Re: DOE regulation -Reply

[Charles Willis <CAW@nrc.gov>]

Joelle, Al, et al.,

In principle, the question of external regulation of DOE should be based on solving
problems; providing benefits commensurate with the costs.  If the NRC were to be
the regulator, no one would expect any improvement in either anti-trust or National
security arenas, so we are left with possible improvement in (a) radiological safety:
occupational exposure, public exposure and/or probability of severe accidents; (b)
operational efficiency; and (c) public confidence.

I believe the over three decades of experience we have is sufficient to show the
regulation, even over-regulation, does NOT engender public confidence.  

The data I have seen seem to indicate that there is little opportunity for
significantly reducing radiation doses either to workers or to the public.  

As to the reduction of the risks of severe accidents, there is little concrete
evidence either way.  However, the record suggests that no attainable risk
reduction would significantly improve public health and safety.

Thus, we seem to be left with possible improvements in operational efficiency. 
While it may surprise some people, this was a, perhaps the, principal argument for
external regulation by the NRC.  Because NRC regulations are promulgated as
they are, there is an inherent degree of regulatory stability.  To people familiar with
the devastation caused by the Admiral and his "tiger teams" as well as subsequent
dramatic changes in management direction, the stability of  possible regulation by
the NRC seemed quite attractive.  The DOE instability problem seemed to be
compounded by the tendency of some administrations to follow the policy of
"having the Nazis run the synagogues."   The NRC regulatory stability image lost
some of its luster with the NIH/MIT "RAM security" cases, which demonstrated
that, while changing the wording of a regulation takes years, the meaning can be
changed over night.  Still, this seems to be the area in which external regulation
might offer a benefit, and which might be worthy of serious investigation.

My suspicion, however, is that any decision will be made in the political arena, with
possible impact on reelection probability being the dominant consideration.

Just a personal opinion,  of course.

Charlie Willis
caw@nrc.gov
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