a

GAO

United States Government Accountability Office

Report to Congressional Requesters

September 2006 NUCLEAR 

REGULATORY 

COMMISSION

Oversight of Nuclear 

Power Plant Safety 

Has Improved, but 

Refinements Are 

Needed

GAO-06-1029
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2006

NUCLEAR REGULATORY COMMISSION

Oversight of Nuclear Power Plant Safety 

Has Improved, but Refinements Are 

Needed 

Highlights of GAO-06-1029, a report to 

congressional requesters 

The Nuclear Regulatory

Commission (NRC) is responsible 

for overseeing the nation’s 103 

commercial nuclear power plants 

to ensure they are operated safely. 

The safety of these plants has 

always been important, since an 

accident could release harmful 

radioactive material. NRC’s

oversight has become even more 

critical as the potential resurgence

of nuclear power is considered. 

NRC implemented a new Reactor 

Oversight Process (ROP) in 2000 to

address weaknesses in its oversight 

of nuclear plant safety. 

In this report, GAO reviewed 

(1) how NRC oversees nuclear 

power plants, (2) the results of the 

ROP over the past several years, 

and (3) the status of NRC’s efforts 

to improve the ROP. To complete 

this work, GAO analyzed 

programwide information, 

inspection results covering 5 years 

of ROP operations, and detailed 

findings from a nonprobability 

sample of 11 plants. 

What GAO Recommends

GAO recommends that NRC 

aggressively monitor; evaluate; and,

if needed, implement additional 

measures to increase the 

effectiveness of its safety culture

changes and make publicly

available more information on 

nuclear power plants’ safety 

culture. In commenting on a draft

of this report, NRC generally 

agreed with GAO’s findings,

conclusions, and

recommendations. 

NRC uses various tools and takes a risk-informed and graded approach to 

ensure the safety of nuclear power plants. These tools consist of physical 

inspections of plants and quantitative measures or indicators of plant 

performance. They are risk-informed in that they focus on the aspects of 

operations considered most important to plant safety. On the basis of the 

results of this information, NRC takes a graded approach to its oversight, 

increasing the level of regulatory attention to plants where safety is 

declining. NRC assesses overall plant performance and communicates the 

results to the public, including providing detailed results of its oversight 

process through a Web site devoted to the ROP. 

Since 2001, the ROP has resulted in more than 4,000 inspection findings 

concerning plants’ failure to fully comply with safe operating procedures,

and NRC has subjected more than 75 percent (79) of the 103 plants to 

increased oversight for varying periods. Almost all of the inspection findings 

were for actions NRC considered important to correct but of low 

significance to safe plant operations. While the majority of plants received 

some level of increased oversight, only 5 plants were subjected to NRC’s 

highest level of oversight. Plants in this category were generally subjected to 

this higher oversight for long periods due to the more systemic nature of 

their performance problems. 

NRC has improved its oversight process in various areas, but it has been 

slow to act on needed improvements, particularly in improving the agency’s 

ability to identify and address early indications of declining safety

performance. NRC is improving its oversight process on the basis of 

feedback from stakeholders, including better focusing inspections on areas 

most important to safety. NRC also is addressing what GAO believes has 

been a significant shortcoming by modifying the ROP to improve its ability 

to address plants’ safety culture—that is, the organizational characteristics

that ensure issues affecting nuclear plant safety receive the attention their 

significance warrants. GAO and others, including some stakeholders, 

believe these changes could enable NRC to better identify safety culture 

issues and thus provide earlier indications of declining plant safety 

performance. However, some in the industry have opposed the changes 

because they believe the changes could introduce undue subjectivity to 

NRC’s oversight, given the difficulty in measuring these often intangible and 

complex concepts. NRC has been reluctant to incorporate safety culture 

into the ROP because it considered this type of activity as a management 

function, and NRC did not believe that it should be directly involved in 

managing licensees’ plants. NRC program officials view the current changes 

as the beginning of an incremental approach and acknowledge that they will 

need to assess their effectiveness at identifying declining safety performance 

at plants before significant safety events occur. 

www.gao.gov/cgi-bin/getrpt?GAO-06-1029.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Jim Wells at 

(202) 512-3841 or wellsj@gao.gov. 
Page i GAO-06-1029 Oversight of Nuclear Power Plant Safety

Contents

Letter 1

Results in Brief 3

Background 6

NRC Uses Various Tools and Takes a Risk-Informed and Graded 

Approach to Ensuring the Safety of Nuclear Power Plants 11

NRC Has Identified Low Risk Problems at Nuclear Power Plants, 

Resulting in Increased Oversight for Varying Periods 21

NRC Is Addressing Weaknesses in Various Areas of Its Oversight 

Process, but More Effort Is Needed 28

Conclusions 38

Recommendations for Executive Action 39

Agency Comments 40

Appendixes

Appendix I: Key Safety-Related Events at the Salem and Hope Creek 

Nuclear Power Plants from 2000 to 2006 43

Summary of Key Safety-Related Events at Salem and Hope Creek, 

April 2000 to June 2006 44

Appendix II: Scope and Methodology 51

Appendix III: Nuclear Power Plant Performance Data on the Basis of the 

Results of NRC’s Reactor Oversight Process, 2001 Through 

2005 55

Appendix IV: Comments from the Nuclear Regulatory Commission 73

Appendix V: GAO Contact and Staff Acknowledgments 74

Tables Table 1: Key ROP Plant Inspection Areas, or Cornerstones 12

Table 2: NRC Reactor Oversight Process Action Matrix 18

Table 3: Commercial Nuclear Power Plants Licensed to Operate in 

the United States 55

Table 4: Total Number of Green Inspection Findings, 2001 Through 

2005 58

Table 5: Total Number of Greater-Than-Green Inspection Findings 

Issued, 2001 Through 2005 60

Table 6: Type of Substantive Cross-cutting Issue Open At Least 

Some Portion of the Year, 2001 Through 2005 62

Table 7: Total Number of Greater-Than-Green Performance 

Indicators, 2001 Through 2005 65
Contents

Page ii GAO-06-1029 Oversight of Nuclear Power Plant Safety

Table 8: Highest NRC Oversight Level Applied during at Least Some 

Portion of the Year, 2001 Through 2005 69

Figures Figure 1: NRC Regions and Operating Nuclear Power Plant Sites in 

the United States 8

Figure 2: NRC’s Oversight Process in Determining Plant Placement 

on the Action Matrix 17

Figure 3: Number of Inspection Findings at All Plants, 2001 

Through 2005 23

Figure 4: Number of Inspection Findings and Inspection Findings 

with Cross-Cutting Aspects at All Plants, 2001 Through 

2005 24

Figure 5: Number of Plants with Substantive Cross-Cutting Issues, 

2001 Through 2005 25

Abbreviations

ACRS Advisory Committee on Reactor Safeguards

ECP Employee Concerns Program

ERB Executive Review Board

INPO Institute of Nuclear Power Operations

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

PRA Probabilistic Risk Assessment

ROP Reactor Oversight Process

RPS Reactor Program System

SALP Systematic Assessment of Licensee Performance

SCWE safety-conscious work environment

SDP Significance Determination Process

UCS Union of Concerned Scientists

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-06-1029 Oversight of Nuclear Power Plant Safety

United States Government Accountability Office

Washington, D.C. 20548

A

September 27, 2006 Letr

Congressional Requesters

The Nuclear Regulatory Commission (NRC) is responsible for overseeing 

the safe operation of the nation’s 103 operating commercial nuclear power 

plants, which provide about 20 percent of U.S. electricity. The safety of 

these plants, which are located at 65 sites in 31 states, has always been 

important, since an accident could result in the release of radioactive 

material and potentially harm public health and the environment. NRC’s 

oversight has become even more critical as the Congress and the nation 

consider the potential resurgence of nuclear power in helping to meet the 

nation’s growing energy needs. No new orders for plants have been placed 

since the 1979 accident at the Three Mile Island plant in Pennsylvania. 

However, in the face of concerns about energy security, global warming, 

aging plants, and the ever increasing need for energy to fuel the nation’s 

economy, nuclear power is resurfacing as a principal option. An accident, 

even on a relatively small scale, could threaten public confidence in 

nuclear power just as it begins to emerge from the shadows of the Three 

Mile Island accident. It is critical that NRC be able to ensure that nuclear 

power plants are operated safely and that public confidence about their 

safety is high. 

NRC is responsible for issuing regulations, licensing and overseeing plants, 

and requiring necessary actions to protect public health and safety, up to 

and including shutting down a plant, if it is not meeting licensing conditions 

and it poses an undue risk to public health and safety. Plant operators are 

responsible for safely operating their plants in accordance with their 

licenses. Prior to 2000, NRC’s oversight of plants’ compliance, which is a 

critical part of the agency’s regulatory program, was criticized because it 

did not always focus on the most important safety issues, and because 

some activities were redundant, inefficient, and overly subjective. While its 

new process—which NRC refers to as the Reactor Oversight Process 

(ROP)—is similar to its prior process in that the oversight activities largely 

consist of physical plant inspections, the inspections now focus on more 

important safety issues. NRC’s goal is to ensure that its oversight of plants’ 

safety performance is objective, predictable, understandable, and 

conducted openly to inform the public and maintain confidence about plant 

safety. The unexpected discovery in March 2002 of extensive corrosion and 

a pineapple-size cavity in the reactor vessel head—one of the vital barriers 

preventing a radioactive release—at the Davis-Besse nuclear power plant 

in Ohio led NRC to reexamine its safety oversight and other regulatory 
Page 2 GAO-06-1029 Oversight of Nuclear Power Plant Safety

processes to determine how such corrosion could have been missed. On 

the basis of the lessons learned from that event, NRC made several changes 

to the ROP. NRC also has assessed the ROP annually since it was 

implemented in 2000 by obtaining feedback from the industry and other 

stakeholders, such as public interest groups.

In this report, we examined (1) how NRC oversees nuclear power plants to 

ensure that they are operated safely, (2) the results of the ROP over the 

past several years, and (3) the status of NRC’s efforts to improve the ROP.1

In addition, this report provides details on recent safety-related events at 

the Salem and Hope Creek nuclear power plants in New Jersey and on 

NRC’s and the licensee’s actions in response to these events (see app. I).

To examine how NRC oversees plants, we reviewed the various tools and 

processes that comprise the ROP. In this regard, we reviewed NRC’s 

policies, inspection manuals, and other guidance documents; interviewed 

NRC headquarters and regional program officials and regional and on-site 

inspectors; visited the Salem and Hope Creek nuclear power plants; and 

attended several public meetings covering various nuclear power plant 

oversight topics. To examine the results of the ROP over the past several 

years, we reviewed the number and types of inspection findings NRC 

issued, along with other performance measures or indicators it collected 

from the plants, and the level of oversight it provided as a result of its 

findings. We analyzed NRC data on nuclear plant safety for 2001 through 

2005, the years since implementation of the ROP for which data were 

available for the full year, and discussed our analysis with NRC program 

officials. We assessed the reliability of these data and determined that they 

were sufficiently reliable for the purposes of our report. To examine the 

status of NRC’s efforts to improve the ROP, we analyzed NRC documents, 

including annual self-assessment reports; interviewed officials from NRC, 

including a former Commission Chairman who is largely credited with 

leading the development of the ROP, and outside stakeholder groups, 

including the Nuclear Energy Institute (NEI), the Union of Concerned 

Scientists (UCS), and Greenpeace; and attended several key public 

meetings covering proposed changes to oversight procedures. We also 

reviewed various external evaluations of the ROP, including our prior 

1

Physical security, which is also covered by the ROP, is not included in this review. For 

information on NRC’s physical security, see GAO, Nuclear Power Plants: Efforts Made to 

Upgrade Security, but the Nuclear Regulatory Commission’s Design Basis Threat Process 

Should Be Improved, GAO-06-388 (Washington, D.C.: Mar. 14, 2006).
Page 3 GAO-06-1029 Oversight of Nuclear Power Plant Safety

reports and those of the Advisory Committee on Reactor Safeguards 

(ACRS)2

 and the NRC Office of the Inspector General. In addition, we 

selected a nonprobability sample of 6 nuclear power sites (totaling 11 

plants, including Salem and Hope Creek) that spanned each of NRC’s four 

regions and represented varying levels of plant performance and NRC 

oversight since 2000. We reviewed relevant inspection reports and 

assessment documents and interviewed NRC and industry officials at each 

site to examine how NRC applies the ROP to identify and correct safety 

problems. Appendix II presents a detailed discussion of our scope and 

methodology. We conducted our work from July 2005 through July 2006 in 

accordance with generally accepted government auditing standards. 

Results in Brief NRC uses various tools and takes a risk-informed and graded approach to 

ensuring the safety of nuclear power plants. These tools include physical 

inspections of plants’ equipment and records and quantitative measures or 

indicators of plant performance, such as the number of unplanned reactor 

shutdowns and the reliability of alert and notification system sirens that 

notify residents living near the plant in the event of an accident. NRC uses a 

risk-informed approach—that is, an approach that considers safety 

significance in selecting the equipment or operating procedures to be 

inspected—to apply these tools. NRC inspectors conduct baseline 

inspections of plant operations almost continuously at each nuclear power 

plant site. When NRC becomes aware of a performance problem at a plant, 

it uses a process to assign the inspection finding one of four colors to 

reflect the finding’s risk significance, which is set on the basis of measures 

that reflect the potential health effects that could occur from radiological 

exposure. Green inspection findings equate to very low risk significance, 

while white, yellow, and red colors represent increasing levels of risk, 

respectively. In response to greater-than-green (white, yellow, or red) 

inspection findings, NRC conducts supplemental inspections, which 

expand the scope of baseline inspections and review (1) the extent of the 

problem, (2) the sufficiency of the licensee’s evaluation of the root cause of 

2

The Advisory Committee on Reactor Safeguards is an independent committee, mandated 

by the Atomic Energy Act of 1954, as amended, which provides advice on nuclear facility 

safety-related topics, among other topics. The ACRS is currently composed of 11 individuals 

with a wide variety of engineering and technical expertise, including nuclear engineering; 

risk assessment; chemistry; and mechanical, civil, and electrical engineering, as well as 

many others. The ACRS is structured to provide a forum where these experts can provide 

independent advice that can then be factored into NRC’s decision-making process. Each 

year, the ACRS produces several reports, many of them related to the ROP.
Page 4 GAO-06-1029 Oversight of Nuclear Power Plant Safety

the problem, and (3) the licensee’s proposed corrective actions in response 

to the identified performance problem. NRC conducts special inspections 

to investigate specific safety incidents or events—such as reactor 

shutdowns due to equipment failures—that are of particular interest to 

NRC because of their potential significance to safety. Nuclear power plants 

also self-report on their safety performance, using performance measures 

or indicators in quarterly reports that they submit to NRC. The plants’ 

reports are verified by NRC’s on-site inspectors. On the basis of the number 

and risk significance of inspection findings and performance indicators, 

NRC places each plant into one of five oversight categories on its action 

matrix, which correspond to graded or increasing levels of oversight, 

largely consisting of supplemental inspections that increase in the breadth 

and depth of issues covered as plants move into higher oversight 

categories. 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 other 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.

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. (See app. III for additional sitespecific plant data.) About 97 percent of the inspection findings were 

green, meaning they were for actions or failures NRC considered important 

to correct but of very low significance to overall safe plant operations. For 

example, a finding of very low risk significance was issued at one plant 

after a worker failed to wear the proper radiation detector, and at another 

plant because the operator failed to properly evaluate and approve the 

storage of flammable materials in the vicinity of safety-related equipment. 

The other 3 percent (98) of the inspection findings were greater-than-green. 

Most of these findings (86 of the 98) were white, meaning they were 

considered to be of low-to-moderate risk significance. The other 12 

inspection findings, or less than 1 percent, were of the highest levels of 

significance to safety (yellow and red). For example, NRC issued a finding 

of the highest risk significance (red) at one plant after a steam generator 

tube failed, causing an increased risk of the release of radioactive material. 

