NRC NEWS

 U.S. NUCLEAR REGULATORY COMMISSION 

 Office of Public Affairs Telephone: 301/415-8200

 Washington, DC 20555-0001 E-mail: opa@nrc.gov 

 Web Site: www.nrc.gov

S-02-021

Constructive Engagement Between the Nuclear Industry 

and the NRC

Remarks by Dr. Richard A. Meserve

Chairman, U.S. Nuclear Regulatory Commission

Seventh NRC/ASME Symposium on Valve and Pump Testing

July 16, 2002

Washington, DC

Good morning. I am very pleased to add my welcome to all of you, particularly those who have

traveled here from overseas. I hope that you are able to enjoy some of the many attractions of the

Nation’s capitol during your stay here.

My theme this morning relates to the benefits of constructive engagement between the industry

and the NRC, and how such engagement benefits everyone. Let me begin by reflecting upon how such

engagement, as exemplified by this symposium, correlates with the overall progress made by the

nuclear power industry in the past decade. I will then turn to the changes at the NRC. I will also have

some observations regarding the value of consensus codes and standards to the NRC’s regulatory

mission.

1. The Improvement of Performance

The testing of pumps and valves might seem like a very specialized topic, of interest to a

relatively small number of people. But I see that more than 50 papers on this subject are being

presented at this meeting – the seventh of its kind. That fact, along with the size of this audience,

provides a clear indication that the performance of these components continues to be a matter of

significant interest to those in the nuclear power community, including utilities, vendors, testing firms,

and regulators. And I have to add that I am quite pleased, as one of those regulators, to see this breadth

of interest. It indicates to me that the industry understands the importance of attention to these sorts of

issues as it strives to improve its collective performance. Let me provide some historical perspective to

help illustrate my point.
In 1990, around the time of the first meeting of this symposium, the U.S. nuclear industry’s

overall performance was mediocre. The average plant’s capacity factor was under 70 percent, and the

average number of unplanned reactor scrams per year was nearly two per unit. At the same time – and

not surprisingly – the safety performance of the industry was lackluster. One might expect, for

example, that a high number of scrams would lead to increased challenges on safety systems, and that

trend was illustrated by an average of about one safety system actuation per plant in 1990, along with

almost 4 safety system failures. On average, nearly half of all U.S. plants experienced one “significant

event” during that year. It is therefore not surprising that, with the beginning of economic deregulation

of the electric utility industry in the mid-1990s, most “pundits” were predicting that economic pressures

would result in the early closure of a substantial percentage of the U.S. operating fleet. The NRC was

advised to start planning for a large number of applications for decommissioning.

A funny thing happened on the way to the shutdown of the nuclear industry. In the mid-1990s,

the industry’s performance started to improve significantly, a trend that has continued as we have

moved into the 21st century. Average capacity factors have risen to around 90 percent, and the average

number of scrams per plant has fallen by a factor of around 4. Safety performance has followed suit,

with rates of safety system challenges and failures less than one-half of their 1990 values. Most

impressive is the reduction in the number of significant events, which is now less than one-tenth of

what it was in 1990. All of these factors have combined to make the production cost of nucleargenerated electricity less than that of coal or natural gas plants. Thus, rather than decommissioning

their operating plants, many electric generating companies have sought – or have told us that they will

be seeking – to renew the licenses of their facilities. Over the last several years, there has even been

increasing interest in the possibility of building new nuclear plants. One might ask, what happened? 

What could cause such a complete reversal of fortune? I believe that this symposium, and others like it,

provide at least part of the answer.

Pumps and valves are common elements of industrial hardware. Certainly, they are basic

components in virtually any sort of machine that involves flowing fluids. Nuclear power plants are no

exception; the typical plant has dozens of pumps of various shapes, sizes, and designs, and hundreds of

valves. But some of these components must operate in extremely challenging environments –

temperatures, pressures, chemical conditions, and radiation fields – that could cause their performance

to degrade. If such degradation affects a pump or valve that is important to safety, and progresses to the

point that the component fails, the degradation can have serious impacts on overall plant operation and

safety. Superior plant performance thus dictates that attention must be paid to the performance of these

components, so that degradation can be avoided, or if it occurs, so that it can be diagnosed and

remediated before failure occurs. 

