Thursday, March 17, 2016

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. 


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