NRC IG Reviews DNFSB Organizational Culture and Climate

The Nuclear Regulatory Commission Inspector General (IG) provides IG services to the Defense Nuclear Facilities Safety Board (DNFSB), an independent government agency.  The DNFSB organizational culture and climate study* reviewed here was performed for the NRC IG by an outside consultant.

Summary of Methods and Results

The study’s methodology is familiar: Review relevant past reports, develop a survey instrument based on employee interviews and focus groups, administer the survey to all employees and interpret the results.

Themes (issues, shortcomings) brought up during the interviews included DNFSB’s handling of change management, communication, personnel development, leadership, internal procedures and performance management (aka personal recognition). (pp. 6-7)

The report compared the DNFSB survey results with three external norms: a cross-section of U.S. industry, U.S. employees working in Research and Development, and industries that have experienced significant changes with widespread employee impact.  The last group consists of organizations under stress because of reorganization, bankruptcy, layoffs, etc. (p. 14)

The report’s summary is not encouraging: “the general trend shows an unfavorable comparison for the DNFSB on all three external benchmarks, . . . Also, many employees feel they do not have the right tools and resources.  Along with that, 38 percent of employees say they plan to leave DNFSB in the next year.” (p. 4)

The employee survey had 14 categories, higher scores mean greater respondent agreement with positive traits.  Analyzing the survey responses in three different dimensions yielded one typical and two unusual results.  In our opinion, they suggest uneven DNFSB management effectiveness across the organization.

Across organizational groups, the General Manager and Admin/ Support groups scored above DNFSB averages on most categories; the Technical Director and Engineering groups scored below DNFSB averages on most categories. (p. 13)  In our experience, this is no surprise; bosses and admin people are usually more satisfied (or less dissatisfied) than the folks who have to get the work done.

Looking at employee tenure, employees with the shortest tenure scored the highest (this is typical) then the scores go downhill.  The longest tenured employees have the lowest scores, which is unusual; most organizations have a U-shaped curve, with newcomers and old timers the most satisfied. (p. 14)

By pay (GS or DN) level, “what is atypical is that the lowest-scoring group is not the lowest-level group, but instead the mid-level group, . . .” (p. 15)

The report identifies Sustainable Engagement (SE)** as a key category.  Using regression analysis, the authors identified five drivers (other survey categories) of SE, two that had acceptable survey scores and three that are candidates for organizational improvement interventions: communication, leadership and performance management. (p.17)  This is as close the report comes to suggesting what the DNFSB might actually do about their problems.

Our Perspective 

This report recognizes that DNFSB has significant challenges but it contains zero surprises.  It’s not even news.  The same or similar ground was covered by a Dec. 2014 organizational study performed for the DNFSB which we reviewed on Feb. 6, 2015.

Problems mentioned in the 2014 report include board dysfunctionality, communications, performance recognition, change management, frequent disruptive organizational changes, and the lack of management and leadership competence.  The 2014 report  included extensive discussion of possible organizational interventions and other corrective actions.

The NRC IG already knew change management was a serious challenge facing the DNFSB; it was mentioned in an Oct. 2014 IG report.***  That report was likely the impetus for this 2015 study.

The DNFSB has been in apparent disarray for over a year.  New members have been appointed to the Board this year, including a new chairman.  It remains to be seen whether they can address the internal challenges and, more importantly, provide meaningful recommendations to their single client, the U.S. Department of Defense.

Bottom line: This NRC IG consultant’s report adds little value to understanding the DNFSB’s organizational issues or developing effective corrective actions. 


*  Towers Watson, “DNFSB 2015 Culture and Climate Survey: Executive Overview of Key Findings” (Aug. 2015).  ADAMS ML15245A515.  Thanks to John Hockert for publicizing this report on the LinkedIn Nuclear Safety Culture forum.

