Principles of Good Regulation: Efficiency

Maureen Wylie
Chief Financial Officer

The American taxpayer, the rate-paying consumer, and licensees are all entitled to the best possible management and administration of regulatory activities. The highest technical and managerial competence is required, and must be a constant agency goal. NRC must establish means to evaluate and continually upgrade its regulatory capabilities. Regulatory activities should be consistent with the degree of risk reduction they achieve. Where several effective alternatives are available, the option which minimizes the use of resources should be adopted. Regulatory decisions should be made without undue delay.

graphic-pogr_efficiencyThe principles of good regulation are critically important to the day-to-day operations of the agency. They’re our guide posts. They’re touchstones to help us be sure that we’re properly executing our mission.

As the chief financial officer, I am partial to the efficiency principle. It is one of the reasons that I come to work every day. We are not only federal employees but also taxpayers and citizens, so we should be sure that we’re taking care of the nation’s resources appropriately. In addition to the payments we receive from our licensees, the NRC also receives an appropriation from the Congress each year. It’s “your money” and “our money” at the same time. Efficiency as we execute the agency’s work supports both the public good and the expectations we have as individuals for the best value we can offer.

As part of our focus on efficiency, the NRC has an initiative underway to improve our ability to plan and execute our mission. Known as Project Aim, this is an effort to find ways to better adapt to a dynamic environment and changes in workload. With direction from our Commissioners, the staff is working to “right-size” the agency to ensure we have the skills we need to accomplish our mission; to use agency resources more wisely; to improve the timeliness of our decision-making and respond quickly to changing conditions; and to promote unity of purpose through clearer agency priorities.

As Steering Committee co-chair, I have seen a lot of creativity from the staff as we work though the initial 19 tasks approved by the Commission, especially as we work to make processes more efficient and to shed unnecessary work. By the time we complete this effort, the NRC will have saved a total of nearly $50 million. That’s real money in my book.

principles-of-good-reg-web-screen_1This work requires us to find the right balance to make sure we are meeting our safety mission while delivering results in a timely and cost-effective way. As an example, we aim to review applications in a timely manner while ensuring safety and security. Meeting this goal depends in part on receiving complete, high-quality applications. Many of our programs have implemented acceptance reviews, which give NRC staff a chance to make sure an application is complete before we begin our detailed technical reviews. If we find things we think are missing or would otherwise slow down our technical review, we ask the applicant to supplement their application. This process saves the licensee money and allows our staff to work on other activities until that application is ready.

For me one of the most important purposes of the principles is cultural. There are many different roles here at the agency. You hear people talk about being a technical or Commission office, as compared to people who provide corporate support. Or the distinction between people in the regions and those here in Rockville, Md. But, no matter your role, the principles apply to all of us. They are a unifying aspect to our culture. I can sit in a meeting with my colleagues in operating reactors or in nuclear materials and wastes and we’d still have an important shared vocabulary that is meaningful and helps us transcend our individual goals and move together toward the right solutions.

This post is the third of five that will explore each of the five principles separately. For the history of the Principles of Good Regulation, read this post.

Singing From the Same Safety Culture Song Sheet

Ronald Frahm
Senior Reactor Operations Engineer
 

What’s in a word? If words are the currency of communication, then common language is important for smooth interaction without misunderstanding or conflict. Think of the many clichés that make this point: “On the same wavelength,” “speaking the same lingo,” or “lost in translation.”

communicationmessThe NRC and the nuclear power industry have taken a significant step toward improving our communication by adopting common language in the important area of safety culture. Safety culture – the idea that safety comes first – is a priority for the NRC, as expressed in our safety culture policy statement revised in 2011. Over the past few years, NRC staff members have met with industry representatives and other interested parties to agree on common language to express safety culture. To use another cliché, we’re now on the same page.

Now it’s time to put that common verbiage into action. As of January 1, the NRC is integrating this common safety culture language into our Reactor Oversight Process, or ROP. The ROP is the agency’s method of assessing a nuclear power plant’s performance by identifying and responding to problems in seven cornerstones of safety, as well as cross-cutting aspects that impact more than one cornerstone.

Using common safety culture language in the ROP will promote clearer and more consistent communication between the NRC and industry about these cross-cutting aspects.

These are not substantial changes to the ROP. The goals, processes and procedures of our regulatory oversight of nuclear plants have not changed. The changes simply incorporate the common-language terminology into the ROP and do not affect the process for applying cross-cutting aspects to findings or evaluating cross-cutting themes.

For example, “The licensee defines and effectively communicates expectations regarding procedural compliance and personnel follow procedures,” has been replaced with “Individuals follow processes, procedures, and work instructions.”

communicationmessAlso, “The licensee takes appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity” is now rendered as “The organization takes effective correction actions to address issues in a timely manner commensurate with their safety significance.” Simple, straightforward, and less bureaucratic, even if we couldn’t get “commensurate” out of there altogether.

These and other changes implementing the common safety culture language are spelled out in a revised Inspection Manual Chapter 0310. Inspection reports for 2013 as well as the end-of-cycle reports to be issued in March will still use the previous language and guidance. The new language will be for inspections conducted in 2014 and in the mid-cycle assessments to be issued in September.