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Improving NRC Processes—Part Two

Patricia Holahan
Director, Office of Enforcement

 

We wrote in June about steps we are taking to improve our “non-concurrence” process, which is a way for NRC staff to air a variety of views before final management decisions are made. Today, we’d like to fill you in on steps we are taking to improve our Differing Professional Opinions (DPO) process—used to bring NRC staff views on agency decisions to the highest levels of NRC management.

publicopinionBoth processes are important to creating an environment where NRC employees feel they can speak up when they disagree—the same safety conscious work environment we expect from our licensees.

First, a little context. The NRC makes hundreds if not thousands of decisions each year. To reach the best decisions, the agency encourages staff to bring their views forward throughout the process. This active engagement is essential.

NRC expects all employees to promptly discuss their views and concerns with their immediate supervisor on a regular basis. Employees are expected to raise concerns and propose solutions as early as possible in the decision-making process. In addition to informal discussions, which should be sufficient to resolve most issues, individuals have various options for expressing and having their differing views heard by decision makers.

In the vast majority of cases, an informal conversation is sufficient. But if not there are a number of avenues for elevating concerns. We have an Open Door policy that allows the staff to request a meeting with any manager at the NRC—including the Chairman and Commissioners—to raise concerns. This policy encourages employees to resolve their concerns informally. There is also the non-concurrence process, which allows the airing of issues through the concurrence chain before a decision is made. An employee who disagrees with an established position can use the DPO process.

The NRC is unique in not only having and promoting these programs, but in assessing them and reporting the results to the public. This transparency helps ensure that differing views do not get lost in the shuffle.

To gauge how well these processes are working, we used a variety of tools to measure user satisfaction and process effectiveness. As with our assessment of the non-concurrence process, the DPO assessment shows the process is sound. NRC staff knows about it and most would be willing to use it. Also like the earlier assessment, the DPO assessment has helped us to identify areas for improvement.

There have been 28 DPOs filed since 2004, or an average of two to three cases per year. In that same time frame, one DPO was withdrawn and 24 DPO decisions were issued. Given that so few NRC employees have direct experience with the process, we were encouraged to see from our agency-wide safety culture survey that only 15 percent of NRC employees would be unwilling to use it. While this number is small, it shows we have some work to do. We want all NRC employees to feel they can use the process, and that it will be effective and lead to better, more informed decision-making. We are also concerned about the 18 percent who worry using the process could impact career development and the 46 percent who are unsure.

These numbers present an opportunity to do more outreach and education to ensure NRC leadership is committed to the DPO process. We will also need to; develop clearer guidance and better tools and support the process; ensure training is readily available to all employees (including a focus on improved communications); and identify ways to address concerns about real and perceived  negative consequences for using the process.

publicopinionAs we work to make these improvements, we can also celebrate the things that make our DPO process strong. From looking at other agencies with similar processes, our assessment shows the NRC is unique in making summaries of our DPO decisions public and, if asked by those who file DPOs, releasing key DPO records.

We are also pleased by the feedback from DPO submitters. We surveyed the 12 who remain at the NRC and received nine responses. All nine reported their views were heard by management. Eight said the DPO panel was sufficiently knowledgeable, independent, impartial, timely, and thorough. The same number said they were understood and treated fairly. Seven said the process added value to the final decision, their views were fully considered, and their management was supportive. Six said they were recognized with a Special Act award or an NRC Team Player award.

As we move forward, we will build on these strengths and take additional steps to foster an organizational culture where employees take personal responsibility for their actions, feel part of a community and work toward shared goals. We value the feedback from these self-assessments and commit to responding constructively so we can continuously improve our performance.

NRC Team Ready to Get to Work at Pilgrim Nuclear Power Plant

Neil Sheehan
Public Affairs Officer
Region I
 

When the Pilgrim nuclear power plant got a second “white” performance indicator in the same area of performance in 2014 it meant we would ratchet up our level of scrutiny until the underlying issues were resolved.

pilgrimStarting Monday, that scrutiny will take the form of a team inspection at the Plymouth, Mass., facility. Eight NRC inspectors will begin performing evaluations in several key areas.

For one, they will review the evaluation done by Entergy, the plant’s owner and operator, looking at why the problems that triggered the indicator changes occurred. The team will also dig into the fixes, or corrective actions, put in place by the company to prevent the issues from happening again. They will also look at whether the issues could have affected other parts of plant operations. The timeframe for the inspection gave Pilgrim time to evaluate and fix the problems, so the NRC inspectors can make sure the corrective actions are adequate.

Another area the team will assess will be whether there were any safety culture weaknesses that caused or played a part in the performance issues. The NRC defines nuclear safety culture as values and behaviors that emphasize safety over competing goals to ensure protection of people and the environment.

