Preparing Shut Down Plants for Decommissioning

David McIntyre
Public Affairs Officer
 
Vermont Yankee
Vermont Yankee

Four commercial nuclear reactors – Kewaunee, Crystal River 3, and San Onofre 2 and 3 – ceased operations in 2013. A fifth, Vermont Yankee, is scheduled to close permanently by the end of this year. The NRC staff has taken several steps to transition our oversight of these plants to focus on decommissioning instead of plant operations.

This is the first time NRC has taken these steps since the last wave of nuclear power reactor decommissioning in the late 1990s.

Once the fuel is permanently removed from a shut-down reactor, the types of possible accidents are significantly fewer, and the risk of an offsite release of radioactivity significantly lower, than when the reactor was operating. A plant owner therefore may request exemptions to the regulations or amendments to its license based on site-specific analyses of the permanently shut-down and defueled reactor.   The NRC closely reviews each exemption request to ensure that public health and safety are adequately maintained and the common defense and security is assured as the plant transitions from operations to decommissioning.  Some recent actions:

  • Dominion Energy Kewaunee requested – and the NRC has approved — exemptions from the NRC’s emergency planning requirements to reflect the reduced risk of accidents. The plant will maintain an onsite emergency plan and response capabilities, including notification of local government officials of an emergency declaration. State and local authorities may still implement protection measures under their comprehensive emergency management plans. But, because the risk of accidents and offsite release is greatly reduced, Kewaunee will no longer be required to maintain offsite radiological emergency preparedness plans or the 10-mile emergency planning zone. After approving the exemptions on October 27 (ML14261A223), the NRC staff approved license amendments implementing the changes. (ML14279A482)
  • Dominion also requested certain exemptions from NRC’s physical security regulations for Kewaunee. The staff denied this request, however, concluding the company failed to demonstrate the changes would continue to provide adequate protection against radiological sabotage. (ML14282A519)
  • The NRC staff approved Dominion Energy Kewaunee’s training program for “certified fuel handlers,” who will manage plant operations from here on, focusing on spent fuel management and the transfer of spent fuel from the pool to dry casks. This approval was issued May 12. (ML14104A046)
  • An exemption issued May 21 allows Dominion to use some of its decommissioning trust fund to cover expenses of managing the plant’s spent fuel, without requiring NRC approval for each withdrawal from the fund. (ML13337A287). The NRC staff determined this would have no significant environmental impact (an Environmental Assessment and Finding of No Significant Impact were published in late April), and verified the trust fund contains enough money to cover spent fuel expenses and fully decommission the plant. (A similar exemption was issued July 21 for the Zion plant in Illinois, which has been in decommissioning for several years. ML14030A590)

Crystal River, San Onofre and Vermont Yankee have requested similar exemptions and license amendments. These requests are being reviewed separately to account for individual circumstances at each plant site. But the objectives are the same: to allow plant operators to focus their resources on the important task of preparing the plants for ultimate dismantling, decontamination and decommissioning, while ensuring adequate measures remain in place to protect public health and safety and the common defense and security.

Improving NRC Processes—Part Two

Patricia Holahan
Director, Office of Enforcement

 

We wrote in June about steps we are taking to improve our “non-concurrence” process, which is a way for NRC staff to air a variety of views before final management decisions are made. Today, we’d like to fill you in on steps we are taking to improve our Differing Professional Opinions (DPO) process—used to bring NRC staff views on agency decisions to the highest levels of NRC management.

publicopinionBoth processes are important to creating an environment where NRC employees feel they can speak up when they disagree—the same safety conscious work environment we expect from our licensees.

First, a little context. The NRC makes hundreds if not thousands of decisions each year. To reach the best decisions, the agency encourages staff to bring their views forward throughout the process. This active engagement is essential.

NRC expects all employees to promptly discuss their views and concerns with their immediate supervisor on a regular basis. Employees are expected to raise concerns and propose solutions as early as possible in the decision-making process. In addition to informal discussions, which should be sufficient to resolve most issues, individuals have various options for expressing and having their differing views heard by decision makers.

In the vast majority of cases, an informal conversation is sufficient. But if not there are a number of avenues for elevating concerns. We have an Open Door policy that allows the staff to request a meeting with any manager at the NRC—including the Chairman and Commissioners—to raise concerns. This policy encourages employees to resolve their concerns informally. There is also the non-concurrence process, which allows the airing of issues through the concurrence chain before a decision is made. An employee who disagrees with an established position can use the DPO process.

The NRC is unique in not only having and promoting these programs, but in assessing them and reporting the results to the public. This transparency helps ensure that differing views do not get lost in the shuffle.

To gauge how well these processes are working, we used a variety of tools to measure user satisfaction and process effectiveness. As with our assessment of the non-concurrence process, the DPO assessment shows the process is sound. NRC staff knows about it and most would be willing to use it. Also like the earlier assessment, the DPO assessment has helped us to identify areas for improvement.

There have been 28 DPOs filed since 2004, or an average of two to three cases per year. In that same time frame, one DPO was withdrawn and 24 DPO decisions were issued. Given that so few NRC employees have direct experience with the process, we were encouraged to see from our agency-wide safety culture survey that only 15 percent of NRC employees would be unwilling to use it. While this number is small, it shows we have some work to do. We want all NRC employees to feel they can use the process, and that it will be effective and lead to better, more informed decision-making. We are also concerned about the 18 percent who worry using the process could impact career development and the 46 percent who are unsure.

These numbers present an opportunity to do more outreach and education to ensure NRC leadership is committed to the DPO process. We will also need to; develop clearer guidance and better tools and support the process; ensure training is readily available to all employees (including a focus on improved communications); and identify ways to address concerns about real and perceived  negative consequences for using the process.

publicopinionAs we work to make these improvements, we can also celebrate the things that make our DPO process strong. From looking at other agencies with similar processes, our assessment shows the NRC is unique in making summaries of our DPO decisions public and, if asked by those who file DPOs, releasing key DPO records.

We are also pleased by the feedback from DPO submitters. We surveyed the 12 who remain at the NRC and received nine responses. All nine reported their views were heard by management. Eight said the DPO panel was sufficiently knowledgeable, independent, impartial, timely, and thorough. The same number said they were understood and treated fairly. Seven said the process added value to the final decision, their views were fully considered, and their management was supportive. Six said they were recognized with a Special Act award or an NRC Team Player award.

As we move forward, we will build on these strengths and take additional steps to foster an organizational culture where employees take personal responsibility for their actions, feel part of a community and work toward shared goals. We value the feedback from these self-assessments and commit to responding constructively so we can continuously improve our performance.