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As of this writing, of the 104 operating nuclear power plants in the US 75 have submitted license renewal applications (LRA) of which 55 have received approvals for the extended operating period from the NRC. So what steps have been taken to prepare for the next twenty years?

BCP has a vibrant LRA business. Our technical and licensing expertise has been integrated to help a number of our customers prepare and submit LRAs and prepare for the extended period of operation. What we have seen with many clients looking to an extended period of operation, is that they are not progressing with preparations for entering their extended period. Does your plant fall into this category?

There are a number of reasons for plants not being prepared or progressing in their preparations. The most glaring reason seems to be that the development of the LRA was budgeted as a project and funded separately from the efforts necessary to implement the commitments established in the LRA. These commitments have the force of the original licensing commitments as one approaches the extended period. The separation of the LRA and licensing renewal implementation (LRI) efforts often means the resources used to develop the LRA and its plant commitments are released after the LRA submittal and no longer available directly to the plant, which now is committed to new requirements with which they were not directly involved in developing.

The second issue seen often is that while being removed from the development of the LRA, and not infinitely familiar with the new commitments, there is often a sense among plant staff that there is adequate time to prepare. Living under this misconception can have ruinous effects. An example of this impact was recently seen in the results of an NRC audit of a plant’s preparations for the extended period. If your plant is approaching the extended period of operation, how would preparations and LRI stack-up?

Unlike many licensing commitments, LRI requires inspection methodologies, technologies and procedures that are more akin to the plant’s technical programs, for example inservice inspections. The actions and activities are dealing with plant hardware, operating schedules and limited staff resources. The LRI inspections and validation of assumptions often require plant outage time. With 18 and 24 month fuel cycles, a plant may only have one or two outage cycles available for completing LRI work prior to the NRC’s audit, which occurs about six months prior to the extended period. So while one might think they have months and years to prepare, those ever precious outage windows come and go while these opportunities to schedule LRI activities are lost. For many of these commitments, new techniques are required and this developmental work is most easily set aside as staff suffer the tyranny of the crisis of the moment on a routine basis.

The third and related issue to preparations for the extended period falling behind is related to resources. Management, while intellectually recognizing the need for the updating of the engineering and technical programs to include the new commitments addressing aging, their daily fire fights, budget battles and pressing plant issues, diverts attention from these longer term commitments. In the effort to continue to do more with less, management may actually be under the impression the necessary work is progressing under the O&M efforts of staff. It is at times missed that those responsible for executing the plant’s technical programs have routine work and outage preparations that are pretty much full time efforts in most organizations. The extra staff or EIT that may have previously provided some support has long been squeezed from the organization. Having someone on staff in that program role with requisite expertise doesn’t translate to there being adequate time to accomplish the program updates dictated in the LRA or revised SER.

Solutions exist. First, if your plant is in the process of developing an LRA or anticipates doing so, push management to consider combining the LRA and LRI efforts into one project with single project funding. Once the utility makes the strategic decision to pursue plant life extension with an LRA it makes sense to complete the work necessary to enter the extended period as part of that project effort.

If your plant has already submitted its LRA (and may have received NRC approval), it is important to know where the plant stands in its LRI and preparation. If this is not well understood and efforts for LRI are not adequately planned and scheduled, we recommend an LRI assessment and review. This effort will provide management with a clearer picture of program initiatives that are on track, those that are behind and can provide a basis for knowing where efforts must be applied to recover. BCP can assist with this. It is critical to adequately plan and execute the LRI plan due to limited time and resources at most operating organizations. As the old adage goes, “Failing to plan means planning to fail.” As one approaches closing out the LRI efforts, a review in advance of the NRC audit of the program preparations may also be prudent.

If your LRI effort is well managed and planned with adequate resources and time to complete the effort, congratulations. You move to the head of the class.

Contributed by Chris Staubus, BCP’s General Manager of Utility Services.

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