oversight

Major Management Challenges and Program Risks: Nuclear Regulatory Commission

Published by the Government Accountability Office on 1999-01-01.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                United States General Accounting Office

GAO             Performance and Accountability
                Series




January 1999
                Major Management
                Challenges and Program
                Risks
                Nuclear Regulatory
                Commission




GAO/OCG-99-19
GAO   United States
      General Accounting Office
      Washington, D.C. 20548

      Comptroller General
      of the United States



      January 1999
      The President of the Senate
      The Speaker of the House of Representatives

      This report addresses the major performance and
      management challenges that have limited the Nuclear
      Regulatory Commission’s (NRC) effectiveness. The report
      also provides information on actions that NRC has taken
      or initiated to address these challenges. For many years,
      we have raised concerns about whether NRC is effectively
      carrying out its safety mission. The performance and
      management challenges identified are the result of NRC
      not defining the conditions that are necessary for a
      nuclear plant’s safety, not being aggressive in requiring
      utilities to comply with safety regulations, and not
      holding utilities accountable for fixing problems more
      promptly and addressing management issues more
      directly.

      NRC  has undertaken various initiatives to help ensure that
      it carries out its regulatory mission more effectively and
      efficiently. These efforts show a commitment by NRC to
      strengthen its oversight and resolve long-standing
      challenges. However, given the nature and extent of the
      challenges facing NRC, it will take time to implement and
      assess the impact of the various initiatives.

      This report is part of a special series entitled the
      Performance and Accountability Series: Major
      Management Challenges and Program Risks. The series
contains separate reports on 20 agencies—one on each of
the cabinet departments and on most major independent
agencies as well as the U.S. Postal Service. The series
also includes a governmentwide report that draws from
the agency-specific reports to identify the performance
and management challenges requiring attention across
the federal government. As a companion volume to this
series, GAO is issuing an update to those government
operations and programs that its work has identified as
“high risk” because of their greater vulnerabilities to
waste, fraud, abuse, and mismanagement. High-risk
government operations are also identified and discussed
in detail in the appropriate performance and
accountability series agency reports.

The performance and accountability series was done at
the request of the Majority Leader of the House of
Representatives, Dick Armey; the Chairman of the House
Government Reform Committee, Dan Burton; the
Chairman of the House Budget Committee, John Kasich;
the Chairman of the Senate Committee on Governmental
Affairs, Fred Thompson; the Chairman of the Senate
Budget Committee, Pete Domenici; and Senator Larry
Craig. The series was subsequently cosponsored by the
Ranking Minority Member of the House Government
Reform Committee, Henry A. Waxman; the Ranking
Minority Member, Subcommittee on Government
Management, Information and Technology, House
Government Reform Committee, Dennis J. Kucinich;
Senator Joseph I. Lieberman; and Senator Carl Levin.




            Page 2              GAO/OCG-99-19 NRC Challenges
Copies of this report series are being sent to the
President, the congressional leadership, all other
Members of the Congress, the Director of the Office of
Management and Budget, the Chairman of the Nuclear
Regulatory Commission, and the heads of other major
departments and agencies.




David M. Walker
Comptroller General of
the United States




            Page 3               GAO/OCG-99-19 NRC Challenges
Contents



Overview                                             6

Major                                               11
Performance and
Management
Issues
Related GAO                                         23
Products
Performance and                                     24
Accountability
Series




                  Page 4   GAO/OCG-99-19 NRC Challenges
Page 5   GAO/OCG-99-19 NRC Challenges
Overview



           Today, nuclear energy supplies electricity to
           about 65 million households, meeting about
           20 percent of the nation’s needs. The Nuclear
           Regulatory Commission (NRC) is responsible
           for, among other things, ensuring that the
           nation’s 103 operating commercial nuclear
           power plants pose no undue risk to public
           health and safety. We, the Congress, NRC’s
           Office of the Inspector General (OIG), and
           others have raised concerns about whether
           NRC is effectively carrying out its safety
           mission. NRC’s management challenges have
           a long history, and the agency has been
           assessing the strengths and weaknesses of
           its regulatory programs and policies to
           address them. Now, however, the entire
           electric utility industry is faced with an
           unprecedented, overarching development:
           the economic restructuring of the nation’s
           electric power system, from a regulated
           industry to one driven by competition.
           According to one study, as many as 26 of the
           nation’s nuclear sites are vulnerable to
           shutdown because production costs are
           higher than the projected market prices of
           electricity. As the electric utility industry is
           deregulated, operating and maintenance
           costs will affect the competitiveness of
           nuclear power plants. Competition
           challenges NRC to reduce any unnecessary
           regulatory burden while ensuring that safety


           Page 6                GAO/OCG-99-19 NRC Challenges
                     Overview




                     margins are not compromised by utilities’
                     cost-cutting measures.


