July 18, 2019 | Mark Paradies

Audits – How Often Should You Conduct Them? Can a nuclear industry controversy improve your audits?

Nuclear Industry Controversy May Improve Your Audits

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How can controversy and political infighting involving the nuclear industry help you improve your safety or process safety audits and assessments? Read on to get some ideas…

First, the Nuclear Industry Controversy

An article from the Associated Press questioned the Nuclear Regulatory Commission’s staff recommendation to cut the frequency of some engineering inspections and change the inspection focus.

Before we get into the details, these engineering inspections are just one part of a complex process of inspections to ensure reactor safety. Each nuclear plant has on-site “Resident Inspectors” who are constantly providing NRC oversight to the plant. (Imagine having full-time OSHA and EPA inspectors at your plant.) The changes discussed aren’t changing the whole oversight programs, but instead, just changes in an engineering inspection program that supplements other inspections.

The internal NRC letter proposing the changes was sent in May of 2018 but the Associated Press story about the letter was published on July 16, 2019.

The NRC Letter says the engineering inspection’s original intent was:

“…identification of latent conditions (e.g., unknown design deficiencies) that could result in structure, system, and component failures during design-basis accidents.”

However, the inspection focus has shifted over the years to:

“…inspecting the licensee’s capability of maintaining equipment to meet its design and licensing-basis function.”

The letter stressing maintaining the same level of safety oversight and safety performance by any future modified engineering inspections. Read the NRC letter to get a full view of the technical changes that are recommended.

Now for the Associated Press article. First, the headline:

Nuclear Regulatory Commission Looking at
Reducing Inspections at Reactors

Then, a few quotes to provide the tone of the reporting…

“Nuclear Regulatory Commission staff is recommending that the agency cut back on inspections at the country’s nuclear reactors, a cost-cutting move promoted by the nuclear power industry but denounced by opponents as a threat to public safety.”
“Some of the staff’s recommendations would require a vote by the commission, which has a majority of members appointed or reappointed by President Donald Trump, who has urged agencies to reduce regulatory requirements for industries.”
“The release comes a day after Democratic lawmakers faulted the NRC’s deliberations, saying they had failed to adequately inform the public of the changes under consideration.”
“‘Cutting corners on such critical safety measures may eventually lead to a disaster that could be detrimental to the future of the domestic nuclear industry,’ Rep. Frank Pallone, D-N.J., chair of the House Energy and Commerce Committee, and other House Democrats said in a letter Monday to NRC Chairwoman Kristine Svinicki.”

Read the whole article and compare it to the actual NRC letter.

Improving Your Audits

The nuclear industry is always tangled up in politics. But what does this debate have to do with your proactive improvement efforts and audits?

FIRST, how did you decide on your audit schedule? Is it related to performance and performance indicators?

SECOND, how often do you revisit the number and types of audits and assessments your company performs? Do you use your operating experience and root cause data when you decide what to audit in the future?

THIRD, could you be more efficient and even more effective in your audits by continually improving the audit practices and focus?

These three topics should help you improve your audits and assessments by focusing on the most important areas for audits and keeping your proactive improvement efforts efficient and effective.

Hopefully, you don’t live under the microscope with every decision questioned in a highly charged political environment. That way your decisions to improve your audit practices won’t be subject to Congressional hearings and Associated Press stories.

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