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RIC 2020 NEI Montgomery
	ML20105A165
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/14/2020
From:	Montgomery B; Nuclear Energy Institute
To:	; NRC/RGN-II
	Terry T
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ML20105A160	List: ML20105A161; ML20105A163; ML20105A164; ML20105A165;
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ISFSI Oversight: A Case Study in Transformative Leadership Bruce Montgomery March 10, 2020

The Point of this Case Study:

Change is difficult.

You wont know if your change is transformative until you reach your desired endpoint and you look back to examine how you got there.

It could be that the path you took, the methods you employed, and the leadership you exercised may indeed be transformative If you believe it was transformative, capture it, celebrate it, train on it, and do it even better next time.

We have a lot of eyes on commercial nuclear operations

Layers of Safety Oversight Internal Layers

Employee, Programs, Processes, Procedures

Management Review

Nuclear Oversight/Quality Assurance

Fleet/Corporate Oversight Assessment External Layers

Nuclear Safety Review Board

American Nuclear Insurers (ANI)

Nuclear Electric Insurance Limited (NEIL)

Institute of Nuclear Power Operations (INPO)

World Association of Nuclear Operators (WANO)

NRC Layers

Resident Inspectors (2 to 3 per site)

Performance Indicators

Inspection Teams

Is There a Premise for Change?

Is there a mis-match between the resources applied to oversight and the safety benefit realized?

Is There a Basis for Change?

Do substantial margins of safety exist in the program?

Has the understanding of the safety significance of the program evolved over time?

Safety margins

Technology

Experience

Safety Margins in Dry Fuel Storage Dry storage technology is robust with significant designed-in safety margins:

Mechanical integrity Source terms Thermal parameters Radiological parameters Fuel qualification Criticality

Technology Enhances Oversight Remote inspection of casks and ISFSI pads using drones:

Heavy haul path

Cooling vents/screens

DSC lids/bolts

Temperature

ISFSI pad condition

Electrical grounding

Housekeeping

Technology Addresses Gaps in Knowledge Remote inspection of canisters using robots provides data not previously available.

Remote inspection reduces uncertainty in material condition while reducing occupational exposure and costs.

Technological advances establish a sound basis for adjustments to oversight.

Dry Storage Experience Used fuel inventory*

Approximately 83,978 MTU Increases 2 - 2.4k MTU annually ISFSI** storage 140,492 assemblies 39,860 MTU (46%)

3,196 casks/modules loaded 73 Operating ISFSIs 72 dry storage, 1 pool Eventually to be deployed at 76 sites Fuel from 119 reactors Long term commitment to ISFSIs Licenses being extended to 60 years Licenses extensions approved at 32 sites Technology is mature *As of December, 2019

- ISFSI = Independent Spent Fuel Storage Installation

NowBack to the Case Study NRC Management Recognizes an Opportunity for Transformative Change NRC Agency-wide Transformation Team formed (early 2018)

NEI letter September 19, 2018, ROP recommendations

Recommendation 1H: Eliminate Materials Inspections of the ISFSI NMSS decides to focus on ISFSI in 2019

Considerations for Change (NEI view)

An ISFSI has no moving parts.

Conditions change very slowly with time, if at all, and have very small safety impacts.

The majority of the things that could negatively affect safety originate during DSC loading, sealing and transfer to the ISFSI.

==

Conclusion:==

Maybe best to focus on the DSC loading and ISFSI transfer activities?

But Change is Not Easy!!!

Setting the parameters for change is hard Defining the change is complicated Organizational inertia resists change Public stakeholders need to be informed of any change Change occasionally generates external controversy Result: It is easier to not change.

NRC Approaches Change in A New Way Unique ISFSI Project Enhancement Team Charter:

Led by Regional staff Broad latitude for developing a clearer risk-informed, comprehensive and consistent approach to ISFSI inspections across the four regions.

Included a communications plan Appropriately involved external stakeholders Established a schedule for deliverables

The Team Delivers on all Charter Elements Demonstrates the transformational value of:

A bottom up approach to leadership; Using a team of personnel close to the issue; Creating an environment encouraging innovation; Listening to and promoting diverse opinions, and Communicating internally and externally.

In the end, this approach facilitated agency decision-making.

NEI believes the approach taken by NMSSs ISFSI team can serve as a model for future transformational change.

ML20105A165

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