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Union of Concerned Scientists

duration of licensing proceedings. As a result, the NRC recently revised its regulations, such as Title 10 of the Code of Federal Regulations (CFR), Part 2, to restrict public involvement in these proceedings. Yet the case studies we have compiled for each of the 51 year-plus outages (see www.ucsusa.org/clean_energy/nuclear_safety) provide scant evidence to support this charge. In a small number of cases, such as Maine Yankee and Michigan’s Donald C. Cook, actions by the public did prolong the outages, but the record also clearly demonstrates that the public did not trump up baseless accusations or entangle the restart in pointless legal wrangling.

As noted above, most extended outages are the result of poor management and overly toler- ant regulatory oversight. It is therefore patently unfair to punish the public for the NRC’s failures and those of its licensees. The agency should take swift steps to remove these unwarranted restric- tions and restore the public to its meaningful role in licensing proceedings.

The other lessons we have learned from year-plus outages follow in descending order of importance and specificity.

Lesson 4: Corrective Action Programs (CAPs) Are Not Adequately Assessed

More than 70 percent of year-plus outages have been caused by broad, programmatic break- downs. Such breakdowns cannot, and did not, occur without a corresponding failure of the programs that were already in place to find and fix problems. Having an effective CAP is not simply prudent public policy and sound business practice; it is also a federal requirement (under Appendix B to 10 CFR Part 50). Nevertheless, the industry and the NRC have a poor track record of evaluating the health of these vital, mandatory programs.

The most recent—but far from the only— example is Ohio’s Davis-Besse. In March 2001,

the NRC gave high marks to the CAP at Davis-Besse:

The team concluded that the licensee effectively identified, evaluated, and corrected plant prob- lems. Problem identification was determined to be effective based on a low condition report initiation threshold and effective Quality Assurance audits and self assessments. . . . Root cause evaluations used structured techniques and were effective in identifying one or more root causes. Corrective actions specified appropriately matched the identified causes and were effective in preventing recurrence of significant condi- tions adverse to quality.

The inspectors conducted interviews with plant staff to assess whether there were impedi- ments to the establishment of a safety conscious work environment. . . . No significant findings were identified during the assessment of safety- conscious work environment. Plant staff interviewed indicated a willingness to identify safety issues. The low threshold for initiating CRs [corrective responses], the increasing number of CRs, and management support for using the CR process observed during the daily management meeting a so supported a safety conscious work environment.7

Less than a year later, workers at Davis-Besse discovered significant degradation of the reactor vessel head. The NRC sent another team to inspect the CA , which this time flunked:

This report documents a special corrective action program implementation team inspec- tion. The inspection was conducted to assess the adequacy of the licensee’s implementation of the facility’s corrective action program. . . . Two Green findings associated with two cited viola- tions, one Severity Level IV Non-Cited Violation (NCV), and twenty-six (26) Green findings associated with 26 NCVs were identified.

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