Once the team’s on-site work is finished, the inspectors will brief Entergy at a high level regarding what it has found. That is followed by an inspection report issued within 45 days.

We also plan to conduct a public meeting with Entergy after the inspection is wrapped up. This meeting, which would likely occur in December or January near the plant, will provide a forum for the NRC and the company to discuss the performance issues, their underlying causes and any improvement steps.

The NRC will provide notice on the date, time and location for this session.

As a refresher on earlier developments, the Pilgrim plant’s performance indicator for Unplanned Scrams (shutdowns) with Complications crossed the threshold from “green” to “white” following the third quarter of 2013. Then, in the fourth quarter of last year, the performance indicator for Unplanned Scrams per 7,000 Hours of Operation also changed to “white,” something that occurs if a plant has more than three such shutdowns during the designated period. This placed Pilgrim in the Degraded Cornerstone Column of the Action Matrix used by the NRC to assess plant performance.

And that, in turn, requires the heightened NRC attention to be paid during the team inspection this week.

 

Science 101: How a Chain Reaction Works in a U.S. Nuclear Reactor

Paul Rebstock
Senior Instrumentation and Control Systems Engineer

 

science_101_squeakychalkThe primary active ingredient in nuclear reactor fuel is a particular variety, or “isotope,” of uranium, called U235. U235 is relatively rare — only about 0.7% of uranium as it exists in nature is U235. Uranium must be enriched to contain about 5% U235 to function properly as fuel for a U.S. commercial nuclear power plant.

U235 has 92 protons and 143 neutrons. Protons and neutrons are some of the almost unimaginably tiny particles that make up the nucleus of an atom — see Science 101 Blog #1. All other isotopes of uranium also have 92 protons, but different isotopes have slightly different numbers of neutrons.

Uranium is a radioactive element. Uranium atoms break apart, or disintegrate, into smaller atoms, releasing energy and a few leftover neutrons in the process. This happens very slowly for U235. If you have some U235 today, in about 700 million years you will have only half as much. You will have the remaining U235, plus the smaller atoms. The energy released will have gone into the environment too slowly to be noticed, and the extra neutrons will have been absorbed by other atoms.

While this happens very slowly, the disintegration of each individual atom happens very quickly, and the fragments are ejected at a very high speed. Those high-speed fragments are the source of the heat generated by the reactor. Under the right man-made conditions, the number of U235 atoms that disintegrate each second can be increased.

When a U235 atom disintegrates, it releases some neutrons. Some of those neutrons can be made to interact with other U235 atoms, causing them to disintegrate as well. Those “target” atoms release more neutrons when they disintegrate, and then those neutrons interact with still other U235 atoms, and so on. This is called a “chain reaction.” This process does not work well for other isotopes of uranium, which is why the uranium needs to be enriched in U235 for use as nuclear fuel.

Most of the energy released when a U235 atom disintegrates is in the form of kinetic energy — the energy of physical motion. The fragments of the disintegrated atom collide with nearby atoms and set them vibrating. That vibration constitutes heat. The fuel rods get hot as the reaction progresses. The faster the chain reaction — that is, the larger the number of U235 atoms that disintegrate each second — the faster energy is released and the hotter the fuel rods become.

The uranium in a U.S. commercial nuclear reactor is thoroughly mixed with neutral material and formed into pellets about half inch wide and three-quarters of an inch long. The pellets are stacked tightly in metal tubes, forming “fuel rods” that are several feet long. Each fuel rod is just wide enough to hold a single column of pellets. The fuel rods are sealed, to keep all of the radioactive materials inside. There are thousands of these fuel rods in a typical reactor. They contain around 60 tons of uranium – but only about three tons are U235. (The majority of the uranium in the reactor is in the form of the most abundant naturally occurring isotope of uranium, U238, which cannot sustain the fission process without the help of an elevated concentration of the isotope U235.)

The people in charge of the reactor can control the chain reaction by preventing some or all of the released neutrons from interacting with U235 atoms. The physical arrangement of the fuel rods, the low U235 concentration, and other design factors, also limit the number of neutrons that can interact with U235 atoms.

The heat generated by the chain reaction is used to make steam, and that steam powers specialized machinery that drives an electrical generator, generating electricity. Science 101 will look at how that works in more detail in a later issue.

The author has a BS in Electrical Engineering from Carnegie-Mellon University.

 

The NRC Commission Has Held 5,000 Meetings—Give or Take

Annette Vietti-Cook
Secretary of the Commission

 

After one of our commissioners noted a milestone in July – the 5,000th meeting of the NRC’s Commission – we thought it might be useful to share what the Secretary of the Commission does behind-the-scenes in planning Commission meetings. There is much more planning than you might think.

The NRC Commissioners conduct a public meeting. Annette Vietti-Cook is on the left.

