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SAFETY

Nuclear power plant enforcement policy: A sharpened safety focus

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The Atomic Energy Act of 1954 and its amendments charge the federal government with ensuring the safe operation of the nation's nuclear power plants.

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The Nuclear Regulatory Commission (NRC), an independent federal agency, is responsible for licensing and monitoring nuclear power plants. The NRC has extensively revised its regulatory oversight process to account for record performance in industry safety, reliability and management and to adapt to the electric industry's transition to a competitive market.

n The NRC's revised enforcement policy incorporates safety insights, thereby focusing nuclear power plants and the agency more clearly on items with a direct impact on protecting public health and safety. This is the same approach used in the agency's revised inspection and assessment processes. Thus, the three components of regulatory oversight are consistent with each other. 
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The result of the NRC's comprehensive reform is a more stable, predictable, safety-focused regulatory regime.

New process reflects safety significance of violations
In the past, the NRC's enforcement process focused attention on regulatory compliance. In addition, escalated enforcement actions were used to send regulatory messages. The NRC's approach was not clear or consistent, resulting in different enforcement treatment of similar violations across the four NRC regions.

Longstanding concerns by Congress; the industry and other stakeholders prompted the NRC to consider simplifying the enforcement process. The agency had two major goals: to eliminate subjectivity from the enforcement process and sharpen its focus to reflect the safety significance of violations.

The need for this reform was highlighted by the fact that 94 percent of violations in 1997-1,427 of 1,519-had little or no safety significance. The number of violations was not consistent with the industry's actual performance. Indeed, the industry has shown a steadily improving trend in performance since the mid-1980s. For example, the average number of automatic shutdowns per plant declined from 7.3 per year in 1980 to zero in 1998 and 1999. Nuclear power plant output in the United States in 1999 was up 8 percent over the previous year-about 50 billion kilowatt-hours-for a total of 728 billion kilowatt-hours. The capacity factors for all units set a U.S. record of 86.8 percent, even with two of the 103 units shut down all year. Capacity factor, a yardstick for plant performance, measures the amount of electricity actually produced compared with the maximum output available.

On May 1, 2000, the NRC issued its revised enforcement policy. In addition to being better coordinated with the agency's overall regulatory program, the revised policy also reflects a sharper focus on safety. The revised enforcement process permits the NRC staff to evaluate the significance of a violation in the same way staff evaluates the results of plant inspections. Enforcement action is now tied to the safety significance of the violation. When the NRC finds a violation that is considered safety significant, the agency issues a notice of violation that requires the nuclear plant to submit a formal written response. Typically, a civil penalty will not be issued unless the violation involves willfulness, actual consequences, or actions that may have an impact on the NRC's ability to carry out its oversight responsibility.

The NRC's new approach also recognizes that the lowest level of violations-formerly called level IV violations-have little or no safety significance. The NRC's treatment of these violations has changed so that nuclear plants no longer are required to provide the agency with a formal response to violations of little safety significance. Nuclear plant operators will address these violations through their corrective action programs, determining their priority based on their relative safety significance. In contrast to previous practice, the significance of each violation will be determined without taking into account a nuclear plant's historical performance. Since enforcement action is now based on objective criteria, the results are far more likely to be consistent, predictable and understandable to nuclear plant operators and the public. These features should lead to increased public confidence.

Overarching goals
Enforcement reform complements the NRC's new nuclear plant inspection and assessment processes, both of which use insights from probabilistic safety studies to evaluate plant performance.

Shifting the focus of NRC enforcement activities to risk insights redirects agency and industry resources to matters that most directly protect public health and safety. Enforcement reform permits the NRC to more effectively use its resources without creating unnecessary regulatory burden that yields little or no safety benefit. By simplifying the process for determining when enforcement action will be taken, and making the bases for enforcement action more predictable and understandable to nuclear plants and the public, the agency will gain greater credibility as a strong regulator.