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Criticality Safety Evaluation (CSE) preparation support and review
The criticality safety evaluation (CSE), also called an NCS analysis or NCS evaluation, is a formal and structured analysis performed to demonstrate the subcriticality of a process or system. This may consist of a single document or multiple documents.
NKENT CONSULTING can help with the preparation or revision of your CSEs. Or perhaps you would like an independent, objective, third person review, to see how your CSEs compare against NUREG-1520 criteria.
Integrated Safety Analysis (ISA) preparation support and review
ISAs identify potential accident sequences in the facility's operations and designates IROFs to prevent or mitigate the consequences of these accidents. ISA Summaries give a synopsis of the ISA results for the higher risk accident sequences whose consequences could exceed the criteria of 10CFR70.61.
NKENT CONSULTING can help with preparation or revision of these documents pertaining to criticality safety, satisfying the requirements of 10CFR70.62 and 10CFR70.65 as referenced in the SRP, NUREG-1520.
Process Hazard Analysis (PHA) support
The primary purpose of a process hazard analysis (PHA) is to identify all uncontrolled and unmitigated accident sequences. These sequences are then categorized as high, intermediate, or low consequence sequences. Although the ISA analysis need focus only on those accident sequences having high or intermediate consequences, NRC often includes a review of the low consequence events to help gage the completeness of the PHA and ISA analyses.
NKENT CONSULTING can help with the PHA as a member of the analysis team, or as an objective third-party reviewer of PHAs.
License Applications: preparation support and review
Regulatory Guide 3.74 provides guidance to fuel cycle facilities on types of process changes that require prior NRC approval before implementation. This means preparing a license amendment, per 10CFR70, with guidance on format and content found in NUREG-1520.
NKENT CONSULTING is happy to help as needed in different capacities, from helping to prepare the amendment request to reviewing the draft against regulatory requirements.
corrective Action Program (CAP) support
Regulatory Guide 3.75 and NUREG 1520 address the corrective action program (CAP). Licensees are required to demonstrate the ability to investigate abnormal events (i.e., process upsets) associated with items relied on for safety (IROFS) and complete appropriate corrective actions. One real incentive for having a CAP that the NRC deems acceptable and effective is that, per the NRC Enforcement Policy, the NRC may disposition NRC-identified severity level IV (SL IV) violations as non-cited violations (NCVs provided certain criteria are met.
Regulatory Guide 3.75 allows licensees to have consultants serve on the independent reviewing organization, providing the licensee retains overall responsibility for the CAP. Recognizing that a licensee's resources are often limited, NKENT CONSULTING is happy to provide this support when needed.
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