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 
Page 5 GAO-06-1029 Oversight of Nuclear Power Plant Safety

category. On the basis of greater-than-green inspection findings and 

performance indicators, NRC has subjected more than 75 percent (79) of 

the 103 operating plants to oversight beyond the baseline inspections for 

varying periods. Most of these plants received the lowest level of increased 

oversight, consisting of a supplemental inspection to follow up on the 

corrective actions taken for performance problems identified through the 

issuance of 1 or 2 white inspection findings or performance indicators. 

Over the past 5 years, 5 plants have been subjected to the highest level of 

NRC oversight that still allows continued operations. Plants in this 

category were generally subjected to this higher oversight for long periods 

due to the more intensive supplemental inspections conducted by NRC and 

the more systemic nature of the plants’ performance problems and 

subsequent corrective actions NRC expected the licensees to take. NRC 

inspectors at the plants we reviewed indicated that when plant 

performance declines, it is often the result of ineffective corrective action 

programs, problems related to human performance, or complacent 

management. In assessing the results of the ROP between 2001 and 2005, 

we found an association between poorer performing plants and 

deficiencies in the plants’ human performance and problem identification 

and resolution programs. 

NRC has improved its oversight process in various areas, but continued 

efforts will be needed to address other shortcomings or opportunities for 

improvement, particularly in improving the agency’s ability to identify and 

address early indications of declining plant safety performance. NRC has 

made several improvements, largely in response to independent reviews 

and feedback from stakeholders, including its regional and on-site 

inspectors, usually obtained during NRC’s annual self-assessment of its 

oversight process. These improvements include better focusing its 

inspections on those areas most important to safety, reducing the time 

needed to determine the risk significance of inspection findings, and 

modifying the way that some performance indicators are measured to 

improve their quality. NRC also is assessing whether it needs to modify its 

oversight, including developing additional inspection procedures, as a 

result of some problems that have surfaced in areas not fully inspected by 

NRC, such as the recent discovery of groundwater contamination from 

radioactive materials at a number of sites. For the most part, NRC 

considers these efforts to be refinements to its oversight process, rather 

than significant changes. One important shortcoming in the ROP that we 

and others have found is that it is not as effective as it could be in 

identifying and addressing early indications of deteriorating safety at 

nuclear power plants before problems develop. In response to this concern, 
Page 6 GAO-06-1029 Oversight of Nuclear Power Plant Safety

NRC recently undertook a major initiative to improve its ability to address 

plants’ safety culture—that is, the organizational characteristics that 

ensure issues affecting nuclear plant safety receive the attention their 

significance warrants. NRC and others have long recognized that safety 

culture attributes, such as attention to detail, adherence to procedures, and 

effective corrective and preventative actions, have a significant impact on a 

plant’s safety performance, and that the lessening of these attributes can 

indicate a decline in safety performance before safety problems occur. 

However, NRC has been somewhat slow to react and only recently 

modified its oversight process by redefining and increasing its focus on 

cross-cutting safety issues—issues that comprise many of the elements of 

safety culture—and developing new requirements under the ROP to more 

directly assess safety culture at poorer performing plants. However, some 

of NRC’s changes have been controversial. While some industry officials 

have expressed concern that the changes could introduce undue 

subjectivity to NRC’s oversight, given the difficulty in measuring these 

often intangible and complex concepts, other stakeholders believe the 

changes will provide NRC with better tools to identify safety culture issues 

at plants and thus provide earlier indications of declining safety 

performance. NRC has been reluctant to incorporate safety culture into the 

ROP because it considered this type of activity a management function, and 

NRC did not believe that it should be directly involved in managing 

licensees’ plants. NRC program officials view these changes as the 

beginning step in an incremental approach and acknowledge that they will 

need to assess the changes they made to the ROP to determine their 

effectiveness in better allowing inspectors to detect deteriorating safety 

conditions at plants before significant safety events occur. 

Given the importance of this initiative to the ROP’s effectiveness, we are 

recommending that NRC aggressively monitor; evaluate; and, if needed, 

implement additional measures to increase the effectiveness of its safety 

culture changes. In line with NRC’s desire to make the ROP an open 

process, we are also recommending that the agency make available 

additional information on plants’ safety culture to the public and its other 

stakeholders to provide a more comprehensive picture of plant 

performance. In commenting on a draft of this report, NRC generally 

agreed with our findings, conclusions, and recommendations. Appendix IV 

contains a reproduction of NRC’s letter.

Background NRC is an independent agency of over 3,200 employees established by the 

Energy Reorganization Act of 1974 to regulate civilian—that is, 
Page 7 GAO-06-1029 Oversight of Nuclear Power Plant Safety

commercial, industrial, academic, and medical—use of nuclear materials. 

NRC is headed by a five-member Commission. The President appoints the 

Commission members, who are confirmed by the Senate, and designates 

one of them to serve as the Chair and official spokesperson. The 

Commission as a whole formulates policies and regulations governing 

nuclear reactor and materials safety, issues orders to licensees, and 

adjudicates legal matters brought before it. NRC’s staff work out of its 

headquarters office in Rockville, Maryland; out of its four regional offices; 

and at each of the operating commercial nuclear power plant sites (see fig. 

1). NRC’s Office of Nuclear Reactor Regulation provides overall direction 

for the oversight process and the Office of Enforcement is responsible for 

ensuring that appropriate enforcement actions are taken when 

performance issues are identified. NRC’s regional offices are responsible 

for implementing the ROP, along with the inspectors who work directly at 

each of the nuclear power plant sites.
Page 8 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Figure 1: NRC Regions and Operating Nuclear Power Plant Sites in the United States 

Nuclear power plant licensees have the primary responsibility for safely 

operating their plants in accordance with their licenses and NRC 

regulations. The plants have many physical structures, systems, and 

components, and licensees have numerous activities under way 24 hours a 

day to ensure that plants operate safely. NRC relies on, among other things, 

its on-site inspectors to assess plant conditions and the licensees’ quality 

assurance programs, such as those required for maintenance and problem 

identification and resolution. Given the numerous activities going on 

during complex plant operations, NRC can inspect only a relatively small 

Sources: NRC and Map Resources (map).

CA

AZ

NM

NV

UT CO

OR

ID

WA MT

WY

TX

OK

KS

NE

SD

ND

MN

IA

MO

AR

LA

IL

WI

IN OH

MI

PA

NY

VT

ME

NH

NC

VA

SC

TN

KY

WV

MS AL GA

FL

NJ

CT

RI

MA

DE

MD

Plants licensed to operate

Region I

Region II (includes PR and VI)

Region III

Region IV (includes AK and HI)
Page 9 GAO-06-1029 Oversight of Nuclear Power Plant Safety

sample of the plants’ activities. According to NRC, its focus on the more 

safety-significant activities is made possible because safety performance at 

plants has improved as a result of more than 25 years of operating 

experience, and because improvements have been made in the risk 

assessment tools available to NRC inspectors.

Commercial nuclear power plants are designed according to a “defense-indepth” philosophy revolving around redundant, diverse, and reliable safety 

systems. For example, two or more key safety components are put in place 

so that if one fails, there is another to back it up. Plants have numerous 

built-in sensors to monitor important indicators, such as water temperature 

and pressure. Plants also have physical barriers to contain radiation and 

provide emergency protection. For example, nuclear fuel is contained in a 

ceramic pellet to lock in the radioactive byproducts, the fuel pellets are 

sealed inside rods made of special material designed to contain fission 

products, and the fuel rods are placed in reactors housed in containment 

buildings made of several feet of concrete and steel. 

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.

Prior to the ROP, NRC conducted Systematic Assessment of Licensee 

Performance (SALP) evaluations. SALP evaluations were largely based on 

physical plant inspections conducted at each operating plant. Every 12 to 

24 months, NRC provided an overall assessment of plant safety 

performance. As part of the assessment process, NRC’s senior management 

met to evaluate plants’ performance and develop a “watch list” of those 

plants requiring increased regulatory attention. The SALP process was 

heavily criticized by the industry and other internal and external 

stakeholders, however, for being inconsistently applied among NRC 

regions and for lacking clear and consistent responses once issues were 

identified. In 1997 and 1998, we reported that NRC’s oversight needed 
Page 10 GAO-06-1029 Oversight of Nuclear Power Plant Safety

substantial revisions to achieve its purpose as an early-warning tool, and 

that NRC did not consistently apply the SALP across the industry.3

 We 

found the inconsistency could be attributed, in part, to a lack of specific 

criteria, the subjective nature of the process, and an ineffective process for 

ensuring that the licensees maintain competent management at their 

plants. 

To address these concerns, NRC undertook a major effort to revise its 

oversight process. NRC held a series of public meetings and workshops 

and formed several task groups to involve its internal and external 

stakeholders, including NEI, UCS, state agencies, and others. In 1999, NRC 

conducted a 6-month pilot program to implement the ROP at various sites 

across the country. On the basis of the input it received from its 

stakeholders and the results from the pilot program, NRC finalized its new 

process and implemented the ROP at all plants in April 2000, which was a 

significant departure from its prior SALP process.

Soon after the ROP was implemented, NRC faced a number of 

unanticipated events— including the attacks of September 11, 2001, and 

the discovery of the Davis-Besse reactor vessel head degradation in 2002—

that challenged its ability to complete its baseline inspection activities at all 

plants in 2002 and 2003. Therefore, NRC staff implemented “coping 

strategies,” which consisted of increasing the use of overtime and 

scheduling flexibility for its inspectors, reducing the level of effort for some 

of its inspection procedures, reducing some of the inspection preparation 

time, and deferring some inspections, among other things. A 2004 audit by 

the NRC Office of the Inspector General found that the resource challenges 

were largely due to changes in NRC’s staffing policy, a hiring policy change, 

an increase in inspection activities due to unanticipated events such as 

Davis-Besse, and a loss of qualified inspectors.4

 NRC increased its 

inspection resources by 9 percent in 2004, and then by another 5 percent in 

2005, and reported that it 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 

3

GAO, Nuclear Regulatory Commission: Preventing Problem Plants Requires More 

Effective Action by NRC, GAO-T-RCED-98-252 (Washington, D.C.: July 30, 1998); and 

Nuclear Regulation: Preventing Problem Plants Requires More Effective NRC Action, 

GAO/RCED-97-145 (Washington, D.C.: May 30, 1997). 

4

NRC, Office of the Inspector General, US Nuclear Regulatory Commission: Audit of NRC’s 

Baseline Inspection Program, OIG-05-A-06 (Dec. 22, 2004).
Page 11 GAO-06-1029 Oversight of Nuclear Power Plant Safety

expended in 2002, the lowest level of inspection resources devoted to the 

ROP since its inception in 2000. According to NRC, the additional resources 

expended in 2005 were due, in part, to increased oversight that was based 

on lessons learned from the Davis-Besse incident and on the increased 

focus on security and emergency preparedness. With its current resource 

levels, NRC program officials believe they will be able to continue to 

implement all program requirements without the need to employ coping 

strategies. 

NRC Uses Various 

Tools and Takes a RiskInformed and Graded 

Approach to Ensuring 

the Safety of Nuclear 

Power Plants

NRC’s tools to oversee the safe operation of nuclear power plants generally 

consist of physical inspections of the various complex plant equipment and 

operations, reviews of plant records, and quantitative measures or 

indicators of plant performance. These tools are risk-informed in that they 

focus on the aspects of operations considered most important to plant 

safety. NRC bases its oversight process on the principle and requirement 

that licensees have programs in place to routinely identify and address 

performance issues without NRC’s direct involvement. Thus, an important 

aspect of NRC’s inspection process is ensuring the effectiveness of licensee 

programs designed to identify and correct problems. On the basis of the 

number and risk significance of inspection findings and performance 

indicators, NRC places each plant into one of five performance categories 

on its action matrix, which corresponds to graded, or increasing, levels of 

oversight. NRC assesses overall plant performance and communicates the 

results to licensees and the public on a semiannual basis. 

NRC Collects Information 

about Plant Performance 

from Physical Inspections 

and Quantitative Measures 

Reported by the Licensees

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. Table 1 summarizes the 

objectives of each cornerstone. 
Page 12 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Table 1: Key ROP Plant Inspection Areas, or Cornerstones

Source: NRC.

a

The physical protection cornerstone consists of physical security issues and, therefore, is outside the 

scope of this review.

During fiscal year 2005, NRC reported that inspectors spent 411,490 hours 

(an average of 77 hours per week at each plant) on plant inspections, which 

consist of baseline, supplemental, and special inspections. About 73 

percent of this time was devoted to baseline inspections, which are the 

minimum level of inspections that all plants receive regardless of 

performance, and are conducted on an almost continuous basis. Baseline 

inspections are conducted by the two or three 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. These procedures involve both physical 

observations of plant activities and reviews of plant reports and data. 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 

Cornerstone Objective

Initiating events Limit the frequency of those events that upset plant operating stability and challenge critical 

safety functions.

Mitigating systems Ensure the availability, reliability, and capability of systems that mitigate initiating events to 

prevent reactor accidents.

Barrier integrity Ensure that physical barriers, such as fuel cladding and containment structures, protect the 

public from radioactive releases caused by accidents.

Emergency preparedness Ensure that actions taken by the emergency plan would provide protection of the public health 

and safety during a radiological emergency.

Occupational radiation safety Ensure adequate protection of worker health and safety from exposure to radioactive material 

during routine civilian nuclear reactor operation.

Public radiation safety Ensure adequate protection of public health and safety from exposure to radioactive material 

released into the public domain as a result of routine civilian nuclear reactor operations.

Physical protectiona Provide assurance that the physical protection system can protect against radiological 

sabotage.
Page 13 GAO-06-1029 Oversight of Nuclear Power Plant Safety

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 (14 

to 21 hours per week), depending on the size of the site, 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. 

When NRC inspectors identify a finding they consider to be more than 

minor,5 they use a significance determination process (SDP) to assign the 

finding one of four colors to reflect the finding’s risk significance. The SDP 

assesses how an identified inspection finding increases the risk that a 

nuclear accident could occur, or how the finding affects the ability of the 

plant safety systems or personnel to prevent such an accident. Risk 

thresholds for each color were set on the basis of measures that reflect the 

potential health effects that could occur from radiological exposure.6

Green inspection findings equate to very low risk significance, while white, 

yellow, and red colors represent increasing levels of risk, respectively. For 

greater-than-green (white, yellow, or red) inspection findings, NRC issues a 

preliminary color determination after an initial analysis. It then analyzes 

any readily available information from the licensee pertinent to the finding 

to ensure that the final determination of risk significance is made with the 

best available information. 

5

“Minor issues” are defined by NRC as those that have little actual safety consequences, little 

or no potential to impact safety, little impact on the regulatory process, and no willfulness. 

For example, if a licensee missed providing an hourly update to a state agency during a 

declared unusual event that resulted in no actual safety consequences, it would be 

considered minor if it did not detract significantly from the state agency’s ability to function 

during the emergency. Also, if a licensee failed to record one section of a surveillance test, 

but the test was performed and the last completed surveillance test revealed that the 

equipment adequately performed its safety function, the finding would be considered minor.

6

The measures used for the characterization of risk are core damage frequency and large 

early release frequency. In some situations, risk calculations cannot be made using these 

measures, such as in the case of measuring the risk for emergency preparedness inspection 

findings. In these cases, thresholds were determined by panels of experts on the basis of 

operating experience and a determination of what the appropriate response would be. 
Page 14 GAO-06-1029 Oversight of Nuclear Power Plant Safety

When NRC issues one or more greater-than-green inspection findings at a 

plant, it conducts supplemental inspections. 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 level 

of supplemental inspection to be carried out depends on the number and 

type of performance problem identified. 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.

NRC conducts special inspections at plants when specific events occur that 

are of particular interest to NRC because of their potential safety 

significance at the plant or because of potential generic safety concerns 

important to all plants. Special inspections determine the cause of the 

event and assess the licensee’s response to the event. For special 

inspections, a team of experts is often formed and an inspection charter 

issued that describes the scope of the inspection efforts. At one plant we 

reviewed, for example, a special inspection was conducted to investigate 

the circumstances surrounding the discovery of leakage from a spent fuel 

storage pool.7

 Among the objectives of this inspection were to assess the 

adequacy of the plant licensee’s determination of the source and cause of 

the leak, the risk significance of the leakage, and the proposed strategies to 

mitigate leakage that had already occurred and repair the problem to 

prevent additional leakage. 

