|By Brian Schimmoller, Contributing Editor|
See if this scenario hits close to home. You’re at work, deep into your second cup of coffee, and getting into the groove of things at work. Your boss walks in with a high-priority task that demands your immediate attention…Thirty minutes later, the team leader for a special project you’re involved in calls to tell you that senior management has reviewed the team proposal and liked what they saw, but have requested that some alternative scenarios be evaluated to support their decision process…Twenty minutes after that, your significant other sends a text altering you that water is leaking into the attic.
All of these represent important demands on your time – things that HAVE TO GET DONE. The combined effect, however, is that your ability to focus energy on your number 1 priority – your day job – has been compromised.
The U.S. nuclear industry has recognized the vulnerability highlighted by this analogy. The issue is referred to as “cumulative effects,” and the industry is taking a hard look at what could and should be done about it. One might think that the impetus for this critical examination was Fukushima, but the wheels actually got in motion prior to March 2011.
The cumulative effects effort got started in 2009, as nuclear plant licensees were struggling to effectively manage their regulatory and industry workloads. Discussions over the next two years led the Nuclear Regulatory Commission staff to issue a paper (SECY 11-0032) just before the Fukushima event.
This paper defined cumulative effects as “the challenges licensees or other impacted entities such as state partners face in implementing new regulatory positions, programs, or requirements” and recognized the difficulties associated with implementing a “significant number of new and complex regulatory actions stemming from multiple regulatory actions.”
Of course, being difficult or complex is not reason enough to jettison regulatory activities or reduce licensee performance expectations. It is reason enough, however, to take a closer look, especially if the possibility exists that some activities could be diverting attention from issues of greater safety significance or diverting supervisor and worker attention from an operational focus on safety.
One example that the Nuclear Energy Institute offers in an online policy brief concerns NRC requirements related to debris screens on reactor containment sumps. While acknowledging the “tangible safety impact” of the issue, NEI maintains that the core issue was quickly addressed by all affected units and that the focus unnecessarily expanded to encompass unrelated concerns. This resulted in additional effort spanning more than a decade and individual reactor costs of up to $20-30 million, ten times the original estimate.
The Union of Concerned Scientists cautions that by devoting resources to an analysis of whether existing regulations represent an undue burden on licensees, the NRC is reducing the agency’s capacity to fulfill its safety mission. In an online post, UCS’s David Lochbaum highlights a number of issues that have been around for a while and that NRC has not fully resolved. These include the debris screen issue mentioned above, as well as issues addressing ice condenser containments, emergency pumps, seismic hazards, and flooding hazards.
So where do we stand? In March 2013, the NRC commissioners voted to adopt the staff’s recommendations outlined in the SECY paper. The commissioners directed the NRC staff to consider the effects of not just rule making, but all agency activities, including how NRC actions affect individual plants and the accuracy of NRC cost and timeline estimates. Specifically, the Commission directed the staff to propose ways that U.S. nuclear plants could prioritize the implementation of “regulatory actions as an integrated set and in a way that reflects their risk significance on a plant-specific basis.”
Throughout 2013, industry worked with NRC to develop a prioritization process and implementation guide, which will be pilot-tested this year through table-top exercises and field testing at select plants. The results of the pilot exercises will inform NRC consideration of potential changes to its rule making processes and procedures. One interesting outcome could be industry-initiated actions taking precedence over regulatory actions based on the relative risk and safety significance. NRC held a public meeting on the cumulative effects topic in November, and requested that the staff provide any recommendations by March 2015.
Regrettably, the cumulative effects discussion is primarily one of trust. One side says there is too much regulation, the other side says there’s not enough (or it’s not being properly enforced). The truth is likely somewhere in the middle.
Over its history, the NRC has done a commendable job safeguarding public safety. Not perfect, but quite respectable. Let’s give them a chance to work this out…and get everyone back to their day jobs.
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