Combatting Air Pollution:

A Role for Nuclear Power

We have all gotten so caught up in the climate change discussion in recent years, that we have nearly forgotten that fossil fuel emissions have been an issue for a very long time.  We used to worry about air pollution.  A recent article noting that air pollution kills over 5 million people a year worldwide suggests we still should think about air pollution. 

It's not hard to guess why air pollution was pushed off our radar screens--it is generally a more localized phenomenon, so maybe you don't think about it if you live far from major cities or industrial centers.  And in some areas, a big contributor to air pollution is from automobiles, which perhaps diverts attention from the fossil fuel power plants.

So perhaps it seemed like climate change was a more universal issue.  But focusing just on climate change has led to debates about whether climate change is real.  And in some circles, focusing on climate change has diverted attention to discussions of ways to slow climate change by geoengineering schemes such as injecting aerosols into the upper atmosphere to reflect sunlight, or by sucking carbon dioxide from the atmosphere, or by adaptation strategies such as seawalls.

Of course, arguments can also be made that this or that portion of air pollution is due to other causes--transportation, the use of coal, wood and charcoal to cook and to heat homes in some countries, etc.

However, looking at the two issues together makes a compelling argument that fossil fuels are a key contributor to two very important environmental concerns--air pollution and greenhouse gas emissions.  Therefore, we should try to get away from the single argument about climate change, and instead address both air pollution and greenhouse gas emissions simultaneously.

In the long term, this means a number of things.  In the developing world, this means moving away from wood, charcoal and coal for home heating and cooking.  All over the world, it means turning to clean sources of electricity generation--nuclear power and renewable energy.  It also means moving away from the use of petroleum for transportation.  And that, in turn, may mean yet greater demands for electricity, and therefore, greater demands for electricity from nuclear power and other clean energy resources.

The bottom line is that, if we look at energy sources and effects holistically, the case for turning to clean energy sources becomes even stronger.  And the resulting growth in demand for these sources means that we will have to exploit all clean energy sources at our disposal. 

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A Regulatory Comparison:

FCC versus NRC

In a recent blog on NRC's Principles of Good Regulation, someone commented that they wished that someday, nuclear power could be less controversial and regulation could be more like that at FAA and FCC.  This comment was particularly interesting to me, as I am quite familiar with the FCC (see below), so I responded that the grass may seem greener on the other side of the fence, but that many issues at FCC were at least equally contentious and divisive.  In return, the commenter pointed out that FCC doesn't regulate the technology that led to, for example, the iPhone.

It was interesting that he chose the FCC as a point of comparison, because my husband worked for the FCC for many years, and for much of that time, we were both in regulatory agencies--he at FCC and me at NRC.  (And, in fact, if I may be allowed a small brag, he was responsible for the regulatory changes at FCC that allowed for the development of what became Wi-Fi.)  Furthermore, we both had postings in Japan involving our regulatory counterparts there, both working in their offices and observing them from other perspectives.

So we have had a lot of opportunity to compare and contrast FCC, NRC, and other regulatory entities--their philosophies, their operations, their staffs and management, etc.  (While my husband also had some familiarity with FAA, as telecommunications is important for the FAA, I have less, so I will leave FAA out of the discussion, and just make my points based on a comparison of FCC and NRC.)

There are many ways in which I could compare and contrast FCC and NRC regulations, but let me focus in this blog post on the particular point raised in the comment on my previous blog--that the controversies at FCC are not at the level where they significantly delay technology development.  The commenter cites as his example that no license submittal is required for the next model iPhone.  

That is technically true.  However, one must consider the whole situation.  The original iPhone was in the eyes of FCC a package of several radio systems--each of which had been previously approved for general use. Hence it was only subject to routine staff approvals. As a result of several decades of deregulation, FCC allows many types of radio technologies "permissionless innovation".  However, this allowance is spotty and all new radio technology above 95 GHz needs nonroutine approvals that could take as long as approving a reactor design.

In fact, at present, there are a number of start-ups developing various telecommunications-related technologies, some of which do require changes in FCC regulations for them to be implemented.  My husband has seen some of these companies fold because of foot-dragging by FCC, mainly to cater to entrenched interests.  In these cases, there is not even a rationale that we need to be move slowly to be sure of the safety.  The delays and roadblocks are strictly about competing economic interests. 