7

Spent fuel storage pools are typically 40-foot deep, steel-lined, concrete vaults filled with 

water to store spent fuel rods no longer capable of being used for nuclear power generation. 

The water is to provide shielding from radiation that is left in the rods.
Page 15 GAO-06-1029 Oversight of Nuclear Power Plant Safety

As part of its inspection process, NRC evaluates all of its findings to 

determine if certain elements of plant performance, referred to as crosscutting aspects, were a contributing cause to the performance problem. 

Cross-cutting aspects represent licensee performance elements that extend 

across all of the cornerstones of safety. There are three cross-cutting aspect 

areas: (1) problem identification and resolution, (2) human performance, 

and (3) a safety-conscious work environment. For example, in analyzing 

the failure of a valve to operate properly at one plant, NRC inspectors 

determined that plant employees had not followed the correct maintenance 

procedures. Thus, NRC concluded that the finding was associated with the 

human performance cross-cutting area. Every 6 months, NRC analyzes all 

findings issued at each plant during a 12-month assessment period. If more 

than three findings have similar causes within the same cross-cutting area 

and if NRC is concerned about the licensee’s progress in addressing these 

issues, it determines that the licensee has a “substantive” cross-cutting 

issue. NRC notifies the licensee that it has opened a substantive crosscutting issue, and it may ask the licensee to respond with the corrective 

actions it plans to take. Also, NRC inspectors said they provide additional 

focus on any substantive cross-cutting issues open through their baseline 

inspection efforts. For example, one regional official said that if a 

substantive cross-cutting issue in the problem identification and resolution 

area is identified, it is the region’s practice to increase the frequency of 

certain baseline inspections that focus on the licensee’s problem 

identification and resolution processes. 

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 indicators8

—quantitative 

measures of plant performance related to safety in the different aspects of 

plant operations. For example, one indicator measures the number of 

unplanned reactor shutdowns during the previous four quarters, while 

another measures the capability of alert and notification systems that 

notify residents living near the plant in the event of an accident. 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 

8

There also are 3 performance indicators in the area of physical security, and, therefore, they 

are outside the scope of this review.
Page 16 GAO-06-1029 Oversight of Nuclear Power Plant Safety

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. If questions arise during the review and verification 

process about how to calculate a particular indicator or what the correct 

value should be, there is a formal feedback process to resolve the issue. 

Similar to its process for conducting supplemental inspections when 

greater-than-green inspection findings are identified, NRC conducts 

supplemental inspections in response to any greater-than-green 

performance indicators.

NRC Uses Its Action Matrix 

to Categorize Plant 

Performance and Apply 

Increased Oversight in a 

Graded Fashion

Under the ROP, NRC places each nuclear power plant into one of five 

performance categories on its action matrix, which corresponds to graded, 

or increasing, levels of oversight.9

 The action matrix is NRC’s formal 

method of determining how much additional oversight—mostly in the form 

of supplemental inspections—is required on the basis of the number and 

risk significance of inspection findings and performance indicators. (See 

fig. 2 for an overview of the process that leads to plant placement on the 

action matrix.) 

9

While NRC formally places plants into performance categories on its action matrix on a 

quarterly basis, NRC assesses plant performance on a continuous basis and takes actions in 

accordance with the action matrix as performance issues are identified.
Page 17 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Figure 2: NRC’s Oversight Process in Determining Plant Placement on the Action 

Matrix

The definitions for the categories of the action matrix indicate more 

pervasive and systematic declines in licensee performance as a licensee 

moves from left to right on the action matrix (see table 2). Also, as the 

licensee moves to the right on the action matrix, NRC’s response and the 

corrective actions it expects of the licensee become more extensive. In 

determining a plant’s placement on the action matrix, greater-than-green 

inspection findings are considered for additional oversight for a minimum 

of four quarters, regardless of whether the licensee corrected the problem, 

to allow sufficient time to identify additional findings that may indicate 

Source: GAO analysis of NRC guidance.

Inspection

Threshold 

exceeded?

Performance 

deficiency?

Minor?

Green

Green

No action

No action White

Yellow

Red

White

Yellow

Red

Significance 

determination 

process

Oversight as

specified by the 

action matrix

Performance 

indicators

No

No

No

Yes

Yes

Yes
Page 18 GAO-06-1029 Oversight of Nuclear Power Plant Safety

more pervasive performance problems. If a licensee fails to correct the 

performance problem within the initial four quarters, the finding may be 

held open and considered for additional oversight. NRC regional officials, 

with the approval of the Executive Director for Operations, can also 

increase or decrease oversight beyond the actions specified by the action 

matrix through deviations to the ROP. Deviations are for rare instances 

when the regulatory actions dictated by the action matrix are not 

appropriate and a more tailored approach is warranted. 

Table 2: NRC Reactor Oversight Process Action Matrix

Source: NRC.

Note: In addition to the actions listed in this table, increasingly higher levels of NRC management will 

meet with the licensee as it moves to the right on the action matrix.

a

For plants at this oversight level, at a minimum, the licensee and NRC are to document agreement on 

the corrective actions the licensee will take through a performance improvement plan. NRC may also 

take actions including making a demand to the licensee for information or issuing an order up to and 

including a plant shutdown. 

Oversight category Lowest level Second level Third level

Highest level (while 

allowing continued 

operations)

Unacceptable 

performance (plant 

shutdown)

Plant performance All green findings 

and performance 

indicators

One white finding or 

performance 

indicator, or two 

white findings or 

performance 

indicators in different 

cornerstones

Two or more white 

findings or 

performance indicators 

in one cornerstone, or 

one yellow finding or 

performance indicator, 

or any three white 

findings or 

performance indicators

Two white findings or 

performance indicators 

or one yellow finding or 

performance indicator 

in one cornerstone for 

five or more quarters, 

or multiple yellow or 

one red finding or 

performance indicator

Overall 

unacceptable 

performance due to 

unacceptable 

margin of safety

NRC oversight 

actions

Baseline 

inspections only

Baseline inspections 

and first level, or 

least intensive, 

supplemental 

inspection

Baseline inspections 

and second level, or 

more intensive, 

supplemental 

inspection

Baseline inspections 

and third level, or most 

intensive, 

supplemental 

inspection.a

Order to modify, 

suspend, or revoke 

licensed activities
Page 19 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Whether NRC takes enforcement actions in response to plant performance 

problems depends on whether there is a violation of a specific regulatory 

requirement.10 Some findings can have risk significance without violating a 

regulatory requirement because the ROP is a risk-informed process, while 

the underlying regulations are not all risk-informed. For example, 

regulatory requirements govern plants’ safety-related equipment, which 

licensees define when their licenses are granted as equipment that would 

be employed to mitigate the effects of an accident. NRC’s risk-informed 

oversight process considers the condition of all of the equipment at a plant, 

not necessarily just that included in its definition of safety-related 

equipment. As such, performance deficiencies could be identified through 

inspection findings that were not associated with safety-related equipment 

and, thus, were not violations of a regulatory requirement. More 

specifically, fire pumps are not typically defined as safety-related 

equipment under the regulations defining safety-related equipment, but 

they could be employed to provide water to cool the reactor in the event of 

an accident. If a licensee specified the use of fire pumps as part of its 

strategy to mitigate the effects of an accident, a performance problem 

associated with the pumps would not necessarily violate regulatory 

requirements, but the problem could be determined to be an inspection 

finding. Even though there is not a regulation requiring the licensee to 

correct such a problem, the finding would be considered for additional 

oversight under the ROP, thus providing an incentive for the licensee to 

correct it. NRC program officials acknowledge that applying the riskinformed ROP to regulations that are not risk-informed allows for these 

types of situations. The officials said NRC has efforts under way to riskinform some of its regulations, which should reduce the likelihood of these 

types of situations occurring. 

10In some cases, a violation of regulatory requirements can occur that results in an 

inspection finding, but the finding is not assigned a color because the issue associated with 

the violation is not amenable to a risk calculation. For these types of findings, a severity 

level is assigned to reflect the significance of the finding, ranging from I for the most 

significant, to IV for the least significant. In assigning a severity level to the finding, NRC 

assesses the following: (1) the actual safety consequences; (2) the potential safety 

consequences; (3) the potential for impacting NRC’s ability to perform its regulatory 

function (e.g., failure to provide complete and accurate information); and (4) any willful 

aspects of the violation. Severity levels I and II violations generally involve actual or highpotential consequences to public health and safety. Severity level III violations are cause for 

significant concern, and severity level IV violations are less serious but are of more than 

minor concern.
Page 20 GAO-06-1029 Oversight of Nuclear Power Plant Safety

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 what level of oversight the plant will receive 

according to 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. 

While each description contains information about whether the finding was 

associated with a cross-cutting issue, the Web site itself does not provide 

information on those plants that have open substantive cross-cutting 

issues. This information can only be found on the Web site by linking to 

each plant’s individual assessment letters. NRC program officials 

acknowledge that, without having the information available in summary 

form, it is difficult to determine which plants have substantive crosscutting issues open. They said that they may look at the possibility of 

including such information on the Web site, although doing so is not part of 

their current plans. 

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 
Page 21 GAO-06-1029 Oversight of Nuclear Power Plant Safety

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. 

NRC Has Identified 

Low Risk Problems at 

Nuclear Power Plants, 

Resulting in Increased 

Oversight for Varying 

Periods

The ROP has identified thousands of performance deficiencies through 

inspection findings at nuclear power plants between 2001 and 2005, but 

most of these findings were considered to be of very low risk to safe plant 

operations. In the performance indicator program, there have been very 

few instances in which performance indicator data were below acceptable 

standards during this period. While the majority of plants received some 

level of increased oversight due to greater-than-green inspection findings 

and performance indicators, only 5 plants were subjected to NRC’s highest 

levels of oversight. Plants in this category were generally subjected to this 

higher oversight for long periods due to the more intensive supplemental 

inspections conducted by NRC and to the more systemic nature of the 

plants’ performance problems and subsequent corrective actions NRC 

expected the licensees to take. In assessing the results of the ROP between 

2001 and 2005, we found an association between poorer performing plants 

and deficiencies in the cross-cutting areas of human performance and 

problem identification and resolution. 

Of the more than 4,000 inspection findings identified between 2001 and 

2005, 97 percent were green. (See app. III for additional site-specific 

inspection findings data.) The number of green findings ranged from 15 at 

one site to 141 at another site, with an overall site average of 59 for the 5-

year period. While green findings are considered to be of very low safety 

significance, they represent a performance deficiency on the part of the 

licensee and it is important that they be corrected. Green findings consist 

of such things as finding that a worker failed to wear the proper radiation 

detector, or finding that a licensee did not properly evaluate and approve 

the storage of flammable materials in the vicinity of safety-related 

equipment. NRC does not follow up on the corrective action taken for 

every green finding; rather, it relies on the licensee to address and track the 

finding’s resolution through the plant’s corrective action program. NRC 

does, however, periodically follow up on some of the actions taken by the 

licensee to address green findings through an inspection specifically 

designed to evaluate the effectiveness of the licensee’s corrective action 

program. NRC program officials stated that even though they do not 

increase oversight as a result of green findings, green findings are assessed 

for the presence of cross-cutting aspects and provide useful information on 
Page 22 GAO-06-1029 Oversight of Nuclear Power Plant Safety

plant performance. NRC inspectors told us they use green findings to 

identify performance trends in the various safety areas and these findings 

help inform their selection of future inspection samples. 

The other 3 percent of the inspection findings identified between 2001 and 

2005, or 98 of the more than 4,000, were greater-than-green (see app. III). 

Eighty-six findings were white, meaning they were considered to be of low 

to moderate risk significance. The white findings were well-distributed 

among the sites, with only 11 sites receiving more than 2 white findings 

during the period. Twenty-three sites were not issued any white (or greater) 

findings during this period. White findings were issued for such things as 

(1) a licensee’s failing to correct a condition in which the auxiliary service 

water pump could not be aligned in sufficient time to mitigate the loss of 

feedwater during a simulated tornado exercise and (2) a licensee’s having 

an improper validation process for its licensed operator requalification 

examinations, which compromised the integrity of the exams. Less than 1 

percent of the inspection findings issued since 2001 were of the highest risk 

significance—yellow or red. During this time, NRC issued 7 yellow findings 

and 5 red findings. The 7 yellow findings were in the mitigating systems and 

emergency preparedness cornerstones and included issues such as the 

failure to develop and maintain emergency plans at one plant, the failure to 

ensure that safety-related equipment was adequately protected from 

flooding at another plant, and the failure to pass an annual licensed 

operator requalification examination by over half of the operator crews at 

one plant. Of the 5 red findings, 1 was issued for the degradation of the 

reactor vessel head at the Davis-Besse plant, 1 was issued for a steam 

generator tube failure at another plant, and the remaining 3 red findings 

were issued at 2 other plants for problems related to their auxiliary 

feedwater pumps.

NRC’s inspection results have remained relatively consistent from 2001 to 

2005. During this time frame, the number of green findings at all plants 

ranged from 657 to 889 per year, and the number of other findings ranged 

from 10 to 30 per year, with no strong trend (see fig. 3). 
Page 23 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Figure 3: Number of Inspection Findings at All Plants, 2001 Through 2005

Only in the area of inspection findings for which one or more cross-cutting 

aspect was associated, is an increasing trend evident (see fig. 4). According 

to NRC, the increase in findings with cross-cutting aspects is due, in part, to 

the recent development of additional guidance for inspectors on the 

identification and documentation of cross-cutting aspects. The number of 

plants where the existence of cross-cutting aspects resulted in NRC’s 

opening a substantive cross-cutting issue is shown in figure 5. (See app. III 

for additional data on plant-specific, substantive cross-cutting issues.) 

0

100

200

300

400

500

600

700

800

900

Red

Yellow

White

Green

2001 2002 2003 2004 2005

Number of inspection findings

751

20 3 2

28

0 2 11 2 1 18 1 0 9 1 0

657

889

835

774

Source: GAO analysis of NRC data.

Year
Page 24 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Figure 4: Number of Inspection Findings and Inspection Findings with CrossCutting Aspects at All Plants, 2001 Through 2005

Note: Almost all inspection findings with cross-cutting aspects were in the areas of human 

performance and problem identification and resolution; only 5 out of 1,890 inspection findings were 

assigned to the safety-conscious work environment cross-cutting area.

Source: GAO analysis of NRC data.

Year

Number of inspection findings

0

100

200

300

400

500

600

700

800

900

Inspection findings with cross-cutting issues

Total inspection findings

2001 2002 2003 2004 2005

32%

23%

56%

52%

68%
Page 25 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Figure 5: Number of Plants with Substantive Cross-Cutting Issues, 2001 Through 

2005 

Note: The totals include those plants that had one or more substantive cross-cutting issue open during 

at least some portion of the year. If a plant had more than one substantive cross-cutting issue open, 

only one was counted.

In the performance indicator program, almost all of the indicator data were 

reported to be within the acceptable levels of performance (green). Only 

156, or less than 1 percent of over 30,000 indicator reports from 2001 to 

2005, did not meet the acceptable performance threshold. (See app. III for 

additional plant-specific performance indicator data.) Four of the 15 

performance indicators have always been reported within acceptable 

performance levels. These 4 indicators include 1 that measures the amount 

of time that the residual heat removal safety system is unavailable, 1 that 

monitors the integrity of a radiation barrier, 1 that measures the 

participation of emergency response organizations in emergency drills or 

exercises, and 1 that monitors radiological releases. In addition, 46 plants 

have never had a performance indicator fall outside of the acceptable 

performance level, and no yellow or red indicators were reported during 

the period. 

On the basis of the greater-than-green inspection findings and performance 

indicators, NRC has subjected more than three quarters (79) of the 103 

0

5

10

15

20

25

30

35

2001 2002 2003 2004 2005 

Number of plants

13

29

30

24 24

Source: GAO analysis of NRC data.

