May-June 2019 NPJ

NuclearPlantJournal.com 33 Nuclear Plant Journal, May-June 2019 Transformation & Innovation at NRC By Jeff Baran, U.S. Nuclear Regulatory Commission (NRC). Jeff Baran The Honorable Jeff Baran was sworn in as a Commissioner of the NRC on October 14, 2014. He is currently serving a term ending on June 30, 2023. Since joining the Commission, Commissioner Baran’s priorities have included ensuring effective implementation of safety enhancements in response to the Fukushima Daiichi accident, improving oversight of power reactors entering decommissioning, and boosting the openness and transparency of agency decision making. Before serving on the Commission, Commissioner Baran worked for the U.S. House of Representatives for over 11 years. Commissioner Baran earned a bachelor’s degree and a master’s degree in political science from Ohio University. He holds a law degree from Harvard Law School. Perspectives from Commissioner Baran at the 2019 Regulatory Information Conference on March 12, 2019. Since the last 2018 Regulatory Information Conference (RIC), a new conversation has started about transformation and innovation at NRC. The staff has begun to focus on how we, as an agency, make decisions and how we communicate with each other and external stakeholders. Regardless of whether we label it “transformation,” I think this particular effort makes a lot of sense. We need to identify the full range of views early so that we can carefully consider them as we move through the decision-making process. Ultimately, we want the decision-maker to have an open- minded and thorough analysis of the different options and viewpoints. There’s no question in my mind that, when we do his well, it improves he quality of the decisions we make. I want to sharemy houghts about how NRC should approach r a n s f o r m a t i o n nd give you some oncrete examples f potential changes see as positive and hanges I believe would take us in the wrong direction. In my view, it makes sense to consider r a n s f o r m a t i o n a l hange when a new technology challenges NRC’s existing regulatory approach or when the agency has historically struggled to regulate effectively in a particular area. On the other hand, when a regulatory process has worked well over the years, it’s better to pursue targeted refinements aimed at solving clearly defined problems. Whether NRC is considering a major, transformational change or a more modest, incremental change, we must keep our focus squarely on our safety and security mission. Transformation at NRC can’t be about rolling back safety and security standards to save money. And it can’t be about fewer inspections or weaker oversight. That would take NRC in the wrong direction. When considered with these criteria in mind, some of the transformational changes proposed by the staff or external stakeholders pass muster and others do not. There are ideas we should explore as part of this effort -- and other ideas we should reject as inconsistent with our mission as an independent safety regulator. A strong case for transformation can be made when it comes to updating NRC’s regulations to account for non- light-water reactor technologies. NRC’s current power reactor regulations were written for light-water reactors, which make up the entire existing fleet. So it makes sense to update those requirements to address different technologies. NRC is already doing a lot of work in this area. And I support developing a performance- based, technology-inclusive regulation for the licensing of non-light-water reactors. As the agency proceeds with this effort, it will be important to balance the broad rulemaking activities with the need to focus sufficient resources on the design- specific work for particular applications. The staff also recommends developing a new digital instrumentation and control regulation based on high- level, performance-based safety design principles rather than on highly prescriptive standards. The new rule likely would move away from exclusive reliance on one set of consensus standards and establish a process by which applicants could meet alternative standards that have been successfully used in other industries and countries. NRC’s regulatory approach to digital instrumentation and control would seem to be a strong candidate for transformational change. Over the years, NRC has struggled with this complex set of issues. It has proven to be a real challenge to ensure that digital upgrades are done safely and do not introduce any unacceptable risks, while establishing a reliable regulatory framework for making these upgrades. Although digital technology has been around for decades and is used extensively in other sectors of the economy, U.S. nuclear power plants still rely primarily on analog technology and components. As a practical matter, digital represents a “new” technology that challenges our existing regulatory framework. Because digital instrumentation and control technology has rapidly evolved in recent decades and will continue to do so, it is particularly ill-suited to rigid standards and prescriptive guidance. If other sectors of the economy or nuclear regulators in other countries have had success with alternative consensus standards, it makes sense for NRC to evaluate whether compliance with theses standards could be an acceptable way of meeting NRC’s safety and security requirements. t t t t a c o I c t c (Continued on page 34)

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