1. Industry Challenges-Quality Opportunities
Mark Richter
Senior Project Manager
2017 Nuclear Oversight Conference
July 26, 2017
NEI Overview:
Industry Challenges-Quality Opportunities

2. Agenda NEI Overview Delivering the Nuclear Promise Quality Topics
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3. Current Status of Nuclear Energy in the U.S.
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4. Sustained Reliability and Productivity
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5. Early Plant Shutdowns
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6. Drivers of Early Shutdown Decisions
For plants shutting down prior to the turn of the century, early shutdown decisions were less complicated
Then the world changed….
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7. An Industry Under Siege: Our Response
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8. Delivering the Nuclear Promise
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9. Strategic Focus Areas
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10. Building Blocks Building Block 1: Analysis and Monitoring
Objective: Analyze plant cost drivers and identify opportunities to improve efficiency.
Building Block 2: Value Recognition
Objective: Leverage federal and state policies to ensure greater recognition of nuclear energy’s value.
Building Block 3: Process and Program Redesign
Objective: Re-design nuclear plant processes to improve efficiency while advancing the fundamentals of safe, reliable operation.
Building Block 4: Strategic Communications
Objective: Implement a communications strategy to ensure industry engagement.
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11. Building Block 3: Process/Program Re-Design to Advance Safety, Reliability and Efficiency
Capture near-term efficiency improvements that can be done under existing guidance
Re-design selected processes to improve efficiency while advancing the fundamentals of safe, reliable operation
Address any impediments to implementation: existing guidance/procedures, regulatory or technological issues
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12. Building Block 3: Process/Program Re-Design to Advance Safety, Reliability and Efficiency
An opportunity to drive efficiency through quality process improvements
Item Equivalency Initiative
Digital I&C Modernization Program #3
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13. Delivering the Nuclear Promise: Quality Opportunity Examples
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14. Standard Item Equivalency Initiative
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15. Item Equivalency Initiative Objectives
Implement a standard item equivalency process that promotes more efficient use of engineering resources
Standard qualifications and mentoring guidance
Facilitates sharing of item equivalencies between utilities to reduce costs (when practical)
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16. Item Equivalency Initiative Objectives
A simplified item equivalency change procedure
Common solutions are developed and shared across the industry not included in this I/O
Common industry wide training
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17. Recommended Structure
Model after SDP DNP Initiative, Red or Blue Bulletin
Step 1 – Benchmarking-Assemble SMEs from DOWG, JUTG, and NSCSL
Step 2 – Compile benchmark data and industry best practices. Develop a new procedure with consistent hand-offs to IP-ENG-001 that addresses applicable regulations
Step 3 – Using the IP-ENG-001 as the base document, modify ENG-001 or develop qualification requirements and mentoring guideline
Can we use existing DEC structure? (SIEP dovetails with DEC)
Graded approach
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18. Status Industry Team Formed Drafts Prepared
Licensees, EPRI, INPO, NEI
Drafts Prepared
Improvement Opportunity Document
Cost Savings
Procedure
Standard qualifications
Process Procedure Under Development
Establish interface with Standard Design Process
Pilot plants being identified
Exelon, SNC and NextEra would perform a “full pilot” whereby IEE products using the new process will be produced
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19. Success Defined Evaluations shared through a “solution library”
Standardization efficiently solves obsolescence issues and facilitates performance and review of item equivalency evaluations
Clear delineation between Item Equivalencies and Design Changes
Cost savings for using a standard Item Equivalency process
Proprietary information adequately controlled
No consequential events attributed to replaced parts-safety and reliability not impacted
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20. Digital I&C Modernization Program #3 – MP3
Acceptance of Digital for Commercial Grade Dedication
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21. NRC Digital I&C Integrated Action Plan (IAP)
SECY and Commission direction:
In early 2016 the NRC Commissioners asked NRC staff to work with industry to develop a strategy to modernize the digital instrumentation and control (I&C) regulatory framework.
An increased collaborative effort since then has resulted in NRC creation of the “Integrated Action Plan to Modernize Digital Instrumentation and Controls Regulatory Infrastructure” (a.k.a. the “IAP”).
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NRC staff submit rev 0 to Commission as SECY May 25, 2016 consisting of four primary modernization plan (MP) components:
MP1 = Protection Against Common Cause Failure (CCF)
MP2 = Considering Digital Instrumentation & Controls in Accordance with 10 CFR 50.59
MP3 = Acceptance of Digital Equipment (in support of Commercial Grade Dedication)
MP4 = Assessment for Modernization of the Instrument & Control Regulatory Infrastructure
Rev.1 published March 31, NEI providing input since original issue
Over-arching document provides macro plans and guides priorities
NRC Steering Committee engaged to assist NRC teams working on these efforts. NEI coordinates digital I&C working group and steering committee, and has formed NEI/Industry teams for each MP initiative.