The Challenges       Today, the major management challenges at
                     NRC are as follows:



NRC Lacks            NRC lacks assurance that its current
Assurance of         regulatory approach ensures safety. NRC
Nuclear Plants’      assumes that plants are safe if they operate
Safety               as designed and follow NRC’s regulations.
                     However, NRC’s regulations and other
                     guidance do not define, for either a licensee
                     or the public, the conditions necessary for a
                     plant’s safety; therefore, determining a
                     plant’s safety is subjective. Furthermore, six
                     major reviews of NRC since 1979 have
                     pointed out that NRC’s regulatory approach is
                     punitive rather than results oriented,
                     licensees are forced to expend considerable
                     resources on complying with regulations
                     that may have a limited impact on safety,
                     and NRC’s focus on achieving compliance
                     with paperwork requirements can divert
                     attention from safety activities.


NRC Is Slow to       NRC’s oversight has been inadequate and
Require Corrective   slow. Although NRC’s indicators show that
Action               conditions throughout the nuclear energy


                     Page 7               GAO/OCG-99-19 NRC Challenges
                    Overview




                    industry have generally improved, they also
                    show that several nuclear plants are
                    chronically poor performers. At three
                    nuclear plants with long-standing safety
                    problems that we reviewed, NRC did not take
                    aggressive action to ensure that the utilities
                    corrected the problems. The problems
                    ranged from failures of equipment to work
                    properly when tested to weaknesses in
                    licensees’ conduct of maintenance programs.
                    As a result of NRC’s inaction, the conditions
                    at the plants worsened, reducing safety
                    margins.


NRC’s Culture and   NRC’s  culture and organizational structure
Organizational      have made the process of addressing
Structure Impede    concerns with the agency’s regulatory
Effective Actions   approach slow and ineffective. Since 1979,
                    various reviews have concluded that NRC’s
                    organizational structure, inadequate
                    management control, and inability to oversee
                    itself have impeded its effectiveness.


Progress and        Even before competition became an issue,
Next Steps          NRC and the nuclear utility industry
                    embarked on initiatives to address
                    long-standing regulatory issues, including
                    the management challenges described in this
                    report, in a way that would ensure that NRC


                    Page 8               GAO/OCG-99-19 NRC Challenges
Overview




carried out its regulatory mission more
effectively and efficiently. These initiatives
are designed to improve safety
decisionmaking through the analysis of risk,
use agency resources more efficiently, and
reduce unnecessary burdens on utilities. In
August 1998, NRC identified various
regulatory efforts and milestones for their
completion. Although NRC will implement
some initiatives in the near future, it will
take some years to complete its efforts.

A framework within which NRC can
accomplish its missions has been provided
by the Government Performance and Results
Act of 1993. The Results Act requires federal
agencies to develop goals, objectives,
strategies, and performance measures in the
form of strategic and performance plans. In
our review of NRC’s first annual performance
plan, covering program activities set out in
the agency’s fiscal year 1999 budget, we
noted that the plan could provide a clearer
picture of intended performance across NRC
and better discuss the strategies and
resources the agency will use to achieve its
performance goals. Although the plan lists
specific strategies NRC will use against
licensees that fail to meet regulatory
standards, including halting operations if
performance falls below an acceptable level,


Page 9                GAO/OCG-99-19 NRC Challenges
              Overview




              NRC  has not developed specific criteria for
              what is “acceptable.” The development of
              strategic and performance plans is a
              dynamic process. Until more experience in
              setting goals and measuring results is
              achieved, better information will not be
              available to evaluate progress towards
              improving NRC’s performance.


