Fission Stories #165
The Nuclear Regulatory Commission’s Reactor Oversight Process (ROP) protects the public by detecting declining safety levels at nuclear power plants and triggering remedial measures.
Perhaps the best part of the ROP is that it is widely recognized to be imperfect.
Being imperfect is not typically viewed as a virtue. But by being imperfect, the ROP is considered a “work in progress” by the NRC. For example, the ROP includes formal assessments to identify weaknesses and implement upgrades.
During the past year, the NRC has conducted an extensive review of the ROP’s baseline inspection program. (The baseline inspection program consists of an array of inspections conducted at every nuclear power reactor. When declining safety levels are detected via baseline inspections, the NRC conducts targeted supplemental inspections to ensure identified problems are corrected and see whether other problems exist. The average reactor received about 6,200 hours of NRC inspection effort last year.)
Baseline Inspection Program
The NRC’s baseline inspection program review:
- involved many internal and external stakeholders,
- allowed virtually all problems and all proposed solutions to be put on the table,
- kept the total number of baseline inspection hours essentially constant, and
- was conducted in public with documents produced/obtained readily made publicly available.
Rather than assign the review task to one or two staffers, the NRC involved dozens of inspectors working full-time at plants, specialty inspectors and supervisors from all four regional offices, and staffers from its headquarters. The NRC also solicited perspectives from external stakeholders, including me.
Because the baseline inspection program forms part of the overall ROP, any changes had to retain fidelity with the other parts. Other than that high-level constraint, the review had few boundaries. In other words, all suggestions for improving how and when the baseline inspections were conducted were considered.
It is tempting to remedy weaknesses by throwing more resources at them. For example, if widgets have been causing a flurry of recent near-misses, safety levels might be enhanced by conducting 40 hours of widget inspections each year. The same concept might also apply to doo-dads and other gizmos. Rather than diluting its inspection spotlight, the NRC sought to sharpen its focus by maintaining the overall number of baseline inspection hours constant. Every inspection hour added had to be offset by an inspection hour being eliminated. This could be accomplished a variety of ways. Some inspections examine samples of 15 items. Inspection hours could be reduced without compromising quality by sampling only 10 items if additional guidance is provided in selecting the “right” items. Additionally, inspections conducted every year could be changed to biannual inspections to save inspection hours.
During the review, the NRC conducted public meetings, solicited public comments and input, and made documents readily available for public viewing.
The NRC deserves an “Atta agency” for the ROP baseline inspection program review. The ROP protects the public from declining safety levels at nuclear power reactors. The NRC invested considerable time and effort in the review, which hopefully will culminate in upgrades to the inspection efforts that pay dividends for many years.
On February 5, 2014, the NRC conducted a public meeting to summarize the upgrades it planned to the baseline inspection program based on its year-long review. UCS was pleased to see that some of the planned changes address concerns we raised.
For example, slide 9 indicates that the guidance for engineering inspections will be revised to use feedback from the NRC’s Special Inspection Team (SIT) and Augmented Inspection Team (AIT) when selecting items to be examined. UCS had recommended this upgrade on slide 8 of our July 2013 presentation.
Slide 19 indicates the problem identification and resolution inspection procedure (i.e., the one used to evaluate whether owners are meeting the regulatory requirements in Appendix B to 10 CFR Part 50 to find and fix problems in a timely, effective manner) may be revised to focus on the effective of the corrective action programs instead of the adequacy of individual corrective actions. UCS had recommended this upgrade on slide 9 of our July 2013 presentation.
And slides 19 and 28 indicate that revisions are planned to periodically re-evaluate fixes implemented to problems outlined by NRC’s generic communications program. UCS had recommended this upgrade on slides 5 and 18 of our July 2013 presentation.
To be sure, UCS made other recommendations in our July 2013 presentation that the NRC does not plan to incorporate. That does not mean we were wrong to suggest them or that the NRC was wrong to reject them. Instead, it means the NRC’s review process worked. The NRC solicited input from a large number of internal and external stakeholders. The NRC prioritized the input and plans to implement the recommendations having the most potential for upgrading the effectiveness and efficiency of the baseline inspection program.
Atta agency, NRC!
“Fission Stories” is a weekly feature by Dave Lochbaum. For more information on nuclear power safety, see the nuclear safety section of UCS’s website and our interactive map, the Nuclear Power Information Tracker.