Inspection Procedures & Performance Indicators by ROP Cornerstone

ROP Regulatory Framework

The regulatory framework for reactor oversight is shown in the diagram below. It is a risk-informed, tiered approach to ensuring plant safety. There are three key strategic performance areas: reactor safety, radiation safety, and safeguards. Within each strategic performance area are cornerstones that reflect the essential safety aspects of facility operation. Satisfactory licensee performance in the cornerstones provides reasonable assurance of safe facility operation and that the NRC’s safety mission is being accomplished.

Within this framework, the NRC’s operating reactor oversight process provides a means to collect information about licensee performance, assess the information for its safety significance, and provide for appropriate licensee and NRC response. The NRC evaluates plant performance by analyzing two distinct inputs: inspection findings resulting from NRC's inspection program and performance indicators (PIs) reported by the licensees.

Additional background information can be found on the Detailed ROP Description page. The Office of Public Affairs has published a plain language description of the ROP in NUREG-1649. The ROP-related program and policy documents are also conveniently summarized by subject area on the ROP Program Documents page.

Initiating Events - The objective of this cornerstone is to limit the frequency of those events that upset plant stability and challenge critical safety functions, during shutdown as well as power operations. If not properly mitigated, and if multiple barriers are breached, a reactor accident could result which might compromise public health and safety. Licensees can reduce the likelihood of a reactor accident by maintaining a low frequency of these initiating events. Such events include reactor trips (scrams) due to turbine trips, loss of feedwater, loss of off-site power, and other reactor transients.

Inspection Procedures - There are twenty-three attachments to the inspection procedure for the reactor safety strategic performance area, which includes the initiating events cornerstone, mitigating systems cornerstone, and the barrier integrity cornerstone:

IP	71111	Reactor Safety-Initiating Events, Mitigating Systems, Barrier Integrity
IP	71111.01	Adverse Weather Protection
IP	71111.04	Equipment Alignment
IP	71111.05AQ	Fire Protection Annual / Quarterly
IP	71111.05T	Fire Protection [Triennial]
IP	71111.05TTP	Fire Protection-NFPA 805 Transition Period (Triennial)
IP	71111.06	Flood Protection Measures
IP	71111.07	Heat Sink Performance
IP	71111.08	Inservice Inspection Activities
IP	71111.11	Licensed Operator Requalification Program
IP	71111.12	Maintenance Effectiveness
IP	71111.13	Maintenance Risk Assessments and Emergent Work Control
IP	71111.15	Operability Evaluations
IP	71111.17	Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications
IP	71111.18	Plant Modifications
IP	71111.19	Post Maintenance Testing
IP	71111.20	Refueling and Other Outage Activities
IP	71111.21	Component Design Bases Inspection
IP	71111.22	Surveillance Testing

Performance Indicators - There are three performance indicators in the initiating events cornerstone:

• Unplanned Scrams - The number of unplanned scrams during the previous four quarters, both manual and automatic, while critical per 7,000 hours. The scram rate is calculated per 7,000 critical hours because that value is representative of the critical hours of operation in a year for a typical plant.
• Unplanned Power Changes - The number of unplanned changes in reactor power of greater than 20% full-power, per 7,000 hours of critical operation excluding manual and automatic scrams.
• Unplanned Scrams with Complications - The number of unplanned scrams while critical, both manual and automatic, during the previous 4 quarters require additional operator actions as defined by the flowchart in NEI 99-02 Rev 6

 

Initiating Events Indicator	Thresholds
	(White) Increased Regulatory Response Band	(Yellow) Required Regulatory Response Band	(Red) Unacceptable Performance Band
Unplanned Scrams	> 3.0	> 6.0	> 25.0
Unplanned Power Changes	> 6.0	N/A	N/A
Unplanned Scrams with Complications	> 1.0	N/A	N/A

The NRC and Industry are working jointly to develop a replacement performance indicator for SCRAMS with Loss of Normal Heat Removal. The new draft indicator is called Unplanned Scrams with Complications.

Mitigating Systems - The objective of this cornerstone is to monitor the availability, reliability, and capability of systems that mitigate the effects of initiating events to prevent core damage. Licensees reduce the likelihood of reactor accidents by maintaining the availability and reliability of mitigating systems. Mitigating systems include those systems associated with safety injection, decay heat removal, and their support systems, such as emergency AC power. This cornerstone includes mitigating systems that respond to both operating and shutdown events. There are five indicators in this cornerstone:

Inspection Procedures - As listed above, there are twenty-three attachments to the inspection procedure for the reactor safety strategic performance area, which includes the initiating events cornerstone, mitigating systems cornerstone, and the barrier integrity cornerstone.

