Closing the RAP GAP for safety, cost and investment protection

September 25, 2009

Honorable Senator Thomas A. Carper
Chairman, Senate Environmental and Public Works
Subcommittee on Clean Air and Nuclear Safety
United States Senate 513 Hart BuildingWashington, DC 20510

Closing the RAP GAP for safety, cost and investment protection

Responding to Three Mile Island (TMI) learning twenty years ago, Part 52’s Combined License Quality Assurance Program (QAP) required certified designs provide a Reliability Assurance Program (RAP). Unfortunately, the nuclear industry failed to recognize that new plant RAPs are simply scheduled maintenance plans. Since introducing Boeing’s 747 in 1967, the FAA has only licensed new airplanes with certified scheduled maintenance plans. NRC should implement Part 52’s intent and letter by only licensing new designs with completed RAPs - the same way U.S. airframe suppliers have done the past 42 years.

Senator Carper:

Title 10 CFR Part 52[1] requires new nuclear plants to have reliability assurance programs (RAP) covering safety-related equipment. The difference between a new and operating plant reliability assurance programs - e.g., their scheduled maintenance plans - creates a RAP gap. Many nuclear plants started up under Part 50 with virtually no scheduled maintenance plans. Three Mile Island (TMI) was one. Few of those scheduled PMs. Surveillance test programs had major omissions, discovered only after industry-wide audits following TMI. New plant owners of that era assumed their operators could patch together various safety-related equipment maintenance and monitoring plans after startup once they completed the immediate startup goal to establish income flow. They did not.

TMI-2[2] demonstrated the huge risks that placed on the plant’s public, operators, and especially the nuclear industry and its financial backers. Those charged to develop plans were often woefully unprepared to do so, lacking formal training, qualification or effective tools. They deferred to operational needs. As a result, as late as 1995 many nuclear plants still ran with substantially incomplete reliability assurance plans.

Few financial lenders today would embrace placing their $8 billion dollar asset into operation without a scheduled maintenance program. Yet regardless of common sense, and rules that require RAP for nuclear safety-related equipment, we are poised to repeat that error again today - even on required, in-scope nuclear safety-related equipment. Although rules formally only cover a small fraction of overall plant equipment - the nuclear safety-related equipment - resistance developing programs before plants start up has emerged again. Regardless of what brokers or owners should expect to protect their huge investments[3] for purely economic reasons, addressing safety-related equipment’s planned monitoring and scheduled maintenance before startup remains unresolved.

Commitment today to implement Part 52’s NUREG-0800[4] and Regulatory Guide (RG) 1.206[5] RAP requirements remains unclear. Guidance remains suitably vague, confused by deterministic design considerations and engineering judgment. Completing the scoping of safety-related equipment classification is the only certain pre-startup requirement today. Thus, the same unprepared workers charged to develop Generation I plans, lacking in formal training, qualification and tools, are poised to do so again. Will they defer that task again to operational needs, and repeat the lessons of 1970’s and 80’s? Incomplete plans started up TMI, placing a huge risk on overall operations. The cumulative result of thirty years of nuclear operations indicates starting new plants with incomplete operating “software” causes confusion and introduces risk. Ignoring TMI, regulatory response the past thirty years has been many rules like as 50.49, Environmental Qualification of Class 1E Electrical Equipment for Nuclear Plants that specify nuclear maintenance programs. Guidance today now covers how to develop effective, comprehensive equipment scheduled maintenance and monitoring plans. For new nuclear construction, Part 52 specifies developing a reliability plan. Prospective licensees see providing the equipment scope covered by the rule, a safety-related MEL, meeting that requirement. Today, few anticipate providing scheduled maintenance plans required by the RAP at startup.

Industry should emulate the Federal Aviation Administration (FAA) and airline industry. FAA certifies new airframes with a preflight reliability assurance program as crew operational checks and scheduled maintenance[6] - before a licensed commercial plane ever leaves the ground! The advantages are many. Aside from having a complete startup plan from the onset, providing a systematic approach yields a structured plan. Plants can realize their design-based reliability, rather than let haphazard chance events determine outcomes. Reasons to develop embedded design-reliability programs include engineering completeness, along with forty-years operating experience. Financing requires realizing nuclear operations consistency from the start. Not only is it imperative not to repeat TMI, new nuclear generation economics require very high cost performance to repay construction loans. Cost-plus scenarios of Part 50 LWR licenses[7] are gone forever; they must meet public utility commission (PUC)-promised rate case projections. Predictable nuclear operating costs from reliability benefit safety directly as well as indirectly over a plants lifetime. Design-forward reliability benefits nuclear power consumers by not funding repetitive, haphazard design basis and scheduled maintenance reconstitution programs over and over, adding unnecessary or even detrimental requirements to maintenance processes. Everyone benefits from standardized operating plans licensed with plant designs.

Conclusion

Important strategic initiatives have hamstrung the nuclear industry in the past. While the industry should legitimately concern itself with the intrusion of regulation, existing safety statutes and rules are mandatory. Extending those sensibly to achieve common success on nonsafety related nuclear plant equipment should remain industry’s prerogative. However, the tools, methods and programmatic understanding to develop, implement and maintain effective, automated reliability programs have never been more available. If loan guarantees effectively make Congress the nuclear industry’s banker, it should require application of the very best methods and processes to protect its capital investment - not just nuclear safety-related equipment.

Given the substance, value and costs before us, as well as our safety interest, it is imperative that those who approve funds to develop safe American nuclear energy resources thoughtfully consider nuclear reliability and licensing. Congress should deliberate these matters as energy debates continue.

Sincerely,

J.K. August, PE
J.J. Hunter SRO
CORE, Inc.
303-425-7408/970-330-1411
[1] Licenses, certifications, and approvals for nuclear power plants
[2] The accident, a $2 billion loss.
[3] in nonsafety balance-of-plant equipment, constituting 80% of overall plant cost
[4] Review of Safety Analysis Reports for Nuclear Power Plants
[5] Regulatory Guide for Combined License Applications for Nuclear Power Plants
[6] See ATA MSG-3 (2001), Operator/Manufacturer Scheduled Maintenance Development, which provides an FAA-approved method for developing aircraft inspection/maintenance programs. Aircraft providers must certify airframes and power plants for commercial service applications.
[7] Under Part 50, most rate-based plants were allowed to recover “reasonable” ongoing construction costs.