U.S. NRC Blog

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Defining the Color of Oversight

Lara Uselding
Public Affairs Officer
Region IV

We regularly interact with various audiences from the media to the public and one question pops up often: Why does the NRC use colors to discuss issues found at a plant and what does it all mean?

PI_ROPThe quick answer is that color-coding is a lot more understandable to people outside the agency than trying to interpret a probabilistic risk calculation of core damage frequency of 10-5. (The NRC uses probabilistic risk in assessing the potential safety significance of nuclear safety issues and plant performance indicators so inspections focus on those plant activities that could have the greatest impact on safety.)

The colors we use — green, white, yellow and red — are used to prioritize the findings with greater safety significance. A more risk-significant issue is called a red finding and that will move an operating plant into our highest category for oversight followed by thousands of extra hours of inspection. An example would be a failure in a key safety-related component.

A green finding might be given when an inspector finds that one of 10 bolts on a valve is looser than the others and should be tightened. While it may not sound like a big deal, the NRC has high standards for safety and a low threshold for issues.

White and yellow findings are medium risk. In 2015, 428 green findings, 13 white findings and two yellow findings were issued. An example of a yellow finding was one given for seals that were not adequate to protect a room housing electrical equipment from flooding. An example of a white finding was for improper maintenance that resulted in a failed emergency diesel generator fan belt.

Who decides the colors? Initially, the inspector determines the safety significance and assigns a tentative color. A green finding may not require additional analysis. But with the higher colors, there is a detailed assessment that could involve NRC risk experts and, in some cases, a discussion with the plant operator to obtain more information.

The final outcome of the review — evaluating whether the finding is green, white, yellow, or red — will be used to determine what further NRC action may be called for, such as moving a plant up in the columns that comprise the NRC’s performance “Action Matrix.” When poor performance lands a plant in one of these higher oversight columns with increased inspections, it takes a lot of hard work to return the plant to a better standing.

15 responses to “Defining the Color of Oversight

  1. Rabby December 30, 2015 at 6:59 am

    Thank you for the information given in this post. It is useful to understand why there are so many colors involved and that each has a different significance. But who evaluates the people making the evaluations? As it comes down to it, a lot of decisions are made by people and human judgment is fallible. It would be interesting to understand how these judgments are regulated so that the system of color-coding is effective and safe.

  2. Garry Morgan October 28, 2015 at 1:14 pm

    How many nuclear power facilities have you issued RED Findings for pressurizer power-operated relief valves (PORVs) not meeting safety specifications of licensing criteria? Federal Register Notice on issue – http://www.gpo.gov/fdsys/pkg/FR-2015-07-17/html/2015-17510.htm

    A retired NRC employee states there are two dozen facilities which do not meet licensing criteria. http://pbadupws.nrc.gov/docs/ML1525/ML15259A016.pdf ( ML1259A016 ).

    Are you going to give yourself a RED Finding for failing the citizenry of the United States of America by placing the financial concerns of nuclear corporations before the safety of communities? More than a decade you have been sitting on this serious problem without taking corrective action.

    This is a classic Human Reliability failure on your part as our regulator and the operators of the “two dozen” or so unnamed nuclear facilities which operate beyond their licensing criteria.

    • Moderator October 29, 2015 at 10:49 am

      After a search of Red findings, none were found related to pressurizer PORVs. There were three related to auxiliary feedwater. A search of yellow findings also found none related to pressurizer PORVs. There were two White findings, but not related to licensing criteria. One was for failure to implement corrective actions to prevent recurring failure, and other was for inadequate procedures which led to PORV actuation.

      Individual findings with final significance colors are available through the ROP public web page, by clicking on individual units. That page is here: http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/

      Dan Merzke

      • Garry Morgan October 29, 2015 at 1:00 pm

        Thank you for the reply.

        Are you saying there are no pressurizer power-operated relief valves which are installed which do not meet safety specifications as maintained by the retired NRC employee, who also states this is a long standing problem and involves licensing specifications. Or, are you saying that the pressurizer power-operated relief valves which do not meet specifications do not warrant a finding. Another possibility would be there have been no inspections related to this problem so no performance findings or inspection findings related to the deficiency have been found, if there is a deficiency. I doubt that since money and time have been spent, and is currently being spent on the issue as indicated by the notice and retired NRC employee documenting past activity regarding the issue of pressurizer power-operated relief valves not meeting specifications. Which is it?.

