Improving Our Aim for Consistent Reactor Oversight

Scott Morris
Director, Division of Inspection and Regional Support

Climate, geography and even accent may vary from state to state, but NRC’s regulations don’t, — and neither should our approach to applying them. So when someone suggests we might do a better job in consistently carrying out our mission, we listen carefully and act accordingly. We’ve followed this approach in following up on a September 2013 report from the Government Accountability Office (GAO).

npp3The GAO looked at how our Reactor Oversight Process objectively examines reactor safety based on inspection results and performance statistics. The report said we consistently and accurately respond to significant issues.

The GAO found, however, that the NRC’s four regional offices produced varied results when assessing the least-significant issues, such as improper maintenance for minor electrical transformers at a plant. While this programmatic variation fell short of creating a safety issue, the report recommended we look into this inconsistency.

Staff from our Office of Nuclear Reactor Regulation studied the regions’ approach to evaluating the least safety-significant inspection findings. The study also examined regional differences in dealing with “non-escalated enforcement” matters — plants must correct these issues, but they frequently fall short of the criteria for a formal NRC finding.

The staff’s study consisted of conducting “table-top” exercises to see how each region reviewed very low-significance issues. The study listened to resident inspectors at the plants as well as region-based inspectors and their supervisors.

The staff’s study and discussions with regional management and staff, along with some employees at headquarters, led to a few conclusions. First, the staff confirmed the results of the GAO’s review that there are indeed regional differences in implementing some reactor oversight program guidance. Secondly, the NRC’s guidance could benefit from some clarification to help the inspectors when it comes to evaluating very-low-significance issues. Finally, the agency’s annual self-assessments of the entire oversight process to date have been focused on dealing with significant issues, so the assessments didn’t consider or evaluate the regional differences with the least safety-significant inspection findings. This meant the inconsistencies went on longer than they otherwise might have.

The staff’s study looked at potential causes for the varying regional approaches. One area showed the agency devotes a lot of effort to training but that training and knowledge management results weren’t always shared as widely as possible. This meant that potential inconsistencies in training across regions should be addressed. The staff’s study saw no connection between inspector experience and the regional differences.

The staff’s study showed that the NRC can improve its objectivity and predictability in dealing with very-low-significance inspection findings. Management in the Office of Nuclear Reactor Regulation will consider changes that include enhancing review procedures, standardizing inspector training and revising the self-assessment process.

Author: Moderator

Public Affairs Officer for the U.S. Nuclear Regulatory Commission

6 thoughts on “Improving Our Aim for Consistent Reactor Oversight”

  1. nuclear is our best option for our long term energy needs its more efficient than coal w just need to find a way to dispose it, i think we can use the south pole for that

  2. The total failure of Region IV’s giving it’s OK to SCE’s bogus replacement steam generating project points out that the NRC has not done enough to protect everyone that much depend upon the NRC to make sure that nuclear operators run NPP safely. All those living in southern California were placed at risk of a nuclear incident/accident because SCE’s shareholders profits were far more important than safety, and SCE even bragged about doing it in an industry trade publication which happened to be published the same month Unit 3 started leaking radioactivity!

    Improving Like-For-Like:

    Click to access col-nrc-tech-paper.pdf

    Then later to make matters worse, the Inspector General even glossed over what happened in their own investigation, so the idea that the NRC is doing a great job of protecting our safety is itself something that immediately needs to reviewed in a public way!

    In short even those tasked with the oversight of the NRC are not getting involved in making sure the NRC is doing its job and my best guess why that is is that there is too much money being spent on Nuclear Payback*


    Those that support nuclear power because nuclear power somehow supports them; no matter what the health implications or other “costs” are for others.

  3. Not only the NRC ROP needs to be improved. That is addressed in the following. But the NRC needs to fundamently change as well. A number of significant recommendations for improvement after the TMI accident have all but been ignored.

    The NRC Has Failed to Implement Institutional Changes Recommended After the TMI Accident

    In his book “Reactor Accidents”, David Mosey cites “institutional failure” as a critical and often overlooked root cause in nuclear power plant accidents. For example, operator error or inadequate operator training is often cited as the cause of the TMI accident. However, significant institutional failures set these operators up for failure.

