Attributes of a Successful Nuclear Construction Project A Regulator s Perspective. Luis A. Reyes NRC Region II Administrator October 26, 2009

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1 Attributes of a Successful Nuclear Construction Project A Regulator s Perspective Luis A. Reyes NRC Region II Administrator October 26,

2 Background Last nuclear plant construction period was not a model of efficiency and effectiveness for all involved Many delays, cancellations, major construction problems, design changes, and cost overruns Licensing process was cumbersome, inefficient, and uncertain Inspection process was not well structured or sufficient Licensee s oversight and involvement was insufficient and ineffective We do not want to repeat that experience 2

3 What is Different This Time? Approved & Current Design Certifications 10 CFR Part 52 for Licensing ITAAC Construction Techniques Improved Vendor Oversight Construction Inspection Program -- NRC Addressing Lessons Learned Learning from International Construction Activities Learning from New Fuel Facility Construction Industry Success Factors What Can Get You Into Trouble? 3

4 Approved and Current Design Certifications AP1000 EPR US APWR ABWR ESBWR 4

5 Goals for 10 CFR Part 52 Licensing More predictable licensing process Resolve safety and environmental issues before authorizing construction Reduce financial risk to licensees Encourage standardization of nuclear plants choose a certified design 5

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7 ITAAC An application for a standard design certification must contain proposed inspections, tests, analyses, and acceptance criteria (ITAAC) for the standard design. The licensee and the NRC review/inspect the ITAAC (verify ITAAC are met) to ensure that the as-built nuclear power plant is constructed and performs as intended. 7

8 Construction Techniques Modular Construction Offsite Fabrication Onsite Assembly 8

9 Improved Vendor Oversight Build upon existing vendor inspection program in coordination with other NRC offices Increase inspection frequency and scope Clarify oversight and improve interface with industry s third-party auditing organization Expand international cooperation in vendor oversight 9

10 Lessons Learned Man learns from history that man learns nothing from history. - Hegel s Paradox 10

11 NRC Lessons Learned Inspect early in any new process Larger resident inspector presence Better integration of individual findings Prompt response to quality issues and allegations Physical work observations rather than paper reviews Improved inspection planning and scheduling Closer relationship between inspection and licensing Complete and accurate inspection record Ensure effective corrective action program 11

12 Learning from International Construction Activities China AP1000 construction Finland EPR construction France EPR construction Taiwan ABWR construction Observe New Construction Techniques Modular Construction Gather Lessons Learned 12

13 Learning from New Fuel Facility Construction Region II, Center for Construction Inspection (CCI) inspectors are currently inspecting the new fuel facilities that are being built 13

14 New Fuel Facilities Under construction National Enrichment Facility (Eunice, NM) Mixed Oxide Fuel Fabrication Facility (Savannah River Plant, SC) American Centrifuge (Piketon, OH) Expected new construction GEH SILEX (Wilmington, NC) Areva (Eagle Rock, ID) 14

15 TVA Reactivation Efforts Watts Bar Bellefonte TVA expects to complete WBN Unit 2 construction and request an operating license WBN Unit 2 Construction Inspection Manual has been issued and Regulatory Framework has been finalized Bellefonte TVA has announced its intent to evaluate feasibility of completing Bellefonte Units 1 and 2 15

16 Industry Success Factors (+) Clear management expectations and oversight including QA/QC Experienced staff, vendors, contractors Self-critical approach Robust corrective action program Clear communications Early completion of detailed design Respect for the hazard 16

17 Licensing Lessons 70 s & 80 s Lack of standardization Design-as-you-go Deferral of resolution of important safety issues Changing regulatory requirements Inefficient and duplicative hearing process 17

18 Recently Revisited Lessons Ambitious schedules Quality assurance/quality control Safety culture Oversight of contractors Active management oversight Clear roles and responsibilities Completed final design details 18

19 What Can Get You Into Trouble (1)? Insufficient skills/experience inventory Inadequate knowledge transfer Non-proactive management of change Errors due to training deficiencies Deferral of needed changes Inadequate investment in the future 19

20 What Can Get You Into Trouble (2)? Decision making dominated by time and due dates Tolerance of standards erosion Unreceptive to outside views Not proactive in building public confidence Not communicating values/fundamentals to staff 20

21 What Can Get You Into Trouble (3)? Distractions from focus on safety Defensiveness vs. communication with the regulator Poor environment for raising issues Symptom fixing Ineffective communications within organization 21

22 SUMMARY Focus on certified designs - ensure critical design parameters are finalized before construction Use Part 52 licensing Ensure ITAAC are clearly met Establish a strong QA/QC presence Hire good staff & contractors Safety focus is paramount stop work when problems are encountered Capture and address problems in a good corrective action system 22