe construction and operation of nuclear power. Since 2009, we have been privileged to work at the VC Summer nuclear plant near Columbia, SC, and the Vogtle plant near Augusta, GA. They are different contracts, with unique challenges because of different owners. Yet the NRC must drive consistent policies at these sites, and any future sites.
Rumors abound. So, here are some notes from two representatives from the NRC.
From Laura Dudes, Director, US Nuclear Regulatory Commission, Division of Construction Inspection and Operational Programs
- Number of inspections increasing with demand from 2011 vendor inspections in 2011 to 30 inspections projected in 2015
- Now covering 80% of ITAAC requirements
- As stated on www.usnrc.gov, “the purpose of NRC inspections is to perform physical validation of program implementation”, not intentions or draft documents, but actual physical validation
- The licensee is ultimately responsible, therefore they are prime respondents to communications
- She wants/expects rigorous vendor oversight, not a superficial process
- She asked “How many of you have been on site when an NRC inspection has occurred?” Only 2 of about 300 raised their hand. (She wanted a higher number. However, it may have been the wrong audience, as those leaders are more likely to be on sites. This audience included vendors and strategic leaders.)
From Chuck Ogle, Director, US Nuclear Regulatory Commission, Division of Construction Inspection at Region II (which includes VC Summer and Vogtle)
- The Atlanta-based Center for Construction Inspection (CCL) has about 60 inspectors, tasked with 1) inspection, 2) enforcement, and 3) assessment
- They emphasize observation and compliance to standards
- He mentioned five focus areas (that keep him up at night): 1) cROP Construction Reactor Oversight Process, 2) applicant/licensee oversight of contractors, 3) scheduling infrastructure, 4) ITAAC, 5) inspection plans vs. emergent issues
- His opinion is that 1) the process is complicated but should work, 2) they are new and only 3.5 years into these new nuclear requirements, 3) they are implementing expertise from their construction inspection experience
- NRC lessons learned include: 1) need to inspect early in any new process, 2) will need a larger resident inspector presence (currently 2 at Vogtle, abt 30-35 year olds), 3) need better integration of individual findings, 4) need a prompt response to quality issues and allegations, 5) physical work observations are better than paper reviews, 6) ongoing need to improve the inspection planning and scheduling process, 7) need closer relationship between inspection and licensing, 8) need complete and accurate inspection records, 9) need to ensure effective Corrective Action Program (Also, in the process of developing an electronic system, likely tablet-based)
- Historical lessons learned include: 1) need to cultivate a self critical approach, especially with safety culture, and continue to always look for our own problems, 2) need a robust CAR process, with NRC requirements as a minimum standard, 3) need clear communications, 4) encourage early completion
- Current Challenge Areas include (and he stated several times that the following are his opinion only, not NRC-endorsed statements): 1) need to understand the regulator-licensee relationship; cannot avoid CARs, cannot ignore concerns, need to anticipate a visit/inspection, should expect that any unresolved issues will be returned, 2) need to understand the oversight of vendors and subcontractors, the hierarchy, and responsibility to the licensee, 3) need to anticipate questions/ content, next aspect of work process in order to stay ahead of the regulator, 4) need to improve the ITAAC process, some are broadly written, in scope, understand that these are not written by the inspectors, some may be open to interpretation
[On the following day, Wednesday, October 26, I had the privilege of facilitating a Construction Oversight Meeting with senior leaders from Shaw Power Group and Southern Nuclear Company.]
If you have any comments or questions please call. I will never breach confidentiality. However, in my opinion, we have a tremendous opportunity to increase our nuclear energy capacity, build safely and under budget, in a reasonable period of time.
All great construction projects, throughout recorded history, have similar responsibilities that require great leadership.