In today’s ever-evolving nuclear industry, the term nuclear “compliance” is tossed around frequently. It is used in day-to-day business conversations routinely, often spoken in a serious, professional tone. But what exactly do we mean as stewards of nuclear safety, when we utter this poignant word?
Merriam-Webster defines the word as follows:
“A: the act or process of complying to a desire, demand, proposal, or regimen or to coercion
B: conformity in fulfilling official requirements”
In the nuclear industry, the second definition is applicable. Each nuclear operating company is always ensuring that as a standard mode of operation, they are seeking “conformity in fulfilling official requirements”. So, how is this done? How do nuclear operating companies demonstrate compliance? That is where the Nuclear Regulatory Commission (NRC) comes into play.
NRC and ROP
The NRC established a Reactor Oversight Process (ROP). This process was developed as a risk-informed, tiered approach to ensuring plant safety. There are three key strategic performance areas: reactor safety, radiation safety, and safeguards. Each strategic performance area contains cornerstones that reflect the essential safety aspects of nuclear facility operation. The cornerstones for each of the three strategic performance areas are as follows:
- Reactor Safety: Initiating Events, Mitigating Systems, Barrier Integrity and Emergency Preparedness.
- Radiation Safety: Public Radiation and Occupational Radiation.
- Safeguards: Security.
The objective of the three strategic performance areas and their cornerstones is to monitor nuclear power plant performance to ensure the safety of the public. Simply put, the cornerstones function to avoid accidents and reduce the consequences of accidents if they occur, to ensure radiation safety for both plant workers and the public during routine operations and to protect the plant against sabotage or other security threats.
At the base of these three cornerstones are three cross-cutting areas. They are Human Performance, Problem Identification and Resolution and Safety-Conscious Work Environment. These cross-cutting areas can affect and are indeed a part of each of the cornerstones.
As a part of the ROP, the NRC measures nuclear plant performance by monitoring objective performance indicators and by conducting the NRC inspection program. Monitoring and inspection closely focus on those plant activities having the greatest impact on safety and overall risk. In addition, the NRC conducts both periodic and annual reviews of the effectiveness of each utility’s programs to identify and correct problems.
Performance indicators use objective data to monitor performance within each of the “cornerstone” areas. The utilities generate the data that make up the performance indicators and submit these data to the NRC quarterly. Each performance indicator is measured against established thresholds which are related to their effect on safety.
While performance indicators can provide insights into plant performance in selected areas, the NRC’s inspection program provides a greater depth and breadth of information for monitoring and assessing plant performance. The NRC uses over 400 inspection procedures to assess the plant’s performance with respect to the cornerstones. The inspection program is designed to verify the accuracy of performance indicator information and to assess performance that is not directly measured by the performance indicator data.
Based on performance indicators and inspection results, the NRC places each plant into one of five columns in the NRC’s Action Matrix. The five columns are:
- Licensee Response (Baseline Inspection)
- Regulatory Response (Response at Regional Level)
- Degraded Performance (Response at Regional Level)
- Multiple/Repetitive Degraded Cornerstone Column (Response at Agency Level)
- Unacceptable Performance (Response at Agency Level)
The goal of every nuclear power plant is of course to be in the Licensee Response column of the Action Matrix.
This ROP is what the NRC uses to ensure “compliance” with applicable rules and regulations, all in the pursuit of maintaining nuclear safety. So, where does Accelerant Solutions fit into a customer’s “compliance” efforts?
Accelerant Solutions provides its clients with compliance specialists in all areas of nuclear power plant operations. The overarching goal is to provide each client with programs, processes and procedures to ensure “Effective implementation and sustainment of compliance guidelines.” By assisting clients in maintaining compliance, Accelerant Solutions provides value to the client organization and helps them to achieve the highest standards of nuclear safety.