Year
Page 26 GAO-06-1029 Oversight of Nuclear Power Plant Safety

operating plants to at least some level of increased oversight for varying 

periods. (See app. III for additional plant-specific oversight level data.)11

Most of these plants received the lowest level of increased oversight, 

consisting of the least intensive supplemental inspection, due to the 

identification of one or two white inspection findings or performance 

indicators. In most of these instances, the licensees did not accumulate 

additional greater-than-green findings, so oversight did not have to be 

increased to higher levels on the action matrix. For example, at one plant, 

NRC issued a white finding after a degraded valve resulted in the failure of 

a drain line from a moisture separator. After allowing time for the licensee 

to analyze the root cause, NRC completed a supplemental inspection to 

assess the licensee’s evaluation and concluded that the licensee’s actions 

were adequate. As a result, NRC did not require any further actions of the 

licensee, and NRC inspectors did not conduct further inspections beyond 

the baseline procedures. In some cases, however, either the licensee was 

not able to sufficiently correct the performance problem, thus triggering 

increased oversight, or additional greater-than-green inspection findings or 

performance indicators were identified, also triggering increased oversight. 

For example, a white finding was issued at one plant because the licensee’s 

fire response procedures were not effective in ensuring a safe shutdown of 

the reactor during a postulated severe fire. Because this finding was issued 

during the same time that one of the plant’s performance indicators was 

white, the plant was moved from the second to the third highest level of 

oversight and NRC conducted a second-level, more-intensive supplemental 

inspection. In this case, NRC determined that the licensee’s corrective 

actions were sufficient to resolve the deficiencies related to both the 

inspection finding and performance indicator and thus reduced its 

oversight back to baseline inspections only. 

While more than three quarters of nuclear power plants received some 

level of increased oversight from 2001 through 2005, only 5 plants were 

placed into NRC’s highest oversight category on the action matrix that still 

allows continued operations, and no plants were placed into NRC’s 

11During this period, NRC also requested and received approval to deviate from its oversight 

process at 6 plants, with 1 of the plants subjected to increased oversight from a deviation on 

two separate occasions. At 4 of the plants, the deviation resulted in increased oversight, 

while at 2 plants it resulted in decreased oversight.
Page 27 GAO-06-1029 Oversight of Nuclear Power Plant Safety

unacceptable performance category.12 Plants subject to the highest level of 

NRC oversight generally remain in this category for longer periods of time 

than the other performance categories on the action matrix. It usually takes 

NRC longer to conduct the more intensive supplemental inspections and 

the licensees longer to implement the actions that NRC expects to correct 

the broader and more systemic performance issues that led to their 

placement in the highest oversight category. For example, one plant was 

subject to NRC’s highest oversight level for approximately 2 years because 

of several greater-than-green inspection findings and performance 

indicators, including a red inspection finding for the failure of a steam 

generator tube. In this case, NRC conducted its most intensive 

supplemental inspection 2 months after the final significance of the red 

inspection finding was determined. NRC inspectors found a number of 

underlying problems with the licensee’s programs for design control, 

human and equipment performance, problem identification and resolution, 

and emergency preparedness. The licensee prepared a plan to address its 

performance deficiencies, as is required for all plants placed into this 

oversight category, and determined that a multiyear effort was necessary to 

adequately 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 in 

implementing its corrective actions. NRC inspectors at the plants we 

reviewed explained that plants subjected to the highest oversight levels 

typically have underlying problems that can take longer periods to resolve. 

It is important for them to ensure that the corrective actions taken by the 

licensee are effective before oversight is reduced. Therefore, inspectors try 

to allow a sufficient amount of time to pass after the licensee has taken a 

corrective action, to be able to examine not only the corrective action itself 

but also whether it is working as intended, which requires it to have been in 

place for awhile.

NRC inspectors at the plants we reviewed also said that a decline in plant 

performance is often the result of ineffective licensee corrective action 

programs, problems related to human performance, or complacent 

management, which often results in deficiencies in one or more of the 

12While it was not placed into NRC’s unacceptable performance category on the action 

matrix, the Davis-Besse plant was subjected to a special oversight process due to its 

significant performance problems related to the reactor-vessel head degradation that 

occurred in 2002. On the basis of this event, NRC placed the plant, which was already in a 

shutdown condition, into an oversight process outside of the ROP and conducted by a 

special oversight panel consisting of region and headquarters NRC officials.
Page 28 GAO-06-1029 Oversight of Nuclear Power Plant Safety

cross-cutting areas. In assessing the results of the ROP data, we found an 

association between plants that had been subjected to increased levels of 

oversight and the presence of substantive cross-cutting issues. For 

instance, all plants subjected to NRC’s highest level of oversight also had a 

human performance and/or problem identification and resolution 

substantive cross-cutting issue open either prior to or during the time that 

they were subjected to increased oversight.

NRC Is Addressing 

Weaknesses in Various 

Areas of Its Oversight 

Process, but More 

Effort Is Needed

NRC has taken a proactive approach to constantly improving its oversight 

process over its first 6 years of implementation, but additional 

improvements are needed. NRC has several mechanisms in place to 

incorporate feedback from both external and internal stakeholders, and it 

is currently working on improving several areas of its oversight process by, 

for example, better focusing inspections on areas most important to safety, 

improving the timeliness and quality of determining the risk significance of 

its inspection findings, and modifying some of the performance indicators 

to improve their quality. NRC is also assessing whether it needs to modify 

its oversight, including developing additional inspection procedures, as a 

result of some problems that have surfaced in areas not fully inspected by 

NRC, such as the recent discovery of groundwater contamination from 

radioactive releases at a number of sites. In addition, NRC is working to 

address what we believe has been a significant shortcoming by making 

changes to its oversight process to improve its ability to better identify and 

address early indications of deteriorating safety at plants before 

performance problems develop. Some of its changes have been 

controversial, however, and NRC officials acknowledge the need to 

carefully assess the effectiveness of the changes.

NRC Is Taking Action to 

Improve Various Areas of Its 

Oversight Process

According to NRC, the ROP was implemented with the understanding that 

it would be an evolving process and improvements would be made as 

lessons were learned. Each year NRC conducts a self-assessment of its 

oversight process to compile feedback from various internal and external 

sources and to outline the changes it intends to make. As a part of its selfassessment, NRC developed numerous performance metrics for its various 

oversight components, including its inspections and performance indicator 

program, to provide quantitative insights into the timeliness, efficiency, and 

overall effectiveness of the ROP. The metrics are based on program data, 

such as the number and color of inspection findings, and feedback received 

from external and internal stakeholders. Each fall, NRC solicits feedback 
Page 29 GAO-06-1029 Oversight of Nuclear Power Plant Safety

from external stakeholders through a survey published in the Federal 

Register. In 2005, NRC received 21 responses from the industry, industry 

organizations, public interest groups, state or local agencies, and members 

of the public. NRC also biannually surveys NRC management, program 

staff, and regional and site inspectors on the effectiveness of the ROP. In 

the most recent survey, which was conducted in 2004, NRC received 

responses from about 50 percent of the surveyed staff. In addition, NRC has 

a formal feedback mechanism whereby NRC staff can submit 

recommendations for improving various oversight components, and NRC 

staff meet with industry officials on a monthly basis—in addition to holding 

various meetings, workshops, and conferences—to discuss the ROP. 

Through NRC’s self-assessment process, its staff also incorporates 

direction provided by the NRC commissioners and recommendations from 

independent evaluations, such as from the ACRS, GAO, and the NRC Office 

of the Inspector General. 

According to NRC program officials, the changes made to the ROP since its 

inception in 2000—including those made in response to the Davis-Besse 

incident—have generally refined the existing oversight process, rather than 

significantly changing it. In the case of Davis-Besse, NRC formed a task 

force to review the agency’s regulatory processes. The task force’s report, 

issued in September 2002, contained more than 50 recommendations, many 

associated with its oversight process. Among the more significant ROPrelated recommendations were those to (1) enhance the performance 

indicator that monitors unidentified leakage; (2) develop specific guidance 

to inspect licensee boric acid control programs and vessel head penetration 

nozzles; (3) modify the inspection program, including modifying an 

inspection procedure to better follow up on long-standing plant 

performance issues; and (4) enhance the guidance for managing plants that 

are shut down as a result of significant performance problems. NRC 

program officials told us that the task force’s most significant 

recommendations were in areas outside of the ROP, such as improving the 

agency’s operating experience program. According to NRC, it has 

implemented almost all of the task force’s recommendations.

Other modifications NRC has recently made or is in the process of making 

include the following:

• NRC recently revised 7 of its baseline inspection procedures to better 

focus the level and scope of its inspection efforts on those areas most 

important to safety. These revisions resulted from a detailed analysis in 

2005 of its more than 30 baseline inspection procedures. For example, 
Page 30 GAO-06-1029 Oversight of Nuclear Power Plant Safety

NRC staff analyzed the number of findings resulting from each of its 

inspection procedures to better understand the areas where 

performance deficiencies were occurring, and compared the time that 

inspectors were spending directly observing plant activities as opposed 

to reviewing licensee paperwork to achieve a balance between the two. 

For this effort, NRC held constant the level of resources devoted to its 

baseline inspection effort and did not assess whether more or fewer 

inspection resources overall should be applied. NRC is now formalizing 

this analysis and making it a regular part of its yearly assessment so that 

it can continually refine its inspections to direct resources to the most 

critical performance areas.

• NRC has efforts under way to improve its SDP. An audit by the NRC 

Office of the Inspector General, a review by a special task group formed 

by NRC, and feedback from other stakeholders such as NEI and UCS 

have pointed to several significant weaknesses with the SDP. Also, other 

internal and external stakeholders, including NRC inspectors and plant 

managers, have raised concerns about the amount of time, level of 

effort, and knowledge and resources required to determine the risk 

significance of some inspection findings. Industry officials commented 

that because most inspection findings are green, one white finding at a 

plant can place it in the “bottom quartile” of plants from a performance 

perspective. Therefore, industry officials explained, licensees try to 

avoid this placement and will expend a great deal of effort and 

resources to provide additional data to NRC to ensure that the risk level 

issued for the finding is appropriate. This can add significant time to the 

process because licensees may use their own technical tools, including 

models, data, and assumptions, to analyze the issue. NRC then considers 

this information in its own analysis. At the plants we reviewed, the time 

it took NRC to determine the final significance of risk-significant 

inspection findings ranged from 24 days to over 200 days. The delay in 

assigning a color to a finding while the new information is being 

considered could affect a plant’s placement on NRC’s action matrix, 

essentially delaying the increased oversight called for if the finding is 

determined to be greater-than-green. NRC program officials said that 

even though there may be a delay in determining the final risk 

significance of the finding, the licensee takes immediate action to fix the 

identified problem. However, supplemental inspections are designed to 

uncover additional associated problems, if they exist, and delaying these 

inspections could delay NRC’s ability to discover additional 

performance problems, potentially allowing performance to worsen. 
Page 31 GAO-06-1029 Oversight of Nuclear Power Plant Safety

NRC developed a plan in 2002 to improve the timeliness of its decisionmaking process, enhance the quality of its various SDP tools, and track 

its progress in implementing key changes. For example, NRC introduced 

a new process aimed at improving timeliness by engaging decision 

makers earlier to more quickly identify the scope of the evaluation to be 

used to determine the inspection finding’s risk significance, the 

resources needed, and the schedule to complete the evaluation. 

As a part of the SDP, NRC uses probabilistic risk assessment (PRA) 

methods, which overall has improved its ability to assess the 

performance and safety of nuclear power plants. PRA is an analytical 

tool for estimating the probability that a potential accident might occur 

by examining how physical structures, systems, and components, along 

with employees, work together to ensure plant safety. Using PRA tools, 

NRC and the plant licensees can estimate the likelihood that different 

accident scenarios at plants will result in reactor core damage and a 

release of radioactive materials. NRC often uses PRA tools to help it 

determine the risk significance of its inspection findings. However, we 

and others have found weaknesses with NRC’s use of PRA.13 For 

instance, in our May 2004 report on the Davis-Besse reactor vessel head 

incident, we found that NRC used some incomplete and faulty PRA 

analyses in deciding whether to allow the licensee to delay shutdown of 

the reactor for inspection.14 While NRC program officials acknowledge 

they can improve their current PRA tools, they said the tools are 

adequate for factoring risk into the oversight process and do achieve 

their intended purpose. NRC has several initiatives under way to 

improve its use of PRA in its decision making, many of which it plans to 

complete by June 2007. For example, NRC recently revised its models to 

assess events that occur at plants during at-power situations to better 

capture individual plant characteristics, and it is in the process of 

developing new models to assess events that occur at plants during lowpower or shutdown conditions. NRC is also developing guidance to 

address broader PRA issues, including establishing overall quality 

requirements for risk information; providing specific instructions for 

13Currently, the NRC Office of the Inspector General is also completing a review, through a 

contract with technical experts, to assess NRC’s use of PRA in its regulation of licensees 

given the current state of the art in the technology.

14GAO, Nuclear Regulation: NRC Needs to More Aggressively and Comprehensively 

Resolve Issues Related to the Davis-Besse Nuclear Power Plant’s Shutdown, GAO-04-415

(Washington, D.C.: May 17, 2004).
Page 32 GAO-06-1029 Oversight of Nuclear Power Plant Safety

documenting the decision process and conclusions; and developing 

improved methods for calculating risk, such as its practices for 

implementing human reliability analysis. 

• NRC is working with the nuclear power industry to improve several of 

its performance indicators, including making the definitions of some 

indicators more concise to improve their quality and to reduce the 

number of discrepancies between licensees and NRC inspectors. 

Because NRC inspectors verify indicator data only once a year, a 

potential disagreement with a licensee over these data might not surface 

for up to 1 year after it is reported, and it may take even longer to 

resolve the disagreement. Similar to delays with the SDP, a delay in 

assigning a color while the disagreement is being resolved could affect a 

plant’s placement on NRC’s action matrix, and delay the increased 

oversight called for if the indicator is determined to be greater-thangreen. To date, NRC’s efforts to improve the performance indicator 

program have largely centered on developing a key indicator to address 

known problems with the indicators that measure the unavailability of 

safety systems. NRC has been working jointly with the nuclear industry 

since 2001 to develop the indicator, which is now risk-informed and 

intended to provide a more accurate indication of the risks associated 

with changes in the availability and unreliability of important safety 

systems. This indicator, referred to as the mitigating systems 

performance index, was implemented in April 2006, and the first plant 

reports were submitted in July 2006. NRC is also in the process of 

changing the definition for several other indicators, in addition to 

considering the feasibility of new indicators.

In addition, NRC program officials said they are taking a broad look at 

the performance indicator program to assess how they might increase 

its overall value to the ROP. The effort is intended, in part, to address 

concerns that performance indicators have not contributed to the early 

identification of poorly performing plants to the degree originally 

envisioned, since all of the indicators are almost always within 

acceptable performance levels (green). When the program was 

developed, thresholds were set using industry performance data such 

that about 5 percent of the plants were expected to exceed the greenwhite threshold—that is, be designated either white, yellow, or red—for 

each of the performance indicators. However, from 2000 through 2005, 

less than 1 percent exceeded it. Furthermore, there have been several 

cases where plants reported an acceptable performance indicator and 

performance problems in the area were subsequently identified. For 
Page 33 GAO-06-1029 Oversight of Nuclear Power Plant Safety

example, NRC inspectors at one plant noted that while performance 

indicator data related to its alert and notification system for emergency 

preparedness had always been reported green, the system did not 

always function properly. On the other hand, industry officials believe 

that the high percentage of green indicators is indicative of plants’ good 

performance. Several plant managers told us that they closely monitor 

and manage to the acceptable performance thresholds established for 

each indicator, and that they will often take action to address 

performance issues well before the indicator crosses the acceptable 

threshold. To assess issues within the performance indicator program, 

NRC developed a standing working group, with representatives from 

both the industry and NRC, that meets on a monthly basis. This group, 

along with senior NRC and industry management, plans to explore 

overall program improvements to better identify declining plant 

performance. 

In addition to the previously mentioned efforts, NRC is assessing whether it 

needs to modify its oversight, including developing additional inspection 

procedures, as a result of some problems that have surfaced in areas not 

fully inspected by NRC. For example, NRC has reported that there have 

been inadvertent, unmonitored releases of radioactive liquids containing 

tritium at a number of nuclear power sites in the past few years.15 To date, 

NRC reports show that the measured levels of tritium discovered were low 

enough that they do not appear to pose a public health hazard. According 

to NRC, the releases were due to equipment failures or structural 

degradation at the plants. At one of the plants we reviewed, for example, 

elevated levels of tritium in the on-site groundwater were discovered 

during the licensee’s testing of its monitoring wells. NRC reports suggest 

that this radioactive release was most likely due to leakage from the spent 

fuel pool’s support structures. Shortly after the licensee reported the 

contamination, NRC initiated a special inspection to further investigate the 

source and cause of the leakage and the licensee’s actions for mitigation. 