Key Contact   Ms. Gary L. Jones, Associate Director
              Energy, Resources, and Science Issues
              Resources, Community, and Economic
                Development Division
              (202) 512-3841
              jonesg.rced@gao.gov




              Page 10              GAO/OCG-99-19 NRC Challenges
Major Performance and Management
Issues


            Commercial nuclear power plants operate in
            31 states and provide about 20 percent of the
            nation’s electricity. Five states (Connecticut,
            Illinois, New Jersey, South Carolina, and
            Vermont) rely on nuclear power for about
            half of their electricity. One of NRC’s missions
            is to ensure that utilities operating nuclear
            power plants do so safely. Identifying
            nuclear plants with safety problems and
            making sure that their owners—licensees—
            correct these problems promptly are
            activities essential to NRC’s safety mission.
            With the restructuring of the nation’s electric
            power industry and the emergence of
            competition in the business of electricity
            generation, NRC will need to exercise
            vigilance to ensure that utilities’ decisions
            related to safety will not be driven primarily
            by economic considerations.

            We, NRC’s OIG, and others have documented
            problems with NRC’s performance and
            management and have recommended
            reforms. This report summarizes these
            various findings, including NRC’s lack of a
            definition of safety and lack of
            aggressiveness in requiring utilities to
            comply with safety regulations, as well as
            the impediments to effective oversight
            presented by NRC’s culture and organization.



            Page 11               GAO/OCG-99-19 NRC Challenges
                  Major Performance and Management
                  Issues




NRC Lacks         Six major reviews conducted between 1979
Assurance of      and 1994 concluded that NRC lacks objective
Nuclear Plants’   criteria for many of its regulatory actions
Safety            and that its focus on achieving compliance
                  on paper can divert attention from such
                  safety activities as inspection and
                  enforcement.1 Since that time, NRC has
                  undertaken various actions to improve its
                  regulatory programs, and industrywide
                  safety indicators have shown continued and
                  significant improvements. Nevertheless, in
                  1997, we found that NRC lacks assurance that
                  its current regulatory approach ensures
                  safety at all plants. We reported that the
                  Congress and the public need confidence in
                  NRC’s ability to ensure that the nuclear
                  industry performs to high safety standards.
                  Although we made no judgments about the
                  safety of nuclear plants or the
                  appropriateness of NRC’s current regulatory
                  structure, the many safety problems


                  1
                   The six reviews were (1) The Report of the President’s
                  Commission on the Accident at Three Mile Island (1979); (2) Three
                  Mile Island: A Report to the Commissioners and to the Public
                  (1980); (3) Survey by Senior Management to Obtain Viewpoints on
                  the Safety Impacts of Regulatory Activities From Representative
                  Utilities Operating and Constructing Nuclear Power Plants (1981);
                  (4) a three-part survey: Industry Perceptions of the Impact of the
                  U.S. Nuclear Regulatory Commission on Nuclear Power Plant
                  Activities, Results of Industry Survey on Licensee Management
                  Involvement in Inspections and Audits, and Survey of Staff Insights
                  on Regulatory Impact (1989); (5) Nuclear Power - Technical and
                  Institutional Options for the Future, National Academy of Sciences
                  (1992), and (6) Nuclear Regulatory Review Study (1994).

                  Page 12                        GAO/OCG-99-19 NRC Challenges
    Major Performance and Management
    Issues




    identified at three plants we examined raised
    questions about whether NRC’s regulatory
    program was working as it should.
    Specifically, we found the following:

•   Determining the safety of nuclear plants is
    difficult because NRC does not precisely
    define safety. Instead, NRC assumes that
    plants are safe if they operate as designed (in
    accordance with their design bases) and
    meet NRC’s regulations. Yet NRC’s regulations
    and other guidance focus on procedural and
    operational requirements for plants’
    equipment and utility practices and do not
    define, for either licensees or the public, the
    conditions necessary for plants’ safety. NRC
    reasons that the many redundant safety
    features and systems built into a plant’s
    design provide an adequate margin of safety,
    even when some are not working properly.
    However, changes made to a plant over
    time—for example, replacing components
    with different parts and reconfiguring
    systems—can alter the plant’s design, thus
    potentially affecting how certain safety
    systems may work in an emergency. NRC
    does not have an effective way to quantify
    the safety of plants that deviate from their
    approved designs.




