President Trump seeks to lessen the economic burden from excessive regulation. The Nuclear Regulatory Commission (NRC) initiated Project AIM before the 2016 elections seeking to right-size the agency and position it to become more adaptive to shifting needs in the future. And the nuclear industry launched its Delivering the Nuclear Promise campaign seeking productivity and efficiency gains to enable nuclear power to compete better against natural gas and other sources of electricity.
In light of these concurrent efforts, we will be reviewing momentous events in nuclear history and posting a series of commentaries on the role of regulation in nuclear plant safety. The objective is to better understand under-regulation and over-regulation to better define “Goldilocks” regulation—regulation that is neither too lax nor too onerous, but just right. That better understanding will enable us to engage the NRC more effectively as the agency pursues Project AIM and the industry tries to deliver on its promise.
Searching for Goldilocks
We will be reviewing “momentous events” with the expectation of examining times when regulation played too little a role as well times when regulation played too large a role. If we are lucky, we will examine events from all three bins—regulation too lax, regulation just right, and regulation overly stringent. Lessons from all three bins will yield the best understanding of what traps to avoid as well as what practices to emulate for the “just right” bin to become more and more popular in the future.
We have a working list of events that will hopefully populate all three bins. While we will not draft the commentaries or bin an event until after reviewing the relevant records, the events likely to fall into the “too lax” bin include the 1979 accident at Three Mile Island, the mid 1990s Millstone, Salem and Cooper problems, and the 2011 accident at Fukushima.
Events likely to fall into the “undue burden” bin include the August 1991 Site Area Emergency declared at Nine Mile Point following a transformer failure, the 1998 Towers Perrin report, and the semi-annual reports by the NRC’s Office of the Inspector General.
And events likely to fall into the “just right” bin include March 1990 station blackout at Vogtle, the September 1997 discovery of and recovery from containment problems at DC Cook, and the flood protection deficiencies identified at Fort Calhoun in 2010 whose remedies sure came in handy during the flood the plant experienced in June 2011.
While we may have reported on or blogged about some of these events already, the perspective is slightly different now. Before, we may have explained how event A resulted in regulatory requirements x, y, and z. Now, we will strive to determine whether there was sufficient awareness prior to the event for these requirements to already have been put in place (i.e, lax regulation), a knee-jerk reaction imposing more regulatory requirements than necessary (i.e., over-regulation), or a prudent reaction to a reasonably unavoidable event (i.e., just right regulation).
The list of potential events for this series contains nearly four dozen candidates. Other candidates may emerge during the reviews. We do not anticipate posting commentaries until every candidate is crossed off the list. Instead, we will continue the series until all three bins are populated with sufficient events to shed meaningful insights on the proper role of regulation in nuclear plant safety. Upon reaching this point, we intend to discontinue the series and share the findings and observations from our reviews in a post and/or report.