"Holding the Center"
Shirley Ann Jackson, Chairman
Nuclear Regulatory Commission
All Employees Meeting
White Flint Complex, on The Green
Thursday, September 3, 1998, 10:30 a.m. [and 1:30 p.m.]
Thank you, Mrs. Norry. Good morning [afternoon], ladies and gentlemen. With me today are NRC Commissioners Nils J. Diaz and Edward McGaffigan, Jr. On behalf of my Commission colleagues and myself, I would like to welcome all of you to this special meeting of the Commission with the NRC staff. I extend that welcome both to those of you assembled here in the tent at Headquarters, and also to the groups of employees connected by video-conference and by telephone from the regions.
These "All Employees" meetings have become an annual tradition at the NRC since 1991. They are intended to stimulate and to facilitate direct communication between the Commission and individual members of the staff on mission-related policies and initiatives; to clarify the Commission's agenda; to engender a shared vision; and to motivate the staff in pursuit of that vision. This year, as you know, the Commission actually moved the date of this meeting forward, because we especially wanted to solicit staff input during this time of transition.
I suppose some of you might be thinking that we have been in a "time of transition" for several years--and that would be an accurate thought--but the pace certainly has accelerated in a number of areas in recent months. I would like to thank all of you, on behalf of the Commission, for the professionalism, hard work, and dedication you have exhibited. As you know, the NRC has been the subject of a number of recent external reviews--from our Congressional appropriations and authorization committees, the General Accounting Office (GAO), and other stakeholders. On July 17, the Commission invited a number of its stakeholders, including some of our harshest critics, to engage in a round-table discussion that was open to the NRC staff, the press, and the public. On July 30, the Commission testified in a hearing before the Senate Committee on Environment and Public Works Subcommittee on Clean Air, Wetlands, Private Property, and Nuclear Safety. These interactions have provided the Commission with beneficial insights. Although the recent feedback has provided a valuable range of perspectives on the strengths and weaknesses of NRC regulatory programs and policies, these general topics also have been the focus of various Commission and staff efforts and initiatives for some time. Some of the particular areas of focus include:
- Providing a more rapid transition to a risk-informed and, performance-based regulatory framework;
- Re-examining our reactor oversight processes--including inspection, enforcement, and performance assessment--to ensure a proper safety emphasis, to enhance the objectivity and defensibility of our methods, and to eliminate unnecessary licensee burden;
- Ensuring that some of our frequently used processes, such as generic communications and confirmatory action letters, are subject to proper controls;
- Streamlining our licensing and adjudicatory processes; and
- Ensuring the overall effectiveness of our organization, management, and self-assessment capabilities, including a re-evaluation of staffing and resource needs.
In addition, a consistent thread that has run through various critiques is the need for us to be clear with our definitions and standards.
Now, I am sure that many of you have read various trade press articles, or have heard discussions, that have led you to ask: "What does it all mean? Where are we headed as an agency?" I would like to make several points in this regard.
First, we should remember that change can be good. Many of you may remember that when I spoke to you at an All Employees Meeting in 1996, I shared my vision which included the need for the NRC to position for change. In fact, the NRC was in the process of active change when some of these external reviews began, including Commission initiatives such as the revisions to 10 CFR 50.59, the integrated review of reactor performance assessment processes (IRAP), the revisions to 10 CFR Part 35, 10 CFR Part 70, and the new registration program for generally licensed devices, and the changes to our agency-wide planning and budget framework. These and many other initiatives had been in various states of gestation before the recent focus on the NRC, but they have not come to fruition. The recent external interest and focus have proven to be helpful in highlighting areas in which we need to accelerate change, as well as in revealing new areas that need additional attention. These changes will have an effect on the entire agency, and will not be limited just to the reactor oversight program areas. Although the short-term focus is predominantly in the reactor programs, it is important that we all understand that we will be assessing and changing how we do business throughout the NRC.
Today I would like to focus your thoughts, briefly, on the importance of what I have called "Holding the Center." Let me emphasize, at the outset, that "holding the center" does not (I repeat does not) mean adopting a defensive posture or "clinging to the past." What it does mean is not losing sight of our primary health and safety mission while enhancing our effectiveness by changing. It means continuing to stay focused on that mission as we make the transition from a traditional deterministic approach to a more risk-informed and performance-based approach to regulation.
How do we go about achieving change in a responsible manner? I have discussed this with the agency senior managers, and today I offer some strategies for your consideration, which are drawn, in part, from a presentation made to the Commission by the Office of Research last month. What was presented seemed to indicate that the presenters "got it"--at least, as articulated in the meeting. What are these strategies?
- We need to be sure that we have articulated clearly and correctly our vision, our goals and our requirements;
- We must use risk-informed thinking and techniques throughout the agency as a means for ensuring a proper safety focus;
- We should encourage a team concept within and among offices--which means avoiding a "stove-pipe" mentality (after all, we are one NRC, with one mission);
- We must encourage agency wide thinking that places greater value on being (1) proactive/anticipatory, (2) outcomes/results-oriented, (3) timely, and (4) cost-effective;
- We should use process mapping (i.e., thinking about how we do things and the best way to do them) as a tool to establish efficient functional relationships and to eliminate duplication of effort;
- We should build on our current strengths (i.e., our people, programs and processes); and
- We need management and staff buy-in. That is one reason we are here today.