      • Moderator October 29, 2015 at 3:32 pm

        With respect to plant operation, pressurizer PORVs have surveillance requirements located in the plant’s Technical Specifications that require the licensee to demonstrate the operability of those valves on a regular basis. NRC inspectors review licensee compliance with their Technical Specifications. Inspectors are concerned with ensuring all safety-related equipment is capable of meeting their safety function, which means they are concerned with the operability of all safety-related equipment. If a PORV were to fail a surveillance test, or be determined to be inoperable, inspectors will determine if there is a performance deficiency associated with the issue. If so, they will evaluate the significance and issue an inspection finding, if appropriate. There have been 31 inspection findings since ROP inception directly related to the operation of pressurizer PORVs: 29 of Green significance and 2 of White significance. The findings generally relate to inadequate maintenance, inadequate procedures, inadvertent opening of the PORV, etc.

        With respect to licensing, the staff conducts a Component Design Basis Inspection triennially that selects many safety-related components to review (which may include pressurizer PORVs) specifically focusing on the design basis and licensing basis of those components. However, no inspection findings related to the licensing basis of pressurizer PORVs have been identified.

        Dan Merzke

        Moderator Note: If you have specific information regarding a plant not complying with their licensing basis, that information should be evaluated through our allegations process. Comments containing allegations cannot be posted to the blog. For more information on submitting an allegation, please go here: http://www.nrc.gov/about-nrc/regulatory/allegations/safety-concern.html

      • Garry Morgan October 30, 2015 at 6:43 pm

        Reference moderator comment: “If you have specific information regarding a plant not complying with their licensing basis, that information should be evaluated through our allegations process. Comments containing allegations cannot be posted to the blog. For more information on submitting an allegation, please go here: http://www.nrc.gov/about-nrc/regulatory/allegations/safety-concern.html

        It is not my allegation, it is a retired NRC employee’s allegation in an official document listed in your files on a pending issue. As such it is not my responsibility to investigate or take action, that is your job as it is an NRC retired employee filing the document which reports a failure to comply with licensing specifications. Reference: “A retired NRC employee states there are two dozen facilities which do not meet licensing criteria. http://pbadupws.nrc.gov/docs/ML1525/ML15259A016.pdf ( ML1259A016 )” Related to this Federal Register Notice. http://www.gpo.gov/fdsys/pkg/FR-2015-07-17/html/2015-17510.htm NRC DOCKET 2015-0167 Anticipated Transients That Could Develop Into More Serious Events.

        I’m not understanding why a critical part such as a pressurizer relief valve which is installed and does not meet safety specifications does not merit a red finding? Particularly since the valve has been in place for 10 years, identified as such and has not been replaced. This sounds very familiar, like in Browns Ferry 2010 familiar. In that situation INPO identified numerous valves while the NRC issued a Red finding for one valve.

  3. Garry Morgan October 28, 2015 at 11:26 am

    You are a regulator regulating the nuclear industry. Your color code system is an indicator of risk you assign to safety problems at each facility. Since you will not or cannot comment on the Corrective Actions Program cumulative issues which have been assigned a color on your scale, why as a regulator do you allow mediation in your regulatory functions? Are you unsure of your actions? Or do you allow the specific nuclear facility operator to determine, or participate in determining their own risk factor, color, which is assigned indicative of a failure. Reference mediation cases settled or not settled for the past 5 years, colorful charts: http://www.nrc.gov/about-nrc/regulatory/enforcement/adr/adr-trend-graph1.pdf end resolutions http://www.nrc.gov/about-nrc/regulatory/enforcement/adr/adr-trend-graph7.pdf

  4. CaptD October 27, 2015 at 2:09 pm

    The four color system is a sham.
    Especially the White Finding , which is really nothing more than “Now—Now don’t do that again.”

    When is the NRC going to “man-up” as some Pro-Nuclear Bloggers always say and start not only correctly identifying major screw ups by Nuclear Operators but also FINE them so that they and their industry cohorts stop “begging for forgiveness instead of asking for the NRC permission”?

    A perfect example of this is what the NRC did after SCE’s RSG debacle at the San Onofre NPP.

    The operator SCE, got a White finding for sneaking in 4 RSG that NEVER should have even been allowed to be constructed, much less installed using the NRC CFR 10.59 “loophole” instead of the full NRC CRF 10.90 review process!

    Who is responsible for giving colored rating to the NRC itself, the answer is nobody? This is why even though the NRR, the ASLB, the NRC IG and many others outside the NRC first warned, then officially complained about #SanOnofreGate * the NRC just swept the entire thing under the rug to protect themselves, SCE, MHI and the entire Nuclear Industry from public ridicule.