    Page 13                 GAO/OCG-99-19 NRC Challenges
    Major Performance and Management
    Issues




•   NRC  has incomplete knowledge of the extent
    to which nuclear plants are operating as
    designed. In the mid- to late 1980s, NRC found
    that some utilities were not documenting
    changes that could affect the safe operation
    of the plants. However, it was not until
    October 1996, after problems were
    discovered with Millstone Unit 1 in
    Connecticut, that NRC required utilities to
    certify that their plants were operating as
    designed. To follow up on utilities’
    certifications, NRC inspected 21 sites (26
    units), all previously targeted for follow-up
    inspections, to verify that the plants were
    operating under the terms and conditions of
    their licenses. Generally, NRC found that
    some utilities had not maintained current
    information on their plants’ designs and had
    not examined the impact of modifications on
    the safety of the plants’ operations. NRC
    identified significant problems during these
    inspections, including instances in which
    utilities had not properly tested
    safety-related components and had made
    errors in their analyses of how emergency
    cooling systems would work in case of an
    accident. NRC concluded that the majority of
    the problems resulted from errors in the
    original design or from design modifications,
    inadequate testing, and discrepancies in
    documentation. As of November 1998, NRC
    had completed all the planned inspections

    Page 14                 GAO/OCG-99-19 NRC Challenges
    Major Performance and Management
    Issues




    and was evaluating the results. As a result of
    the inspections, NRC initiated escalated
    enforcement actions for violations found at
    five plants. A utility shut down one of the
    five plants as a result of an inspection’s
    findings.
•   NRC faces many challenges to make its
    regulatory program work as effectively as
    possible, particularly in light of major
    changes taking place in the nuclear industry.
    As the electric utility industry is deregulated,
    safety margins may be compromised when
    licensees cut costs to stay competitive.
    According to one study, as many as 26 of the
    nation’s nuclear sites are vulnerable to
    shutdown because production costs are
    higher than the projected market prices of
    electricity. NRC will be deciding what
    constitutes safety and how nuclear plants
    should be regulated in the future. NRC also
    has initiated a major effort to consider risk
    in its regulatory decisions and activities.
    NRC’s regulatory approach needs to be
    anchored in goals and objectives that are
    clearly articulated and performance
    measures that hold NRC managers as well as
    licensees accountable.

    During deliberations on the fiscal year 1999
    budget, both the Senate and House
    Committees on Appropriations were highly


    Page 15                 GAO/OCG-99-19 NRC Challenges
Major Performance and Management
Issues




critical of NRC. Most of the Committees’
concerns focused on NRC’s oversight of
commercial nuclear power plants in the
areas of inspection, performance
assessment, and enforcement; risk-informed,
performance-based regulation; and
organizational structure and resources.
Questions from Members of Congress
revealed a perception that NRC’s
requirements and expectations for utilities
that operate commercial nuclear power
plants are not clear and that NRC has created
an atmosphere of regulatory uncertainty. In
response to the criticisms raised, NRC has
been assessing the strengths and weaknesses
of its regulatory programs and policies to
(1) better understand their impact on the
industries it regulates and (2) determine
whether it responds effectively to changes in
the regulatory environment. Specifically, in
August 1998, NRC identified various
areas—including risk-informed regulation,
inspection, enforcement, organizational
structure, resources, and other issues, such
as license transfers and decommissioning—
and compiled a catalog of short- and
long-term actions and milestones to address
each of the areas. We agree that the actions
NRC has under way are worthwhile steps.
Although NRC will implement some initiatives
in the near future, it will take some years to
complete these activities.
Page 16                 GAO/OCG-99-19 NRC Challenges
                    Major Performance and Management
                    Issues




NRC Is Slow to      NRC  did not take aggressive action at three
Require             facilities we examined that had
Corrective Action   long-standing safety and performance
                    problems. The problems ranged from
                    failures of equipment to work properly when
                    tested to weaknesses in how licensees
                    conducted their maintenance programs. As a
                    result, conditions at the plants worsened,
                    reducing safety margins. NRC staff repeatedly
                    gave the plants’ operators more time to take
                    corrective actions and were slow to place
                    plants with declining performance on NRC’s
                    “Watch List”—a list of plants with declining
                    performance trends that require closer
                    regulatory attention.