**  Sustainable Engagement is defined as follows: “Assesses the level of DNFSB employees’ connection to the organization, marked by being proud to work at DNFSB, committing effort to achieve the goals (being engaged) having an environment that support productivity (being enabled) and maintaining personal well-being (feeling energized).” (p. 9)

**  H.T. Bell (NRC) to Chairman Winokur (DNFSB), “Inspector General’s Assessment of the Most Serious Management and Performance Challenges Facing the Defense Nuclear Facilities Safety Board,” DNFSB-OIG-15-A-01 (Oct. 1, 2014).  ADAMS ML14274A247.

Fukushima and Volkswagen: Systemic Similarities and Observations for the U.S. Nuclear Industry

Fukushima

VW Logo (Source: Wikipedia)

Recent New York Times articles* have described the activities, culture and context of Volkswagen, currently mired in scandal.  The series inspired a Yogi Berra moment: “It’s deja vu all over again.”  Let’s look at some of the circumstances that affected Fukushima and Volkswagen and see if they give us any additional insights into the risk profile of the U.S. commercial nuclear industry.

An Accommodating Regulator

The Japanese nuclear regulator did not provide effective oversight of Tokyo Electric Power Co.  One aspect of this was TEPCO’s relative power over the regulator because of TEPCO’s political influence at the national level.  This was a case of complete regulatory capture.

The German auto regulator doesn’t provide effective oversight either.  “[T]he regulatory agency for motor vehicles in Germany is deliberately starved for resources by political leaders eager to protect the country’s powerful automakers, . . .” (NYT 12-9-15)  This looks more like regulatory impotence than capture but the outcome is the same.

In the U.S., critics have accused the NRC of being captured by industry.  We disagree but have noted that the regulator and licensees working together over long periods of time, even across the table, can lead to familiarity, common language and indiscernible mutual adjustments. 

Deference to Senior Managers

Traditionally in Japan, people in senior positions are treated as if they have the right answers, no matter what the facts facing a lower-ranking employee might suggest.  Members of society go along to get along.  As we said in an Aug. 7, 2014 post, “harmony was so valued that no one complained that Fukushima site protection was clearly inadequate and essential emergency equipment was exposed to grave hazards.” 

The Volkswagen culture was a different but had the same effect.  The CEO managed through fear.  At VW, “subordinates were fearful of contradicting their superiors and were afraid to admit failure.”  A former CEO “was known for publicly dressing down subordinates . . .”  (NYT 12-13-15)

In the U.S., INPO’s singled-minded focus on the unrivaled importance of leadership can, if practiced by the wrong kind of people, lead to a suppression of dissent, facts that contradict the party line and the questioning attitude that is vital to maintain safe facilities.

Companies Not Responsible to All Legitimate Stakeholders

In the Fukushima plant design, TEPCO gave short shrift to local communities, their citizens, governments and first responders, ultimately exposing them to profound hazards.  TEPCO’s behavior also impacted the international nuclear power community, where any significant incident at one operator is a problem for them all.

Volkswagen’s isolation from public responsibilities is facilitated by its structure.  Only 12% of the company is held by independent shareholders.  Like other large German companies, the labor unions hold half the seats on VW’s board.  Two more seats are held by the regional government (a minority owner) which in practice cannot vote against labor. So the union effectively controls the board. (NYT 12-13-15)

We have long complained about the obsessive secrecy practiced by the U.S. nuclear industry, particularly in its relations with its self-regulator, INPO.  It is not a recipe for building trust and confidence with the public, an affected and legitimate stakeholder.

Our Perspective

The TEPCO safety culture (SC) was unacceptably weak.  And its management culture simply ignored inconvenient facts.

Volkswagen’s culture has valued technical competence and ambition, and apparently has lower regard for regulations (esp. foreign, i.e., U.S. ones) and other rules of the game.

We are not saying the gross problems of either company infect the U.S. nuclear industry.  But the potential is there.  The industry has experienced events that suggest the presence of human, technical and systemic shortcomings.  For a general illustration of inadequate management effectiveness, look at Entergy’s series of SC problems.  For a specific case, remember Davis-Besse, where favoring production over safety took the plant to the brink of a significant failure.  Caveat nuclear.