Public meetings/drop-ins advance the MPs and keep the IAP current
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23. MP3 Objectives Few Options Exist:
Nuclear licensees do not have a wide variety of options when it comes to selecting digital equipment for safety related applications
Providing more options will enable industry to reduce costs
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24. MP3 Background
Most digital equipment used in nuclear safety related applications was not designed under a 10 CFR 50 Appendix B QA program so it must be evaluated and accepted for nuclear safety applications
Many cases of commercial grade digital equipment acceptance are first-of-a-kind efforts, with uncertainties in duration, cost, and overall success
Impeded by lack of Original Equipment Manufacturer (OEM) engagement and/or information
The small market often does not justify OEM resources necessary to support the acceptance process unique to the nuclear industry. Some industries address similar challenges by employing certification from an independent 3rd party to a particular Safety Integrity Level (SIL).
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25. MP3 Acceptance Guidelines for CGD
Reg. Guide 1.164, rev 0, Feb 2017 “Dedication of Commercial-Grade Items for use in Nuclear Power Plants” endorses…
EPRI , Revision 1 of EPRI NP-5652 and TR , “Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications”
Section 14.1 “Digital Equipment and Computer Programs Integral to Plant SSCs”
For digital equipment one (or both) of the following apply:
EPRI TR , “Generic Requirements Specification for Qualifying a Commercially Available PLC for safety-Related Applications in Nuclear Power Plants”
EPRI TR , “Guideline on Evaluation and Acceptance of Commercial-Grade Digital Equipment for Nuclear Safety Applications”.
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26. MP3 Basis for Improvement
Global Best Practices Exist: IEC 61508, “Functional Safety of Electrical/Electronic/Programmable Electronic Safety-Related Systems”, contains requirements for ensuring both hardware and software are designed, implemented, operated, and maintained to provide the required SIL that industry suggests be leveraged
There is NRC established regulatory precedent for this concept:
In 2001SER issued on PLC-based platform that leveraged results of a third-party certification.
In 2015 NRC endorsed NEI “GUIDELINES FOR THE USE OF ACCREDITATION IN LIEU OF COMMERCIAL GRADE SURVEYS FOR PROCUREMENT OF LABORATORY CALIBRATION AND TEST SERVICES”
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27. MP3 Success Defined
NRC acknowledges SIL Certification represents acceptable level of digital equipment basic quality – in particular, dependability:
Desired outcome is that NRC
Endorses a previously performed SIL certification that constitutes an acceptable demonstration of commercially available digital hardware and software basic quality
Accepts as verification of certain dependability critical characteristics per NRC endorsed EPRI TR (Guideline on Evaluation and Acceptance of Commercial-Grade Digital Equipment for Nuclear Safety Applications).
Acceptance includes elements within the scope of an independent third-party SIL certification, and exclude elements not within such scope (e.g., application specific functionality and performance critical characteristics such as environmental compatibility and response time)
Mechanism established for U.S. nuclear industry and NRC to establish and maintain ongoing confidence in the SIL certification process
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28. MP3 Benefits Anticipated benefits include, but are not limited to:
Acceptance of objective certification criteria for establishing the basic quality of commercially available DI&C equipment.
Relieves NRC of burden associated with ongoing reviews of “out-of-the-box” digital I&C equipment
Allows NRC to focus regulatory resources on the application of DI&C equipment to nuclear power plants
Reduction of risk for both licensees and nuclear suppliers
Increases safety and dependability
Increases efficiency and cost savings for licensee or dedicator by eliminating need for commercial grade survey
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29. MP3 Next Steps
Industry maintain dialogue with NRC regarding questions or provision of additional information
EPRI to research and evaluate third-party process certification for digital equipment and publish results in April 2018
NEI will lead development of a guidance document for NRC endorsement for 3rd party certification to be drafted by the end of 2018.
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30. Conclusions
The U.S. nuclear industry is facing economic challenges and regulatory and market uncertainty
Industry recognizes the complexity of the challenges and the existential threat that they pose.
Industry is engaged and developing strategic plans and actions to address the challenges on a variety of fronts
Quality processes and principles will play a key role in resolution of a variety of challenges our industry faces
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31. Questions?