Nuclear Power: Analysis of Regional Differences and Improved Access to Information Could Strengthen NRC Oversight
Highlights
What GAO Found
The Nuclear Regulatory Commission (NRC) relies on its staff's professional judgment in implementing its processes for overseeing the safety of U.S. commercial nuclear power reactors. In implementing this oversight, NRC allocates specific roles and responsibilities to resident inspectors assigned to each plant, regional officials at one of four regional offices responsible for most oversight activities, headquarters officials, and the nuclear power industry. NRC also builds into its processes incentives for plant managers to identify concerns about reactor safety, report those concerns to NRC, and take prompt actions to correct them. NRC's processes for identifying and assessing findings and violations are based on prescribed agency procedures and include several points where NRC staff must exercise their professional judgment, such as determining whether issues of concern identified during physical inspections constitute findings or violations and the risk significance of any findings or the severity of any violations, among other things.
NRC is aware of differences across regional offices in identifying and resolving findings that result from physical inspections. GAO's analysis of NRC's data indicated that the number of escalated findings had fewer differences across regions than nonescalated findings, which are lower-risk findings and less severe violations. According to NRC officials, several factors, such as the hours spent on inspections, may explain the differences in nonescalated findings. However, GAO found that the regional office with the fewest reactors and the fewest inspection hours had the most nonescalated findings. NRC officials and industry representatives have raised concerns that the differences may also be due to differences in how NRC staff identify and resolve findings. NRC has taken some steps to examine the consistency of its oversight. For example, in 2009, the four regional offices implemented an initiative to explore how the regional offices identify and assess inspection findings. However, NRC has not conducted a comprehensive analysis of the causes of the differences in the number of nonescalated findings across regions. Under federal standards for internal control, managers are to compare actual performance with planned or expected results throughout the organization and analyze significant differences. Without such an analysis, NRC does not know whether its regional offices are applying regulations and guidance consistently.
NRC has both formal and informal methods for developing lessons learned to improve its oversight. Formal methods include agencywide programs, annual and biennial assessments, and special initiatives. Informal methods include reaching out to peers and technical experts across the agency and accessing various agency databases. Although NRC guidance directs inspectors to use information in agency databases on past experiences to plan and conduct inspection activities, inspectors face challenges accessing this information, which may limit their ability to use it. For example, several NRC inspectors reported contacting other inspectors informally because NRC's database search tools contain limited instructions and do not ensure thorough results. Without better search tools, inspectors may overly rely on information available through informal channels.
Why GAO Did This Study
The 2011 disaster at Japan's Fukushima Daiichi Nuclear Power Plant demonstrated that unexpected nuclear accidents with extreme consequences can occur and, thus, heightened concerns about NRC's ability to oversee the safety of U.S. commercial nuclear power reactors. NRC oversees safety through multiple processes, such as physically inspecting reactors and also responding to signs of declining performance (i.e., findings) or violations of its requirements.
GAO was asked to review NRC's oversight of the U.S. nuclear power industry. This report examines (1) how NRC implements its processes for overseeing the safety of commercial nuclear power reactors; (2) the extent to which NRC consistently identifies and resolves findings through these processes; and (3) NRC's methods for developing lessons learned to improve its oversight and challenges, if any, NRC faces in doing so. GAO reviewed NRC policies and guidance; visited five nuclear power plants located in multiple NRC regions; analyzed NRC data on findings, violations, licensee performance, and inspection hours; interviewed NRC officials and industry representatives; and observed demonstrations of NRC's database search tools.
Recommendations
GAO recommends, among other things, that NRC analyze the causes of differences in identifying and resolving findings across regional offices and address these differences, and that it improve its database search tools. NRC agreed with GAO's recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Nuclear Regulatory Commission | To improve NRC's oversight processes, and to better meet its goal of implementing objective and consistent oversight, the NRC Commissioners should direct agency managers to conduct a comprehensive analysis of the causes of the differences in the identification and resolution of findings. |
In April 2014, NRC reported that, in response to GAO's recommendation, it had developed and implemented a tabletop exercise designed to identify the cause of regional inconsistencies in identifying findings of very low safety significance. According to NRC, the exercise challenged participants from NRC headquarters and all four regions to correctly identify performance deficiencies and characterize their safety significance using NRC guidance. NRC reported that it was assessing the data from the exercise to determine apparent causes and would revise inspection program guidance, if necessary. In December 2014, NRC documented its analysis of the causes of the differences in the identification and resolution of findings in a report entitled, "Analysis of the Causes of Regional Differences in the Number of Inspection Findings of Very Low Significance (Green) and Non-Escalated Violations." According to NRC, the analysis confirmed that there are regional differences in implementing some reactor oversight program guidance. According to the report, the analysis team concluded that certain enhancements could improve objectivity and predictability associated with inspection findings of very low safety significance. The report added that potential enhancements include procedure changes, standardized training, management awareness briefings, and augmented self-assessment activities. In March 2015, NRC reported that it is assessing potential program changes in response to the results of this analysis.
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| Nuclear Regulatory Commission | To improve NRC's oversight processes, and to improve transparency and better enable the public, Congress, and others to independently track findings, all documents related to the findings, and the findings' resolution, the NRC Commissioners should direct the agency to either modify NRC's publicly available recordkeeping system to do so or develop a publicly accessible tool that does so. |
In March 2015, NRC reported that, as part of its Reactor Oversight Process (ROP) enhancement project, NRC developed a communications strategy focused on improving the openness and transparency of the ROP. According to NRC, two major components of this strategy include the re-design and organization of NRC external and internal websites, placing emphasis on the use of plain language versus technical jargon, and the accessibility of NRC documents and related findings to end-users. NRC stated that the communications strategy includes enhancements to provide a publicly available option ("Contact Us" form) as an additional method for stakeholders to ask questions and receive answers regarding the ROP. NRC reported that it will continue to identify ways to improve ROP transparency and effectively and efficiently track documents related to inspection findings through enhanced tools to facilitate public access to inspection information.
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| Nuclear Regulatory Commission | To improve NRC's oversight processes, and to help NRC staff more efficiently use past experiences in their oversight activities, the NRC Commissioners should direct agency officials to evaluate the challenges inspectors face in retrieving all relevant information on plant performance and previous oversight activities and improve its systems accordingly to address these challenges. |
In April 2014, NRC reported on the results and recommendations of a key effort to evaluate its baseline inspection program for commercial nuclear power reactors. The recommendations include actions aimed at improving the inspection program's application of "reactor operating experience," which includes information on past experiences from inspection findings, events, and other sources. In March 2015, NRC reported that it will make plant performance and oversight information more readily searchable and available to NRC inspection staff and other appropriate NRC personnel. As an example, NRC reported that it is working to upgrade the Reactor Program Systems software and improve staff access to operating experience. NRC also reported that it is evaluating methods for soliciting anonymous feedback on administrative and support concerns relevant to resident inspectors. In February 2016, NRC reported that it had implemented new methods for soliciting this anonymous feedback. In April 2017, NRC reported that it improved access to information used in oversight activities, including by upgrading search features in its documents management system and upgrading internal web pages to improve organization and usability. In July 2017, NRC reported that it had implemented a variety of systems to track information, such as operating experience and plant performance, and that information from these systems is available to staff in several locations and different formats to suit anticipated needs. For example, according to NRC, staff developed an application that will allow inspectors to visualize and trend certain operating experience data. NRC also reported that it is working to consolidate this information in a consistent format and more centralized location to make it easier for staff to access. For example, according to NRC, the Reactor Program Systems software is being upgraded to provide more complete inspection information and is expected to be operational by late 2017.
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