In addition to these overall "high-level" strategies, we also should be using a series of what I have referred to as "implementing strategies." For example, we should be:
- Developing reasonable thresholds for decision-making in areas of potential high risk or safety significance;
- Conducting continual self-assessment, and soliciting feedback from those we regulate and other stakeholders;
- Assessing whether our requirements achieve their intended purpose; and
- Sunsetting activities when they are no longer relevant for regulatory purposes.
These are examples of strategies for achieving change in a manner that ensures that we are "holding the center"--that is, identifying and preserving our core or baseline requirements as we change to be more effective in accomplishing our fundamental mission.
Let us take our reactor oversight processes as an example. As I have discussed with NRC senior management, we should ask and answer a series of questions: (1) Within a risk-informed framework, what is the minimum level of inspection (or assessment, or licensing oversight) that will continue to give us confidence that licensed facilities are being operated and maintained in a safe manner? (2) What processes and methods must we establish to achieve a risk-informed baseline as effectively and efficiently as possible? (3) What core competencies and resources must we have to implement those processes? (4) What measures are necessary that will tell us when we have succeeded? and (5) How can all of this be achieved in the most timely and cost-effective manner possible?
It is important that we establish this framework expediently and reasonably. To repeat--our objective is to be more effective in accomplishing our public health and safety mission by being risk-informed, performance-based (results-oriented), and cost-effective. If we truly move to a program with these characteristics, appropriate burden reduction, in fact, will occur, because being risk-informed means that there will be burden reduction in areas of low risk, just as it may entail increased focus in areas we previously may have under-emphasized. In the end, we will impose no more, but no less, than what is required.
Before I close, I would like to offer to all of you a few "watch-words" of which to be mindful as we continue to improve: confidence, courage, and conviction.
Confidence: We need to be confident that our new inspection, assessment, and enforcement programs provide objective criteria and consistent methodologies for providing reasonable assurance of public health and safety, and that they accomplish what they are designed to accomplish. We can achieve this through being risk-informed, by obtaining input from all of our stakeholders, and by rigorously challenging the expected outcomes and potential weaknesses of all the options that we consider.
Courage: We need to have the courage, and the discipline, to implement fully and consistently our new programs as they are developed and formally adopted. We need to build an assessment function into each of the programs and processes to allow early self-identification of performance results that are not consistent with effective public health and safety regulation. We need to self-initiate course corrections to our programs (based on self-assessment results) before our various stakeholders feel compelled to attempt to force change on us (with the attendant potential for over-reaction). As the NRC, we should be leading change in response to a changing external environment, and because we have new tools and approaches to allow us to better define safety and to implement our programs in new ways.
Conviction: We need to have the conviction, and the objective evidence, to argue the merits of our programs and policies when challenged. We will be much more effective at resisting the "pendulum effect" (and therefore in maintaining regulatory stability) if we are willing to change ourselves, and, in changing, to defend the soundness and the effectiveness of our programs as they evolve (as demonstrated by the results of our self-assessments and input from others).
I believe I can speak for my colleagues when I say that the Commission encourages the staff to communicate directly with us when you have concerns. The Commission's "open-door policy" is always there, and I would encourage you to use that avenue if you have a public health and safety issue to which you feel that NRC management, or the agency as a whole is not properly responding. More broadly, as we are making these changes in various programs, we are open to your suggestions for improvement.
In closing, I would like to disabuse you of the view, that some may have, that we are jumping off the bridge in reaction to criticism from the Congress, or from other stakeholders. We are doing what we need to do; we are finishing what we started. The changes we make will be made because they are the right things to do--all predicated on safety first and foremost, but we will be better and smarter at how we carry out our mission. We should be excited and energized in our belief that these changes will allow us to have an even better safety focus, to be clearer in our expectations for our licensees and for ourselves, to reduce burden where appropriate, to be responsive to all of our stakeholders in a responsible way. In its criticism, the Congress has provided us with a platform to accelerate our movement in a direction that we know we must go--a direction we ourselves had decided we needed to go.
We talk a lot about risk and risk assessment, but there is a different kind of risk we must assume. Drawing on the watch-words, I ask you to keep the following in mind about risk: "You cannot discover new oceans unless you have the courage to lose sight of the shore." (1) So, please stay focused on safety, have confidence, work hard, remain committed, maintain your conviction and, above all, have the courage to change! Thank you.
This concludes my preliminary remarks. Before taking questions, I would like to ask Commissioner Diaz to share his thoughts with us, especially on risk-informed decision-making; and then I would ask Commissioner McGaffigan to share his insights, especially on the role of our Congressional oversight committees.
making; and then I would ask Commissioner McGaffigan to share his insights, especially on the role of our Congressional oversight committees.
1. This is a modified (gender neutral) version of a phrase by Andre Gide, as indicated on a motivational product sold by Successories Inc., Aurora, Illinois.