November 27, 2006

The Honorable Tom Davis

Chairman, Committee on Government Reform

United States House of Representatives

Washington, D.C. 20515

Dear Mr. Chairman:

On behalf of the U.S. Nuclear Regulatory Commission (NRC) and in accordance with

31 U.S.C. 720, enclosed is the NRC's response to the recommendations made by the U.S.

Government Accountability Office (GAO) in its report entitled “Nuclear Regulatory Commission: 

Oversight of Nuclear Power Plant Safety Has Improved, but Refinements Are Needed” (GAO06-1029). If you have any questions or comments, please contact me. 

Sincerely,

 /RA/

Dale E. Klein

Enclosure: 

NRC Response to GAO Recommendations

cc: Representative Henry Waxman
Identical letter sent to:

The Honorable Tom Davis 

Chairman, Committee on Government Reform

United States House of Representatives

Washington, D.C. 20515

cc: Representative Henry Waxman

The Honorable Susan Collins

Chair, Committee on Homeland Security

 and Governmental Affairs

United States Senate

Washington, D.C. 20510

cc: Senator Joseph I. Lieberman

The Honorable George V. Voinovich

Chairman, Subcommittee on Clean Air, 

 Climate Change, and Nuclear Safety

Committee on Environment and Public Works

United States Senate

Washington, D.C. 20510

cc: Senator Thomas Carper

The Honorable Ralph M. Hall

Chairman, Subcommittee on Energy 

 and Air Quality

Committee on Energy and Commerce

United States House of Representatives

Washington, D.C. 20515

cc: Representative Rick Boucher

The Honorable Joe Barton

Chairman, Committee on Energy and Commerce

United States House of Representatives

Washington, D.C. 20515

cc: Representative John D. Dingell

The Honorable James M. Inhofe

Chairman, Committee on Environment 

 and Public Works

United States Senate

Washington, D.C. 20510

cc: Senator James M. Jeffords

The Honorable David M. Walker

Comptroller General of the United States

U.S. Government Accountability Office

Washington, D.C. 20548

cc: James E. Wells, GAO

The Honorable Rob Portman

Director, Office of Management and Budget

Washington, D.C. 20503
Enclosure

NRC RESPONSE TO GAO RECOMMENDATIONS

In its report, “Nuclear Regulatory Commission: Oversight of Nuclear Power Plant Safety Has

Improved, but Refinements Are Needed” (GAO-06-1029), the U.S. Government Accountability

Office (GAO) made recommendations for improving the U.S. Nuclear Regulatory Commission’s

(NRC’s) ability to identify declining safety performance at nuclear power plants before

significant safety problems develop. Specifically, GAO recommended that the NRC:

1. Aggressively monitor; evaluate; and, if needed, implement additional methods or

processes to increase the effectiveness of its efforts under the reactor oversight process

(ROP) to assess safety culture at plants.

2. In addition to periodically evaluating the effectiveness of its safety culture efforts, NRC

may also be able, through its performance indicator program, to develop specific

indicators to measure important aspects of plants' safety culture. Trends in these

performance indicators could be useful feedback to NRC on its safety culture activities.

The indicators could also provide useful information to the public and other NRC

stakeholders on the safety culture at plants.

3. In the absence of performance indicators or other performance metrics for plants' safety

culture, make publicly available, through the ROP Web site, consolidated and

comprehensive data on the plants that have substantive, open cross-cutting issues to

provide a more comprehensive picture of plant performance and provide insights into

aspects of the plants' safety culture that otherwise are not readily available on the Web

site.

NRC Response:

As noted in the GAO’s report, the staff has taken significant actions to incorporate safety

culture into the ROP. These efforts included: (1) implementing a multi-office ROP safety

culture focus team to resolve implementation issues, to interface with internal and external

stakeholders, and to evaluate and act on lessons learned; (2) revising guidance documents and

inspection procedures to further define key safety culture aspects and prescribe when an

independent assessment of a licensee’s safety culture is warranted based on licensee

performance; (3) conducting training for inspectors on the safety culture ROP changes; and

(4) interacting with external stakeholders during the development phase, including the

opportunity to provide comments on the draft ROP documents that incorporated the safety

culture changes. 

The staff is monitoring the implementation of the safety culture enhancements through the NRC

safety culture focus team. An 18-month initial implementation period is under way, during

which time the NRC staff will monitor and evaluate the effectiveness of the enhancements using

performance metrics through its self-assessment process. We will determine the need to

implement additional methods or processes to increase the effectiveness of the ROP based on

the lessons learned during this initial implementation phase. 
-2-

The NRC is revising Inspection Manual Chapter (IMC) 0307, “Reactor Oversight Process SelfAssessment Program,” to add specific measures to determine the effectiveness of this

important initiative. In support of this effort, we have added specific questions to the internal

and external ROP surveys, which are currently being administered, in order to solicit feedback

on the safety culture effort. The survey responses will be consolidated and analyzed, and the

results will be presented in the annual performance metric report and discussed in the annual

ROP self-assessment provided to the Commission for review.

NRC believes the annual ROP self-assessment process and performance metric report, versus

the ROP performance indicator program, are better tools to gather and assess feedback on the

safety culture enhancements. We will use these feedback processes to provide useful

information to internal and external stakeholders, and make the ROP more efficient and

effective at identifying declining licensee performance. 

As a first step in the process, and as recommended by the GAO, we have added a Web page

that presents consolidated and comprehensive data on the plants that have substantive, open

cross-cutting issues. We plan further refinements to the ROP Web pages to more prominently

highlight plants that have substantive cross-cutting issues to provide a more comprehensive

picture of plant performance.