Improving NRC’s Internal Processes

Dave Solorio
Branch Chief
Concerns Resolution Branch

differingopinionThe most effective organizations are constantly evaluating how well their processes work and looking for ways to improve them. The NRC uses many different tools to measure its organizational effectiveness. When we identify improvements that can be made, we try to find the best way to put those changes in place — and then we measure their effectiveness.

In 2006, recognizing the need for standardization to replace procedures that varied by office, the NRC created an agency-wide “non-concurrence” process. The process encourages employees to bring different views to management related to policy papers, technical and administrative determinations, and other agency actions. And to do it as the supporting draft documents make their way through the management approval chain. The process is meant to promote the airing of views before final management decisions are made—in an effort to empower everyone involved and reach better decisions.

The NRC is fortunate to have so many talented, dedicated professionals–who may not always agree–and we appreciate their willingness to speak up. We encourage critical thinking and a questioning attitude not just among our licensees, but throughout our agency. As a safety regulator, the NRC recognizes the importance of an open, collaborative work environment, where people can raise concerns and differing views without fear of reprisal. Having an environment where people feel comfortable making varied views known supports our safety mission and makes for better decision-making.

My office recently evaluated the effectiveness of our non-concurrence process and used the results to revise the procedure for professional disagreements on draft documents. We feel confident these revisions will improve the process and allow the NRC to make the best possible decisions.

Our assessment provided encouraging feedback, but also identified areas where we have more work to do. On the positive side, we are encouraged NRC employees see the process as a way to be heard, understood and responded to. It’s also gratifying to see that most employees are aware of the process and would be willing to use it. On the other hand, some users of the process felt they faced negative consequences, or that their views were not reflected in final decisions. In many respects, the negative feedback was the most useful because it helps us target the areas where further improvement is needed.

For one thing, we are looking at ways to provide better training and clarify through that training and the revised procedure what is expected of supervisors who receive differing views, such as providing positive feedback for raising concerns. We are also working to make information on non-concurrence experiences (both positive and negative) more widely available.

Keeping a Finger on the Pulse of Dam Safety

Ken Karwoski
Dam Safety Officer


damWhile the NRC’s authority is limited to nuclear power plants and other civilian uses of nuclear material, dams play a role in what we regulate. Hydroelectric dams, for example, have supplied backup power for at least one reactor. A few reactors are downstream from various kinds of dams, so keeping the dams safe also helps keep the reactors safe.

We do our part in all this by participating in the Interagency Committee on Dam Safety. The federal government founded the committee in 1980 to help create and maintain effective programs, policies, and guidelines to enhance dam safety and security. FEMA chairs the committee.

The NRC has lots of company on the committee. Other members include:

  • Army Corps of Engineers
  • Agricultural Research Service
  • Natural Resources Conservation Service
  • Forest Service
  • Department of Energy
  • Bureau of Indian Affairs
  • Bureau of Land Management
  • Bureau of Reclamation
  • Fish and Wildlife Service
  • National Park Service
  • Federal Energy Regulatory Commission
  • Tennessee Valley Authority

We meet formally at least once every three months to discuss dam safety issues, but committee members work together on issues whenever necessary. For example, the NRC works regularly with FERC to inspect safety-related water retention ponds at a handful of reactor sites and evaporation ponds at two uranium mills. Other interactions included sharing operating experience and research results.

A typical committee meeting involves members providing updates on major dam safety topics, such as proposed changes to federal guidelines or new training. The other members, including the NRC, provide advice and feedback that reflects each organization’s perspective. 

The NRC worked with other committee members related to the flooding hazard re-evaluations all U.S. nuclear power plants have been working on since March 2012, as directed by the NRC following the accident at Fukushima. We asked committee members to review parts of the re-evaluation guidance related to dam failures. The NRC incorporated the committee’s input into the final guidance to nuclear plants.

We’ll continue to discuss the flooding re-evaluation process, including the results where appropriate, as part of the dam safety committee’s ongoing work.