    A special and independent inquiry into the TMI accident was authorized by the NRC Commission shortly after the accident. A number of recommendations were made in their 1980 report (NUREG/CR-1250). The lion’s share of those recommendations called for significant changes in the NRC itself. My read is that almost all of these institutional recommendations were not implemented by the Commission. Let me cite several examples:

    Recommendation: The NRC needs to be a single-administrator agency.
    Status: Not implemented even after 34 years.
    Comment: The NRC is still run by committee. The inquiry report noted that the “NRC is virtually the only agency in the federal government headed by a commission”. Agencies responsible for public health and safety have single administrators. Examples include the FAA, FDA, OSHA, and the EPA. This is one that only the US Congress can implement by legislative action.

    Recommendation: An independent reactor safety board needs to be established with its sole focus on the safety of existing US nuclear power plants (NPPs).
    Status: Not implemented.
    Comment: The Advisory Committee on Reactor Safeguards (ACRS) has existed since the early days of commercial nuclear power. They advise on many matters that have absolutely nothing to do with existing NPP safety. I know of no change that was made to the ACRS as a result of the accident at TMI even though the ACRS was aware of similar precursor events at other plants prior to the TMI accident. They are mandated by law to review new license applications for NPPs and they were busy doing that decades ago. But new NPP license applications are few and far between today. Just look at what the ACRS looks at today. They have a dozen or so subcommittees and there was only one that even had the term “operations” in it. There were five subcommittees looking at designs for future nuclear plants though.

    Recommendation: NRC-qualified Engineer Supervisor on each NPP shift.
    Status: Partially Implemented
    Comment: A Shift Technical Advisor has been assigned to each NPP shift. They do not have to be engineers and they can only advise the Shift Supervisor who also does not have to be an engineer either.

    Recommendation: Operator training must be drastically improved.
    Status: Implemented
    Comment: Operator training is much better at US NPPs and training tools and training organizations vastly enhanced.

    Recommendation: The NRC inspection program needs significant improvement.
    Status: Partially Implemented.
    Comment: Additional inspectors were assigned both in the field and in NRC regional offices and NRC headquarters after TMI. Funding limitations later have reduced the NRC staff assigned to oversee existing NPPs. Also the so-called NRC baseline inspection program is flawed. When NPPs have been forced from service due to significant operational events, subsequently many problems are found when both the NRC and the power plant look hard at the plant. These problems were not discovered earlier through NRC inspection efforts. Millions of utility dollars (really these are rate-payer dollars) are paid to the NRC for these inadequate inspections at each nuclear site each and every year.

    Recommendation: Establish a centralized body to analyze and evaluate NPP operational data and provide a mechanism to promptly distribute this information to appropriate licensees.
    Status: Implemented in 1984 and abolished in 1998.
    Comment: The Office for the Analysis and Evaluation of Operational Data (AEOD) was established in 1984. Although AEOD was abolished its functions were spread out to five different NRC offices.

    Although the NRC has a poor track record on implementing significant accident inquiry report recommendations, so does the nuclear industry itself. For example,

    Recommendation: Form a National Operating Company or Consortium.
    Status: Partially Implemented
    Comment: The Institute of Nuclear Power Operation (INPO) was established by the nuclear industry shortly after the TMI accident. INPO evaluates NPPs on a periodic basis and establishes standards of excellence in nuclear operation for the industry. The inquiry report recommended much more than an INPO. Large utilities with large nuclear fleets operate NPPs better than single nuclear plant utilities. They have vastly superior technical and monetary resources. The inquiry report envisioned that the single NPPs belonging to small nuclear utilities could be brought under a large operating company so that all necessary resources to support the complexities of NPP operation could be more easily brought to bear.

    Recommendation: Form an industry-run off-site data center.
    Status: Partially Implemented.
    Comment: Each nuclear power plant now has its own dedicated group to analyze operational data from other plants. Since the NRC has dissolved the AEOD it appears that the industry as a whole has taken one step forward and two steps back.

    In my opinion it is high time to re-look at the inquiry report recommendations. It appears that significant improvements have been made to safety at each NPP, but that necessary institutional changes, involving the NRC and the nuclear industry as a whole, have been all but ignored.

  4. We are not worried about the consistency, but about the quality of being a tough nosed regulator and not an industry promoter. Don’t worry you have job security, plenty of decomm work coming up.

  5. The concluding paragraph is very applicable: “The staff’s study showed that the NRC can improve its objectivity and predictability in dealing with very-low-significance inspection findings. Management in the Office of Nuclear Reactor Regulation will consider changes that include enhancing review procedures, standardizing inspector training and revising the self-assessment process.”

  6. “When someone says …” NO! When a government watchdog agency notifies us …” Do your real job of safety and don’t complain about not having enough staff to mess with every needle. And don’t take time to broadcast about it.

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