Performance Indicators - There are currently five performance indicators in the mitigating systems cornerstone:

• Safety System Functional Failures - The number of events or conditions that alone prevented, or could have prevented, the fulfillment of the safety function of structures or systems in the previous four quarters.
• Emergency AC Power Systems - The sum of the unavailability of the emergency AC power plus the unreliability for the emergency AC power system during the previous twelve quarters.
• High Pressure Injection Systems - The sum of the unavailability of the high pressure injection system plus the unreliability for the high pressure injection system for the during the previous twelve quarters.
• Heat Removal Systems - The sum of the unavailability of the heat removal system plus the unreliability for the heat removal system during the previous twelve quarters.
• Residual Heat Removal Systems - The sum of the unavailability of the residual heat removal system plus the unreliability for the residual heat removal system during the previous twelve quarters.
• Cooling Water Systems - The sum of the unavailability of cooling water systems plus the unreliability for the cooling water systems during the previous twelve quarters.




Mitigating System Indicator			Thresholds
			(White) Increased Regulatory Response Band	(Yellow) Required Regulatory Response Band	(Red) Unacceptable Performance Band
Safety System Functional Failures		BWR	> 6.0	N/A	N/A
		PWR	> 5.0	N/A	N/A
Mitigating System Performance Index, Emergency AC Power Systems			> 1.0E-06 OR PLE = YES	> 1.0E-05	> 1.0E-04
Mitigating System Performance Index, High Pressure Injection Systems			> 1.0E-06 OR PLE = YES	> 1.0E-05	> 1.0E-04
Mitigating System Performance Index, Heat Removal Systems			> 1.0E-06 OR PLE = YES	> 1.0E-05	> 1.0E-04
Mitigating System Performance Index, Residual Heat Removal Systems			> 1.0E-06 OR PLE = YES	> 1.0E-05	> 1.0E-04
Mitigating System Performance Index, Cooling Water Systems			> 1.0E-06 OR PLE = YES	> 1.0E-05	> 1.0E-04

Note 1: Thresholds that are specific to a site or unit will be provided in Appendix D, of NEI 99-02 Rev 6 , when identified.

Note 2: PLE System Component Performance Limit Exceeded (see Appendix F, Section F4, page F-44)

The NRC and the nuclear industry have jointly implemented a replacement to the Safety System Unavailability Performance Indicators, called the Mitigating System Performance Index (MSPI). Data collection for the MSPI began in April 2006 with the first licensee submittal occurring in July 2006 (to include data up through 2Q2006).

Barrier Integrity - The objective of this cornerstone is to provide reasonable assurance that the physical design barriers protect the public from radionuclide releases caused by accidents. Licensees can reduce the effects of reactor accidents if they do occur by maintaining the integrity of the barriers. The barriers are the fuel cladding, reactor coolant system boundary, and the containment.

Inspection Procedures - As listed above under the initiating events cornerstone, there are twenty-three attachments to the inspection procedure for the reactor safety strategic performance area, which includes the initiating events cornerstone, mitigating systems cornerstone, and the barrier integrity cornerstone.

Performance Indicators - There are two performance indicators in the barrier integrity cornerstone:

• Reactor Coolant System (RCS) Activity - The maximum monthly RCS activity in micro-Curies per gram (µCi/gm) dose equivalent Iodine-131 per the technical specifications, expressed as a percentage of the technical specification limit.
• Reactor Coolant System (RCS) Leakage - The maximum RCS Identified Leakage in gallons per minute each month as defined in Technical Specifications, expressed as a percentage of the technical specification limit.

 

Barrier Integrity Indicator	Thresholds
	(White) Increased Regulatory Response Band	(Yellow) Required Regulatory Response Band	(Red) Unacceptable Performance Band
RCS Activity	> 50.0 %	> 100.0 %	N/A
RCS Leakage	> 50.0 %	> 100.0 %	N/A

Emergency Preparedness - The objective of this cornerstone is to ensure that licensees are capable of implementing adequate measures to protect public health and safety during a radiological emergency. Licensees provide reasonable assurance that their emergency preparedness program is effective through drills and exercises, participation in actual events, and testing of the Alert and Notification System (ANS). This cornerstone does not include the off-site actions, which are covered by FEMA.

