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The ROP, Clear Thinking & All Things Nuclear

"Be the change that you wish to see in the world."  Mahatma Gandhi

Change has come fast and hard to the nuclear industry, indeed to the entire energy sector.  We are in a race to adapt to new realities: abundant, cheap natural gas; little or no growth in electricity demand; mixed signals about the importance of controlling carbon emissions; and market rules tied to the old world order that inadequately reward 24-7 reliability, fuel supply diversity, and carbon-free baseload generation.  In the spirit of Mahatma Gandhi, the U.S. nuclear industry is pursuing a thoughtful and ambitious program to simplify how we work together to ensure safety and reliability remain the clear and constant focus of our efforts.  It is inspiring to see how teams of experts from across the industry are, through the Delivering the Nuclear Promise initiative, sharing experience, good ideas and best practices to identify better ways to accomplish the myriad tasks required to maintain the outstanding performance of the U.S. nuclear fleet.

The U.S. Nuclear Regulatory Commission is also racing to adapt to new realities:  a mature industry facing the premature closure of several nuclear plants due to economic conditions; pressure from the Congress and public for greater transparency and accountability in management of budget and fees collected from industry; loss of corporate memory as senior staff retire and are replaced by less experienced personnel; higher expectations for timely and efficient decision making.  The NRC's Project AIM is but the latest and most significant effort to rethink how the agency works and address the changing pressures the agency faces from stakeholders on all sides.

In the tumult of such a dynamic environment, it is hard to know when to resist change and when to "go with the flow".  We're dealing with this very question in one of my areas of responsibility at NEI - the Reactor Oversight Process (ROP). 

Sixteen years ago, in a remarkable collaboration brought on by similarly strong forces of change, the NRC, industry and public stakeholders came together to transform the way in which NRC determined where to focus its attention within the operating fleet.  This collaboration enabled NRC to move from a subjective and inscrutable process known, now ironically, as the Systematic Assessment of Licensee Performance (SALP) process to the more rational and balanced ROP we have today.  In simplest terms, the ROP uses both NRC inspection results and industry-generated performance indicators to gauge the status of plant performance.  By contrast, the SALP process depended largely on a consensus judgment of NRC regional and headquarters management.  The basis for such judgments was difficult to quantify or reproduce, leading to great dissatisfaction among those affected by the results.

Today, the challenge is a continuing effort by the NRC to modify the ROP with, at times, little or no objective evidence of a specific problem that needs fixing.  Experience in our nuclear power plants tells us that in all things nuclear, every change in procedures and programs should be carefully thought out.  To us that means we should begin every change project with a clear problem statement.  That problem statement must be supported by hard data and analysis.  A concise project plan with a strategy, milestones, deliverables and schedule is needed in order for us to know how likely we are to succeed and how we will measure the outcome of our project once it is complete.

The NRC is working on two major changes to the ROP right now.  One is streamlining the so-called Significance Determination Process (SDP).  This project intends to improve NRC management of inspection results, so that the agency can complete its "safety grading" of results more quickly.  Our concern has always been that the agency might sacrifice accuracy of grading for speed.  Our concern is shared by Commissioners of the NRC, as well as members of Congress and public stakeholders. 

The other major change involves a procedure for inspecting the industry's corrective action programs.  Our plants rely on the so-called CAP process to capture, analyze and fix problems before they have a chance to grow larger or recur.  The NRC inspects this important process through samples taken in the course of several routine inspections, and then in a deep dive into the program taken through a biennial inspection known as their Problem Identification and Resolution (PI&R) inspection.  In our discussions with the staff about their plans to change the PI&R inspection, we have heard many ideas that sound like solutions in search of a problem.  We don't doubt for a moment the NRC staff's sincerity in this effort.  However, we approach this project with the same mindset with which we approach projects in our power plants - what is the specific problem this effort is meant to solve?  So far, we have not heard that clear and compelling problem statement that we need in order to explain to our stakeholders why this project is essential to advance safety.

As we and the NRC strive to adapt to our changing environment, we want to ensure that NRC's resources and ours remain focused on safety as our highest priority.  Projects undertaken without the basis of a clear problem statement, linked by objective evidence to a compelling safety issue, risk distracting both industry and NRC from our primary obligation as stewards of nuclear power - to embrace change thoughtfully and with due consideration, but to resist change for change's sake in order to preserve what works.

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