Reactor Inspector Qualification Support

Note to readers: The following analysis comes directly from Everstar's Gordian Research platform and was edited only for web formatting and to remove internal Gordian links. It was generated in about two minutes using this prompt: "I am working on my IMC 1245 reactor inspector qualifications. Help me get ready to complete OJT-OPS-8, Emergent Work Control and Maintenance Risk Assessments." For more insights, see our other resource posts or contact hello@everstar.ai to get on the waiting list for an account.

Executive Summary

OJT-OPS-8 (Emergent Work Control and Maintenance Risk Assessments) is a critical component of the IMC 1245 reactor operations inspector qualification process. This on-the-job training activity requires 32 hours of inspection effort and focuses on two primary areas: understanding licensee processes for controlling emergent work activities and familiarizing yourself with methods used to assess and manage plant risk during maintenance. The activity is grounded in 10 CFR 50.65(a)(4), which requires licensees to assess and manage risk during maintenance activities in all plant operational modes. Successful completion requires demonstrating knowledge of work control centers, risk assessment methodologies, and the ability to evaluate licensee compliance with regulatory requirements. [1] [2] [3]

Technical Analysis

Scope and Purpose of OJT-OPS-8

OJT-OPS-8 is designed to provide you with practical experience in evaluating how nuclear facilities handle emergent work and assess maintenance risk. The activity has two primary purposes:

1. To familiarize you with typical licensee processes for controlling emergent work activities
2. To familiarize you with various methods (such as online risk monitors) that licensees use to assess and manage plant risk associated with scheduled or emergent work activities

This training requires 32 hours of inspection effort and is a mandatory component of the reactor operations inspector qualification process outlined in IMC 1245 Appendix C1. Upon completion, you must demonstrate specific competencies related to work control and risk assessment to a qualified operations inspector or supervisor. [1] [2] [3]

Key Regulatory Framework

The primary regulatory basis for this inspection activity is 10 CFR 50.65(a)(4), commonly known as the Maintenance Rule. This regulation requires licensees to:

• Assess and manage plant risk related to maintenance activities during all modes of plant operation
• Consider both scheduled maintenance and emergent work in risk assessments
• Implement risk management actions to minimize risk-significant configurations
• Maximize the availability of mitigating systems and barriers to radiological releases

The implementation of these requirements is inspected through IP 71111.13, "Maintenance Risk Assessments and Emergent Work Control," which provides detailed guidance on how to evaluate licensee compliance with 10 CFR 50.65(a)(4). [4] [5] [6] [7]

Maintenance Risk Assessment Process

Licensees must perform risk assessments before conducting maintenance activities that could affect structures, systems, and components (SSCs) within the scope of the Maintenance Rule. These assessments can be:

1. Quantitative: Using probabilistic risk assessment (PRA) tools like online risk monitors
2. Qualitative: Based on deterministic judgments and defense-in-depth principles
3. Blended: Combining elements of both approaches

Risk assessments must consider:

• Current plant configuration
• Expected changes due to planned maintenance
• Potential impact of external conditions (weather, grid stability, flooding, seismic events)
• Internal flooding potential
• Containment integrity considerations

The assessment should properly determine the risk impact of planned maintenance configurations to allow effective implementation of risk management actions (RMAs) to limit potential risk increases. [6] [7] [8] [9]

Emergent Work Control

Emergent work refers to unplanned maintenance activities that arise during normal operations or during execution of planned maintenance. Licensees must have processes to:

1. Control the impact of emergent work on plant safety
2. Update risk assessments when plant conditions change
3. Implement appropriate risk management actions
4. Restore equipment to service in a manner that doesn't place the plant in an unacceptable configuration

As an inspector, you'll need to understand how licensees handle these activities, including how they enter limiting conditions of operation (LCOs), control troubleshooting, conduct tagging, implement temporary modifications, and restore equipment to service. [3] [10] [11]

Work Control Center Functions

A critical aspect of OJT-OPS-8 is understanding the functions of a typical work control center at a nuclear power plant. These centers typically handle:

1. Work planning and scheduling
2. Processing of work orders
3. Risk assessment and management
4. Coordination of maintenance activities
5. Implementation of temporary modifications
6. Equipment restoration

During your training, you'll need to discuss these functions with a qualified operations inspector and observe how the work control center at your assigned facility operates. [3] [10] [11]

Regulatory Considerations

Inspection Procedure 71111.13

IP 71111.13 is the primary inspection procedure for evaluating licensee compliance with 10 CFR 50.65(a)(4). This procedure requires inspectors to:

1. Sample maintenance activities before commencement, in progress, or completed
2. Include a mixture of scheduled and emergent work in the sample selection
3. Consider relative plant risk and prevalent types of work activities
4. Verify performance and adequacy of risk assessments
5. Verify implementation of risk management actions
6. Verify control of emergent work activities

The procedure includes a flowchart in Appendix A that guides the inspection process and helps determine whether the licensee is appropriately applying all Maintenance Rule requirements. [12] [4] [5] [13]

Evaluation Criteria

To successfully complete OJT-OPS-8, you must demonstrate the ability to:

1. Describe how a licensee controls emergent work activities, including entering LCOs, controlling troubleshooting, conducting tagging, implementing temporary modifications, and restoring equipment to service
2. Demonstrate knowledge of work control center functions, including work planning, scheduling, and processing work orders
3. Explain how to select risk-significant work activities for inspection
4. Explain why licensees assess and manage plant risk for both scheduled and emergent work
5. Demonstrate knowledge of methods licensees use to assess and manage plant risk, such as online risk monitors