A key contributor to this process of improving plant performance is the careful attention to

operating experience. That is, the systematic evaluation of experience is a time-tested element of

performance enhancement. But it is also essential that these experiences be shared as widely as

possible, so that the entire industry may benefit from the lessons learned by each of its members. This

symposium stands as an outstanding example of what can be accomplished when operating experience

and related information is exchanged and discussed. It also represents cooperation between the industry

and its regulator, under the auspices of an independent professional society. The exchanges fostered by

this symposium and others like it have played a significant role in the vast improvement in both

operational and safety performance that the nuclear power industry has accomplished in the last 10

years.
Of course, now that the industry has achieved the high level of performance that it currently

enjoys, the challenge is to maintain that performance and – if possible – continue to improve it. Since

we are approaching a performance asymptote, any improvements will clearly not be as dramatic as in

the past. But the role of information exchange and experience sharing is no less important now than it

has been in the past. There are two reasons for this. First, as the industry becomes increasingly

sophisticated, new procedures for accomplishing necessary inspections, testing, and maintenance of

plant components will undoubtedly be developed that increase the effectiveness and efficiency of such

operations, and – most important for the NRC – further improve plant safety performance. I am

thinking here, for example, of advancements in modeling component performance and thereby

anticipating problems, permitting action to be taken before those problems actually arise. 

Communicating these improvements will allow implementation across the industry. 

The second reason is less visionary and more pragmatic: no matter how much we know and how

much we learn, there is still the possibility – in fact, the likelihood – that something we had not

anticipated will arise. A recent example of such an occurrence, not directly related to the subject of this

symposium but instructive all the same, is the corrosion of the reactor head at Davis Besse. When these

types of unanticipated events arise, the sharing of pertinent information is indispensable in helping to

determine what happened, whether other plants may be similarly vulnerable, and how to prevent such

problems from arising in the future.

2. Change at the NRC

It is also imperative that the NRC participate in the sharing of information with the industry

because in this way we can improve our accomplishment of our regulatory mission. It is not enough to

react to problems once they become evident. We need to develop processes that will allow our

inspection and oversight programs to help identify potential problems before they occur. Although we

perform research to help us do our jobs better, there is no way that our studies can duplicate the learning

that can arise from careful examination of the hundreds of reactor-years of experience that the industry

accumulates each year. It is thus essential that we learn along with you, to allow us to improve our

performance as the industry does.

The industry’s operational experience is also of substantial value as we implement an important

and potentially far-reaching modification of our regulatory process: risk-informed regulation. As most

of you are aware, the NRC has undertaken an initiative to use the experience gained by the agency and

the industry, along with knowledge gained from quantitative risk assessment, to restructure our

regulations to provide a better focus on aspects of nuclear plant design and operation that are most

important to risk. We are guided in this effort by the belief that overall plant safety is improved when

both our licensees’ resources and the NRC’s regulatory attention are directed primarily toward issues

that are safety-significant. 

This effort will result in fundamental changes in the NRC’s regulatory approach. Some

requirements will be relaxed, but it is clear that there will also be areas in which risk insights show that

our regulatory requirements need to be strengthened. I should note that since our past deterministic

practices have tended to be very conservative, the opportunities for reducing unnecessary regulatory

burden are likely to outnumber those areas in which requirements must be enhanced. Nonetheless, I

must emphasize that the goal of this effort is not to deregulate the industry, but rather to provide a sound

technical basis for regulatory oversight. We will continue to insist on adequate safety margins,

consistent with the NRC’s traditional defense-in-depth philosophy.
Some of our current regulations involve risk as one of their elements. For example, the

maintenance rule requires licensees to assess and manage any increase in risk that might result from

maintenance operations. Our recently revised reactor oversight process also has a major focus on risk,

both in allocating inspection resources and in analyzing the results of inspections and performance

indicator data. And we have undertaken a risk-informed approach in the assessment of changes to

technical specifications and inservice inspection and testing requirements. 

