Recovering from column 3 or column 4 of the NRC performance matrix can be an expensive proposition for the owner of a nuclear power plant. Recovering from the conditions or events that led to a 95002 can be in the $10-20 million range. Recovering from a 95003 is an order of magnitude higher - $100-200 million. In the past, Conger & Elsea, Inc. provided support to the NRC Supplemental Inspection teams. CEI provided root cause analysis, corrective action program and management effectiveness expertise to the NRC 95003 inspection teams at Cooper, Point Beach and Perry. In addition, CEI has assisted plants and corporations in recovering after NRC supplemental inspections. CEI performed an independent audit of the corrective action program at Point Beach with recommendations for continuing to improve the corrective action program. FirstEnergy Nuclear Operating Company requested CEI’s assistance in upgrading the fleet wide CAP, including program revisions and training at all fleet locations. Now, CEI has begun providing an integrated assistance process for nuclear plants recovering from conditions and events that produced an NRC 95002 or 95003 Supplemental Inspection. The process merges CEI expertise into an integrated approach.

Root Cause Analysis and Corrective Action Program – Conger& Elsea, Inc. has long been associated with state-of-the-art root cause analysis processes and corrective action programs. CEI has provided root cause analysis and incident investigation training to NRC inspectors since 1986. With the advent of the reactor oversight process (ROP), CEI expanded the training to include evaluating corrective action programs. In June 2006, NRC introduced the 13 Components of safety culture as a part of the ROP. The CEI training was expanded to include evaluating the safety culture components. CEI has an intimate familiarity with the NRC expectations. The recovery process begins with assisting the station in upgrading the quality of the root cause analysis and the related reports for the events or conditions that moved the plant into the third or fourth column of the NRC matrix. The plant’s root cause staff receives the same training as NRC inspectors. The plant’s management staff receives training to familiarize them with the new process being used at the plant and mentoring in the application of the new processes. The station management team is trained on the modified root cause process and the NRC Supplemental Inspection process. Simultaneously, the CEI staff evaluates the plant’s corrective action program and develops recommendations for the station to bring the CAP process into line with current expectations. Typically, the CEI staff assists the plant in performing a common cause analysis of historical condition reports to identify any other areas of concern. Once the enhanced cause evaluations are completed and corrective actions approved, the station embarks on a planned process for implementing the corrective actions prior to the start of the NRC inspection.

Mock NRC Inspection – As a measure of the plant’s readiness for the NRC inspection, a mock 95002 inspection is conducted using the NRC’s 95002 Inspection Procedure. CEI consultants include former NRC inspectors, branch chiefs and directors, as well as individuals with significant INPO and utility experience. CEI’s staff led and participated in the mock inspections at Kewaunee, Fort Calhoun, Farley and Browns Ferry. The mock inspection is typically three weeks long with 6-8 experienced inspectors and a team leader. The team is onsite for the first two weeks, and the final week is spent offsite preparing the inspection report. During the inspection, a daily meeting is held with site management to provide immediate feedback and status. At the conclusion of the onsite inspection, the team makes an exit presentation that includes a full discussion of the key findings, station vulnerabilities, and recommended actions for the station to take before the NRC inspection. Following the mock inspection, two of the key elements necessary to assure the readiness of the station for the NRC inspection are preparing an integrated response plan for all the corrective actions and developing a comprehensive communication plan to ensure that everyone on site has the right message.

Follow-up Support – After the mock inspection, CEI provides follow-up support in the form of providing independent reviews of the plant’s implementation efforts, training in the improved plant root cause and CAP processes, and access to the regulatory perspective from experts.

For information about these services, please contact –
Dorian Conger, General Manager,
Conger & Elsea, Inc.,
9870 Highway 92, Suite 300,
Woodstock, GA 30188;
or at dorian.conger@conger-elsea.com; or call toll free 1-800-875-8709.