The NRC Commissioners conduct a public meeting. Annette Vietti-Cook is on the left.

First some background. The “Commission,” in NRC-speak, means the presidentially-appointed, Senate-confirmed Commissioners acting together. At full-strength there are five Commissioners. The Commission sets policy for the NRC, develops regulations on nuclear reactor and nuclear materials safety, issues orders to licensees and adjudicates legal matters.

The federal Sunshine Act requires that any time the Commissioners meet to conduct agency business, the meeting must be public. Exceptions to this requirement are made when the Commission discusses matters such as security or confidential legal, personnel, personal or proprietary information. Our regulations lay out how we will meet the Sunshine Act requirements.

Public Commission meetings are held at NRC headquarters in the Commissioners’ Conference Room, with planning starting months in advance. This is where the staff members in the NRC’s Office of the Secretary (we call it SECY) come into play.

To prepare for the meeting, SECY works with NRC staff to plan agendas for proposed public meetings, including lists of potential internal and external contributors, which are intended to provide the Commission with a range of perspectives.

In the weeks ahead of a meeting, the NRC staff and other presenters send background materials and slides to the Commissioners. This advance information allows the Commissioners to come prepared to get their questions answered. Meanwhile about a half-dozen people in SECY are making sure of the details— arranging parking and pre-registration for external participants, getting relevant information posted on our public website, creating a seating chart for those who will brief the Commission.

As meeting day approaches, SECY ensures other logistics are in order. They make sure the room is set up properly, with name tags, microphones, and water pitchers placed on the conference table, chairs arranged, flags properly positioned. On meeting day, these preparations probably won’t be noticed by the 50-60 people who may come to the meeting and the untold number tuning into the webcast. (Incidentally, the room holds 155). The Chairman opens the meeting and turns the meeting over to the presenters. Following, the presentations, the Commissioners have an opportunity to ask questions.

Even after the meeting ends, SECY has more to do. All public Commission meetings are webcast, recorded and transcribed. The transcript must be validated and posted to the NRC website. The webcast is archived. And following most every meeting, SECY develops a memo to give the staff direction (we call this an SRM, or staff requirements memorandum), which must be approved by the Commission.

So you see, a lot of work goes into organizing the 5,000 or so Commission meetings we’ve held since the inception of the NRC almost 40 years ago – not just in my office. We hope you’ll tune in or attend a Commission meeting in the future. You can find the Commission’s meeting schedule here and a complete schedule of NRC public meetings here.

NRC Joins Five Other Agencies in Addressing Uranium Contamination on the Navajo Nation

Dominick Orlando
Senior Project Manager

 

Navajo coverLast year, after five years of work to reduce risks from uranium contamination on territory that is part of the Navajo Nation, the NRC, along with four other federal agencies, reported on our progress to Congress. This week, the five federal agencies issued a plan that spells out how we’ll continue coordinating that work for the next five years.

 The agencies’ second Five-Year Plan builds on lessons learned from the first five years. It reflects new information and defines the next steps to address the most significant risks to human health and the environment. The new plan commits us to working together to reduce these risks and find long-term solutions.

 In October 2007, Congress asked the agencies to develop a plan to address the contamination on Navajo land, which dates back to the 1940s when uranium was in high demand. The Navajo Nation had large uranium deposits but regulations were not what they are today and mining companies left extensive contamination requiring cleanup. Legislation and new regulatory provisions were put in place to address these issues.

 The 2013 report capped off a five-year program the agencies conducted, in consultation with Navajo and Hopi tribal officials, to address uranium contamination on their land. Part of this work was government-to-government consultations with the Navajo.

 The program was a joint effort among EPA, the NRC, the Department of Energy, the Bureau of Indian Affairs, the Centers for Disease Control and the Indian Health Service. It focused on collecting data, identifying the most imminent risks, and addressing contaminated structures, water supplies, mills, dumps, and mines with the highest levels of radiation. We also learned more about the scope of the problem and the work that still remains.

 The NRC’s role is to oversee the work done by DOE, which is the long-term custodian for three sites storing uranium mill tailings—a sandy waste left over from processing uranium—and one former processing site. We do that by reviewing and, if acceptable, concurring on DOE’s plans to clean up contaminated groundwater, visiting the sites to evaluate how DOE is performing long-term care activities, and reviewing DOE’s performance and environmental reports.

 We will work closely with EPA, DOE, the New Mexico Environment Department, and the Navajo during the cleanup of the Northeast Church Rock site—which EPA and Navajo officials identified as the highest priority site for cleanup. The NRC will also be part of outreach activities detailed in the plan, including participating in stakeholder workshops and contributing, as appropriate, to educational and public information activities.

 Five years from now, we look forward to being able to say that with close coordination among all the parties, we have continued to make major progress in addressing concerns about uranium contamination.

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