Inspection Procedures - There are seven attachments to the inspection procedure for the emergency preparedness cornerstone:

IP	71114	Reactor Safety Emergency Preparedness
IP	71114.01	Exercise Evaluation
IP	71114.02	Alert and Notification System Testing
IP	71114.03	Emergency Preparedness Organization Staffing and Augmentation System
IP	71114.04	Emergency Action Level and Emergency Plan Changes
IP	71114.05	Correction of Emergency Preparedness Weaknesses and Deficiencies
IP	71114.06	Drill Evaluation
IP	71114.07	Emergency Preparedness Component, of the Force-On-Force (FOF) Exercise Evaluation

Performance Indicators - There are three performance indicators in the emergency preparedness cornerstone:

• Drill/Exercise Performance - The percentage of all drill, exercise, and actual opportunities that were performed timely and accurately during the previous eight quarters.
• Emergency Response Organization (ERO) Drill Participation - The percentage of key ERO members that have participated in a drill, exercise, or actual event during the previous eight quarters, as measured on the last calendar day of the quarter.
• Alert and Notification System Reliability - The percentage of ANS sirens that are capable of performing their function, as measured by periodic siren testing, in the previous 12 months. Periodic tests are the regularly scheduled tests that are conducted to actually test the ability of the sirens to perform their function (e.g., silent, growl, siren sound test).




Emergency Preparedness Indicator	Thresholds
	(White) Increased Regulatory Response Band	(Yellow) Required Regulatory Response Band	(Red) Unacceptable Performance Band
Drill/Exercise Performance	< 90.0 %	< 70.0 %	N/A
ERO Drill Participation	< 80.0 %	< 60.0 %	N/A
Alert and Notification System	< 94.0 %	< 90.0 %	N/A

Occupational Radiation Safety - The objective of this cornerstone is to ensure adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. This exposure could come from poorly controlled or uncontrolled radiation areas or radioactive material that unnecessarily exposes workers. Licensees can maintain occupational worker protection by meeting applicable regulatory limits and ALARA guidelines.

Inspection Procedures - There are five attachments to the inspection procedure for the occupational radiation safety cornerstone:

IP	71124	Radiation Safety—Public and Occupational
IP	71124.01	Radiological Hazard Assessment and Exposure Controls
IP	71124.02	Occupational ALARA Planning and Controls
IP	71124.03	In-Plant Airborne Radioactivity Control and Mitigation
IP	71124.04	Occupational Dose Assessment
IP	71124.05	Radiation Monitoring Instrumentation

Performance Indicators - There is one performance indicator in the occupational radiation safety cornerstone:

• Occupational Exposure Control Effectiveness - The performance indicator for this cornerstone is the sum of the following:
• Technical specification high radiation area occurrences
• Very high radiation area occurrences
• Unintended exposure occurrences



Occupational Radiation Safety Indicator	Thresholds
	(White) Increased Regulatory Response Band	(Yellow) Required Regulatory Response Band	(Red) Unacceptable Performance Band
Occupational Exposure Control Effectiveness	> 2	> 5	N/A

Public Radiation Safety - The objective of this cornerstone is to ensure adequate protection of public health and safety from exposure to radioactive material released into the public domain as a result of routine civilian nuclear reactor operations. These releases include routine gaseous and liquid radioactive effluent discharges, the inadvertent release of solid contaminated materials, and the offsite transport of radioactive materials and wastes. Licensees can maintain public protection by meeting the applicable regulatory limits and ALARA guidelines.

Inspection Procedures - There are three attachments to the inspection procedure for the public radiation safety cornerstone:

IP	71124	Radiation Safety—Public and Occupational
IP	71124.06	Radioactive Gaseous and Liquid Effluent Treatment
IP	71124.07	Radiological Environmental Monitoring Program
IP	71124.08	Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

Performance Indicators - There is one performance indicator in the public radiation safety cornerstone:

• Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual (RETS/ODCM) - Radiological effluent release occurences per reactor unit that exceed the values listed below:
• Liquid Effluents
• Whole Body - 1.5 mrem/qtr
• Organ - 5 mrem/qtr
• Gaseous Effluents
• Gamma Dose - 5 mrads/qtr
• Beta Dose - 10 mrads/qtr
• Organ Doses from I-131, I-133, H-3 & Particulates - 7.5 mrems/qtr



Public Radiation Indicator	Thresholds
	(White) Increased Regulatory Response Band	(Yellow) Required Regulatory Response Band	(Red) Unacceptable Performance Band
RETS/ODCM Radiological Effluents	> 1	> 3	N/A

Security - The objective of this cornerstone is to provide assurance that the licensees's security system and material control and accounting program use a defense-in-depth approach and can protect against (1) the design basis threat if radiological sabotage from external and internal threats, and (2) the theft of loss of radiological materials. Although the NRC is actively overseeing the security cornerstone, the Commission has decided that certain security related inspection and assessment information will not be publicly available to ensure that potentially useful information is not provided to a possible adversary. Therefore, the cover letters to security inspection reports may be viewed.