*  See, for example: J. Ewing and G. Bowley, “The Engineering of Volkswagen’s Aggressive Ambition,” New York Times (Dec. 13, 2015).  J. Ewing, “Volkswagen Terms One Emissions Problem Smaller Than Expected,” New York Times (Dec. 9, 2015).

Foolproof by Greg Ip: Insights for the Nuclear Industry

This book* is primarily about systemic lessons learned from the 2008 U.S. financial crisis and, to a lesser extent, various European euro crises. Some of the author’s observations also apply to the nuclear industry.

Ip’s overarching thesis is that steps intended to protect a system, e.g., a national or global financial system, may over time lead to over-confidence, increased risk-taking and eventual instability.  Stability breeds complacency.**  As we know, a well-functioning system creates a series of successful outcomes, a line of dynamic non-events.  But that dynamic includes gradual changes to the system, e.g., innovation or adaptation to the environment, that may increase systemic risk and result in a new crisis or unintended consequences

He sees examples that evidence his thesis in other fields.  For automobiles, the implementation of anti-lock braking systems leads some operators to drive more recklessly.  In football, better helmets mean increased use of the head as a weapon and more concussions and spinal injuries.  For forest fires, a century of fire suppression has led to massive fuel build-ups and more people moving into forested areas.  For flood control, building more and higher levees has led to increased economic development in historically flood-prone areas.  As a result, both fires and floods can have huge financial losses when they eventually occur.  In all cases, well-intentioned system “improvements” lead to increased confidence (aka loss of fear) and risk-taking, both obvious and implicit.  In short, “If the surroundings seem safer, the systems tolerate more risk.” (p. 18)

Ip uses the nuclear industry to illustrate how society can create larger issues elsewhere in a system when it effects local responses to a perceived problem.  Closing down nuclear plants after an accident (e.g., Fukushima) or because of green politics does not remove the demand for electric energy.  To the extent the demand shortfall is made up with hydrocarbons, additional people will suffer from doing the mining, drilling, processing, etc. and the climate will be made worse.

He cites the aviation industry as an example of a system where near-misses are documented and widely shared in an effort to improve overall system safety.  He notes that the few fatal accidents that occur in commercial aviation serve both as lessons learned and keep those responsible for operating the system (pilots and controllers) on their toes.

He also makes an observation about aviation that could be applied to the nuclear industry: “It is almost impossible to improve a system that never has an accident. . . . regulators are unlikely to know whether anything they propose now will have provable benefits; it also means that accidents will increasingly be of the truly mysterious, unimaginable variety . . .” (p. 252)

Speaking of finance, Ip says “A huge part of what the financial system does is try to create the fact—and at times the illusion—of safety.  Usually, it succeeds; . . . On those rare occasions when it fails, the result is panic.” (p. 86)  Could this description also apply to the nuclear industry? 

Our Perspective

Ip’s search for systemic, dynamic factors to explain the financial crisis echoes the type of analysis we’ve been promoting for years.  Like us, he recognizes that people hold different world views of the same system.  Ip contrasts the engineers and the ecologists:  “Engineers satisfy our desire for control, . . . civilization’s needs to act, to do something, . . .” (p. 278)  Ecologists believe “it’s the nature of risk to find the vulnerabilities we missed, to hit when least expected, to exploit the very trust in safety we so assiduously cultivate with all our protection . . .” (p. 279)

Ip’s treatment of the nuclear industry, while positive, is incomplete and somewhat simplistic.  It’s really just an example, not an industry analysis.  His argument that shutting down nuclear plants exacerbates climate harm could have come from the NEI playbook.  He ignores the impact of renewables, efficiency and conservation.