On the basis of this and other discoveries of contaminated groundwater, in 

March 2006, NRC formed a lessons-learned task force to evaluate NRC’s 

regulatory processes related to the radioactive releases and to recommend 

areas for improvement. For example, NRC is reviewing related regulations 

15Tritium is a mildly radioactive type of hydrogen that occurs both naturally and during the 

operation of nuclear power plants. Water containing tritium and other radioactive 

substances is normally released from nuclear plants under controlled, monitored conditions 

that NRC mandates to protect public health and safety.
Page 34 GAO-06-1029 Oversight of Nuclear Power Plant Safety

and guidance, inspection program requirements, and its communications 

with external stakeholders and the public. In addition, the nuclear industry 

recently undertook an initiative to improve its groundwater protection, and 

intends to develop site-specific action plans at all plants and improve the 

industry’s data collection, reporting, and protocols for sharing lessons 

learned.

NRC is also taking action to improve its requirements for licensees to 

control and account for their spent nuclear fuel, that is, the used fuel 

periodically removed from reactors in nuclear power plants. NRC requires 

licensees to control and account for all of their spent fuel materials 

because of the hazardous nature of spent nuclear fuel.16 However, reviews 

by both GAO and the NRC Office of the Inspector General found 

weaknesses with NRC’s oversight of licensees’ spent fuel control and 

tracking programs.17 Between 2000 and 2004, several plants experienced 

instances of missing or unaccounted-for spent fuel, and NRC reported 

weaknesses in the material control and accounting programs at various 

other plants. In investigating these issues, we and the NRC Office of the 

Inspector General determined that NRC’s inspections did not adequately 

ensure that all licensees properly controlled and accounted for their spent 

nuclear fuel. From the late-1980s through implementation of the ROP, NRC 

did not conduct routine material control and accounting inspections; 

instead it looked at these activities indirectly through other inspections, 

such as those of licensee operations during refueling of the reactor. We also 

found that while NRC requires plants to maintain an accurate record of all 

their spent fuel and its location, NRC regulations did not specify how 

licensees are to conduct physical inventories or how they are to control 

and account for loose spent fuel rods and fragments. NRC is currently in 

the process of revising several of its guidance documents and developing 

inspection procedures to better assess the effectiveness of licensee 

material control and accounting programs. NRC reports that most of these 

efforts will be completed by the end of 2007.

16While spent nuclear fuel is too inefficient to power a nuclear reaction, it is still intensely 

radioactive and continues to generate heat for thousands of years. Thus, the potential health 

and safety implications make the control of spent nuclear fuel of great importance. 

17GAO, Nuclear Regulatory Commission: NRC Needs to Do More to Ensure that Power 

Plants Are Effectively Controlling Spent Nuclear Fuel, GAO-05-339 (Washington, D.C.: Apr. 

8, 2005); and NRC, Office of the Inspector General, US Nuclear Regulatory Commission: 

Audit of NRC’s Regulatory Oversight of Special Nuclear Materials, OIG-03-A-15 (May 23, 

2003).
Page 35 GAO-06-1029 Oversight of Nuclear Power Plant Safety

NRC Is Taking Its First 

Major Step to Address a 

Significant ROP Weakness 

in the Area of Safety Culture 

One significant shortcoming in the ROP that we and others have found is 

that it has not been as effective as it could be in identifying and addressing 

early indications of deteriorating safety performance at nuclear power 

plants before problems develop. NRC and others have long recognized that 

a safety culture—the organizational characteristics that ensure that issues 

affecting nuclear plant safety receive the attention their significance 

warrants—can have a significant impact on a plant’s safety performance. 

The identification of a weak safety culture—or weaknesses in the 

attributes that make up a safety culture, such as attention to detail, 

adherence to procedures, and effective corrective and preventative 

actions—can point to early signs of deteriorating safety performance 

before conditions become so serious that a safety accident occurs. As early 

as 1989, NRC recognized the importance of developing a safety culture at 

each nuclear power plant that ensures safe plant operations, but NRC’s 

policy stated that it was the licensee’s duty and obligation to monitor and 

maintain a strong safety culture. 

Despite the recognition of the importance of a safety culture and several 

external groups’ recommendations to better incorporate safety culture 

aspects into NRC’s oversight process, NRC did not include specific 

measures to comprehensively assess plant safety culture when it 

implemented the ROP in 2000. As its new oversight process was being 

developed, external stakeholders, including the ACRS, concluded that 

additional oversight measures were needed to characterize licensees’ 

human performance and safety culture. The 2002 Davis-Besse reactor 

vessel head incident highlighted that this was a significant weakness in the 

ROP. Our May 2004 report concluded that the event occurred, in part, 

because NRC did not have an effective means to identify and address early 

indications of deteriorating safety at plants before performance problems 

develop. 

NRC did not take immediate action, however, contending that direct safety 

culture evaluations would cross the line from a regulatory function to a 

licensee management function. In August 2004, the NRC Commission 

directed the staff to improve the ROP by more fully addressing safety 

culture. In response, NRC staff formed a safety culture working group in 

early 2005 to lead the agency’s efforts to make changes to the ROP to better 

incorporate safety culture into its oversight process. As a part of this 

initiative, the working group obtained the input of external stakeholders 

through a series of public meetings held in late 2005 and early 2006. The 

group also incorporated lessons learned from events that occurred at the 

Salem and Hope Creek site during this same period. In 2004, NRC 
Page 36 GAO-06-1029 Oversight of Nuclear Power Plant Safety

confirmed there were problems with aspects of the site’s safety culture. In 

addressing the problem, NRC concluded that the ROP did not provide 

adequate tools to monitor the situation or the sufficiency of the licensee’s 

corrective actions. As a result, NRC deviated from the ROP to increase its 

oversight at the site, which included conducting special inspections and 

forming a team with expertise in the area to review the licensee’s corrective 

actions. (See app. I for additional information on the events at Salem and 

Hope Creek.) 

In February 2006, NRC issued proposed changes to some of its inspection 

procedures and guidance documents to incorporate safety culture into the 

ROP, and implemented the changes in July 2006. NRC used the following 

two overall approaches: first, it developed additional guidance for 

identifying and addressing cross-cutting aspects, and, second, it developed 

a structured way to determine the need to evaluate plants’ safety culture. 

Several inspection procedures were also modified to direct inspectors to be 

sensitive to and take into consideration safety culture components when 

planning and conducting their inspections. Although the three cross-cutting 

aspects (problem identification and resolution, human performance, and a 

safety conscious work environment) did not change, NRC developed new 

definitions for them to more fully encompass safety culture aspects. Also, 

NRC developed additional guidance on the treatment of cross-cutting 

aspects once they have been identified. For example, the problem 

identification and resolution cross-cutting area now has several 

components—a corrective action program, operating experience, and self 

and independent assessments. The human performance cross-cutting area 

is composed of decision making, resources, work control, and work 

practices. NRC inspectors are required to assess every inspection finding to 

determine if it is associated with one or more of the components that make 

up each of the cross-cutting areas. While the process for assessing 

inspection findings for the existence of cross-cutting aspects and 

substantive cross-cutting issues remains largely unchanged, now the 

definitions for the cross-cutting areas are more detailed and track more 

closely with those elements that comprise safety culture.18 In addition, 

under NRC’s new guidance, if the same substantive cross-cutting issue is 

18NRC also defined four additional components—accountability, continuous learning 

environment, organizational change management, and safety policies—that are not 

associated with the cross-cutting issues, but when combined with them, comprise all 

components that make up safety culture. While these additional components are not 

considered in relation to baseline inspection findings, they would be considered during the 

conduct of supplemental inspections.
Page 37 GAO-06-1029 Oversight of Nuclear Power Plant Safety

identified in three consecutive assessment periods, NRC may request that 

the licensee evaluate its safety culture. The intent is to provide an 

opportunity to diagnose a potentially declining safety culture before 

significant safety performance problems occur. NRC program officials said 

they consider the identification and treatment of substantive cross-cutting 

issues the most proactive element of the ROP, because all other oversight 

actions are taken only when more significant performance problems have 

been identified.

NRC’s changes to the ROP now also include a structured way for NRC to 

determine the need for a safety culture evaluation. NRC’s new guidance 

calls for the licensees of plants with more than one white finding in the 

same cornerstone or one yellow finding to evaluate whether the 

performance issues were caused by any safety culture components, and 

NRC may request the licensee to independently evaluate its safety culture, 

if the licensee does not identify a safety culture component. Any safety 

culture deficiencies are expected to be entered into the licensee’s 

corrective action program. Regional officials would discuss the licensee’s 

proposed corrective actions with the licensee, and NRC may hold a public 

meeting to discuss the issues. For plants where more significant or multiple 

findings have been identified, NRC will not only independently assess the 

adequacy of the licensee’s independent evaluation of safety culture, but 

may also conduct its own evaluation. Following the completion of any 

evaluations, regional and headquarters officials together determine 

whether additional agency actions are warranted, and, at a minimum, the 

licensee will be required to document its plan to make improvements and a 

public meeting will be held to discuss the licensee’s performance. 

According to an NRC official familiar with the Salem and Hope Creek 

situation, had these requirements been in place at the time, they would 

have been adequate to address the concerns at Salem and Hope Creek 

without the need to deviate from the ROP. 

NRC’s approach to incorporating safety culture into the ROP has been 

controversial, and some stakeholders disagree with certain changes. For 

example, some in the nuclear power industry have expressed concern that 

the changes could introduce undue subjectivity to NRC’s oversight, given 

the difficulty in measuring these often intangible and complex concepts. 

Several of the nuclear power plant managers at the sites we reviewed said 

that it is not always clear why a cross-cutting aspect is associated with a 

finding, or what it will take to clear themselves once they have been 

identified as having a substantive cross-cutting issue. Some industry 

officials worry that the changes will further increase the number of findings 
Page 38 GAO-06-1029 Oversight of Nuclear Power Plant Safety

that have cross-cutting aspects associated with them, and, if all of the 

findings have these aspects, whether the process will lose its value. 

Industry officials also warn that if the changes are not implemented 

carefully, resources could be diverted away from other important safety 

issues. Other external stakeholders, such as an official from UCS, on the 

other hand, suggest that this effort is an important step toward improving 

NRC’s ability to identify performance issues at plants before they result in 

safety problems. Importantly, there are now additional tools in place for 

NRC to use when it identifies potential safety culture concerns. In 

reviewing NRC’s proposed approach in April 2006, the ACRS concluded 

that the approach was appropriate and will enhance the agency’s ability to 

address safety culture issues; although after gaining some experience with 

the process, it stated that NRC should reassess the adequacy of some 

procedures. 

NRC program officials acknowledged that they will need to assess the 

changes they made to the ROP to determine if they better allow inspectors 

to detect deteriorating safety conditions at plants before significant safety 

events occur. Some at NRC view these changes as the beginning step 

toward an incremental approach. For its current efforts, NRC also 

acknowledged that additional training for its inspectors on safety culture is 

needed. NRC provided computer-based and regional training to its 

inspectors as the changes were being finalized, and it is currently working 

to incorporate aspects of its safety culture changes into its more permanent 

training programs. NRC plans to evaluate stakeholder feedback—both 

through its normal processes, such as its monthly meetings, and potentially 

through specific industry-sponsored workshops dedicated to the issue—

and make additional changes on the basis of the lessons learned as part of 

its annual self-assessment process for 2007. 

Conclusions NRC is devoting considerable effort to overseeing the safe operation of the 

nation’s commercial nuclear power plants, and its process for doing so 

appears logical and well-structured. NRC’s oversight process is finding 

safety problems and is getting the industry to constantly improve. However, 

weaknesses with its inspection and performance indicator programs have 

been identified—in particular, the timeliness of the process used to 

determine the risk significance of inspection findings, and the ability of 

performance indicators to contribute to the early identification of poorly 

performing plants. Importantly, NRC is demonstrating that it is aware of 

these weaknesses and is actively making changes to improve its oversight. 

NRC’s proactive approach is demonstrated by the important progress it is 
Page 39 GAO-06-1029 Oversight of Nuclear Power Plant Safety

making in several key areas, including making efforts to improve the 

timeliness and quality of its significance determination process, redefining 

some of its performance indicators, and assessing the need for additional 

inspection procedures based on careful analysis. Its efforts to continuously 

consider the need to improve and obtain feedback from both internal and 

external stakeholders are critical as nuclear power plants age and the 

nation considers building new plants. In this regard, it is also important that 

the ROP continue to be a very open process in which NRC provides the 

public and its other stakeholders with considerable information on its 

oversight activities and findings related to plant safety performance. 

Although NRC has been working to improve its oversight in several key 

areas, its efforts to incorporate safety culture into the ROP may be its most 

critical future change. More than 4 years have passed since Davis-Besse 

highlighted that a significant weakness in NRC’s oversight was its inability 

to identify deteriorating safety conditions at plants before they resulted in 

performance problems. NRC has been reluctant to regulate in the area of 

safety culture because it did not want to be directly involved in managing 

the licensees’ plants. However, NRC is now taking concrete actions to 

begin incorporating safety culture into the ROP, although it acknowledges 

that regulating the often complex and intangible aspects of safety culture is 

challenging, and that its recent changes are simply a first step. As a result, it 

will be important to closely monitor this effort to ensure that it is achieving 

the goal of objectively assessing safety culture, while providing an early 

indication of declining safety performance. An additional challenge for 

NRC will be how to provide information to the public and other 

stakeholders on this important but complex area of plant performance. 

Given that it may take some time for NRC to develop performance metrics 

for safety culture, data on substantive cross-cutting issues, which provide 

insight into aspects of plants’ safety culture, could be useful to the public 

and other stakeholders as they look for assurances that plants are operated 

safely. Summary-level information on plants with substantive cross-cutting 

issues is not currently available to the public through NRC’s Web site. 

Recommendations for 

Executive Action

Given its importance to improving NRC’s ability to identify declining safety 

performance at nuclear power plants before significant safety problems 

develop, we recommend that the NRC commissioners take the following 

two actions: 
Page 40 GAO-06-1029 Oversight of Nuclear Power Plant Safety

• Aggressively monitor; evaluate; and, if needed, implement additional 

methods or processes to increase the effectiveness of its efforts under 

the ROP to assess safety culture at plants. 

• 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. 

In addition, in the absence of performance indicators or other performance 

metrics for plants’ safety culture, we recommend that the NRC 

commissioners make publicly available, through the ROP Web site, 

consolidated and comprehensive data on the plants that have substantive 

cross-cutting issues open. These data would 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.

Agency Comments We provided a draft of this report to NRC for its review and comment. In a 

letter from NRC’s Executive Director for Operations, NRC generally agreed 

with the report’s findings, conclusions, and recommendations (see app. IV). 

NRC also commented that the report is comprehensive, fair, and balanced. 

In addition, NRC provided minor, technical comments, which we have 

incorporated into the report, as appropriate.

We are also sending copies of this report to interested congressional 

committees, the Chairman of NRC, and other interested parties. We also 

will make copies available to others upon request. In addition, the report 

will be available at no charge on the GAO Web site at http://www.gao.gov.
Page 41 GAO-06-1029 Oversight of Nuclear Power Plant Safety

If you or your staffs have any questions about this report, please contact 

me at (202) 512-3841 or wellsj@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix V.

Jim Wells

Director, Natural Resources and Environment 
Page 42 GAO-06-1029 Oversight of Nuclear Power Plant Safety

List of Requesters

The Honorable James M. Inhofe

Chairman

Committee on Environment and Public Works

United States Senate

The Honorable George V. Voinovich

Chairman

Subcommittee on Clean Air, Climate Change, 

and Nuclear Safety

Committee on Environment and Public Works

United States Senate

The Honorable Ed Whitfield

Chairman

Subcommittee on Oversight and Investigations

Committee on Energy and Commerce

House of Representatives

The Honorable Joseph R. Biden, Jr.