By pointing this out, I am not implying that NRC regulations are perfect or that NRC gets a pass because of the focus on safety.  I just want to be sure that people who compare regulatory agencies--particularly these two--see the whole picture.  

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Women, Energy, and Careers:

Some Interesting Perspectives

I had occasion last week to serve as a member of a very interesting panel on women and careers in energy.  Although the fields represented by the panelists ranged from biomass to nuclear to solar energy, I was surprised at the common experiences we shared and thought some of these experiences might be of interest to others as well.

The panel was organized by the Council of Women in Energy and Environmental Leadership (CWEEL) of the Association of Energy Engineers (AEE) and was held on February 5 on the Arlington, Virginia campus of George Mason University.  The panel was part of a day-long event that also featured a Showcase of Energy and Sustainability Educational and Research programs at GMU.

Despite the fact that it was a cold day, with snow flurries on and off, the meeting got a good attendance, and there seemed to be a lot of interest in the topic.  Although the panel was all women, the audience included a lot of men, and it included both students and people who were already working.

I was a little surprised that, for the most part, the discussion really didn't particularly emphasize issues relating only to women.  Rather, the focus was on general issues, like how you get that critical first job, and what the career opportunities are in each of the fields we represented.

I think this focus reflects the fact that things have changed a lot over the years.  I have seen that change personally since I embarked on my own career.  I recounted to the audience how my entering undergraduate class at MIT was only 5% women, yet recent entering classes at MIT are approaching 50-50.  I was also the only woman in the whole nuclear engineering department at MIT the entire time I was there (although I was not the first woman to have been a student in that department).  In a way, the proof that there has been significant change is that the audience found the historical facts from my own experience somewhat astonishing.

Outside the panel, some of us did trade "war stories"--things people said to us years ago that they would never say today.  And hopefully, that they no longer think today.  Although we still see some glass ceilings and other barriers, we were all confident that the women entering the workforce today will have much more opportunity than women did even a few years ago.

What I found particularly fascinating is that the panelists seemed to have some overlapping experiences.  I always like to recount how I once saw an article about a woman who had sat down early in her career and written a detailed plan for what she was going to do and when.  By contrast, I note that I have held jobs in organizations that I didn't know existed when I first began my professional career.  Had I outlined a detailed plan and tried to follow it, I would certainly be in a very different place today.  (And, I happen to think, a place that would not have been as good a fit for my interests and capabilities.)  Therefore, when the first panelist spoke of how an event she attended in college turned her career path towards an she hadn't even known about before, I followed up by pointing out that I had similar experiences, although at a different stage of my career.  We also seemed to have similar messages for the audience in terms of the breadth of career opportunities in each of our fields.

In the end, the panel offered a mix of advice to the audience.  There were a number of specific suggestions, such as about the value of participating in professional society activities and about how to approach people for help in identifying and getting jobs.  There was also some general guidance, such as that people need to be flexible in their careers in order to be able to take advantage of opportunities as they arise.

I guess that's good advice for both careers and for other aspects of life.

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Principles of Good Regulation--25th Anniversary:

NRC Celebrates 25 Years of the 

Principles of Good Regulation

On January 19, the US Nuclear Regulatory Commission launched what they characterize as a year of celebration of the 25th anniversary of the Principles of Good Regulation.  The first event was an employee seminar on the history and evolution of the Principles.  I was very pleased and proud to have been asked to be a part of that event.

I had wanted to report on this seminar earlier, but Mother Nature (the Snowzilla that hit the Washington, DC area a few days later) caused me to move up my vacation plans.  I escaped the blizzard in time, but the things I'd planned to do the remainder of that week got put off until now.

I have previously discussed the thinking behind the NRC Principles of Good Regulation and will not repeat that here.  I will focus instead primarily on what was discussed at this event.