These criteria align with the regulatory requirements and inspection focus areas outlined in IP 71111.13. [3] [10] [14]

Common Performance Deficiencies

Understanding common licensee performance deficiencies will help you focus your inspection activities. These include:

1. Failure to perform risk assessments for maintenance configuration changes
2. Failure to update risk assessments when conditions change
3. Incomplete risk assessments that don't consider all affected SSCs or relevant conditions
4. Improper use of risk assessment tools beyond their capabilities or limitations
5. Failure to implement adequate risk management actions
6. Deficient risk-informed evaluation processes

Identifying these issues is a key part of the inspection process and will be an important skill to develop during your OJT activity. [7] [15] [16]

Uncertainties and Limitations

Variability in Licensee Approaches

Licensees may use different approaches to risk assessment and management, which can present challenges during inspection:

1. The level of sophistication in risk assessments varies between plants
2. Some licensees use quantitative tools while others rely more on qualitative judgments
3. Risk management actions may differ based on plant-specific considerations
4. The scope of SSCs included in risk assessments may vary based on licensee-specific analyses

Understanding these variations and how they align with regulatory requirements will be important for effective inspection. [6] [8] [9]

Assessment Tool Limitations

Risk assessment tools have inherent limitations that must be understood:

1. Most shutdown risk assessment tools don't easily allow evaluation of duration effects
2. Qualitative assessments rely heavily on expert judgment
3. Quantitative tools may not capture all risk contributors
4. External events and rare conditions may not be fully modeled

Recognizing these limitations will help you evaluate whether licensees are appropriately using their risk assessment tools within their capabilities and addressing any gaps through other means. [6] [7] [15]

Recommendations and Next Steps

Preparation Activities

To prepare for OJT-OPS-8, I recommend the following steps:

1. Review Key References:
2. • Locate and study 10 CFR 50.65(a)(4) requirements
   • Review IP 71111.13 in detail, including the flowchart in Appendix A
   • Obtain licensee procedures for control of emergent work
   • Obtain licensee procedures for conducting risk assessments and managing risk
2. Understand Site-Specific Processes:
3. • Identify which SSCs at your facility are classified as (a)(1) under the Maintenance Rule
   • Learn how the licensee's work control center functions
   • Understand the risk assessment tools used at your facility
   • Familiarize yourself with the licensee's risk categories and associated management actions
3. Practical Application:
4. • Identify a risk-significant emergent work activity to observe
   • Apply IP 71111.13 to this activity, reviewing work planning, LCO entry, troubleshooting, tagging, temporary modifications, equipment restoration, and risk management
   • Discuss your observations with a qualified operations inspector
4. Documentation:
5. • Prepare to have your supervisor or a qualified operations inspector sign your qualification card upon successful completion
   • Document your activities and findings for future reference

These steps will help ensure you're well-prepared to complete OJT-OPS-8 successfully. [3] [10] [14] [11]

Key Focus Areas During Inspection

When conducting your OJT activity, focus on these key areas:

1. Risk Assessment Adequacy:
2. • Verify risk assessments are performed when required
   • Ensure assessments consider all relevant SSCs and conditions
   • Check that assessments are updated when conditions change
2. Risk Management Actions:
3. • Verify appropriate actions are implemented based on risk level
   • Ensure actions effectively address the identified risks
   • Check that defense-in-depth and key safety functions are maintained
3. Emergent Work Control:
4. • Observe how the licensee handles unexpected maintenance needs
   • Verify proper coordination between operations and maintenance
   • Ensure equipment is restored to service properly
4. Documentation and Communication:
5. • Review how risk assessments and management actions are documented
   • Observe communication between work groups
   • Verify that risk information is effectively communicated to relevant personnel

Focusing on these areas will help you develop the skills needed to effectively inspect maintenance risk assessment and emergent work control activities in the future. [12] [4] [5] [7]

By following this guidance, you should be well-prepared to complete OJT-OPS-8 and advance in your IMC 1245 reactor inspector qualification process. Remember that the goal is not just to check a box, but to develop the knowledge and skills needed to effectively ensure licensees are properly assessing and managing risk during maintenance activities.

References

• [1, 2, 3, 10, 11, 14] IMC 1245, Appendix C1, " Reactor Operations Inspector Technical Proficiency Training and Qualification Journal": https://www.nrc.gov/docs/ML2303/ML23030A607.pdf
• [4, 5, 12, 13] IP 71111.13, "Maintenance Risk Assessments and Emergent Work Control": https://www.nrc.gov/docs/ML2215/ML22154A388.pdf
• [6] IP 62709, “Configuration Risk Assessment and Risk Management Process”: https://www.nrc.gov/docs/ML0101/ML010180067.pdf
• [7, 15, 16] IMC 0609 App K Maintenance Risk Assessment and Risk Management Significance: https://www.nrc.gov/docs/ML2333/ML23335A018.pdf
• [8] Inspection Manual Chapter 0308, Att 3, App K, "Technical Basis for Maintenance Risk Assessment and Risk Management SDP.": https://www.nrc.gov/docs/ML2333/ML23335A013.pdf
• [9] SRP 17.6, Revision 2 - Maintenance Rule, Final: https://www.nrc.gov/docs/ML1409/ML14099A044.pdf