tag:blogger.com,1999:blog-4170623839736191950.post1031000426483324622..comments2022-12-03T19:22:46.911-08:00Comments on Safetymatters: Safety culture information, analysis and management: Safety Management and CompetitivenessBob Cudlinhttp://www.blogger.com/profile/08502712287881656493noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-4170623839736191950.post-46698670338663711222013-05-16T13:30:40.846-07:002013-05-16T13:30:40.846-07:00This review by French regulatory authorities offer...This review by French regulatory authorities offers a too rarely gained insight into the mindset that is characteristically behind the concepts and precepts of "risk-informed decision-making" as articulated in the TECDOC 1436 footnoted.<br /><br />Rare that is because current thinking in regulatory agency thinking continues to presume that adequate protection can be achieved without regard to the ability of licensed enterprises to sustain themselves economically.<br /><br />The term "competition" as used in this account seems to be driven by the onset of French national policy to open electricity markets to less control by government-owned and rate regulated monopoly enterprise. <br /><br />There seems to be a presumption in the design of the assessment that in the future plant owners and operators will be under external pressure to conform with market pricing. <br /><br />It seems significant that the regulatory authority offers no preconditional analysis of the regulator's own sense of how this change in national policy will impact its concept of responsibility for assurance of adequate protection given any tacit expectation by the public that perhaps a low margin of safety is acceptable in return for reduced cost of supply.<br /><br />From the report I conclude the regulatory authorities anticipate that whatever transfers of risk share might occur during privatization and price deregulation that the regulatory system is unaffected. Perhaps not a surprising stance, but a crucial one nonetheless - particularly if a taken-for-granted one.<br /><br />In reviewing the TECDOC 1436 I was struck by how thoroughly persuaded the guidance developers seem to be that the design and conduct of regulation exists apart from the enterprises conducting regulated activity. <br /><br />So long as the LNTH and the ALARA Principle enable the establishment of arbitrary and uncosted consequence findings, reference in 1436 to "Integrated Decision Making for Plant Safety Issues" will be problematic. <br /><br />The elaborate and in-depth dissociation of the social/cultural and technical aspects of nuclear energy enterprises in effect contradicts national policy tending toward more Whole-Risk Reckoned and performance-based sense and decision-making.<br /><br />TECDOC 1436 notes the distinction among regulatory regimes with some being highly prescriptive and others taking a more goal-setting, tailored and performance-based strategy to achievement of basic protection principles. <br /><br />The TECDOC seems to suggest that Integrated Decision Making approaches to "risk-informed regulation" is applicable to both strategies. I would be more sanguine about this conclusion if the French approach to assessment for "competition" resilience of safety decision making were to become a normative approach. <br /><br />This conclusion is based in part upon the complete absence of reference to production efficiency (short term or long term) in the literature of "risk-informed regulation" - that combined with the presumption that a collection of regulators are suited by experience and competence to assess processes related to balancing both nuclear safety and other enterprise risk factors.Bill Mullinsnoreply@blogger.com