He doesn’t discuss the nuclear industry’s penchant for secrecy, but we have and believe it feeds the public’s uncertainty about the industry's safety.  As Ip notes, “People who crave certainty cannot tolerate even a slight increase in uncertainty, and so they flee not just the bad banks, the bad paper, and the bad country, but everything that resembles them, . . .” (p. 261)  If a system that is assumed [or promoted] to be safe has a crisis, even a local one, the result is often panic. (p. 62)

He mentions high reliability organizations (HROs) focusing on their avoiding catastrophe and “being a little bit scared all of the time.” (p. 242)  He does not mention that some of the same systemic factors of the financial system are at work in the world of HROs, including exposure to the corrosive effects of complacency and system drift. (p. 242)

Bottom line: Read Foolproof if you have an interest in an intelligible assessment of the financial crisis.  And remember: “Fear serves a purpose: it keeps us out of trouble.” (p. 19)  “. . . but it can keep us from taking risks that could make us better off.” (p. 159)


*  G. Ip, Foolproof (New York: Little, Brown, 2015).  Ip is a finance and economics journalist, currently with the Wall Street Journal and previously with The Economist.

**  He quotes a great quip from Larry Summers: “Complacency is a self-denying prophecy.”  Ip adds, “If everyone worried about complacency, no one would succumb to it.” (p.263)

Cultural Tidbits from McKinsey

We spent a little time poking around the McKinsey* website looking for items that could be related to safety culture and found a couple.  They do not provide any major insights but they do spur us to think of some questions for you to ponder about your own organization.

One article discussed organizational redesign** and provided a list of recommended rules, including establishing metrics that show if success is being achieved.  Following is one such metric.

“One utility business decided that the key metric for its efficiency-driven redesign was the cost of management labor as a proportion of total expenditures on labor.  Early on, the company realized that the root cause of its slow decision-making culture and high cost structure had been the combination of excessive management layers and small spans of control.  Reviewing the measurement across business units and at the enterprise level became a key agenda item at monthly leadership meetings.” (p. 107)

What percent of total labor dollars does your organization spend on “management”?  Could your organization’s decision making be speeded up without sacrificing quality or safety?  Would your organization rather have the “right” decision (even if it takes a long time to develop) or no decision at all rather than risk announcing a “wrong” one?

A second article discussed management actions to create a longer view among employees,*** including clearly identifying and prioritizing organizational values.  Following is an example of action related to values.

“The pilots of one Middle East–based airline frequently write incident reports that candidly raise concerns, questions, and observations about potential hazards.  The reports are anonymous and circulate internally, so that pilots can learn from one another and improve—say, in handling a particularly tricky approach at an airport or dealing with a safety procedure.  The resulting conversations reinforce the safety culture of this airline and the high value it places on collaboration.  Moreover, by making sure that the reporting structures aren’t punitive, the airline’s executives get better information and can focus their attention where it’s most needed.”

How do your operators and other professionals share experiences and learning opportunities among themselves at your site?  How about throughout your fleet?  Does documenting anything that might be construed as weakness require management review or approval?  Is management (or the overall organization) so fearful of such information being seen by regulators or the public, or discovered by lawyers, that the information is effectively suppressed?  Is your organization paranoid or just applying good business sense?  Do you have a culture that would pass muster as “just”?

Our Perspective

Useful nuggets on management or culture are where you find them.  Others’ experiences can stimulate questions; the answers can help you better understand local organizational phenomena, align your efforts with the company’s needs and build your professional career.


*  McKinsey & Company is a worldwide management consulting firm.

**  S. Aronowitz et al, “Getting organizational redesign right,” McKinsey Quarterly, no. 3 (2015), pp. 99-109.

***  T. Gibbs et al, “Encouraging your people to take the long view,” McKinsey Quarterly (Sept. 2012).

IAEA International Conference on Operational Safety, including Safety Culture

IAEA Building

Back in June, the International Atomic Energy Agency (IAEA) hosted an International Conference on Operational Safety.*  Conference sessions covered Peer Reviews, Corporate Management, Post-Fukushima Improvements, Operating Experience, Leadership and Safety Culture and Long Term Operation.  Later, the IAEA published a summary of conference highlights, including conclusions in the session areas.**  It reported the following with respect to safety culture (SC):

“No organization works in isolation: the safety culture of the operator is influenced by the safety culture of the regulator and vice versa. Everything the regulator says or does not say has an effect on the operator. The national institutions and other cultural factors affect the regulatory framework. Corporate leadership is integral to achieving and improving safety culture, the challenge here is that regulators are not always allowed to conduct oversight at the corporate management level.”

