Responding to Regulatory Findings
ScottMadden assisted a multi-unit nuclear operator in preparing for a NRC 95002 inspection resulting from a security-related “greater-than-green” finding. Project goals were to ensure readiness for the Nuclear Regulatory Commission’s (NRC) inspection and to address cultural gaps around safety and security integration across the site.
ScottMadden provided project management and change management leadership for the inspection, including an initial extent of condition assessment, development of a 95002 communication strategy and content, and day-to-day project management and project support.
The NRC identified deficiencies in the client’s security program, resulting in a “greater-than-green” violation for the station and placing it in Column 3 (Degraded Cornerstone) of the NRC’s action matrix. This required a NRC 95002 inspection. A consequence of not passing the 95002 inspection was a more intrusive and resource-consuming inspection (Column 4 – 95003 inspection), potentially resulting in preparation/mitigation costs between $100–200M. The purpose of this project was to correct the deficiencies, pass the 95002 inspection, and eliminate the need for a 95003 inspection.
ScottMadden was retained by the client because of our nuclear industry and project management expertise, as well as our ability to react and mobilize quickly. Additionally, ScottMadden had a strong relationship with this client, previously supporting merger and integration efforts and a number of improvement projects. To align with the client’s needs, the project was organized into two primary focus areas:
- Extent of Condition Assessment – Complete an extent of condition assessment around the NRC’s violation
- 95002 Preparedness – Ensure site preparedness for the 95002 inspection, including integration of key security programs into daily station activities
The client faced two key challenges. First, a high-quality extent of condition assessment was critical to correct the deficiencies and successfully pass the 95002 inspection. Some previous work was done on this assessment—presenting a challenge to leverage what had been done, refocusing the extent of condition team, and completing the work in time to support the inspection.
Second, there was a need to change the station’s culture as it related to nuclear security. Nuclear security is included in the NRC’s definition of a strong nuclear safety culture. In order to meet this expectation, station personnel needed to better understand and acknowledge security’s relative importance to plant safety and in day-to-day operational activities. Additionally, the security organization needed to expand its focus from operational excellence to include programmatic excellence to better drive security expectations throughout the station.
Given the regulatory consequences associated with the project and the importance of the issue to client leadership, it was highly visible within the organization and carried an elevated level of scrutiny.
How We Helped
To prepare for the 95002 inspection, ScottMadden provided day-to-day project management support for the following work streams:
- Extent of Condition Assessment
To ensure the extent of condition assessment was successful, ScottMadden worked with the client team to establish a thorough, formal, and standard process to identify, document, and evaluate potential items in question, assessing them against NRC standards. ScottMadden’s assistance included organization and oversight of dedicated client teams that reviewed documentation, performed physical site inspections, and validated station alignment with NRC requirements. When completed, the final document served as the design basis for a new program focused on the proactive identification, mitigation, and control of the items in question with a focus on effective practices, defensibly documented.
- 95002 Preparedness
To ensure thorough and comprehensive preparations for the 95002 inspection, the client team was organized into a four-team construct:
- The root cause evaluation team focused on ensuring the appropriate completion and documentation of each root cause finding and on resulting corrective action. The associated documentation was organized in volumes for quick reference during the inspection.
- The training team focused on training security and site personnel on the new security program as well as the 95002 inspection protocols/process. This included computer-based training, daily/ weekly communications, site demonstrations, and targeted training sessions.
- The inspection readiness team focused on coordinating a mock 95002 inspection and facilitating pre-inspection preparations. This included establishing NRC interaction protocols, completing corrective actions resulting from the mock inspection, ensuring alignment with NRC and client inspection requirements, and addressing pre-inspection NRC information requests.
- The internal communications team focused on the cultural change management needs associated with integrating a security focus into all station activities. This team also managed pre-inspection interactions with regulatory and external stakeholders. Figure 1 highlights the key messages and focused communications used to achieve cultural change management and 95002 preparedness expectations.
This project was completed successfully. The NRC’s inspection resolved the original issue and resulted in no additional findings. The NRC moved the station from Column 3 (Degraded Cornerstone) to Column 1 (Licensee Response) of the NRC’s action matrix. This outcome avoided a 95003 inspection with an estimated preparation cost of $100–200 million.
In their exit interview, the NRC noted the station’s safety culture as a strength with excellent participation and energy in focus group interviews and field observations. Also, they noted that the extent of condition design basis and the new security program were now industry leading practices.