One day’s delivery brings a directive stipulating that the sidewalks must be widened to permit two wheelchairs to cross paths without bumping. Another says the school cafeteria must be made accessible by elevator. Trees must be trimmed of branches six feet up their trunks, the orders go, and only government-certified technicians can change a light bulb on city property.
This is from a story in the Washington Post about a small French town (pop. 600) called Albaret-Sainte-Marie and its relationship with regulators in Paris. Now, except for the light bulb changing, all these directives could have truly beneficial outcomes, making life easier for a slice of the population, notably the disabled slice, but if various agencies are all putting their stamps onto the daily life of Albaret-Sainte-Marie simultaneously, the result could drain the town’s resources and kill the town’s overall civic effort to enable a better life for its people.
“We are being strangled,” [Mayor Michel] Therond complained, sifting through a pile of rules and regulations on his desk that he largely ignores — and many of which he does not even understand.
The larger argument against this is that it stifles economic growth, though the balance between beneficial regulation and economic activity is very tough to achieve. And there’s another large argument that edges us closer to the nuclear energy industry.
Therond said the problem has grown acute because France increasingly has a mind-set in which all risks must be eliminated, what is called “the principle of precaution.” “But you just can’t do that,” he objected.
No, you really just can’t do that, though some of the French regulation cited is geared not toward eliminating risk but improving access – those widened sidewalks and elevators to the cafeteria – and that’s an unalloyed good. Therond (or the Post) overreaches a little, but his point is good.
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In the case of nuclear energy and the NRC (and other regulators, including the industry’s safety watchdog, INPO), the issue isn’t to slough off anything that might make plants safer or reduce risk, but to implement the rules and regulations in an order that gets the most essential items done first. This would achieve the regulators goal while not bankrupting utilities or placing undo strain on the work force. It is possible without compromising safety – in fact, it improves safety by giving each item its due.
“This is our No. 1 issue right now,” NEI Senior Vice President and Chief Nuclear Officer Tony Pietrangelo said. “It’s not just an [NRC] regulatory issue. We want to make sure that the focus necessary on safety and reliability at the sites is not inadvertently diverted by the collective weight of meeting both industry and regulatory demands.”
Pietrangelo explained that a “cultural change” is needed to manage the cumulative impact of the regulatory demands made by the NRC and the activities of NEI, the Institute of Nuclear Power Operations [INPO] and the Electric Power Research Institute [EPRI] on the time and resources of nuclear energy facility staff.
And the NRC recognizes it.
Also this week, the NRC’s five-member commission approved the agency staff’s proposals for implementing process enhancements for the cumulative impact of regulation process as described in its October 2012 paper (SECY-12-0137)
And:
The commission’s memorandum directed agency staff to consider more deeply cumulative impact on licensees.
“The staff should continue to develop and implement outreach tools that will allow NRC to consider more completely the overall impacts of multiple rules, orders, generic communications, advisories, and other regulatory actions on licensees and their ability to focus effectively on items of greatest safety import,” the memorandum said.
This was at the March NRC Regulatory Information Conference, so it’s still a big topic.
In setting the industry’s priorities for the Department of Energy’s Fiscal Year 2014 budget request (what the industry would like to see, not necessarily what will come to pass), NEI’s President and CEO Marvin Fertel made a further push in testimony before the House Appropriations Committee:
The industry welcomes the oversight of the NRC by Congress to ensure that the agency effectively prioritizes its activities, based on safety significance, and achieves closure on issues in a timely manner. The agency is making important initial progress in these areas – addressing the cumulative impacts of its regulatory activities – and the industry believes the agency should be encouraged to continue these efforts.
This is how it happens – through a shared recognition of a problem. The industry is not sloughing off safety – and the regulator acknowledges there could be a more effective approach. This is a topic that’s going to pop up every now and then and has a fairly large chance of being misunderstood. But it enhances safety and reduces risk not the opposite – unless you happen to think all risk can be eliminated all at once.
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And in France? It provides a pretty good example of how not to engage the regulatory process.
The second-floor cafeteria for Albaret-Sainte-Marie’s 70 students will have to be moved to the ground floor, he said, because the cost of an elevator would be prohibitive for a community of 600 residents with an operating budget of just over $500,000.
Let’s keep the atomic café on the second floor – it’s safer there - and find a way to do it that gives both regulatory and industrial concerns their due.
The Post story is worth a read to understand the problem of regulation run amok, even without a specific nuclear angle.
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