Fission Stories #157
The NRC originally licenses a nuclear power reactor to operate for 40 years. The NRC renews an operating license for an additional 20 years. An operating license gives the owner the right to operate the reactor, provided a plethora of regulatory requirements are met. Many of these regulatory requirements seek to ensure safety margins are maintained throughout the full term of the operating license rather than just until next week or next month.
Getting old is but one of the reasons safety margins can decrease, or disappear, over time. The bathtub curve shown below shows that wear-out failures can cause the overall failure rate to increase. As a result, considerable resources and attention are devoted to monitoring the condition of nuclear plant components and replacing or repairing them as required before aging degradation compromises safety margins.
That, at least, is the theory.
Earlier this year, the NRC’s Operating Experience Branch released a report following its review of data from 2007 to 2011, inclusive. The NRC staff reviewed records such as findings by NRC inspectors and Licensee Event Reports (LERs) submitted by plant owners. Among the NRC’s key findings:
- “Since 2009, there is a notable increase in the number of inspection findings and LERs involving highly reliable components whose failure was attributed to age degradation after being in service for over 15 years.”
- “It is interesting to note that in more than 75 percent of the 105 datum that were reviewed, it was determined that the System, Structure, or Component (SSC) either exceeded its recommended service life or was effectively run-to-failure. Thus, it is reasonable to question the oversight effectiveness of the baseline inspection program in this area.”
- “About 40 percent of the 77 inspection findings were also Appendix B related findings, but only seven were cited against Criterion III, Design Control. Appendix B, Criterion III required licensees to verify or check the adequacy of design if safety-related equipment will remain in service beyond its qualified life. Thus, with greater than two-thirds of findings and events involving SSCs left in service well beyond expected service life, it is reasonable to question why NRC oversight programs are not more focused on aging management of active SSCs.”
Bear in mind that NRC inspectors and plant owners don’t waste time and resources writing up age-related failures of lightbulbs in the warehouse and instead restrict their penmanship to failures of things that have a safety role to play in protecting workers and the public. Thus, the NRC’s report identified the inability of plant owners to prevent age-related failures coupled with the NRC’s inability to adequately enforce the regulatory requirements being violated.
That the NRC was inadequately enforcing regulatory requirements was documented in an audit report released on October 28, 2013, by the NRC’s Office of the Inspector General (OIG). OIG audited the NRC’s oversight of active component aging. (Active components are valves, motors, fans, electrical relays, etc. whereas passive components include pipes, supports, and tanks.)
OIG’s conclusion was critical:
“The NRC’s approach for oversight of licensee’s management of active component aging is not focused or coordinated. This has occurred because NRC has not conducted a systematic evaluation of program needs for overseeing licensees’ aging management for active components since the establishment of the Reactor Oversight Process (ROP) in 2000, and does not have mechanisms for systematic and continual monitoring, collecting, and trending of age-related data for active components. Consequently, NRC cannot be fully assured that it is effectively overseeing licensees’ management of aging active components.”
Per established protocols, OIG provided the NRC staff with its draft audit report and included the NRC staff’s response letter as Appendix B to the final report. In Appendix C of its final report, OIG provided a point-by-point rebuttal of the NRC staff’s arguments. OIG performed a masterfully brutal demolition of the NRC’s eleven positions. For example:
NRC Position: “NRC disagrees with the major premise of this audit, which is that the NRC oversight of active component aging is not being effectively dealt with under existing oversight programs.”
OIG Rebuttal: “The agency misunderstands and has misinterpreted the audit’s major premise.”
UCS Scoring: Point to OIG. OIG leads 1-0.
NRC Position: “Nearly all of the active component aging data contained within the Office of Nuclear Reactor Regulation (NRR) Operating Experience Branch (IOEB) Aging Study was derived from inspection findings in which NRC inspections effectively documented active component aging issues and cited associated violations of the regulations.”
OIG Rebuttal: “The agency’s claim that almost all of the 105 events were cited violations derived from inspection activity is inaccurate. In fact, more than half of the events in the report did not result in violations of any kind.”
UCS Scoring: Point to OIG. OIG leads 2-0.
NRC Position: “The staff also does not agree that its activities for managing active component aging are not focused or coordinated.”
OIG Rebuttal: “NRC’s approach for oversight of licensees’ management of active component aging is not focused or coordinated because NRC’s approach includes staff-initiated projects, using inspections that are not aging-related, and agency senior managers who are not aware of these uncoordinated activities.”
UCS Scoring: Point to OIG. OIG leads 3-0.
NRC position: “Licensee performance is assessed against these regulations under the Reactor Oversight Process (ROP), which allows inspectors and NRC managers to ensure regulatory compliance. The NRC deals with issues identified under the ROP in a performance based and risk informed manner.”
OIG Rebuttal: “OIG did note that NRC was not in a position to determine whether or not oversight of active aging components was effective because NRC had not collected or evaluated the requisite data to determine the need for further action regarding active component aging. In such a scenario, it would be inappropriate for OIG, NRC, or anybody else to conclude one way or the other whether the regulations or reporting methods were adequate.”
UCS Scoring: Point to OIG. OIG leads 4-0.
NRC Position: “The NRC staff points to the overall capability of the ROP (including the structure of the Significance Determination Process) and current reporting requirements as substantive evidence that there is adequate assurance that it is addressing active component aging issues impacting safety.”
OIG Rebuttal: “The agency did not provide substantive evidence of adequate assurance that it is addressing active component aging issues impacting safety. In fact, the agency provided no evidence and believes that active component issues are addressed through ROP.”
UCS Scoring: Point to OIG. OIG leads 5-0.
And so on. The final tally had OIG winning 11 to 0.
The blog’s title of “This is Getting Old” applies to both safety components at nuclear power plants and to the NRC’s tired denials.
The reason the NRC’s Operating Experience Branch reviewed five years of data was to ascertain what is working well and where improvements might be warranted. The report it produced well served that purpose.
OIG’s audit had a similar objective in determining where the NRC is doing well and where improvements are warranted. The audit report it produced fully met that objective.
Collectively, these reports constitute an action plan identifying which practices should be sustained and those practices to be supplemented or strengthened.
But instead of viewing the reports as roadmaps showing timely mid-course corrections, NRC’s senior management responded by essentially denying that the eleven problems even exist.
In a sad sense, they are quite right—it’s not that eleven problems exist. Their denial of the problems makes for an even dozen—the eleven problems joined by the stubborn refusal to authorize the improvements so clearly identified and badly needed.
The first step in any 12-step program involves admitting there’s a problem to be solved. NRC’s senior managers should stop their two-step pretending that no problems exist and start on the path to solutions.
“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.