NRC’s Reactor Oversight Process – TapRooT® RCA & 3 Cross-Cutting Areas
From the NRC’s webpage detailing the Reactor Oversight Process (ROP) and their Plain Language outline.
“The NRC uses the Reactor Oversight Process (ROP) to assess a licensee’s ability to safely operate a nuclear power plant in accordance with the NRC rules, regulations, etc. The ROP is the agency’s program to inspect, measure, and assess operating commercial nuclear power plant licensees’ safety and security, and to predictably respond to declining performance.“
NRC’s ROP is the grading and correction matrix for civilian nuclear power.
That Plain Language Outline is a great intro, and digging in to the whole framework reveals an incredibly detailed and trip-wired plan to “Protect Public Health and Safety in the Use of Nuclear Power.”
With seven cornerstones of Reactor Safety, Radiation Safety, and Security, there are three Cross-Cutting Areas evaluated very strictly, as they form the backbone of Individual Performance, Team Performance, and Management System Performance in the nuclear organization:
Cross-Cutting Area 1 – Human Performance
“This element monitors the licensee’s decision-making process, availability and adequacy of resources to ensure nuclear safety, coordination of work activities, and personnel work practices.”
TapRooT® was created from the discipline of Human Performance Improvement over 40 real-time years of research, pan-industry use, and constant feedback, challenging and near-perfecting the advanced RCA process.
Your regulators probably used TapRooT® Human Performance expertise to build their requirements and frameworks. We don’t just “meet or exceed requirements”; we’re the foundation for them.
Cross-Cutting Area 2 – Problem Identification and Resolution
“This element monitors the licensee’s corrective action and operating experience programs, and the licensee’s self- and independent assessments.”
Purely, this is proper Root Cause Analysis used properly as an organizational learning framework, and a functional (vice dysfunctional) Corrective And Preventive Action program that executes fixes and tracks the effectiveness of those changes. NRCs Inspection Procedure 95001, the least severe of the three supplemental IPs, has three objectives.
- 01.01 To provide assurance that the root causes and contributing causes of risk-significant performance issues are understood.
- 01.02 To provide assurance that the extent of condition and the extent of cause of risk-significant performance issues are identified.
- 01.03 To provide assurance that the licensee’s corrective actions for risk-significant performance issues are sufficient to address the root and contributing causes and prevent recurrence.
What happens if you have no formal training in Advanced Root Cause Analysis? The NRC can tell, and commissions a team of experts to review your RCA, and in this case, they found the licensee…
“…expended a considerable level of effort evaluating the accident and prescribing corrective actions to fix the identified root causes…The overall assessment conclusion is that, while the event root cause provides sufficient actions such that they can be reasonably expected to prevent another undetected latching event, there are significant structural evaluation issues indicating that the root cause conclusions are not at the appropriate depth to ensure underlying organizational or cultural drivers are identified and actions prescribed.“
Read more about that 2021 fuel failure, RCA, and review here:
Here is how organizations properly investigate and correct an event like a nuclear fuel element failure.
Cross-Cutting Area 3 – Safety-Conscious Work Environment
“This area monitors an environment in which workers feel free to raise nuclear safety concerns without fear of harassment, intimidation, retaliation, or discrimination.”
TapRooT® Root Cause Analysis System is designed to change “behavior” and “culture” without mentioning either one or getting into in-depth Ph.D. discussions. Undesired behaviors are a symptom of much deeper dysfunction that can be a proper RCA.
“Culture” is amorphous, meta, but generates specific, tangible undesired behaviors and human errors. Every TapRooT® investigation prompts your team to analyze two important categories – Work Direction and Management System, and here are just a few of the issues you will analyze.
| Work Direction | Management System |
| Worker selection and competency programs Overscheduling and Fatigue Substance abuse and distress Team dysfunction PPE and Lockout/Tagouts Supervision Crew teamwork and relationships Pre-job briefings, PHA, and work package prep | Confusing and ambiguous policies Requirements impossible to implement P&ID system inadequacies Enforcement and accountability Communicating safety expectations Listening to worker feedback Past fixes that didn’t work Blame and punishment responses to mistakes |
A 5-Day TapRooT® Team Leader course prepares any and all disciplines at your company to
- Thoroughly analyze Human Performance Difficulties
- Investigate reactor equipment failures with Equifactor®
- Lead major investigations spanning decades of data from extended-life nuclear facilities
- Identify and correct major organization dysfunctions and systemic problems
- Plan and Conduct evidence collection and interviewing strategies
- Perform safeguard analysis
- Produce comprehensive, evidence-based reports routinely approved by (and frequently used) by nuclear regulators world wide.
Check out our TapRooT® in Nuclear and Utilities page, send a trusted evaluator to attend any of our Public 5-Day TapRooT® Root Cause Analysis Team Leader certifications, and make your RCA program professional and disciplined, as everything in nuclear power should be.
