Re: DOE regulation by NRC -Reply

[Charles Willis <CAW@nrc.gov>]

Paul, Drifter, et al., 

It may be fun to denigrate another group, but it is desirable to keep in mind the
objective of regulation, which is to meet a need or solve a problem.  

When the world and I were young, there was a need for the regulation of most NRC
licensees because of the lack of technical expertise.  There were exceptions, of
course, but when I first went to work for a utility the general absence of expertise
in health physics and other fields was something to behold.  In those days,
according to the ANSI standard, the health physics staff at a nuclear power plant
was to be a person working half time; the other half of that person's time was to be
spent as the plant chemist and the HP/chemist was NOT expected to have a
college degree.  In fact, no NPP employee was expected to have a degree.  Despite
regulation that many people considered excessive, this lack of expertise showed up
in radiation exposure and in the safety record.  For NPP, the expertise deficiency
largely has been resolved since the TMI accident but we now face the
utility-deregulation problem; safety-regulation seems essential maintain safety
standards in the face of efforts to cut operating and maintenance costs.  For
numerous other NRC and state licensees, the expertise-deficiency  problem seems
to continue.

In the days of the Atomic Energy Commission, there was little need for the
regulatory folk to worry with the major AEC contractors.  The bulk of the world's
radiological and nuclear knowledge resided at Hanford, Los Alamos, Oak Ridge,
Argonne, Brookhaven, Bettis,  etc.  Furthermore, the SL-1 accident had a profound
effect on the senior management of the AEC.  The impact of the public relations
problems from SL-1 generated a degree of safety-consciousness that has been
equaled only rarely.  

The diversity of the activities in AEC/DOE facilities was another factor in the
consideration of external regulation and  is still an important consideration. 
Currently, the NRC does not have the expertise needed to effectively regulate the
diverse activities at DOE facilities.  

Technically, the need should be identified before external regulation is imposed. 
As a practical matter, of course, the dictates of Congress will be followed.

Strictly personal opinions, of course.

Charlie Willis
caw@nrc.gov
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