One of our most significant initiatives is still unfolding: risk-informing the so-called “special

treatment” requirements imposed on nuclear plant systems, structures and components, or SSCs. By

special treatment, I mean regulatory requirements in such areas as technical specifications, quality

assurance, and environmental qualification requirements or SSCs. I cannot discuss this effort in detail,

since there are technical and policy issues that must be resolved; the Commission is looking forward to

receiving the NRC staff’s recommendations on the final form of the new rule within the next couple of

months. However, I can say that the outcome of the effort is expected to be a fundamental change in the

criteria used to determine when special treatment requirements should be imposed. Rather than relying

solely on our traditional classifications of “safety-related” and “non-safety-related,” special treatment

will be keyed primarily to the risk significance of a given system, structure, or component. Consistent

with my earlier comment, we have found many SSCs classified as safety-related that are of low risk

significance. But we have also found a few non-safety-related SSCs that are highly risk significant, so

the sword really does cut both ways.

Our accomplishments to date in our efforts to risk-inform our regulations represent only a few

baby steps, but we are committed to pursue these initiatives over the long term. Your engagement,

along with that of our other stakeholders, is essential as we move forward.

3. Constructive Engagement through Consensus Codes

I would like to address one other area today that is related to my theme of constructive

engagement and the exchange of information: the development of consensus codes and standards.

In preparing to address this symposium, I had the opportunity to reflect on the extent to which

codes and standards contribute to the NRC’s regulatory process. It is not an exaggeration to say that

consensus codes and standards form the foundation for a large part of the NRC’s reactor regulations. 

ASME’s Boiler and Pressure Vessel Code and the Code for Operation and Maintenance of Nuclear

Power Plants are incorporated into the NRC’s regulations in 10 CFR 50.55a and underpin many of the

issues that will be discussed at this symposium. Other examples include a wide variety of standards

developed under the aegis of other professional societies, such as the IEEE standards on instrumentation

and control systems, also cited in Section 50.55a, and the ANS decay heat standard used for accident

analysis codes that conform to the requirements of 10 CFR Part 50, Appendix K. 

These codes and standards are essential to the NRC not only in a technical sense, but also

because they enhance public confidence in our agency’s regulatory processes. They are developed by

broadly based groups of experts representing all of the sectors of the relevant technical disciplines,

coordinated by an independent professional organization, and are subjected to rigorous peer review to

ensure that the scope and technical content are appropriate and reflective of good engineering practice. 

The process provides confidence that our regulatory system is built on sound technical judgment. I am

pleased to note that many members of the NRC staff are also members of various standards committees. 

I strongly support such involvement, and consider it to be an important element of their professional

activities.
I should also note that the development of new standards is playing a significant role as we

move forward in risk-informing our regulations. We are currently engaged in a number of major

standards-development efforts that will ultimately contribute directly to a risk-informed approach to

regulation, including: a new fire protection standard, coordinated by the National Fire Protection

Association; an ASME standard for probabilistic risk assessment under full power conditions, which is

now nearing completion; and a complementary standard on PRAs for low-power and shutdown

conditions and seismic risk evaluation, which is being managed by the American Nuclear Society.

Almost by definition, the development of consensus standards is a long and often difficult

process. Reaching a consensus among the various viewpoints requires considerable effort and

creativity, not to mention a healthy dose of patience. But as I hope I have made clear this morning, the

process of constructive engagement is beneficial in and of itself. The final product is all the more

useful because it has been subjected to this approach.

Let me close by conveying my thanks to all of you for participating in this symposium and my

best wishes to you for a successful and productive meeting.

Thank you.