    But as everyone knows, the dirt under the rug always does get discovered. Now separate investigations are being held and it will be interesting to see how the NRC handles them, since everything was so well documented. Redacted SCE, MHI and NRC documents will only make all involved more suspect, since San Onofre is now being decommissioned (which was conveniently done to stop the root cause investigation) so the claim of redacting documents to protect proprietary information is just a canard.

    * The new hashtag that will allow you to keep up to date on the ongoing investigation into the multi-billion $ SCE-CPUC ripoff.

  5. Public Pit Bull October 27, 2015 at 1:32 pm

    Defining the Color of Oversight
    In this recent NRC Blog, “Defining the Color of Oversight”, unfortunately, the first color that came to my mind for NRC oversight was “Yellow”. The NRC, in my mind, has become complacent and impotent. We have a cowardly agency that has been captured by the nuclear industry it is supposed to regulate. Recent examples are spelled out by the Union of Concerned Scientists in an article on their “allthingsnuclear” blog.
    This NRC article says, “…the NRC has high standards for safety and a low threshold for issues.” I disagree.
    Almost every issue identified by the NRC has been classified as a “green” finding. Not a single issue was classified as a “red” finding (the most safety significant). Here are the numbers for 2015 to date provided by the NRC in this article: 428 green findings, 13 white findings and two yellow findings. These colors were chosen, the NRC says, because they are “a lot more understandable to people outside the agency”. As a person outside the agency what does a color of “green” mean? I think it means “go”, everything is hunky dory. Nothing could be farther from the truth. To the NRC “green” means we have found a violation of regulatory requirements but of the lowest safety significance. Therefore of 443 color-coded violations of regulatory requirements cited by the NRC, just this year, 428 were green findings. To this person outside the agency, this means the NRC is finding lots of violations but please consider them to mostly be “no-never-minds! Furthermore, this is in spite of the fact that very serious near-miss accidents have occurred at the Pilgrim nuclear plant, near Boston, and the Indian Point Nuclear Power Plant near New York City, just this year.
    No, the NRC is not a nuclear industry watchdog, they are a nuclear industry lapdog!

  6. Dan Williamson October 27, 2015 at 12:31 pm

    Let the caterwauling begin…..

  7. Nikohl Vandel October 27, 2015 at 12:02 pm

    Thank you. A helpful explanation.

  8. Garry Morgan October 27, 2015 at 11:36 am

    Thank you for this informative article.
    2 multiple part questions:
    1) (a)How many findings at nuclear facilities have been issued over the past 5 years relative to Safety Culture failures as a result of corrective action program findings, CAP, not being followed up on to fix repetitive failures as identified on CAP’s – (b)what colors were assigned to them?
    2) (a)How many failures have been identified within the past 5 years relative to Safety Culture where failures should have been placed on a corrective action program, CAP, but were not placed on the respective facilities CAP – (b)what colors were assigned to them?

    • Garry Morgan October 27, 2015 at 3:50 pm

      Please, an answer or a link to where the cumulative performance indicators and/or cumulative inspection findings may be found for each nuclear facility? Specifically interested in each facility’s corrective action plans, CAPs, as it pertains to the NRC’s probabilistic risk assessment as a cumulative or historical indicator of problems at the facility.

    • Moderator October 28, 2015 at 12:21 pm

      The NRC does not issue inspection findings related to safety culture because there’s no regulatory requirement related to safety culture. There is a Commission Policy Statement that communicates the Commission’s expectation that licensees have a positive safety culture commensurate with the risks associated with nuclear power.

      However, the NRC does have a regulation governing quality of licensee quality assurance programs under which corrective action programs (CAPs) fall, 10 CFR 50 Appendix B, Criterion XVI. It states that licensees shall establish measures so that conditions adverse to quality, including failures, malfunctions, and deficiencies are promptly identified and corrected. For significant conditions adverse to quality, licensees shall assure that corrective action is taken to prevent recurrence. The NRC may issue a violation of Criterion XVI for several reasons: failure to identify a condition adverse to quality (and enter it into their CAP), failure to correct a condition adverse to quality in a timely manner, or failure to implement corrective actions to prevent recurrence for those failures considered to be significant conditions adverse to quality. Since January 1, 2010, there have been 475 Green findings, 13 White findings, and 1 Red finding associated with violations of Criterion XVI.

      Dan Merzke
      Project Manager

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