Nuclear Plant Journal, July-August 2015 NuclearPlantJournal.com
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Extend Life
Your Energy. Our Experience.
Mitsubishi’s Water Jet Peening (WJP) technique mitigates stress
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entire WJP process is conducted underwater during plant outage, with
no foreign materials or heat introduced into the reactor. Because the
WJP equipment is controlled remotely, the occupational dose exposure
is extremely low. Mitsubishi has successfully provided more than three
dozen WJP applications and operates a complete training center for
WJP services. Make Mitsubishi your plant renewal partner.
mandating this, rather this is an example
of the industry cumulative impact. Over
the years, we have done apparent cause
evaluations that don’t have the safety
significance of an event that would
require a root cause investigation. We’ve
made those apparent cause evaluations
look like root causes. Now, they’re so
detailed that we’re losing the opportunity
to understand the learnings, implement
them into our programs, and move on.
We are working to use a better graded
approach in causal evaluations depending
on the significance of the issue.
3.
Have the industry’s pilot projects on
cumulative impact of regulations been
launched?
What we’re doing as an industry
is endorsing the NRC guidance
document on this issue (SECY 150050,
Cumulative Effects of Regulation
and Risk Prioritization Initiative:
Response to Commission Direction
and Recommendations)
. The SECY
prioritizes the guidance and the pilot
for the NRC expert panel to prioritize,
schedule and eliminate when appropriate
proposed rules, orders and generic
communications are issued. The next
step is NRC approval.
We see the benefit of this program
in looking at the cumulative effects of
all the rules that have been put in place.
We want to know which rules add value
and which rules do not. Then we can
check and adjust both from a regulatory
perspective and be able to prioritize the
most important actions first, regardless
of whether they are required by the
NRC or by the industry. Training, for
example, would be an industry-initiated
requirement.
The “tabletop approach” is just
taking a sample for one particular facility
and taking a look at the cumulative effects
for that one facility. We would take the
results from the tabletop and apply
them to sites across the industry. It’s the
industry vetting a process with the NRC
in institutionalizing the learnings for the
rest of the plants.
All of our utilities have endorsed
this. All the company chief nuclear
officers have had an opportunity to weigh
in, to give their opinions, and it’s been
endorsed by the NRC staff. Now it’s with
the commissioners for a decision.
4.
How has the industry and the U.S.
NRC collaborated on the cumulative
impact effort?
This is the first time the industry and
the NRC have worked together to look at
the impacts of various requirements and
which actions that are adding value. In
no way does this relieve the NRC from
putting together the proper cost-benefit
analysis for new regulations. That’s
also very important and, as Congress
has noted, an area where the NRC
must improve. This gives the NRC the
opportunity to take a look at how this
specific regulation or initiative impacts
other regulations and assigns a priority
for implementation.
Up until the cumulative impact
initiative, we’ve dealt with each
regulation on a one by one basis without
looking at the cumulative impact of
each new regulation. We have always
been committed to safety, but we also
recognize that there has been layer upon
layer of regulatory obligations imposed
on the industry—some that doesn’t make
sense today. The industry has managed
