Request to suspend all licensing proceedings until NRC fixes ADAMS search

Dear Mr. Borchardt: Beginning in November 1999, the Nuclear Regulatory Commission (NRC) transitioned from disseminating docketed information concerned operating power reactors to dozens of local public document rooms in communities across the United States to depositing that information in an online electronic library called the Agencywide Documents Access and Management System (ADAMS). As described on NRC webpage http://www.nrc.gov/reading-rm/adams.html:

The Agencywide Documents Access and Management System (ADAMS) is an information system that provides access to all image and text documents that the NRC has made public since November 1, 1999, as well as bibliographic records (some with abstracts and full text) that the NRC made public before November 1999. The NRC continues to add several hundred new documents daily. ADAMS permits full-text searching and enables users to view document images, download files, and print locally.

But this is a fallacy; specifically in the “ADAMS permits full-text searching” part. Earlier today, I used the Citrix-based access to ADAMS to conduct a full-text search for documents on the Vermont Yankee docket (50-271) dated between January 1, 2005, and December 31, 2008. That search returned a single document. That seemed unusually low for such a long time period. I then performed a second search using all the same search parameters except moving “safety evaluation” from the Document Text Contains box to the Title Contains box. This second search returned 51 documents. Having more than a passing awareness of how the staff enters documents into ADAMS, I understand that the title field is typed in by the NRC staff rather than being taken verbatim from the document, so it’s conceivable that documents with “safety evaluation” in their title may not have “safety evaluation” in their text. So I spot-checked a few documents to see if this explained the disparate search results. Every document I spot-checked had “safety evaluation” in its text. I have attached screen captures of the two search results along with some of the spot-checked documents to save you replicating this exercise, though you are welcome to do so. ADAMS is the NRC’s official source for docketed material. I used ADAMS to look for specific docketed material related to Vermont Yankee (VY). Using the full-text search tool that NRC explicitly describes to the public, I find 1 document. Yet it appears that there may be 50 other documents on the VY docket that the full-text search fails to identify. The actual number of “hidden” documents may be far higher than 50 because there could very easily be documents with “safety evaluation” in their text but not in their titles. The NRC’s purported “full-text search” finds less than 2 percent of the relevant information. Thus, ADAMS is essentially NRC’s electronic hide & seek game. The NRC places docketed materials in ADAMS, which is allegedly then publicly available but in reality is equivalent to being withheld from the public because the tool for finding materials inside the electronic library is fundamentally flawed. I respectfully ask that you immediately suspend ALL LICENSING PROCEEDINGS – ALL OF THEM – until the NRC corrects its flawed search engine for docketed materials in ADAMS. The public cannot participate meaningfully in these proceedings maintains a large electronic library with the equivalent of a bibliographic card catalog of blank pages. We cannot find relevant materials in ADAMS because your search tool is broken. Licensing proceedings conducted with this massive impairment to information access are a sham and must cease until the NRC-imposed impairment is remedied. Sincerely, David Lochbaum Director, Nuclear Safety Project