Thursday, March 17, 2016

St. Patrick's Day and Green Energy:

Fifty Shades of Green?

On this St. Patrick's Day, when even the beer is green, it may be appropriate to think about all the claims about which energy sources are green.

Most people view renewable energy sources, such as solar and wind power, as green, and fossil fuel sources, especially coal, as not green.  The reasons are clear.  Coal produces particulates, which cause significant health and other problems locally, and also generate greenhouse gases, which have global impacts.  The sun and the wind are "natural" and, in themselves, benign.  Some people think that means green, but it isn't that simple.

People tend to be uncertain how to rank nuclear in this regard.  On the one hand, they know it doesn't produce the particulates or greenhouse gases that coal and other fossil fuels produce.  On these grounds, pro-nuclear people claim that nuclear power is green.  On the other hand, it produces nuclear waste, which is not natural and lasts a long time.  On these grounds, anti-nuclear people claim that nuclear power isn't green.

The truth is that nothing is perfectly green.

As many experts have pointed out, we can't extract large quantities of sun or wind or hydropower without building solar panels or windmills or dams.  Solar panels, windmills and dams require materials.  The materials have to be mined and processed.  These steps cause environmental impacts, just like mining coal or uranium, or anything else.  Some of the materials and processes generate toxic by-products.   

But because the wind and the sun are diffuse, they tend to require more structures per unit of energy produced than more concentrated forms of energy, like fossil fuels and nuclear power.  And that means more materials and more mining and processing.   And more land use.

In truth, there are shades of green.  I don't know if there are 50.  There are probably more.  The designation "green energy" is, unfortunately, an oversimplification that has caught people's imaginations.  However, it greatly oversimplifies the situation.  Different energy sources use different materials, in different quantities, and generate different kinds of pollution in different places.  What looks green at point of use has negative environmental impacts elsewhere.

We seem to have a hard time acknowledging that human population and modern lifestyles have an inevitable impact on the environment.  There are measures we can take to reduce the impact, but we shouldn't fool ourselves into thinking that the green label we have bestowed on some energy sources really solves the problem.

So, maybe nothing is truly green today except the beer.  Sorry, Saint Pat!


Thoughts from the NRC Leadership:

More from the 
NRC Regulatory Information Conference

In my last blog, I focused on one session held at the NRC Regulatory Information Conference (RIC)--the session on the 25th anniversary of the Principles of Good Regulation.  I focused on that because, of course, the subject was near and dear to my heart.  However, I did not want to leave the subject of the RIC without reporting on a little more of that conference. 

I think some of the remarks made by the leadership of NRC--the Chairman, the other Commissioners, and the EDO--also deserve mention.  For brevity, I will just summarize portions of their presentations.  Their complete remarks, as well as videos of their presentations, are available on the NRC website. 

The RIC opened with a speech by Chairman Stephen Burns.  One focus of his presentation was a discussion of risk.  He noted the changing public attitudes toward risk that have led, over the years, to requirements for things like seat belts in private automobiles and bicycle helmets for recreational bike riders, and to concerns over processed foods.  While acknowledging the increasing sensitivity to risk, he also cautioned against treating all risks alike, quoting Justice Breyer as saying that treating all risks as equal is like the boy who cried wolf.  He pointed out that the general public rates nuclear as the #1 risk, while experts put it at #20 out of a list of 30 risks, well below car accidents, guns, smoking, and food additives.  

The next speaker was the NRC Executive Director for Operations Victor McCree.  Interestingly (to me, at least), both the Chairman and the EDO are long-time NRC employees, both having joined NRC in the 1980s, which is also the time I joined the NRC.  Vic talked about two issues that I've worked on over the course of my career, the Principles of Good Regulation and Knowledge Management (KM).  I actually got involved in KM after I left NRC, but while working in this area, first at the Department of Energy and later, at the OECD/Nuclear Energy Agency, I communicated frequently with NRC staff, who had developed some very advanced KM tools.  Vic noted all the significant challenges the nuclear industry and the NRC are facing--post-Fukushima changes, decommissioning, license renewal from 60 to 80 years, licensing advanced and small modular reactors, and economic challenges the industry is facing.  He notes that all these things challenge KM.  I would observe that they also make it all the more important.

The next session featured two Commissioners, Kristine Svinicki and Bill Ostendorff, and the newest Commissioner, Jeff Baran, spoke the next morning.  This was Commissioner Ostendorff's last speech as an NRC Commissioner before his term expires at the end of June, so several of the Commissioners used the opportunity to particularly thank him for his contributions to the NRC during his time there.  While this was, perhaps, not unexpected, what was most interesting was some of the detail of what the Commissioners said.  In particular, several of them explicitly acknowledged the differences of opinion among the Commissioners.  They did not present that as a negative.  Rather, they indicated that they had learned from each other.  Most interestingly, Commissioner Svinicki even noted she had a couple of differences with with Commissioner Ostendorff (even though both of them are Republicans).  Commissioner Baran noted that, while he and Commissioner Ostendorff have disagreed on some things, they have agreed a lot, too.  And that they have "good, respectful discussions...often finding ground on a constructive way forward." 

Beyond that, each of them reflected on issues and themes of particular interest to them.  Commissioner Svinicki addressed some issues of organizational culture, noting that organizational culture can change more slowly than people or processes, but that some consistency is a good thing.  In fact, she prefers the word "adaptation" to change.  Picking up the theme of differences of opinion with other Commissioners, she also commented on the role of dissent versus majority opinion. 

