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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.

Ensuring State Regulators Meet Our Expectations

Duncan White
Chief, Agreement State Programs Branch
 

People are often surprised to learn that regulators in 37 states oversee 87 percent of the radioactive materials users in the United States. agreementstatesSome people might ask, isn’t that the NRC’s job?

In fact, the NRC oversees all commercial power reactors. But Congress in 1959 gave states a role in regulating nuclear materials. A governor can ask the NRC to enter into an “Agreement” to oversee materials used in medicine, academia, research and commerce. The state must develop regulations, inspection and licensing programs, and hire and train staff. Once we find the state program to be adequate and compatible with the NRC’s, we can relinquish our authority.

But our job does not end there. The NRC plays an important role by overseeing state regulators. We review Agreement State programs, usually every four years (see our earlier blog post on this oversight program). Overall, the Agreement States do a very good job. But from time to time we find issues that need fixing. A management board looks at the review team’s findings and draws a conclusion. The board can find the program:

 Adequate and compatible
 Adequate but needs improvement
 Adequate but not compatible
 Not adequate
 

For programs that show weaknesses, the board can direct additional actions. They might place an Agreement State on monitoring or in a heightened oversight mode. At any one time, six to eight states may be in heightened oversight or monitoring. For these states, the NRC provides extra support and closer scrutiny. States on heightened oversight must develop plans to improve their programs and discuss their progress with NRC staff every two to three months.

If the board thinks the issues are more serious, it can recommend probation. A majority of NRC’s five commissioners must approve the recommendation before a state would be put on probation. This week, we announced we have put Georgia on probation.

georgiaGeorgia has been on a monitoring status since 2008. But in an October 2012 review, the review team found the state’s program had declined. They found significant deficiencies that could impact public health and safety if left uncorrected. Earlier this year, a management board recommended probation. Georgia developed a plan for improving its program and has had bimonthly conference calls with NRC staff ever since.

This is the first time the NRC has put a state on probation. In addition to our close scrutiny, we are notifying and coordinating with other government officials. NRC staff will stay in close contact and continue to work with the state on improvements. We will review Georgia’s program again in January 2014. If the state’s plan works, we could decide then to decrease our oversight. If not, we may continue the probation. If we see additional problems, we could suspend or even terminate the program.

One Tool for Safe Food: Commercial Irradiators

Maureen Conley
Public Affairs Officer
 

Foodborne Pathogen Sickens Many

This headline appears far too often. While the U.S. food supply is among the safest in the world, there are an estimated 48 million food-borne illnesses here annually, according to the Food and Drug Administration. That translates into one in six Americans falling ill every year. Of those, 128,000 are hospitalized and 3,000 die.

irradiatorOne important tool in the fight against foodborne illnesses may surprise you. Exposing food to radiation can eliminate pathogens—bacteria, viruses and parasites. Much like pasteurizing milk or canning produce, irradiation makes food safer and extends its shelf life.

The FDA has overseen the safe irradiation of food for more than 30 years. Other U.S. and world organizations, including the Centers for Disease Control and Prevention, the U.S. Department of Agriculture, and the World Health Organization, have all agreed that food irradiation is safe. The NRC plays a role too. The NRC licenses, inspects and oversees the operation of commercial irradiators.

It is important to understand that irradiated food does not become radioactive. The nutritional quality is unaffected and the process does not change the taste, texture or appearance of the food. Consumers will know their food has been treated this way only by its label. All irradiated food must have a label that states it has been treated with radiation. The label must also carry the international symbol for irradiation. fdalabel

For more information on the NRC’s role in licensing and overseeing irradiators, see our newly updated backgrounder on commercial irradiators.

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