EXCEL is synonymous with innovative regulatory approaches. Our technical support of the Pressurized Water Reactor Owners Group (PWROG), the Boiling Water Reactors Owners’ Group (BWROG), and the AP1000® Owners Group (APOG), and our management of the Technical Specifications Task Force, keeps EXCEL on the forefront of regulatory opportunities and issues. Our industry involvement gives EXCEL a unique, industry-wide viewpoint that is invaluable to our utility clients. When operating plants are faced with difficult regulatory questions, they turn to EXCEL.
EXCEL’s associates have decades of experience and are recognized as the experts in their field. Utilities call on EXCEL to create or manage complex regulatory products, take advantage of risk-informed opportunities, solve difficult regulatory problems, and train their regulatory staffs. EXCEL has signification experience in all phases of project management lifecycle, including scoping studies, researching and designing, licensing, procedure development, implementation, and trending. EXCEL has been on the ground floor with most NRC and industry initiatives, and is ready to support clients with innovative solutions and strategic assistance to implement all future technology, licensing, and process changes, helping our clients achieve their business goals.
EXCEL is the only firm hired by the Pressurized Water Reactor Owners Group (PWROG) Licensing Subcommittee, the Boiling Water Reactor Owners Group (BWROG) Committee Licensing Committee, and the AP1000 Owners Group (APOG) to provide technical and project management support. EXCEL administers and provides technical support to the Technical Specifications Task Force and also supports the NEI Licensing Action Task Force and NEI Risk Informed Technical Specifications Task Force, as well as other NEI technical committees.
EXCEL has provided regulatory and technical support to the PWROG, BWROG, APOG, and their predecessor organizations, for over 20 years. Through the Owners Groups, EXCEL provides “any time, on request” regulatory and technical support to every commercial reactor in the United States and abroad. EXCEL also manages the joint Owners Group Technical Specifications Task Force (TSTF), that is the focal point for industry interaction with the Nuclear Regulatory Commission on generic technical, regulatory, and compliance issues related to the Technical Specifications.
EXCEL has been involved with most NRC and industry initiatives, and is ready to support clients with innovative solutions and strategic assistance to implement all future technology, licensing, and regulatory process changes. Whether it’s transforming the physical and cyber security requirements and guidance for operating plants, emergency preparedness requirements for small modular and advanced reactors, risk-informing the 10 CFR 50.59 change process, or streamlining the digital instrumentation and control change process, EXCEL is standing by to support our clients. EXCEL believes the adoption of a holistic strategy is imperative if the nuclear industry wants to achieve significant reductions in operation and maintenance costs, and works with our clients to understand what the most informed investment is for their organization; which technologies are most transformative and where they should plan on spending in future.
EXCEL participates in NEI’s Accident Tolerant Fuel (ATF) Working Group and in the ATF Licensing Task Force. The large-scale deployment of ATF, along with higher enrichment and burnup limits could result in significant improvements in Light Water Reactor (LWR) fuel performance. These performance improvements could make much longer fuel cycles (30+ months) viable for both PWRs and BWRs in the U.S. In addition, the significant impacts on the units’ Safety Analyses would mean a significant increase in the number licensing and Technical Specifications that would need to be made. EXCEL is the recognized as the premier supplier of licensing, regulatory compliance, and Technical Specifications (TS) services, and has extensive experience in successful negotiation regarding licensing and TS issues.
ATF presents new and unique technical issues that may not be readily addressed with the current guidance, review plans, and regulatory criteria for zirconium/UO2based nuclear fuel. EXCEL is ready to support clients with innovative solutions and strategic assistance to implement the technology, licensing, and process changes needed, helping our clients achieve their business goals.
Advanced reactor developers and Combined Operating License applicants have the opportunity to engineer-in an improved and potentially less costly security physical solution to reactors and sites that are still in the design and development stages. Some refer to this as security-by-design, where protections against theft and sabotage are incorporated into the architecture and engineering of the reactor. Advanced reactors give developers and security experts an opportunity to think holistically about how to integrate the most stringent and forward-thinking security features much earlier in the process, and EXCEL has the experience and skill-sets to support this goal.
EXCEL can also provide licensing and regulatory assistance to clients, to support interactions with the regulator and developing and/or reviewing licensing packages. A critical component of EXCEL’s participation in these activities, in addition to many years of experience in the technical aspects of security, is the regulatory background of all team members.
EXCEL is reactor technology neutral and is very knowledgeable of all global large, small, and advanced reactor technology designs. This gives EXCEL an industry-wide viewpoint that is invaluable to our utility clients. EXCEL routinely provides this service utilizing former NRC and industry senior managers to advise and provide assistance to senior client management in coming up with solutions to complex engineering and technical issues. EXCEL has a broad bench of talent with extensive experience in many areas, which allows clients to select experts with varied skill sets to address the precise problem that exists.
The adoption of a holistic strategy is imperative if the nuclear industry wants to achieve significant reductions in efficiency, reliability, and operation and maintenance costs. However, for plant modernization, utilities are faced with challenges when demonstrating return on investment. For utilities to proceed, the return on investment needs to include: reduced plant staffing, higher equipment reliability, increased maintenance efficiency and effectiveness, all while increasing plant safety. Utilities need to know what the most informed investment is for their organization; which technologies are most transformative and where they should plan on spending in future.
Current NRC rules generally prohibit use of decommissioning trust funds for expenses not directly related to decommissioning, which does not begin until a plant has ended operations. The fund can only be accessed for planning purposes until the facility owner provides the agency with its post-shutdown decommissioning activities report, which is allowed up to two years after closure. To implement a different approach, a licensee would need a regulatory exemption to use decommissioning trusts for pre-closure disposal of major radioactive components such as retired reactor steam generators. The NRC is currently considering a company’s request to revise federal regulations to allow nuclear power plant operators to use their decommissioning trust funds for removal of major components prior to shutdown.
With its strong licensing and regulatory experience, EXCEL can support clients in developing exemption request packages, allowing them to use decommissioning trust funds, in cases where excess funds can be shown to exist. By removing radioactively contaminated equipment from power plants early; it reduces potential radiation exposure, and possibly shrinks the cost of decommissioning.
EXCEL can further enhance and optimize regulatory and engineering approaches to decommissioning activities in all phases. EXCEL has served as the Project Manager / Contractor for the multiple actions of several full decommissioning projects. As such, EXCEL has developed creative approaches based on best practices.