Commissioner Ostendorff spoke a lot about accountability, and how necessary it is for trust.  He gave NRC, both the Commissioners and the staff, high marks for a sense of accountability, and he gave industry high marks as well.  He also summarized the principles guiding the post-Fukushima activities:  clear priorities based on safety importance, integrated decision making (incorporating cost-benefit considerations for changes exceeding the base requirement of adequate protection, and mitigation for beyond design basis issues), and regulating in the open.  He noted the number of public meetings (about 300) and votes (about 25) on Fukushima issues alone. 

Commissioner Baran also addressed some of the post-Fukushima efforts, discussing his votes on several issues such as severe accident management guidelines and filtered vents, and his rationale for his views.  He also discussed the additional reviews needed for the Tier 2 and Tier 3 post-Fukushima measures that are still under review in the NRC.  He also noted there are sometimes qualitative factors that have to be considered, noting that some post-Fukushima actions were based more on qualitative factors than on cost-benefit analysis, and citing the importance of things like enforceability and public confidence.  Finally, he noted the need for the NRC to give more attention to the plants shutting down to minimize the need to grant exemptions.

Several of these speakers also addressed internal NRC activities such as Project AIM, a current initiative for the NRC to right-size itself in light of current and expected needs.  

Many of these remarks by the leadership reflected issues that are important for the NRC at the present time, and that were reflected in one way or another in many of the technical sessions that took place during the rest of the RIC. 


Monday, March 14, 2016

NRC Principles of Good Regulation:

Compliments and Critiques

This week was an eventful one in the nuclear field.  The US Nuclear Regulatory Commission held its annual Regulatory Information Conference (RIC) on March 8 through 10, and the 5th anniversary of the Fukushima-Daiichi accident fell on March 11.  Since I have already read some excellent blogs on 3-11, as the Japanese sometimes call it, I will focus my attention on the RIC, and in particular, on a session near and dear to my heart.  (All RIC sessions were recorded and should soon be available on the NRC webcast archive.)

As I have previously reported, this year marks the 25th anniversary of the promulgation of NRC's Principles of Good Regulation.  NRC started its celebration of this milestone with the internal seminar covered in my earlier blog.  They continued the celebration with a technical session at the RIC.  The session was chaired by Mike Weber, Director of the NRC Office of Nuclear Regulatory Research, and included speakers addressing the PGR, as they have come to be called, from a variety of perspectives. 

The first two speakers were Tom Wellock, the NRC historian, and Kenneth Rogers, who was the Commissioner responsible for proposing that NRC develop a set of principles and for directing their development.  Tom Wellock put the PGR in historical context--noting events of the time and the evolving view of regulation, as well as how the concept of the PGR has spread.  Commissioner Rogers described some of the internal processes and debates behind the PGR, and also spotlighted some places where similar sets of principles have taken root.

The third speaker was Maria Korsnick, currently the COO of the Nuclear Energy Institute.  She gave the NRC high marks for independence and openness, but said that the principles of efficiency, clarity and reliability need more work.  Particular areas for improvement that she cited include better prioritization of regulatory actions and more accurate and transparent cost-benefit analysis.  She also had messages for the industry, saying they need to be more accountable in explaining how they would implement NRC requirements.  Overall, she concluded that NRC is "justifiably internationally renowned." 

The next speaker, Diane Curran, an attorney who has represented citizens groups against the NRC, had a different view.  She critiqued the implementation of the principles of openness and transparency.  On openness, she seemed to suggest that NRC may hold open meetings but is not necessarily making them easy for the public to attend, and is not necessarily listening to the public.  On the principle of independence, she seemed to suggest that it was wrong of the principles to equate licensees and the general public in this principle, as the interests of the public are paramount.  (The principle states:  "All available facts and opinions much be sought openly from licensees and other interested members of the public.  The many and possibly conflicting public interests much be considered.  Final decisions must be based on objective, unbiased assessments of all information, and must be documented with reasons explicitly stated.") 

The final speaker, Joseph Klinger, from the Illinois Emergency Management Agency, gave a state perspective.  He said that, 25 years ago, he saw isolation between the NRC and the states.  This isolation has largely disappeared.  He attributes the change to the PGR.  He felt the NRC really excelled in openness and transparency.  He also said that Illinois had embraced the same principles.  He noted that the 37 Agreement States are responsible for most of the regulation of radioactive materials, and thus collaboration between NRC and the states is critical.  He particularly cited the importance of collaboration to achieve efficiency, one of the five principles. 

References to the PGR were not confined to this session.  They were mentioned in Chairman Stephen Burns' welcoming letter on the first page of the RIC program, and again in a one-page summary of the NRC on the third page.  And they were raised repeatedly by Commissioners, NRC managers, and others throughout the conference.

Later, speaking to someone from NRC in the hallway between sessions, I learned that one of the non-US attendees in the audience at the session on the PGR (the RIC had attendees from 33 countries this year) noted that he thought that it was good to have something like the PGR, and he intended to bring the idea back to his country. 

It was interesting to see the mix of positive and negative comments.  While the compliments were, of course, good to hear, I think the criticism is also important to hear.  While we may individually debate whether we agree with the comments, positive and negative, they all reflect how the NRC and its action appear to the various stakeholders.  Like all lofty, aspirational goals, NRC will never be able to declare victory and rest on its laurels.  There will always be times when it didn't meet the goals perfectly, and even when it does, there will still be room for improvement in the future.  

I like to reflect back on the period, 25 years ago, when I worked in Commissioner Rogers office and helped develop the PGR.  Little did I know then what impact it would have.  It is nice to see that it thrives today, and if anything, its influence is growing.