Thursday, March 8, 2007

GAO Report---ignored by Hall?


HAVEN'T YOU READ YOUR OWN GAO REPORT?


In response to Several Democrats' call for an Independent Safety Assessment at Indian Point, I decided to see what resources were out there, if I were a congressperson, and just wanted to know how well NRC was managing Indian Point, without passing a special law, or holding a lot of wasteful press conferences.

And Whaddya know! I didn't have to believe NRC. I didn't have to ask Entergy. And I didn't have to pass a new law, either! The GAO, Congress' own investigative arm, had already published a report in September, 2006, describing just how well NRC was doing, managing the oversight of Indian Point.

I couldn't believe it! Had the anti-nuclear staffers of these Democrats hidden the GAO report from them? Probably, is my own conclusion.

Anyway, the report contains tables, showing Indian Point's safety rating improving continuously, since 2001. (2001 was the year that Entergy bought the place, by the way). The same charts show Indian Point firmly "In the Green". I guess that ought to reassure Hillary, and Mr Hall, Schumer & Hinchey.

All they have to do is read this post, or link to:
http://www.gao.gov/new.items/d061029.pdf
They don't have to even bother Congress with a useless new brouhaha, attracting a lot of attention, and wasting $20 million doing it! Of course, you don't get any media coverage, reading a report!



GAO-06-1029
September 2006


NUCLEAR
REGULATORY
COMMISSION
Oversight of Nuclear
Power Plant Safety
Much Improved

(these are exerpts, the whole report is much longer).

NRC provides an overall assessment of each plant’s performance through assessment letters issued to plants at the end of each 6-month period describing their specific performance and the level of oversight that will result. In addition, NRC has mechanisms to make available its oversight results, such as an Internet Web site devoted to the ROP that provides detailed summaries of each plant’s performance.

In the area of performance indicators, there were 156 instances out of more than 30,000 reports, or less than 1 percent, in which data reported for individual indicators were outside of NRC’s acceptable performance category. NRC assesses overall plant performance and communicates the results to licensees and the public on a semiannual basis.

Since 2001, the ROP has resulted in more than 4,000 inspection findings concerning nuclear power plant licensees’ failure to fully comply with NRC regulations and industry standards for safe plant operation, and NRC has subjected more than 75 percent (79) of the 103 operating plants to increased oversight for varying periods.

In addition, the nuclear power industry formed an organization, the Institute of Nuclear Power Operations (INPO), whose mission is to “promote the highest levels of safety and reliability, to promote excellence, in the operation of nuclear electric generating plants.” INPO provides a system of personnel training and qualification for all key positions at nuclear power plants, and workers undergo both periodic training and assessment. INPO also conducts periodic evaluations of operating plants, focusing on plant safety and reliability, in the areas of operations, maintenance, engineering, radiological protection, chemistry, and training. Licensees make the results of these evaluations available to NRC for review, and NRC staff use the evaluations as a means to determine whether its oversight process has missed any performance issues.


NRC increased its inspection resources by 9 percent in 2004, and then by another 5 percent in 2005, and was able to fully implement its baseline inspection program at all plants for both years. NRC reports show that resources expended in 2005 were almost 20 percent higher than those expended in 2002.With its current resource levels, NRC program officials believe they will be able to continue to implement all program requirements.


Physical plant inspections are the main tool NRC uses to oversee plant safety performance. NRC defined specific inspection areas by developing a list of those elements most critical to meeting the overall agency mission of ensuring nuclear power plant safety. These safety elements—or key plant inspection areas—are known as cornerstones.


During fiscal year 2005, NRC reported that inspectors spent 411,490 hours on plant inspections, which consist of baseline, supplemental, and special inspections. About 73 percent of this time was devoted to baseline inspections, which are conducted on an almost continuous basis. Baseline inspections are conducted by the NRC inspectors located at each site and specialists who travel to each site from NRC’s regional offices. These inspections are designed to detect declining safety performance in each of the cornerstones, and to review licensee effectiveness at identifying and resolving its safety problems. There are more than 30 baseline inspection procedures conducted at intervals that range from quarterly to triennially. Each of the baseline procedures specify a range of sample activities to inspect. Inspectors then select the type and number of activities to review on the basis of factors such as the sample activities available; their risk significance; the amount of time since a particular system or component was last inspected; and the inspector’s judgment, which is based on information such as reviews of the licensee’s corrective action program, allegations, or plant employee interviews. Risk is factored into the baseline inspection procedures in the following four ways: (1) areas of inspection are included in the set of baseline procedures, in part, on the basis of their risk importance; (2) risk information is used to help determine the frequency and scope of inspections; (3) the selection of activities to inspect within each procedure is informed with plant-specific risk information; and (4) the inspectors are trained in the use of risk information in planning their inspections. In addition to the more than 30 baseline inspection procedures, inspectors spend an average of 750 to 1,100 hours per year, conducting plant status reviews. These reviews are to ensure that inspectors are aware of plant conditions on a routine basis and include such activities as reviewing control room activities and status, attending licensee meetings, and conducting walk-downs of various plant areas.


