AICPA SOC Service Organizations - Certrec

Regulatory Expert Certrec Finds That “Greater Than Green Indicators” Within the Reactor Oversight Process (ROP) Could Have Been Avoided by Nuclear Operators

Organizational weaknesses with Margin management, and a weak understanding of Mitigating System Performance Index (MSPI) requirements, have resulted in greater than Green NRC Performance Indicators.

Fort Worth, TX (PRWEB) June 27, 2013 — Certrec, a leading licensing and regulatory compliance provider for NRC, FERC, and NERC compliance, and a recognized industry expert in the Reactor Oversight Process (ROP), announced today that nuclear operators can be in jeopardy of tripping Green-to-White or Green-to-Yellow performance indicator thresholds due to organizational weaknesses with MSPI Margin management and a weak understanding of Mitigating System Performance Index (MSPI) requirements. 

“A strong understanding of the Mitigating System Performance Index in the Reactor Oversight Process is needed by licensing, regulatory compliance, system engineers, PRA engineers, and plant managers to avoid unnecessarily tripping ROP thresholds and being subject to a supplemental inspection,” says Ted Enos, CEO of Certrec. “In the past year, several plants could have avoided supplemental inspections if they had proactively addressed potential MSPI problems.” 

At one facility, the MSPI Cooling Water Performance Indicator went from Green to White – resulting in NRC performing a 95001 Supplemental Inspection. The licensee identified that organizational weaknesses with MSPI margin management, and weak understanding of MSPI requirements contributed to the White indicator. 

“Several years ago, an Emergency AC Power NRC performance indicator went from Green to Yellow at a large nuclear generator on a single failure,” notes MSPI expert Ken Heffner, Senior Project Manager within Certrec’s Office of Assessment and Recovery. “As a result, the Nuclear Regulatory Commission (NRC) performed Inspection Procedure 95002. During the preparation of the root cause evaluation, the utility identified that the underlying performance issues were poor understanding and management of the risk margin for the EAC system, or MSPI “margin management. In our assessments of MSPI programs, we have found two instances this year of utilities unaware that they are in the same situation.” 

“Complying with MSPI requirements can be challenging,” adds Enos. “In addition to understanding the algorithm used to calculate the value of the performance indicators, nuclear operators need to understand the risks of MSPI compliance. Unfortunately, simple deficiencies in knowledge transfer, training, and communication of information about issues often contribute to greater than green indicators.” 

“The Reactor Oversight Program is always evolving,” notes Heffner. “In addition, the Nuclear Regulatory Commission (NRC) has new employees who are looking at the performance indicator process. Managers need to proactively stay abreast of MSPI requirements, better understand Margin reporting and the specifics of Derivation Reports, and ensure staff and management understand the performance indicators in order to avoid additional NRC inspection.” 

Certrec’s Office of Assessment and Recovery (OAR) is currently engaged with three leading generators who are seeking to more proactively manage their MSPI margin compliance.

Outcomes of these OAR engagements include increased: 

  • understanding of the MSPI Indicator values, the algorithms used to calculate them, and conditions that trigger green-to-white and green-to-yellow indicators, 
  • ability to predict the impact of equipment failures and unavailability, 
  • communication of MSPI margin to management, and 
  • attention to deficiencies in knowledge transfer, training, and communication of MSPI information

About Certrec:
Certrec is a leading provider of regulatory compliance solutions for the energy industry with the mission of helping ensure a stable, reliable, bulk electric supply. Since 1988, Certrec’s SaaS applications and consulting know-how have helped hundreds of power-generating facilities manage their regulatory compliance and reduce their risks.

Certrec’s engineers and business teams bring a cumulative 1,500 years of working experience in regulatory areas of compliance, engineering, and operations, including nuclear, fossil, solar, wind facilities, and other Registered Entities generation and transmission.

Certrec has helped more than 120 generating facilities establish and maintain NERC Compliance Programs. We manage the entire NERC compliance program for 60+ registered entities in the US and Canada that trust us to decrease their regulatory and reputational risk. Certrec is ISO/IEC 27001:2022 certified and has successfully completed annual SOC 2 Type 2 examinations.

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