Showing posts with label principles of good regulation. Show all posts
Showing posts with label principles of good regulation. Show all posts

Saturday, July 7, 2012

Fukushima Accident Report:

"Made in Japan"


The long-awaited report from the Japanese Diet's Fukushima Nuclear Accident Independent Investigation Commission is out.  While I have not been able to read it completely (and I believe only portions are available in English at present), one item that has gotten a lot of attention so far is the statement by Kiyoshi Kurokawa, the chairman of the panel, that the accident was "Made in Japan"--that is, that it was a product of Japanese cultural tendencies.  Specifically, he states:

"Its fundamental causes are to be found in the ingrained conventions of Japanese culture: our reflexive obedience; our reluctance to question authority; our devotion to 'sticking with the programme'; our groupism; and our insularity.  What must be admitted – very painfully – is that this was a disaster 'Made in Japan'."

These are observations that have long been made by people outside Japan, myself included, so the conclusions come as no surprise.  (Some of my comments on this blog site include:  a number of blogs I wrote in the first 6 months after the Fukushima accident, and a report on comments by Professor Yoshiaki Oka I prepared somewhat after that.  What will be important is how the government and industry react to these observations.

As Japan begins to grapple with addressing these concerns, it would be well to keep several points in mind:

1.  These traits are "cultural tendencies," not laws of nature.  All countries have some traits that we would call "national" or "cultural" traits--Americans are "cowboys," British are "stiff upper-lipped," French are "arrogant."  The list goes on and on.  But when you get to know individual Japanese, or Americans, or British, or French, you realize that these characteristics vary widely over each population.  For every stereotypical national trait, I can probably find an exception among the people I know. 

2.  These cultural tendencies are not all bad.  Each tendency is very appropriate at certain times and places.  Societies need a certain degree of obedience to function.  A group mentality can help a civilization survive.  Cowboys represent the "pioneering spirit" that served America so well in its early days, and still is beneficial in many ways to this day.  I hope this statement by Professor Kurokawa, does not cause the Japanese to feel that they have "bad" characters.  

3.  These traits are not all good either.  Any personality or cultural trait taken to an extreme, or applied in the wrong environment, can backfire.  In the US, we tend to laud the pioneering spirit, the "can do, go it alone" attitude.  In a nuclear power plant, however, rules and procedures must be followed.  I'm not a sociologist, but I know that in Japan, the "groupism" and "obedience to authority" arises from the historic agricultural economy, and is beneficial in many ways.  However, individuals sometimes need to stand up and confront authority.

4.  All nations and all organizations struggle to find the right balance.  The US Nuclear Regulatory Commission was founded to assure separation from development and promotional functions and to assure "independence."  However, when I worked for Commissioner Rogers at the NRC, a number of us had begun to feel uncomfortable with the fact that some of the staff and management felt that "independence" should almost be a wall between the regulator and the licensee, and that any direct communication between them was inherently bad.  It was that concern, among others, that prompted Commissioner Rogers to instigate the preparation of NRC's Principles of Good Regulation. The very first of the Principles of Good Regulation, independence, is described as follows:

Independence does not imply isolation. All available facts and opinions must be sought openly from licensees and other interested members of the public. The many and possibly conflicting public interests involved must be considered. Final decisions must be based on objective, unbiased assessments of all information, and must be documented with reasons explicitly stated.

I have previously commented in more detail on both the Principles of Good Regulation and on the issue of independence as it might apply in Japan.

5.  The changes needed are fundamental and won't be easy.  In the past, there have been several reorganizations in Japan intended to address problems that were previously observed.  These have involved both the government agencies and the research and development institutes that serve them.  After one such reorganization, a very senior official in that organization commented to me that "We have changed the name, but nothing has really changed."  This was some time ago and was the private comment of one individual, so I do not want to blow it out of proportion.  However, at the time, I sensed that this was a widespread attitude.

Cosmetic changes were really not enough at that time, and perhaps in the long run, helped contribute to the situation Japan faces today.  Cosmetic changes certainly will not suffice today and in the future.  The Japanese government must make profound changes in the way the different parts of the government communicate and coordinate, and in the way that the regulator coordinates with the licensees.  The lines of authority must be drawn in a way that differs from how they have traditionally been drawn and how they may continue to be drawn elsewhere in the government.  Embedded practices, such as amakudari (which I previously addressed, and on which I also issued a post highlighting some comments made on the first blog), that may hamper the ability of the regulator to operate independently, must be addressed, but doing so has profound implications on basic personnel practices.

Japan seems to be making a promising start with its plans for regulatory reform.  However, many details of these plans have not yet been finalized, so it is difficult to comment further at this time.  In addition, just establishing a new organization will not be enough.  The implementation plan must assure that the fundamental changes are really made, and that the reorganization does not turn out to be just another case of changing the name of the organization.      

