EPRI and industry stakeholders develop guidance for conducting ‘source verifications’ remotely.
In nuclear power, in-person oversight is an essential part of maintaining safe, reliable operations. One type of quality assurance activity, known as source verification, involves witnessing important manufacturing processes, inspections, or tests. An example of a source verification is when a nuclear plant owner sends technical personnel to a lab to verify that a plant component is calibrated properly.
Source verifications also are used after certain steps during the manufacturing of expensive or complex components such as pressure vessels, pumps, and motors. Technical personnel may go to a manufacturing facility to witness a test or other quality assurance activity that provides confidence that the component has been fabricated properly and will perform effectively. If any mistakes or defects are identified, they can be corrected before manufacturing proceeds or before the item is shipped to the nuclear plant.
“Source verifications are an effective tool for providing assurance that important components will function reliably,” said Marc Tannenbaum, an EPRI technical executive who conducts research on procurement, supply chains, and related quality assurance activities. “They’re also used regularly in many other industries such as bridge construction, aviation, ship manufacturing, and the military.”
Current U.S. Nuclear Regulatory Commission (NRC) regulations require source verifications to be in-person, but the coronavirus pandemic has challenged the ability to comply. “Travel restrictions and safety concerns may make it impossible for a verifier to get on a plane and travel to a lab or supplier to witness component calibrations and tests,” said Tannenbaum. “But failure to complete these verifications can delay plant activities such as maintenance.”
In March 2020, several nuclear utilities and suppliers contacted Tannenbaum asking if there was any available EPRI guidance on conducting source verifications remotely using video-conferencing and other communications tools. The inquiries prompted Tannenbaum to convene a series of virtual meetings with procurement and quality assurance experts to develop guidance for use of remote verification during the pandemic. It was a collaborative, iterative process, with participation from utilities, suppliers, and other nuclear power industry stakeholders.
In May 2020, EPRI submitted the completed report to the NRC for review. In September 2020, the NRC transmitted to EPRI a safety evaluation report concluding that appropriate implementation of EPRI’s guidance is acceptable for meeting regulatory requirements during a pandemic or other state of emergency. EPRI plans to reissue the guidance with a copy of the NRC’s evaluation. The NRC recently accepted a request by Energy Northwest (a consortium of public utilities in Washington state) to use the guidance.
Screening Criteria and Process
The EPRI guidance includes screening criteria to determine an activity’s eligibility for remote verification. One important criterion is whether an activity can be adequately verified remotely. For example, some straightforward calibration and testing activities may be appropriate for remote verification. On the other hand, certain types of inspections may be ineligible because the inspector may need to examine the item in-person to make an adequate assessment.
“If the verifier is relying on someone holding a video camera who is not trained in the type of inspection being performed, something may be lost in translation,” said Tannenbaum.
Another key criterion: remote verification needs to be conducted in real-time. “A verifier needs real-time video and audio communication to verify that an activity is completed,” said Tannenbaum. “At any point during the verification, the verifier may need to stop the person conducting the activity, request adjustments, or ask for measurements to be double-checked before moving to the next step. This would not be possible with pre-recorded video.”
The guidance outlines a detailed process for planning and conducting remote source verifications.
“The most important elements of the process are to define the objectives, have a good plan to accomplish the objectives, and be prepared with contingency plans,” said Tannenbaum. “Clearly identify the video cameras and other remote communications tools to be used, the components and activities to be verified, and a ‘plan B’ to address problems like loss of internet or smartphone signal.”
Key EPRI Technical Experts:
Marc Tannenbaum
For more information, contact techexpert@eprijournal.com.