Whether NRC takes enforcement actions in response to plant performance problems depends on whether there is a violation of a specific regulatory requirement.


When NRC issues greater-than-green inspection findings at a plant, it conducts supplemental inspections. One plant was subject to NRC’s highest oversight level in 2001 & 2002 because of a red finding for the failure of a steam generator tube. NRC conducted its most intensive supplemental inspection 2 months after the red finding was determined The licensee prepared a plan to address its deficiencies, and determined that a multiyear effort was necessary to develop and implement all corrective actions. Once the corrective actions were in place, NRC inspectors conducted follow-up inspections to examine the adequacy of the licensee’s efforts. Supplemental inspections, performed by regional staff, expand the scope beyond baseline inspection procedures and focus on diagnosing the cause of the performance
deficiency. There are three levels of supplemental inspections that are increasingly expansive in the breadth and depth of their analysis. The lowest level of supplemental inspection assesses the licensee’s corrective actions to ensure they were sufficient in both correcting the problem and identifying and addressing the root and contributing causes to prevent recurrence. The second level of supplemental inspection has an increased scope that includes independently assessing the extent of the condition for both the specific and any broader performance problems. The highest level of supplemental inspection is even more comprehensive and includes determining whether the plant can continue to operate and whether additional regulatory actions are necessary. The highest level of supplemental inspection is usually conducted by a multidisciplinary team of NRC inspectors and may take place over several months. Also, as a part of this supplemental inspection, NRC inspectors assess the adequacy of the licensee’s overall programs for identifying, evaluating, and correcting its performance issues, among other things.



In addition to its various inspections, NRC also collects plant performance information through its performance indicator program, which it maintains in cooperation with the nuclear power industry. On a quarterly basis, each plant submits data for 15 separate performance indicators—quantitative measures of plant performance related to safety in the different aspects of plant operations. Working with the nuclear power industry, NRC set thresholds for acceptable performance and assigned colors to each of the indicators to reflect increasing risk. In contrast to inspection findings, a green indicator does not indicate a performance deficiency but instead reflects performance
within the acceptable range, while white, yellow, and red represent decreasing levels of plant performance. NRC inspectors review and verify the data submitted for each performance indicator annually through their baseline inspections



On the basis of the results of its oversight process, NRC provides plant licensees and the public with an overall assessment of each plant’s performance. At the end of each 6-month period, NRC issues an assessment letter to each plant to describe its placement on the action matrix, what actions NRC is expecting the plant licensee to take as a result of the performance issues identified, any specific enforcement actions NRC has taken, and any documented substantive cross-cutting issues. If a substantive cross-cutting issue is identified, the letter will describe what actions NRC intends to take to monitor the issue and how the licensee is expected to respond to NRC with the corrective actions it intends to take. NRC also holds an annual public meeting at or near each site to review its performance and address questions from members of the public and other interested stakeholders.

In addition, NRC reviews the conclusions of independent plant assessments, such as those conducted by INPO. The purpose of this review is to selfassess the NRC inspection and assessment process to ensure that NRC is identifying similar performance issues.

NRC communicates the results of much of its oversight process to members of the public through an Internet Web site devoted to the ROP. This Web site makes available plants’ inspection reports and assessment letters, and other general materials related to NRC’s oversight process. NRC also provides a quarterly summary of every plant’s performance, consisting of its inspection findings, the color of each performance indicator, and its placement on the action matrix. NRC also provides a
short description of each inspection finding issued during the quarter.


In addition to its plant-level assessments, NRC assesses the results of its oversight process on an industry-level basis. NRC management holds an annual meeting to (1) discuss any significant performance issues identified at specific plants and (2) analyze the overall results of its inspection and performance indicator programs and compare them with other industrycollected and reported performance data. NRC program officials said that if they identified any negative trends or inconsistencies, they would take action to better understand and address the cause.
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The report , as are most GAO reports, is long, hard, dry reading. That should not have been an obstacle for a congress person truly dedicated to truth-finding, and his/her staff, PROVIDED NO BIAS, OR PRESET AGENDA WAS CARRIED INTO THE OFFICE WITH THEM.

The report clearly shows, in chart form, the vast improvements undertaken by Entergy, since buying Indian Point, as each year's successive NRC rating from 2001 thru 2005 (the last year looked at), ascends into higher & higher categories.

The report clearly mentions ACRS --the advisory committee on reactor safeguards, and mentions its role in taking an "outside look", at NRC's internal activities, as a kind of internal affairs department, as an impartial or independent referee. This function was brought out several weeks ago , in earlier posts on this blog, as fulfilling Mr. Hall's desire for an independent view.

True, Hall was not in office when this report was written, but I found it, so Mr. Hall's office ought to be at least as able to locate it as me.

So what are the choices?

1) read the report.

or

2) pass a law, to spend $20 million re-creating the report a year from now.


THE CORRECT CHOICE SEEMS OBVIOUS TO ME.


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