6.  Maintaining a new culture is a continuing process.  Even beyond the implementation phase, the kinds of changes Japan needs include fundamental behavioral changes by the individuals in the system.  Some undoubtedly go against the cultural traditions that all Japanese grow up with.  For example, children are taught that "the nail that sticks up gets hammered down."  That message provides a powerful disincentive to speaking up when someone sees something wrong.  The "rules of the road" for staffers of nuclear power plants and nuclear regulatory organizations needs to be a little different from the rules for the prevailing culture.

Once again, this is equally true for other characteristics in other cultures.  I have written in the past about what I called the "eraser mentality" in Japan--a tendency I saw to try to cover up errors.  We have seen that tendency in reports on some of the smaller accidents in Japan in the past.  Although I focused on this trait in Japan, perhaps because I saw it there in a more exaggerated form, this is a human tendency.  Who among us, after all, has not been tempted to try to deny that they did something wrong, especially if they thought they could get away with it?  In the US, I know that creating and maintaining an environment that encourages people to own up to mistakes is an on-going process and requires actions at every level.

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Saturday, July 2, 2011

Comm. Rogers on the Current NRC:

Too much politicization?

I recently became aware that my former boss, Commissioner Kenneth C. Rogers had published a guest column in the Seattle Times addressing what he sees as the politicization the US Nuclear Regulatory Commission (NRC) under the current Chairman.

Since I know Japan is now considering how to change its regulatory approach, some of Commissioner Rogers' comments on this issue, and some of my recollections of my time at the NRC, may be useful.

Commissioner Rogers refers to the Principles of Good Regulation, which were developed under his leadership during his time on the Commission. The very first principle is independence. One of the main criticisms of the Japanese regulatory system was its lack of independence--from licensees, from the promotional parts of the government, and from politics. What Commissioner Rogers' guest column makes clear is that an organizational structure can help foster independence, but structure alone is not enough, and saying you are independent is not enough. The ongoing commitment of all parties to maintaining independence is required.

Commissioner Rogers identifies his concerns about some of what we are hearing is happening at the Commission now, and says that, in his 10 years on the Commission, he "even though there were policy disagreements between commissioners...I never identified any initiatives by a member as politically driven."

This is very true. The Commission of the late 1980s and early 1990s, when I worked for him, was an excellent model for how a commission should act. The commissioners set the tone. Athough it was surely not perfect, as far as I could ever tell all information was shared, and all the commissioners' offices were invited to meetings where issues were discussed and views were exchanged. The commissioners didn't always agree on everything, but the tone was open and professional. And it was usually apolitical. I once commented to my husband that I usually couldn't tell by their votes what party each commissioner came from. Occasionally, yes. But often not.

By contrast, my husband worked, at the time, for the Federal Communications Commission (FCC). There, every vote was strictly along party lines. There, every commissioner actually had either a donkey or an elephant after his name in the annual report! But communications issues are financial issues and nuclear issues are health issues, and therein lies the difference. Or so I thought at the time.

It is for just that reason that I think Commissioner Rogers' guest column is important. As he so eloquently said, the Commission must have "a status of independent, solidly based integrity in which broad public interests rather than narrow partisan interests must dominate. Dedicated adherence to The Principles of Good Regulation could provide the way to get there, if all commissioners shed the political attachments they entertained before joining the commission."

This also is the goal to which the new Japanese regulatory organization, whatever form it takes, must constantly strive.

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Wednesday, December 29, 2010

Year-End Reflections:

A Quick Review

The end of the year is always a good time for stepping back to think about what has happened and what lies ahead, so at the risk of adding to lots of other reflections, wishes, and predictions, I will offer my own, both personal and on a broader level.

On a personal level, my really big accomplishment this year was the completion and publication of my book, Nuclear Firsts: Milestones on the Road to Nuclear Power Development, which I described in an earlier blog. I have never been one to have a list of 101 things to do before I die--perhaps I've been afraid I'd accomplish all 101 things, and then what?--but I have certainly had an unwritten and unnumbered wish list in the back of my mind, and writing a book was always one of the items on that virtual list. Over the course of the last few years, the nearly constant drumbeat of 50th anniversary celebrations made me think that this might be an appropriate topic. So for me, this book on nuclear milestones is a career milestone as well. In recent days, I've been gratified to see some very nice reviews on LinkedIn (accessible to members) and Amazon that suggest that other people agree that this is a timely topic--and that they like my treatment of the topic.