                    NRC’s  programs are designed to ensure that
                    utilities comply with NRC’s regulations, take
                    prompt actions to correct any deficiencies
                    found, and operate their plants safely. NRC
                    gives utilities considerable latitude to fix
                    their problems. This strategy works well
                    when the utilities’ managers place priority on
                    maintaining a strong safety culture. We
                    found, however, that this condition was not
                    present in the three plants we examined and
                    that the problems worsened when NRC did
                    not hold the utilities accountable for fixing
                    them. For example, some of the problems
                    that caused the 1994-95 shutdown of the
                    Cooper Nuclear Station in Nebraska dated


                    Page 17                 GAO/OCG-99-19 NRC Challenges
Major Performance and Management
Issues




back to 1974, when the plant started
operations. According to NRC inspectors with
whom we spoke, the utility’s management
should have addressed the problems years
earlier. In addition, NRC was very slow to
impose fines on the three plants we
examined. For example, NRC levied the first
fine on one utility well after its plants had
begun to decline. NRC’s OIG reported similar
findings, noting that one utility lulled NRC
into allowing an excessive amount of time to
institute proposed corrective actions. NRC is
strengthening its processes for assessing the
effectiveness of utilities’ corrective action
programs and tracking and verifying utilities’
commitments.

We also found that NRC’s safety oversight has
not focused on the competency of nuclear
plant management, even though the nuclear
industry and NRC officials widely agree that
such competency is perhaps the most critical
factor in safe performance. For example, NRC
found safety problems at nuclear plants in
Illinois in January 1997 that the agency
attributed to weak management processes
and a lack of involvement by management.
Although NRC staff had proposed options to
assess the performance and competency of
the utilities’ management, the agency
rejected the options in June 1998 and


Page 18                 GAO/OCG-99-19 NRC Challenges
                    Major Performance and Management
                    Issues




                    directed its staff to continue inferring
                    competency on the basis of plant inspections
                    and other routine assessments.

                    NRC’s  Chairman has complained about the
                    consequences of NRC’s patience with some
                    problem utilities, adding that the agency is
                    reviewing its internal processes to
                    strengthen its ability to identify and act on
                    utilities’ corrective action programs. NRC
                    staff agreed that they need to do a better job
                    of making utilities fix their problems and
                    bring to management’s attention those
                    utilities that are not responsive. NRC is
                    examining its inspection, enforcement, and
                    plant performance assessment programs to,
                    in part, address these issues. These efforts
                    show a commitment by NRC to strengthen its
                    oversight. In doing so, NRC must hold utilities
                    accountable for fixing problems more
                    promptly and addressing management issues
                    more directly.


NRC’s Culture       At the heart of safe plant operations is NRC’s
and                 holding utilities accountable for fixing
Organizational      problems more promptly and addressing
Structure Impede    management issues more directly. The need
Effective Actions   to ensure that NRC’s regulatory programs
                    work as effectively as possible is extremely
                    important, particularly in light of major


                    Page 19                 GAO/OCG-99-19 NRC Challenges
Major Performance and Management
Issues




changes taking place in the electric utility
industry. Yet changing NRC’s culture will not
be easy. Six major reviews conducted since
1979 found chronic and significant problems
with NRC’s regulatory culture. The most
recent review, sponsored by the industry and
completed in October 1994, concluded that
NRC had been unable or unwilling to address
its own problems. The 1994 review also
found that NRC’s management did not
adequately control and oversee its own staff,
programs, and operations and that each NRC
unit acted somewhat independently,
resulting in decisions that often conflicted
with one another. The review also found that
because of significant duplication and
conflict in roles and responsibilities among
various NRC offices, licensees had differing
relationships with the offices, leading to
confusion in regulatory interpretations.

Since the 1994 review, NRC has taken various
actions to improve its organization and
culture. For example, in August 1995, NRC
initiated the Strategic Assessment and
Rebaselining Project to streamline its
operations. This effort was intended to take
a new look at NRC, redefine the basic nature
of the work and the means by which that
work is accomplished, and apply the
redefined activities to a rigorous screening


Page 20                 GAO/OCG-99-19 NRC Challenges
Major Performance and Management
Issues




to produce a new set of assumptions, goals,
and strategies (rebaseline). The rebaselining
project provided the foundation for NRC to
implement the Government Performance
and Results Act and to develop an
agencywide planning, budgeting, and
performance management process that
builds in accountability and self-assessment
and provides a mechanism for NRC to refocus
its efforts and resources in response to
change. In 1996, NRC began to strengthen its
skills in certain key processes and to identify
opportunities for efficiency and
effectiveness.