United States Senate

The Honorable Tom Carper

United States Senate

The Honorable Michael N. Castle

House of Representatives

The Honorable Edward J. Markey

House of Representatives
Page 43 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Appendix I

Key Safety-Related Events at the Salem and Apendxies

Hope Creek Nuclear Power Plants from 2000 

to 2006 ApendxiI

This appendix summarizes key safety-related events at the Salem and Hope 

Creek nuclear power plants and the Nuclear Regulatory Commission’s 

(NRC) and licensee’s actions to follow up on and correct them. This 

information is presented to enhance the public’s understanding of the 

events and timing of NRC’s actions. We did not conduct an independent 

audit or assessment of the events, other than to help illustrate how NRC is 

using its oversight process to ensure plant safety. 

The Salem and Hope Creek plants are located at one site in Hancocks 

Bridge, New Jersey, 18 miles southeast of Wilmington, Delaware, on the 

Delaware River. The two Salem plants (Salem 1 and Salem 2) consist of two 

pressurized water reactors, and the Hope Creek plant is a boiling water 

reactor. The three plants produce a combined 3,237 megawatts of 

electricity. Salem 1 began operating in the late-1970s and Salem 2 and Hope 

Creek began operating in the 1980s. PSEG Nuclear LLC is licensed to 

operate all three plants, with their current licenses expiring roughly 40 

years after the start of their operations. In January 2005, PSEG entered into 

a nuclear operating services contract with Exelon, the first step of a 

planned merger between the two companies. Under the terms of this 

contract, Exelon manages operations at Salem and Hope Creek.

From 2000 through 2006, there were several safety-related events at the site 

that affected the plants’ performance. As a result, NRC increased its 

oversight to include supplemental and special inspections, and required the 

licensee to take specific actions to address its performance issues. NRC 

also deviated from its normal oversight process from August 2004 through 

2006 to increase its oversight and address problems with the licensee’s 

ability to provide an adequate safety-conscious work environment (SCWE). 

A SCWE is defined by NRC as an environment in which employees feel free 

to raise safety concerns, both to their management and to NRC, without 

fear of retaliation. During this period, NRC and the licensee held several 

public meetings to discuss performance issues related to the site’s safety 

work environment, or the SCWE, and the actions the licensee was taking to 

improve it.

The following summary provides details on the key safety-related events at 

Salem and Hope Creek, along with NRC’s and the licensee’s responses to 

the events, from the initial implementation of NRC’s reactor oversight 

process in April 2000 to June 2006.
Appendix I

Key Safety-Related Events at the Salem and 

Hope Creek Nuclear Power Plants from 2000 

to 2006

Page 44 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Summary of Key 

Safety-Related Events 

at Salem and Hope 

Creek, April 2000 to 

June 2006 

White Performance 

Indicator for Unplanned 

Scrams

During the fourth quarter of 2000, Salem 1 reported a white color for the 

unplanned scrams performance indicator, an indicator that monitors the 

number of unplanned scrams—reactor shutdowns—that occurred during 

the previous four quarters. During 2000, Salem 1 had four scrams, which is 

one more than the acceptable performance level. NRC conducted a 

supplemental inspection in March 2001 to follow up on why such a high 

number of scrams occurred and on the corrective actions the licensee was 

taking to address the problem. In conducting its inspection, NRC 

determined that the licensee had performed a comprehensive common 

cause analysis of the associated performance deficiencies, which identified 

human performance, equipment failure, and procedure and preventive 

maintenance program issues as root causes of the performance problems. 

The licensee documented these issues in its corrective action program and 

developed a plan to outline the actions it would take to address them. NRC 

concluded this effort was sufficient and did not require the licensee to take 

any additional corrective actions beyond what it had outlined in its plan. 

White Performance 

Indicator for Unplanned 

Changes in Reactor Power

During the first quarter of 2002, Salem 1 reported a white color for the 

performance indicator that monitors unplanned changes in reactor power 

that could have challenged safety functions during the previous four 

quarters. Salem reported a total of seven power changes, which exceeded 

the acceptable performance threshold by one. NRC conducted a 

supplemental inspection in October 2002 and concluded that the licensee’s 

implementation of several programs to address the underlying causes of 

the unplanned power changes, such as the replacement of certain pieces of 

equipment, sufficiently addressed the performance problem. NRC did not 

require the licensee to take any additional corrective actions.
Appendix I

Key Safety-Related Events at the Salem and 

Hope Creek Nuclear Power Plants from 2000 

to 2006

Page 45 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Substantive Cross-Cutting 

Issue in Problem 

Identification and 

Resolution

In March 2003, NRC opened a substantive cross-cutting issue in the 

problem identification and resolution area at all three plants on the basis of 

the identification of a number of green inspection findings that 

documented ineffective problem evaluations and untimely, ineffective 

corrective actions by plant employees, including recurring equipment 

failures. Upon opening this substantive cross-cutting issue, NRC stated that 

it would closely monitor the licensee’s performance in this area. This 

substantive cross-cutting issue remained open until March 2006, when NRC 

concluded that the licensee’s efforts to improve its ability to identify and 

resolve performance problems were sufficient. 

White Inspection Finding 

for Failure of a Part on an 

Emergency Diesel 

Generator

In May 2003, NRC determined that the failure of a part on an emergency 

diesel generator at the Salem 1 plant that occurred in September 2002 

would result in a white inspection finding. NRC conducted a supplemental 

inspection in October 2003 and concluded that although the licensee had 

adequately fixed the emergency diesel generator, it would need to take 

additional action to address broader performance problems. Specifically, 

NRC had concerns with the licensee’s ability to ensure that the controls and 

procedural requirements determined to be necessary on the basis of 

evaluations of equipment failures, were reliably tracked and implemented. 

The licensee implemented procedural changes to more effectively track its 

corrective actions to prevent recurrence. NRC conducted a second, followup supplemental inspection in September 2004 and, on the basis of this 

inspection, concluded that the licensee’s corrective actions were sufficient. 

White Inspection Finding 

for the Failure of a Rotating 

Screen That Is Part of the 

Station Service Water 

System at Hope Creek

In May 2004, NRC determined that the failure in July 2003 of a rotating 

screen that is part of the station service water system at Hope Creek would 

result in a white inspection finding. NRC determined that the failure 

resulted from the licensee’s inadequate maintenance procedures and its 

failure to adhere to procedural instructions. In September 2004, NRC 

conducted a supplemental inspection to follow up on the corrective actions 

that licensee had taken. It determined that the licensee’s corrective actions, 

which included revising relevant maintenance procedures, were sufficient 

and did not require additional actions from the licensee. 
Appendix I

Key Safety-Related Events at the Salem and 

Hope Creek Nuclear Power Plants from 2000 

to 2006

Page 46 GAO-06-1029 Oversight of Nuclear Power Plant Safety

White Inspection Finding 

for the Failure of a Drain 

Line in the Moisture 

Separator System at Hope 

Creek

In February 2005, NRC determined that the licensee’s failure to properly 

evaluate and correct a degraded valve, which resulted in the failure of a 

drain system at Hope Creek in October 2004, would result in a white 

inspection finding. NRC conducted a supplemental inspection in June 2005 

to follow up on the licensee’s corrective actions, which included the 

development of new guidance; revisions to relevant plant operating 

procedures; inspections of pipe hangers, one of which was determined to 

be the initiator of the degraded valve; and the development of a new 

procedure for additional monitoring of degraded equipment. NRC 

determined that these actions were sufficient and did not require additional 

actions from the licensee. 

Increased Oversight to 

Address Safety-Conscious 

Work Environment 

Problems

In late 2003, NRC initiated a special review of the site’s SCWE on the basis 

of allegations concerning its SCWE, plant events and inspection findings 

that indicated problems with its SCWE, insights from NRC interactions 

with the licensee, observations made by NRC inspectors, and the presence 

of a substantive cross-cutting issue in problem identification and 

resolution. NRC’s special review consisted of (1) in-depth interviews by 

NRC experts of more than 60 current and former plant employees, (2) an 

analysis of the site’s inspection and assessment record over the previous 

several years, and (3) information from plant employees’ allegations 

related to the SCWE. NRC provided the interim results of its review to the 

licensee in January 2004. Although NRC did not identify any serious safety 

violations, the information led to concerns about the site’s SCWE, 

particularly as it related to the handling of emergent equipment issues and 

associated operational decision making. The review accumulated 

information about a number of events that, to varying degrees, called into 

question the openness of management to concerns and alternative views, 

strength of communications, and effectiveness of the licensee’s corrective 

action and feedback processes. There were several differences of opinion 

among operators and senior managers on plant operating decisions, 

particularly as they might impact continuing plant operation and outage 

schedules. On the basis of these interim results, NRC requested that the 

licensee conduct an in-depth assessment of its SCWE.

NRC issued the final results of its special review in July 2004, confirming 

many of the concerns it identified through its interim review. In its final 

results, NRC concluded that there were weaknesses in the licensee’s 

leadership and management approaches, leading to a perception among 

some staff and mangers that the company emphasized production over 
Appendix I

Key Safety-Related Events at the Salem and 

Hope Creek Nuclear Power Plants from 2000 

to 2006

Page 47 GAO-06-1029 Oversight of Nuclear Power Plant Safety

safety. NRC also determined that licensee management was not consistent 

in its support of staff identifying concerns and providing alternate views, 

and cited examples of unresolved conflicts and poor communication 

between management and staff.

In May 2004, the licensee submitted an independent assessment of its 

SCWE. The assessment included interviews of employees, and reviews of 

the licensee’s inspection record and employee concerns program, among 

other things. Among the findings of the assessment were that (1) some 

plant employees were hesitant to raise issues; (2) management was not 

receptive to or effective at addressing some employee concerns, such as 

those surrounding long-standing equipment problems; (3) a significant 

number of employees did not view the employee concerns program as a 

viable means to raise concerns; and (4) management was not effective at 

understanding or addressing the potential for a “chilling” effect––that is, an 

environment that discourages workers from raising safety concerns––in 

response to highly visible employee concerns and actions associated with 

operational events.

As a result of the assessment, the licensee submitted to NRC in June 2004 

an action plan to improve its overall safety work environment. The plan 

addressed the licensee’s corrective action program, work management 

program, and safety-conscious work environment. For example, to 

improve the licensee’s corrective action program, the plan identified 

actions to improve monitoring, such as developing and implementing an 

integrated corrective action training program and developing performance 

indicators. The plan also included a number of actions to improve the 

licensee’s management alignment, prioritization, support for and 

awareness of the workweek schedule, and communication and training 

strategies to support work management improvements. In addition, the 

plan included actions to improve the willingness of plant employees to 

raise concerns, improve the effectiveness of policies and procedures for 

resolution of issues, enhance key elements of the employee concerns 

program, and improve management effectiveness in detecting and 

preventing retaliation or a chilled environment. The licensee’s action plan 

included 17 metrics designed to measure safety work environment 

improvements. The licensee provided the results of these metrics to NRC 

on a quarterly basis.

In August 2004, NRC regional officials received approval from headquarters 

to deviate from the normal oversight process to increase oversight at the 

site to monitor the licensee’s actions to improve its safety work 
Appendix I

Key Safety-Related Events at the Salem and 

Hope Creek Nuclear Power Plants from 2000 

to 2006

Page 48 GAO-06-1029 Oversight of Nuclear Power Plant Safety

environment. NRC’s increased oversight consisted of (1) reviewing the 

results of the specific actions the licensee took as a part of its action plan, 

(2) creating an NRC team with expertise in the area to assist with 

coordinating and focusing these review efforts, and (3) conducting 

additional special inspections and enhancing existing inspections by 

adjusting their focus and scope. NRC determined that it could reduce its 

oversight to baseline levels once the licensee completed a self-assessment 

of its SCWE that concluded that it had made substantial, sustainable 

progress, and NRC confirmed the licensee’s conclusion.

NRC also opened a substantive cross-cutting issue in the SCWE area at all 

three plants in August 2004, on the basis of the results of its special review 

of the site’s SCWE completed that July. Upon opening this substantive 

cross-cutting issue, NRC requested that the licensee discuss its progress in 

improving its SCWE and the effectiveness of its corrective action program 

in a public meeting planned for late 2004. This substantive cross-cutting 

issue remained open in the 2005 annual assessment letter, issued in March 

2006. NRC will consider closing this substantive cross-cutting issue after 

the licensee provides the results of an assessment that concludes that it has 

made substantial, sustainable progress, and NRC has completed a review 

that confirms these results.

In June 2005, NRC issued the results of an inspection of the licensee’s 

employee concerns program (ECP) conducted as a part of its increased 

oversight to monitor the site’s safety work environment. NRC inspectors 

did not identify any findings of safety significance and concluded that the 

ECP provided a framework for investigating concerns, maintaining the 

confidentiality of personnel who use the program, and protecting 

employees who use the program against retaliation. They also concluded, 

however, that it was too early to fully assess the effectiveness of recent 

program improvements and initiatives. The inspectors observed that a 

statistically significant portion of the personnel interviewed indicated that 

they would not use the ECP due to a perception that the process did not 

take adequate measures to protect users’ confidentiality. NRC inspectors 

cited a section of the ECP that appeared to affirm this perception. The 

licensee emphasized that it was making efforts to protect confidentiality, 

and acknowledged that the ECP should reflect these efforts. 

NRC also provided the preliminary results of its review of the licensee’s 

executive review board (ERB) process in June 2005. The ERB was 

established to improve the site’s safety work environment and 

management’s effectiveness in detecting and preventing retaliation and a 
Appendix I

Key Safety-Related Events at the Salem and 

Hope Creek Nuclear Power Plants from 2000 

to 2006

Page 49 GAO-06-1029 Oversight of Nuclear Power Plant Safety

chilled work environment. NRC inspectors determined that lapses in the 

licensee’s use of the ERB process constituted a green inspection finding, 

although it did not represent a violation of regulatory requirements. NRC 

requested that the licensee reassess the review of the ERB in the broader 

context of the work environment, identify additional actions planned or 

taken to address negative worker perceptions, and provide a written 

response to NRC within 30 days. The licensee responded with planned 

corrective actions, including developing and implementing continuing 

training on the SCWE, and developing and implementing a plan to improve 

its corrective action program.

In July 2005, NRC headquarters extended regional officials’ permission to 

deviate from the normal oversight process and provide increased oversight 

at Salem and Hope Creek. The extension was necessary because the 

licensee had not yet met the criteria to move back to normal, or baseline 

levels of oversight. Increased oversight included (1) continued 

management meetings and site visits to review the implementation of the 

licensee’s corrective actions; (2) increased efforts, including using more 

inspectors and samples than what would typically be used, to conduct a 

baseline inspection of the site’s effectiveness at identifying and resolving 

problems; and (3) an additional inspection to monitor the licensee’s 

progress in resolving the substantive cross-cutting issue in the SCWE.

In November 2005, NRC issued the results of the special inspection on the 

site’s SCWE. The inspection included assessing the licensee’s progress and 

plans for making improvements to its SCWE, its metrics to monitor the 

effectiveness of the improvements made, and effectiveness of the licensee’s 

corrective actions and self assessment initiatives. NRC inspectors did not 

identify any findings of safety significance and determined that the licensee 

had made progress in improving its SCWE. For example, NRC inspectors 

concluded that workers’ willingness to raise safety concerns had increased. 

In addition, the licensee had taken a significant number of actions to 

improve the corrective action and work management programs and had 

implemented several corrective actions for the employee concerns 

program. They also concluded that the licensee had made progress in 

preventing and detecting retaliation. However, NRC inspectors also 

observed that some issues required additional action and focused 

attention, such as the need for the licensee to fully evaluate and address 

negative perceptions about its work environment in certain work groups. 