NRC dates the effective beginning of the Principles of Good Regulation to the publication of the Principles in the Agency's Five Year Plan for 1991-1995 and the dissemination of the Principles to all NRC staff in a memorandum from the Chairman of NRC at the time, Kenneth M. Carr, on January 17, 1991.  The Principles have become very important to the Agency in the last 25 years, and therefore, the NRC has apparently decided to do a number of things this year to recognize the role of the Principles and to set the scene for their future.

The first of these events was the January 19 staff seminar.  It was held in the Rockville, MD headquarters of the NRC, but was broadcast to all the NRC regional offices.  (I will also note that it was held on the 41th anniversary of the day NRC started--January 19, 1975.)   There are plans for several other events and initiatives to be held this year focusing on the Principles.  For example, at the upcoming NRC Regulatory Information Conference (RIC), there will be a panel discussion on the Principles.

The seminar brought together a number of people who had been at the NRC when the Principles were developed, as well as some who have been involved with the Principles in more recent years.  The current NRC Chairman, Steven Burns, the current head of the NRC Office of Nuclear Regulatory Research, Michael Weber, and the current Executive Director for Operations, Victor McCree, were all on the NRC staff at the time the Principles were promulgated.  Mike Weber and Vic McCree each made opening remarks.  Mike had been a technical assistant in Chairman Carr's office in 1991, so was heavily involved in the "birth" of the Principles.  Vic McCree noted how the Principles later led to a staff-initiated statement of values a few years later.  Commissioner Ostendorff, who has been one of the more recent champions of the Principles, made opening remarks as well, focusing on how he has tried to promote this concept to regulators in other countries.

The main speakers were former Commissioner Kenneth C. Rogers, myself, and the current NRC historian, Thomas Wellock.  The three of us tried to detail how the concept for the Principles developed and evolved. 

The idea for the Principles came from Kenneth C. Rogers, who was a Commissioner at the time.  While many people contributed to the Principles, Commissioner Rogers had assigned me the task of gathering and synthesizing inputs to the document.  The two of us reconstructed for the NRC audience some of the details of that effort:  his discussions with the other Commissioners, my interactions with their assistants and with senior NRC management, initial skepticism in some quarters and our efforts to incorporate suggestions that helped bring everyone aboard, the attempt to draw from previous statements and documents, the process for identifying and narrowing the list of potential principles to a reasonable set, and the decisions on what order to put the principles in and what language to use to explain and clarify them.

Tom Wellock then tried to give some historical perspective to the Principles.  (He abbreviated them PGR, which is probably a good idea.  And while I'm mentioning good ideas, I noticed that, although I always painstakingly try to put them in the order we initially used--independence, openness, efficiency, clarity, and reliability--I have seen the acronym ICORE used, which probably makes them a whole lot easier to remember!)  He confirmed what we always thought--that as far as he has been able to find, NRC's Principles were the first of their kind.  However, he noted that he has found a number of other statements of regulatory principles that were created after NRC's, including in the UK, Ireland, the EU, and IAEA.  He also put the initiative in a broader historical perspective--pointing to the 1960s, when more regulation was often viewed as a good thing (he cited Nader's initiatives), to the deregulatory efforts of the 1980s.   Most interestingly, he pointed to antecedents for some of the principles we used--words like independent, open and reliable began popping up in NRC documents in the 1980s. 

Of course, the true measure of the value of something like the Principles is in their impact, and that is much harder to assess.  The explanation of several of the Principles suggests the difficulty.  Each of these Principles is important, but there is always a balance to be struck.  Independence should not mean isolation.  Efficiency should not force NRC staff to act so quickly that they miss something.  Therefore, the goal is to minimize delay as much as is reasonably possible.  Reliability should not mean that regulations must be cast in stone.  Rather, the goal should be to make sure that changes in regulations are justifiable.

I have certainly seen times when NRC has been criticized for falling short on its adherence to the Principles of Good Regulation.  Some of this criticism may have been colored by the viewpoints and positions of the critics.  But even someone without an ax to grind might find fault at times in some of NRC actions.  After all, the Principles are a very ambitious set of rules to follow, and require a continual balance between opposing objectives.  What I think is encouraging is that, after performing this balancing act for 25 years, the NRC has made a conscious decision that this is still a valid standard of behavior to set for themselves, and has committed to continuing to try to hold themselves to that standard. 

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