On a broader level, a lot has happened in the past year. I hesitate to try to write a list because I will inevitably leave out something important. Instead of trying to do that, I looked at my blogs over the past year to see if there were any patterns to what I'd covered. Now, my blog doesn't pretend to be a news publication, so there are certainly topics I didn't cover, and what I covered clearly reflects my personal interests. Still, in most cases, the items were spurred by one or more items in the news, so in a sense, my coverage may suggest some trends. Among them are the following:

Principles of Good Regulation: This one is both personal and broader. I have been very gratified to hear and read presentations by some of the current NRC Commissioners, especially Commissioners Svinicki and Ostendorff, highlighting the importance of NRC's Principles of Good Regulation. From the personal point of view, as I reported in an earlier post, I was heavily involved in the development of these Principles when I worked for Commissioner Kenneth Rogers at the NRC some years ago, so it is very gratifying to see that it is so highly regarded. I was also very pleased to discover that the "promotion" of the Principles by the Commissions is reaching audiences abroad, and I recently provided a summary of the Principles for a Japan NUS website.

Small modular reactors (SMRs): I had three or four blogs on SMRs during the past year. There is a growing interest in these reactors, both for small grids in developing countries or remote areas, and even for larger applications (in multiples). There are a number of designs being promoted and many claims being made, so much so that the anti-nuclear community, which had been rather silent on this issue, is waking up and beginning to realize that people may think a small reactor is just about as cute and cuddly as a windmill. (Yes, yes--I realize that not everyone thinks a windmill is cuddly--I mean my statement in both the serious and the sarcastic sense.) Some of the more thoughtful of the discussions on SMRs that I covered included one on an IEEE article and another on a CSIS meeting.

Nuclear waste: This certainly has been a significant year on the nuclear waste front, so I also blogged about this topic several times. Perhaps my most interesting post on this topic was on DOE's decision to withdraw its application for Yucca Mountain and NRC's initial response. I also covered the establishment of the Blue Ribbon Commission and some recommendations on how it should approach its assignment.

Global warming: With the Copenhagen conference having taken place in December 2009 and the continued concern and debate about global warming, I probably hit this topic in one way or another about half a dozen times. The blog on this topic that resonates most strongly at the moment is one on a conversation I had with Lew Branscomb in February where he bemoaned the use of the term global warming because of the doubt it raises in people's minds whenever we are blanketed in snow. Since this winter has already caused a number of snow-related disruptions, both in the U.S. and in Europe, it is timely to remember this discussion.

Other energy alternatives: If anything has surprised me about the topics I've covered in the last year, it is how many times my blogs have not been about nuclear power at all, but rather, about other energy alternatives. Sometimes my coverage has been spurred by articles that seem to compare nuclear power to other alternatives in overly simplistic ways, other times it is because I have been struck by how often decisions seem to be made without thinking ahead--i.e., where there are unintended negative consequences of what appeared to be good ideas. One example that stands out in my mind was on the use of LEDs in traffic lights. They were supposed to save energy, but because they were so efficient, they didn't emit much heat, and therefore, didn't melt the snow in winter, thus causing accidents and fatalities.

The most interesting thing I observed when I went back through my old posts--and which I have not previously commented on--is that I talked much more about wind power than about solar power. It seems to me that wind has emerged as the darling of the renewable movement. Solar power is beginning to be recognized as being land intensive, requiring a lot of water, and having several other drawbacks. Wind is regarded as having less of a footprint. Therefore, it kept recurring as a subject in the news, and I kept covering it. Still, as one of my posts noted, the jury is still out on the actual land requirements, and as another post noted, the comparison is not straightforward.

Between wind, other energy sources, and global warming, I spent a fair amount of time on topics that were not explicitly about nuclear energy. But we live in the bigger world, and as a practical matter, we must understand and react to the pros and cons of other energy technologies and of issues, such as global warming, that concern the public. Therefore, I felt and still feel that these topics were relevant to the readers of my blog. The comments I've received on several of these topics suggest that others feel the same way.

So much for looking back. Looking ahead is always harder. I can say with great confidence that I will not write another book in the coming year. (Not that I don't want to. It's just that it will take me time to gear up to do that again.) I can also say with great confidence that there will continue to be plenty to write about in my blog in the year ahead, both on nuclear power and on other related topics.

A lot of the nuclear-related topics are ones where the emotion has sometimes outweighed the reasoned discussion. One of the reasons I started this blog was that I was seeking complete, factual assessments of nuclear power and the alternatives--the kinds of analyses that tried to figure out the unintended consequences ahead of time, that tried to extrapolate the impacts as demand grows, etc. In that regard, I have appreciated the comments from readers who have helped provide a more complete perspective.

So much as I normally hate New Year's resolutions, I think this is one that I can keep: I resolve to continue to try to add a reasoned voice to the important discussions on nuclear power and other energy-related issues in the year ahead, and I hope to continue to discuss these issues with others who share that interest.

Until then, though, I want to wish everyone a happy, healthy New Year. See you next year!

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