The licensee initiated actions to address these observations.
Appendix I

Key Safety-Related Events at the Salem and 

Hope Creek Nuclear Power Plants from 2000 

to 2006

Page 50 GAO-06-1029 Oversight of Nuclear Power Plant Safety

In May 2006, the licensee submitted to NRC an independent peer 

assessment that concluded that it had made substantial improvements to 

its SCWE, and a solid foundation existed to sustain them. The assessment 

included interviews with site personnel; observations of station activities 

and meetings; and reviews of the licensee’s programs, procedures, policies, 

and other relevant information. Among the assessment’s conclusions were 

that personnel throughout the organization exhibited a willingness to 

engage in open-and-candid discussions and raise safety and quality issues, 

the corrective action and work management programs had improved, 

management had been effective at detecting and preventing retaliation and 

addressing chilling effects in response to the raising of safety concerns, and 

management provided high-visibility and strong and continuous 

reinforcement of good work environment principles. In response, NRC 

began a review of the effectiveness of the licensee’s actions to improve its 

safety work environment. The results of this review will be a key input into 

NRC’s midcycle assessment of the site’s overall safety performance to be 

completed in August 2006; through the midcycle assessment NRC will 

determine any changes in the level of oversight for Salem and Hope Creek.
Page 51 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Appendix II

Scope and Methodology ApendxiI

To examine how NRC oversees plants, we reviewed the various tools and 

processes that comprise the Reactor Oversight Process (ROP). In this 

regard, we analyzed NRC’s documentation of its oversight process, 

conducted interviews with NRC program staff and other officials, visited 

one NRC regional office, and visited one nuclear power plant site that was 

of specific interest to our requesters. In particular, we reviewed NRC’s 

policies, inspection manuals, and other guidance documents outlining its 

various oversight process components—including reports discussing the 

ROP design basis; inspection and reporting requirements; performance 

indicator program guidance; and other requirements, such as those related 

to its enforcement and assessment processes. We interviewed NRC 

headquarters and regional officials and regional and on-site inspectors 

responsible for implementation of the ROP and visited the Salem and Hope 

Creek nuclear power plants to observe firsthand how the ROP is 

implemented by the resident inspectors located at each power plant. To 

learn more about how ROP results are communicated to the public, we 

attended the annual public meeting held at the Indian Point nuclear power 

plant. We also reviewed the information NRC makes available to the public 

on a Web site devoted to ROP topics, which includes both detailed plantspecific information and general program information and guidance. In 

addition, we interviewed external stakeholder individuals and groups 

about their experiences with the ROP, including the NRC Commission 

Chairman from 1995 to 1999, who is largely credited with leading the 

development of the ROP; officials from the NRC Office of the Inspector 

General, the Nuclear Energy Institute (NEI), the Union of Concerned 

Scientists (UCS), and Greenpeace; and nuclear power plant managers at six 

sites. 

To examine the results of the ROP over the past several years, we reviewed 

the number and types of inspection findings NRC issued, the performance 

indicators reported by the plants, and the level of oversight NRC provided 

to the plants. Specifically, we obtained and analyzed NRC data on its 

inspection findings for 2001 through 2005, the years since implementation 

of the ROP for which the data were available for the full year, and 

discussed our analysis with NRC program officials. We obtained inspection 

findings data from the NRC Reactor Program System (RPS) database and 

assessed the reliability of the RPS data by (1) performing electronic and 

manual testing of required data elements; (2) reviewing existing 

information about the data and the system that produced them; (3) 

reviewing an audit of the RPS database performed by the NRC Office of the 

Inspector General in 2005, and documents related to NRC’s implementation 

of the audit’s recommendations; and (4) interviewing agency officials 
Appendix II

Scope and Methodology

Page 52 GAO-06-1029 Oversight of Nuclear Power Plant Safety

knowledgeable about these data. We determined that these data were 

sufficiently reliable for the purposes of this report. Data elements included 

a breakout of inspection findings identified at each nuclear power plant, 

including information on their risk significance, or color; cornerstone; date; 

cross-cutting aspects; a brief description of the problem identified; and 

other related information. We also obtained and analyzed ROP data 

provided on NRC’s Web site, including a list of performance indicator data 

broken out by plant and by quarter and a list of the plants in each column of 

the action matrix by quarter since inception of the ROP in 2000. We 

assessed the reliability of these data by interviewing the appropriate 

agency officials about how these data are reported on the Web site and 

compared the data with source information contained in inspection reports 

and assessment letters for sample plants. We determined that these data 

were sufficiently reliable for the purposes of this report. In addition, we 

reviewed every assessment letter issued to each of the 103 plants since the 

inception of the ROP to document the plants that had one or more 

substantive cross-cutting issue open and the length of time that the issue 

was held open. We discussed the results of our data analysis with NRC 

headquarters program officials and compared the results of the ROP with 

other industry-collected and reported performance data, including data 

collected through NRC’s industry trends program, to identify any 

inconsistencies in trends or industry safety performance indicators.

To examine the status of NRC’s efforts to improve the ROP, we reviewed 

specific components of the ROP where weaknesses had been identified and 

recent and current staffs’ efforts to improve them. We analyzed NRC 

documents, including all annual self-assessment reports issued by NRC 

since 2001; interviewed officials from NRC headquarters, regional, and site 

offices and outside stakeholder groups, including NEI and UCS; and 

attended two public meetings covering proposed changes to incorporate 

safety culture into its oversight process. In reviewing the annual selfassessment reports, we analyzed comments submitted by both internal and 

external stakeholders that were collected during recent surveys. We 

analyzed responses submitted by internal staff, including management, 

program staff, and regional and site inspectors, and responses from 

external stakeholders, including industry, industry organizations, public 

interest groups, state and local agencies, and members of the public. We 

examined all proposed and final documents related to NRC’s safety culture 

changes, including inspection manuals, training documents, and other 

guidance documents. We also reviewed public comments submitted to 

NRC on its safety culture changes, such as those submitted by NEI, UCS, 

and meetings held on the topic by the Advisory Committee on Reactor 
Appendix II

Scope and Methodology

Page 53 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Safeguards (ACRS). In addition, we assessed various external reports and 

evaluations related to the ROP or specific aspects relevant to NRC’s 

oversight, such as issues surrounding safety culture, including our prior 

reports, those of the NRC Office of the Inspector General and of the ACRS. 

We met with NRC program officials responsible for assessing and 

implementing changes to the ROP to obtain a clear understanding of the 

actions they were taking and the status of their efforts.

Additionally, we selected a nonprobability sample1 of 6 nuclear power sites 

(totaling 11 of the 103 operating plants)2 that provided coverage of each of 

NRC’s four regional offices and varying levels of plant performance and 

NRC oversight since 2000. The following nuclear power sites were included 

in our review: Cooper (1 plant) located near Nebraska City, Nebraska; 

Indian Point 2 (1 plant) located near New York, New York; Oconee (3 

plants) located near Greenville, South Carolina; Perry (1 plant) located 

near Painesville, Ohio; Salem and Hope Creek (3 plants) located near 

Lower Alloways Creek, New Jersey; and Surry (2 plants) located near 

Newport News, Virginia. Our selection criteria was designed to represent 

geographic diversity, a variety of safety problems in which inspection 

findings or performance indicators of higher risk significance (white, 

yellow, and red) were issued, trends reflecting both improving and 

declining safety performance, and plants that have been subjected to at 

least some level of increased oversight since the ROP was implemented. 

The purpose of our review was to understand how performance problems 

were identified by NRC’s oversight process, what caused them, actions 

taken by NRC and the licensee in response to the problems, and how NRC 

documented their resolution. We analyzed all publicly available inspection 

reports and assessment documents covering years 2000 through 2005 for 

each site to examine how NRC applied the ROP to identify and correct 

safety problems.3

 We analyzed each green and greater-than-green 

inspection finding documented through the inspection reports and 

1

Because these plants represent a nonprobability sample, results cannot be used to make 

inferences about the population, or nuclear power industry as a whole. This is because in a 

nonprobability sample, some elements of the population being studied have no chance or an 

unknown chance of being selected as part of the sample.

2

The 6 sites are out of a total possible of 65. Oftentimes, there are 2 or 3 operating plants 

located at each nuclear power site, often operated and licensed by the same company, and 

therefore combined for NRC oversight purposes. 

3

Physical security inspection reports were not included in our analysis because physical 

security issues were not within the scope of this review.
Appendix II

Scope and Methodology

Page 54 GAO-06-1029 Oversight of Nuclear Power Plant Safety

collected data associated with each finding, including how it was identified, 

which cornerstone it was assigned to, whether the finding was associated 

with a violation of regulatory requirements, and whether there were any 

cross-cutting elements associated with the finding. For the greater-thangreen inspection findings, we collected additional information to determine 

the length of time it took the licensee to correct the performance problem, 

the length of time and level of effort NRC inspectors took to follow up on 

the issue, and the actions it required the licensee to take. Additionally, for 

each of the sites, we reviewed NRC reports and documentation showing 

that all baseline inspection procedures were completed (for 2004 and 

2005), and that inspectors verified the licensees’ reporting of the 

performance indicator data (for 2000 through 2005). We also interviewed 

NRC branch chiefs and resident inspectors and industry management 

officials at each site to learn more about NRC’s implementation of the ROP 

at the site. We conducted our work from July 2005 through July 2006 in 

accordance with generally accepted government auditing standards. 
Page 55 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Appendix III

Nuclear Power Plant Performance Data on the 

Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005 ApendxiI

Table 3: Commercial Nuclear Power Plants Licensed to Operate in the United States

Nuclear power plant City State NRC region

Arkansas Nuclear 1 Russellville AR IV

Arkansas Nuclear 2 Russellville AR IV

Beaver Valley 1 McCandless PA I

Beaver Valley 2 McCandless PA I

Braidwood 1 Joilet IL III

Braidwood 2 Joilet IL III

Browns Ferry 1 Decatur AL II

Browns Ferry 2 Decatur AL II

Browns Ferry 3 Decatur AL II

Brunswick 1 Southport NC II

Brunswick 2 Southport NC II

Byron 1 Rockford IL III

Byron 2 Rockford IL III

Callaway Fulton MO IV

Calvert Cliffs 1 Annapolis MD I

Calvert Cliffs 2 Annapolis MD I

Catawba 1 Rock Hill SC II

Catawba 2 Rock Hill SC II

Clinton Clinton IL III

Columbia Generating Station Richland WA IV

Comanche Peak 1 Glen Rose TX IV

Comanche Peak 2 Glen Rose TX IV

Cooper Nebraska City NE IV

Crystal River 3 Crystal River FL II

D.C. Cook 1 Benton Harbor MI III

D.C. Cook 2 Benton Harbor MI III

Davis-Besse Toledo OH III

Diablo Canyon 1 San Luis Obispo CA IV

Diablo Canyon 2 San Luis Obispo CA IV

Dresden 2 Morris IL III

Dresden 3 Morris IL III

Duane Arnold Cedar Rapids IA III

Edwin I. Hatch 1 Baxley GA II

Edwin I. Hatch 2 Baxley GA II

Fermi 2 Toledo MI III
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 56 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Fort Calhoun Omaha NE IV

Ginna Rochester NY I

Grand Gulf 1 Vicksburg MS IV

H.B. Robinson 2 Florence SC II

Hope Creek 1 Lower Alloways 

Creek

NJ I

Indian Point 2 New York NY I

Indian Point 3 New York NY I

James A. FitzPatrick Oswego NY I

Joseph M. Farley 1 Dothan AL II

Joseph M. Farley 2 Dothan AL II

Kewaunee Green Bay WI III

La Salle 1 Ottawa IL II

La Salle 2 Ottawa IL II

Limerick 1 Philadelphia PA I

Limerick 2 Philadelphia PA I

McGuire 1 Charlotte NC II

McGuire 2 Charlotte NC II

Millstone 2 New London CT I

Millstone 3 New London CT I

Monticello Minneapolis MN III

Nine Mile Point 1 Oswego NY I

Nine Mile Point 2 Oswego NY I

North Anna 1 Richmond VA II

North Anna 2 Richmond VA II

Oconee 1 Greenville SC II

Oconee 2 Greenville SC II

Oconee 3 Greenville SC II

Oyster Creek Toms River NJ I

Palisades South Haven MI III

Palo Verde 1 Phoenix AZ IV

Palo Verde 2 Phoenix AZ IV

Palo Verde 3 Phoenix AZ IV

Peach Bottom 2 Lancaster PA I

Peach Bottom 3 Lancaster PA I

Perry 1 Painesville OH III

Pilgrim 1 Plymouth MA I

(Continued From Previous Page)

Nuclear power plant City State NRC region
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 57 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Source: NRC.

Point Beach 1 Manitowoc WI III

Point Beach 2 Manitowoc WI III

Prairie Island 1 Minneapolis MN III

Prairie Island 2 Minneapolis MN III

Quad Cities 1 Moline IL III

Quad Cities 2 Moline IL III

River Bend 1 Baton Rouge LA IV

Salem 1 Lower Alloways 

Creek

NJ I

Salem 2 Lower Alloways 

Creek

NJ I

San Onofre 2 San Clemente CA IV

San Onofre 3 San Clemente CA IV

Seabrook 1 Portsmouth NH I

Seqouyah 1 Chattanooga TN II

Seqouyah 2 Chattanooga TN II

Shearon Harris 1 Raleigh NC II

South Texas Project 1 Bay City TX IV

South Texas Project 2 Bay City TX IV

St. Lucie 1 Ft. Pierce FL II

St. Lucie 2 Ft. Pierce FL II

Summer Columbia SC II

Surry 1 Newport News VA II

Surry 2 Newport News VA II

Susquehanna 1 Berwick PA I

Susquehanna 2 Berwick PA I

Three Mile Island 1 Harrisburg PA I

Turkey Point 3 Miami FL II

Turkey Point 4 Miami FL II

Vermont Yankee Battleboro VT I

Vogtle 1 Augusta GA II

Vogtle 2 Augusta GA II

Waterford 3 New Orleans LA IV

Watts Bar 1 Spring City TN II

Wolf Creek 1 Burlington KS IV

(Continued From Previous Page)

Nuclear power plant City State NRC region
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 58 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Table 4: Total Number of Green Inspection Findings, 2001 Through 2005

Number of green inspection findings, by 

year

Nuclear power sitea 2001 2002 2003 2004 2005 Total

Arkansas Nuclear 12 9 15 23 23 82

Beaver Valley 14 10 10 8 9 51

Braidwood 11 12 5 5 7 40

Browns Ferry 5 5 4 10 8 32

Brunswick 4 4 3 6 9 26

Byron 13 9 16 14 19 71

Callaway 17 11 15 17 17 77

Calvert Cliffs 18 4 6 19 6 53

Catawba 10 6 7 5 8 36

Clinton 8 10 5 16 8 47

Columbia Generating 

Station 11 5 21 17 10 64

Comanche Peak 6 12 3 9 11 41

Cooper 32 23 29 23 34 141

Crystal River 5 4 5 5 5 24

D.C. Cook 14 27 24 7 16 88

Davis-Besse 4 16 24 46 12 102

Diablo Canyon 11 14 22 25 23 95

Dresden 20 19 22 26 13 100

Duane Arnold 1 7 22 12 19 61

Farley 8 5 5 4 11 33

Fermi 6 6 11 14 18 55

FitzPatrick 12 7 8 5 8 40

Fort Callhoun 7 18 11 15 21 72

Ginna 4 11 14 9 10 48

Grand Gulf 13 9 6 10 11 49

Harris 5 5 5 5 6 26

Hatch 11 8 4 2 4 29

Hope Creek 18 24 19 25 16 102

Indian Point 2 44 21 20 25 13 123

Indian Point 3 13 3 14 6 8 44

Kewaunee 12 9 14 24 20 79

La Salle 9 13 7 11 20 60

Limerick 15 11 13 8 4 51
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 59 GAO-06-1029 Oversight of Nuclear Power Plant Safety

McGuire 5 9 8 14 9 45

Millstone 20 13 8 12 17 70

Monticello 17 8 12 13 9 59

Nine Mile Point 16 9 15 19 8 67

North Anna 4 4 5 9 12 34

Oconee 16 11 13 11 19 70

Oyster Creek 11 12 7 15 12 57

Palisades 23 13 13 10 8 67

Palo Verde 16 3 4 46 29 98

Peach Bottom 14 13 18 7 9 61

Perry 7 10 18 16 59 110

Pilgrim 8 4 9 6 7 34

Point Beach 15 10 28 24 23 100

Prarie Island 4 6 5 10 16 41

Quad Cities 6 21 15 14 11 67

River Bend 19 6 17 18 7 67

Robinson 4 1 4 3 3 15

Saint Lucie 13 7 6 10 9 45

Salem 17 14 26 24 25 106

San Onofre 4 9 9 16 13 51

Seabrook 10 6 10 9 8 43

Sequoyah 11 16 9 7 4 47

South Texas 14 7 15 13 12 61

Summer 13 9 10 10 9 51

Surry 6 5 7 3 7 28

Susquehanna 11 17 11 13 7 59

Three Mile Island 19 8 7 12 12 58

Turkey Point 6 2 9 13 9 39

Vermont Yankee 11 9 9 14 3 46

Vogtle 4 8 6 8 3 29

Waterford 5 14 15 17 15 66

(Continued From Previous Page)

Number of green inspection findings, by 

year

Nuclear power sitea 2001 2002 2003 2004 2005 Total
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 60 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Source: GAO analysis of NRC data.

a

NRC reports these data by nuclear power site as opposed to by individual plant. Oftentimes, there 

are 2 or 3 plants located at each site. Therefore, data for all 103 plants are included here, but at the 

site level.