Despite these activities, in the fall of 1997,
NRC’s OIG surveyed NRC staff to obtain their
views on the agency’s safety culture. In its
June 1998 report, the OIG noted that the staff
had a strong commitment to protecting
public health and safety but expressed high
levels of uncertainty and confusion about the
new directions in regulatory practices and
challenges facing the agency. The employees
said that, in their view, they spend too much
time on paperwork that may not contribute
to the safety mission of the organization.
From the results of the survey as a whole,
the OIG concluded that without significant
and meaningful improvement in
management’s leadership, employees’


Page 21                 GAO/OCG-99-19 NRC Challenges
Major Performance and Management
Issues




involvement, and communication, NRC’s
current climate could eventually erode the
employees’ outlook and commitment to
doing their job.




Page 22                 GAO/OCG-99-19 NRC Challenges
Related GAO Products



            Results Act: NRC’s Annual Performance Plan
            for Fiscal Year 1999 (GAO/RCED-98-195R, May 27,
            1998).

            Nuclear Regulation: Preventing Problem
            Plants Requires More Effective NRC Action
            (GAO/RCED-97-145, May 30, 1997).

            Nuclear Regulatory Commission: Preventing
            Problem Plants Requires More Effective
            Action by NRC (GAO/T-RCED-98-252, July 30,
            1998).




            Page 23               GAO/OCG-99-19 NRC Challenges
Performance and Accountability Series



             Major Management Challenges and Program
             Risks: A Governmentwide Perspective
             (GAO/OCG-99-1)

             Major Management Challenges and Program
             Risks: Department of Agriculture
             (GAO/OCG-99-2)

             Major Management Challenges and Program
             Risks: Department of Commerce
             (GAO/OCG-99-3)

             Major Management Challenges and Program
             Risks: Department of Defense (GAO/OCG-99-4)

             Major Management Challenges and Program
             Risks: Department of Education
             (GAO/OCG-99-5)

             Major Management Challenges and Program
             Risks: Department of Energy (GAO/OCG-99-6)

             Major Management Challenges and Program
             Risks: Department of Health and Human
             Services (GAO/OCG-99-7)

             Major Management Challenges and Program
             Risks: Department of Housing and Urban
             Development (GAO/OCG-99-8)




             Page 24             GAO/OCG-99-19 NRC Challenges
Performance and Accountability Series




Major Management Challenges and Program
Risks: Department of the Interior
(GAO/OCG-99-9)

Major Management Challenges and Program
Risks: Department of Justice (GAO/OCG-99-10)

Major Management Challenges and Program
Risks: Department of Labor (GAO/OCG-99-11)

Major Management Challenges and Program
Risks: Department of State (GAO/OCG-99-12)

Major Management Challenges and Program
Risks: Department of Transportation
(GAO/OCG-99-13)

Major Management Challenges and Program
Risks: Department of the Treasury
(GAO/OCG-99-14)

Major Management Challenges and Program
Risks: Department of Veterans Affairs
(GAO/OCG-99-15)

Major Management Challenges and Program
Risks: Agency for International Development
(GAO/OCG-99-16)




Page 25                    GAO/OCG-99-19 NRC Challenges
Performance and Accountability Series




Major Management Challenges and Program
Risks: Environmental Protection Agency
(GAO/OCG-99-17)

Major Management Challenges and Program
Risks: National Aeronautics and Space
Administration (GAO/OCG-99-18)

Major Management Challenges and Program
Risks: Nuclear Regulatory Commission
(GAO/OCG-99-19)

Major Management Challenges and Program
Risks: Social Security Administration
(GAO/OCG-99-20)

Major Management Challenges and Program
Risks: U.S. Postal Service (GAO/OCG-99-21)

High-Risk Series: An Update (GAO/HR-99-1)




The entire series of 21 performance and
accountability reports and the high-risk
series update can be ordered by using
the order number GAO/OCG-99-22SET.




Page 26                    GAO/OCG-99-19 NRC Challenges
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