Table 5: Total Number of Greater-Than-Green Inspection Findings Issued, 2001 

Through 2005

Watts Bar 4 13 10 8 8 43

Wolf Creek 5 3 7 9 6 30

Total 751 657 774 889 835 3,906

Site average 11 10 12 13 13 59

Range (for each column) 1-44 1-27 3-29 2-46 3-59 15-141

Total number of inspection findings, by color

Nuclear power sitea White Yellow Red

Arkansas Nuclear 1

Beaver Valley 2

Braidwood 1

Browns Ferry

Brunswick 1

Byron

Callaway 3

Calvert Cliffs 3 1

Catawba

Clinton 1

Columbia Generating Station 1 1

Comanche Peak 2

Cooper 5

Crystal River 1

D.C. Cook 3

Davis-Besse 4 1 1

Diablo Canyon

Dresden 2

Duane Arnold

Farley

(Continued From Previous Page)

Number of green inspection findings, by 

year

Nuclear power sitea 2001 2002 2003 2004 2005 Total
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 61 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Fermi 1

FitzPatrick

Fort Callhoun 2

Ginna 1

Grand Gulf

Harris 2

Hatch 1

Hope Creek 2

Indian Point 2 2 1 1

Indian Point 3

Kewaunee 4 1

La Salle 1

Limerick 2

McGuire

Millstone

Monticello

Nine Mile Point 1

North Anna

Oconee 7

Oyster Creek 3

Palisades 2

Palo Verde 1

Peach Bottom 3

Perry 5

Pilgrim

Point Beach 3 1 3

Prarie Island 1

Quad Cities

River Bend 2

Robinson

Saint Lucie

Salem 1

San Onofre

Seabrook 1

Sequoyah 1

South Texas

(Continued From Previous Page)

Total number of inspection findings, by color

Nuclear power sitea White Yellow Red
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 62 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Source: GAO analysis of NRC data. 

a

NRC reports these data by nuclear power site as opposed to by individual plant. Oftentimes, there are 

2 or 3 plants located at each site. Therefore, data for all 103 plants are included here, but at the site 

level.

Table 6: Type of Substantive Cross-cutting Issue Open At Least Some Portion of the 

Year, 2001 Through 2005

Summer

Surry 2

Susquehanna 1

Three Mile Island 2

Turkey Point

Vermont Yankee 1

Vogtle

Waterford 1

Watts Bar 1

Wolf Creek

Total 86 7 5

Type of substantive cross-cutting issue open, by year

Nuclear power plant 2001 2002 2003 2004 2005

Arkansas Nuclear 1 PIR PIR PIR

Arkansas Nuclear 2 PIR PIR PIR

Beaver Valley 1

Beaver Valley 2

Braidwood 1

Braidwood 2

Browns Ferry 2

Browns Ferry 3

Brunswick 1

Brunswick 2

Byron 1 HP

Byron 2 HP

Callaway PIR PIR HP HP

Calvert Cliffs 1 PIR PIR

Calvert Cliffs 2 PIR PIR

(Continued From Previous Page)

Total number of inspection findings, by color

Nuclear power sitea White Yellow Red
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 63 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Catawba 1

Catawba 2

Clinton

Columbia Generating Station HP HP PIR, HP PIR, HP PIR, HP

Comanche Peak 1

Comanche Peak 2

Cooper PIR,HP PIR,HP PIR,HP PIR,HP PIR,HP

Crystal River 3

D.C. Cook 1 PIR PIR

D.C. Cook 2 PIR PIR

Davis-Besse

Diablo Canyon 1 PIR,HP PIR,HP

Diablo Canyon 2 PIR,HP PIR,HP

Dresden 2 HP

Dresden 3 HP

Duane Arnold HP

Farley 1

Farley 2

Fermi 2 HP HP

FitzPatrick PIR

Fort Callhoun

Ginna

Grand Gulf 1

Harris 1

Hatch 1

Hatch 2

Hope Creek 1 PIR PIR PIR, 

SCWE

PIR,SCWE

Indian Point 2 PIR,HP PIR,HP PIR,HP PIR PIR

Indian Point 3

Kewaunee PIR PIR

La Salle 1 HP HP HP HP

La Salle 2 HP HP HP HP

Limerick 1

Limerick 2

McGuire 1

(Continued From Previous Page)

Type of substantive cross-cutting issue open, by year

Nuclear power plant 2001 2002 2003 2004 2005
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 64 GAO-06-1029 Oversight of Nuclear Power Plant Safety

McGuire 2

Millstone 2 PIR,HP PIR

Millstone 3

Monticello

Nine Mile Point 1 PIR

Nine Mile Point 2 PIR

North Anna 1

North Anna 2

Oconee 1

Oconee 2

Oconee 3

Oyster Creek PIR HP HP PIR PIR

Palisades PIR, HP PIR PIR

Palo Verde 1 PIR, HP PIR, HP

Palo Verde 2 PIR, HP PIR, HP

Palo Verde 3 PIR, HP PIR, HP

Peach Bottom 2 PIR PIR

Peach Bottom 3 PIR PIR

Perry 1 PIR,HP PIR,HP

Pilgrim 1

Point Beach 1 PIR PIR, HP PIR, HP PIR, HP

Point Beach 2 PIR PIR, HP PIR, HP PIR, HP

Prairie Island 1

Prairie Island 2

Quad Cities 1 HP HP

Quad Cities 2 HP HP

River Bend 1

Robinson 2

Saint Lucie 1

Saint Lucie 2

Salem 1 PIR PIR PIR,SCWE PIR,SCWE

Salem 2 PIR PIR PIR,SCWE PIR,SCWE

San Onofre 2

San Onofre 3

Seabrook 1 PIR PIR

Sequoyah 1

(Continued From Previous Page)

Type of substantive cross-cutting issue open, by year

Nuclear power plant 2001 2002 2003 2004 2005
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 65 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Legend:

HP = human performance

PIR = problem identification and resolution

SCWE = safety-conscious work environment

Source: GAO analysis of NRC data. 

Table 7: Total Number of Greater-Than-Green Performance Indicators, 2001 Through 

2005

Sequoyah 2

South Texas 1

South Texas 2

Summer

Surry 1

Surry 2

Susquehanna 1 HP PIR, HP PIR

Susquehanna 2 HP PIR, HP PIR

Three Mile Island 1 HP HP PIR PIR

Turkey Point 3 PIR

Turkey Point 4 PIR

Vermont Yankee

Vogtle 1

Vogtle 2

Waterford 3 PIR PIR

Watts Bar 1 HP

Wolf Creek 1

Number of greater-than-green performance 

indicators, by yeara

Nuclear power 

plant 2001 2002 2003 2004 2005 Total

Arkansas Nuclear 1

Arkansas Nuclear 2

Beaver Valley 1

Beaver Valley 2

Braidwood 1 1 2 3 1 7

Braidwood 2

Browns Ferry 2

(Continued From Previous Page)

Type of substantive cross-cutting issue open, by year

Nuclear power plant 2001 2002 2003 2004 2005
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 66 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Browns Ferry 3

Brunswick 1

Brunswick 2 1 1

Byron 1

Byron 2

Callaway 2 2

Calvert Cliffs 1 4 3 7

Calvert Cliffs 2

Catawba 1

Catawba 2

Clinton

Columbia 

Generating Station 5 5

Comanche Peak 1

Comanche Peak 2

Cooper 1 1

Crystal River 3 1 1

D.C. Cook 1 1 1

D.C. Cook 2 4 5 2 11

Davis-Besse 1 1 2

Diablo Canyon 1 1 1

Diablo Canyon 2 1 1

Dresden 2 1 1

Dresden 3 1 4 2 7

Duane Arnold

Farley 1

Farley 2

Fermi 2 4 1 4 1 10

FitzPatrick 2 2

Fort Callhoun 1 2 2 5

Ginna

Grand Gulf 1

Harris 1 1 3 1 5

Hatch 1

Hatch 2

(Continued From Previous Page)

Number of greater-than-green performance 

indicators, by yeara

Nuclear power 

plant 2001 2002 2003 2004 2005 Total
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 67 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Hope Creek 1

Indian Point 2

Indian Point 3 3 3

Kewaunee

La Salle 1

La Salle 2 2 1 3

Limerick 1

Limerick 2

McGuire 1

McGuire 2

Millstone 2 2 3 5

Millstone 3

Monticello

Nine Mile Point 1 4 2 6

Nine Mile Point 2 1 1 1 3

North Anna 1

North Anna 2 1 1

Oconee 1 2 2

Oconee 2

Oconee 3

Oyster Creek

Palisades

Palo Verde 1

Palo Verde 2

Palo Verde 3

Peach Bottom 2 1 1 3 5

Peach Bottom 3

Perry 1 3 1 4

Pilgrim 1

Point Beach 1 4 1 5

Point Beach 2 2 2

Prarie Island 1

Prarie Island 2

Quad Cities 1

Quad Cities 2

(Continued From Previous Page)

Number of greater-than-green performance 

indicators, by yeara

Nuclear power 

plant 2001 2002 2003 2004 2005 Total
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 68 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Source: GAO analysis of NRC data. 

Note: Plant licensees report their performance indicator data on a quarterly basis for 15 different 

indicators (excluding 3 physical security indicators). Yearly totals include a summary for all 15 

indicators and the four quarters. Thus, if the same indicator was white for two quarters during the year, 

it would count twice in the yearly total.

a

All of the greater-than-green indicators were white during this period, no yellow or red indicators were 

reported.

River Bend 1 2 2

Robinson 2 1 1

Saint Lucie 1

Saint Lucie 2 1 1 2

Salem 1 2 2

Salem 2

San Onofre 2 1 3 1 5

San Onofre 3

Seabrook 1 1 1

Sequoyah 1

Sequoyah 2 1 2 3

South Texas 1

South Texas 2 1 1 2

Summer 3 3

Surry 1 3 6 3 12

Surry 2 2 4 4 1 11

Susquehanna 1

Susquehanna 2

Three Mile Island 1

Turkey Point 3 1 1

Turkey Point 4 2 2

Vermont Yankee

Vogtle 1

Vogtle 2

Waterford 3

Watts Bar 1

Wolf Creek 1

Total 34 25 41 33 23 156

(Continued From Previous Page)

Number of greater-than-green performance 

indicators, by yeara

Nuclear power 

plant 2001 2002 2003 2004 2005 Total
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 69 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Table 8: Highest NRC Oversight Level Applied during at Least Some Portion of the 

Year, 2001 Through 2005

Highest level of oversight applied during at least 

some portion of the yeara

Nuclear power plant 2001 2002 2003 2004 2005

Arkansas Nuclear 1 L

Arkansas Nuclear 2

Beaver Valley 1 L L L

Beaver Valley 2 L L L

Braidwood 1 L M L L

Braidwood 2

Browns Ferry 2

Browns Ferry 3

Brunswick 1

Brunswick 2 L L

Byron 1

Byron 2

Callaway M L L L

Calvert Cliffs 1 M M L

Calvert Cliffs 2 L L L

Catawba 1

Catawba 2

Clinton L L

Columbia Generating Station M M L

Comanche Peak 1 L L

Comanche Peak 2 L

Cooper M H H H

Crystal River 3 L L

D.C. Cook 1 L L L

D.C. Cook 2 M M M L

Davis-Besse b b b b

Diablo Canyon 1 L

Diablo Canyon 2 L

Dresden 2 L

Dresden 3 L L L

Duane Arnold

Farley 1 L

Farley 2 L
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 70 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Fermi 2 L L L L L

FitzPatrick L

Fort Callhoun L L L L

Ginna L L

Grand Gulf 1

Harris 1 L M L L

Hatch 1 L

Hatch 2 L

Hope Creek 1 L L

Indian Point 2 H H M L L

Indian Point 3 L

Kewaunee M L L M

La Salle 1

La Salle 2 L L

Limerick 1 L L

Limerick 2 L L

McGuire 1

McGuire 2

Millstone 2 M L

Millstone 3

Monticello

Nine Mile Point 1 L L L

Nine Mile Point 2 L L L

North Anna 1

North Anna 2 L

Oconee 1 M L L M L

Oconee 2 L L M L

Oconee 3 L L L M L

Oyster Creek L L L L

Palisades L L L L

Palo Verde 1 M

Palo Verde 2 M

Palo Verde 3 M

Peach Bottom 2 L L L L L

Peach Bottom 3 L L L

(Continued From Previous Page)

Highest level of oversight applied during at least 

some portion of the yeara

Nuclear power plant 2001 2002 2003 2004 2005
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 71 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Perry 1 L M H H

Pilgrim 1

Point Beach 1 L L H H H

Point Beach 2 L L H H H

Prarie Island 1 L L

Prarie Island 2 L L

Quad Cities 1 L

Quad Cities 2 L

River Bend 1 L L

Robinson 2 L

Saint Lucie 1

Saint Lucie 2 L L

Salem 1 L L L

Salem 2

San Onofre 2 L L L

San Onofre 3

Seabrook 1 L L

Sequoyah 1 L L

Sequoyah 2 L L

South Texas 1

South Texas 2 L L

Summer L

Surry 1 L L L M

Surry 2 L L L L

Susquehanna 1 L L

Susquehanna 2 L L

Three Mile Island 1 L L

Turkey Point 3 L

Turkey Point 4 L

Vermont Yankee M L L

Vogtle 1

Vogtle 2

Waterford 3 L

Watts Bar 1 L

Wolf Creek 1

(Continued From Previous Page)

Highest level of oversight applied during at least 

some portion of the yeara

Nuclear power plant 2001 2002 2003 2004 2005
Appendix III

Nuclear Power Plant Performance Data on 

the Basis of the Results of NRC’s Reactor 

Oversight Process, 2001 Through 2005

Page 72 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Legend:

L = 1st or lowest level of increased oversight beyond the baseline

M = 2nd level of increased oversight beyond the baseline

H = 3rd and highest level of oversight that still allows continued plant operations

Source: GAO analysis of NRC data. 

a

All plants receive a baseline level of oversight, regardless of their safety performance. Plants are also 

placed into performance categories on NRC’s action matrix on a quarterly basis, which corresponds to 

the level of oversight NRC will provide based on the plant’s safety performance. The level of oversight 

reported here corresponds to the highest oversight level the plant received during the year, even if it 

was only for a portion of the year. Thus, if a plant was placed into a different category each quarter, the 

highest category in which it was placed is reported here.

b

Davis-Besse was under a separate oversight category not considered part of the ROP due to the 

reactor vessel head incident that occurred in 2002.
Page 73 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Appendix IV

Comments from the Nuclear Regulatory 

Commission ApendxiIV
Page 74 GAO-06-1029 Oversight of Nuclear Power Plant Safety

Appendix V

GAO Contact and Staff Acknowledgments ApendxiV

GAO Contact Jim Wells, (202) 512-3841 or wellsj@gao.gov

Staff 

Acknowledgments

In addition to the individual named above, Raymond H. Smith, Jr. (Assistant 

Director), Alyssa M. Hundrup, and Dave Stikkers made key contributions 

to this report. Also contributing to this report were Cindy Gilbert, Carol 

Kolarik, Alison O’Neill, Ilene Pollack, Keith A. Rhodes, and Barbara 

Timmerman.

(360585)
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