Whoa!  This is an example of the kind of systemic thinking that we have been preaching for years.  We wondered who said that so we reviewed all the SC presentations looking for clues.  Perhaps not surprisingly, it was a bit like gold-mining: one has to crush a lot of ore to find a nugget.

Most of the ore for the quote was provided by a SC panelist who was not one of the SC speakers but a Swiss nuclear regulator (and the only regulator mentioned in the SC session program).  Her slide bullets included “The regulatory body needs to take different perspectives on SC: SC as an oversight issue, impact of oversight on licensees’ SC, the regulatory body’s own SC, [and] Self-reflection on its own SC.”  Good advice to regulators everywhere.

As far as we can tell, no presenter made the point that regulators seldom have the authority to oversee corporate management; perhaps that arose during the subsequent discussion.

SC Presentations

The SC presentations contained hearty, although standard fare.  A couple were possibly more revealing, which we’ll highlight later.

The German, Japanese and United Kingdom presentations reviewed their respective SC improvement plans.  In general these plans are focused on specific issues identified during methodical diagnostic investigations.  The plan for the German Philippsburg plant focuses on specific management responsibilities, personnel attitudes and conduct at all hierarchy levels, and communications.  The Japanese plan concentrates on continued recovery from the Fukushima disaster.  TEPCO company-wide issues include Safety awareness, Engineering capability and Communication ability.  The slides included a good system dynamics-type model.  At EDF’s Heysham 2 in the UK, the interventions are aimed at improving management (leadership, decision-making), trust (just culture) and organizational learning.  As a French operator of a UK plant, EDF recognizes they must tune interventions to the local organization’s core values and beliefs.

The United Arab Emirates presentation described a model for their new nuclear organization; the values, traits and attributes come right out of established industry SC guidelines.

The Entergy presenter parroted the NRC/INPO party line on SC definition, leadership responsibility, traits, attributes and myriad supporting activities.  It’s interesting to hear such bold talk from an SC-challenged organization.  Maybe INPO or the NRC “encouraged” him to present at the conference.  (The NRC is not shy about getting licensees with SC issues to attend the Regulatory Information Conference and confess their sins.)

The Russian presentation consisted of a laundry list of SC improvement activities focused on leadership, personnel reliability, observation and cross-cultural factors (for Hanhikivi 1 in Finland).  It was all top-down.  There was nothing about empowering or taking advantage of individuals’ knowledge or experience.  You can make your own inferences.

Management Presentations

We also reviewed the Management sessions for further clues.  All the operator presenters were European and they had similar structures, with “independent” safety performance advisory groups at the plant, fleet and corporate levels.  They all appeared to focus on programmatic strengths and weaknesses in the safety performance area.  There was no indication any of the groups opined on management performance.  The INPO presenter noted that SC is included in every plant and corporate evaluation and SC issues are highlighted in the INPO Executive Summary to a CEO.

Our Perspective

The IAEA press release writer did a good job of finding appealing highlights to emphasize.  The actual presentations were more ordinary and about what you’d expect from anything involving IAEA: build the community, try to not offend anyone.  For example, the IAEA SC presentation stressed the value in developing a common international SC language but acknowledged that different industry players and countries can have their own specific needs.

Bottom line: Read the summary and go to the conference materials if something piques your interest—but keep your expectations modest.


*  International Atomic Energy Agency, International Conference on Operational Safety, June 23-26, 2015, Vienna.

**  IAEA press release, “Nuclear Safety is a Continuum, not a Final Destination” (July 3, 2015).

Training Materials for Teaching NRC Personnel about Safety Culture

This is a companion piece to our Aug. 24, 2015 post on how the NRC effectively regulates licensee safety culture (SC) in the absence of any formal SC regulations.  This post summarizes a set of NRC slides* for training inspectors on SC basics and how to integrate SC information and observations into inspection reports.

The slides begin with an overview of SC, material you’ve seen countless times.  It includes the Chernobyl and Davis-Besse events, the Schein tri-level model and a timeline of SC-related activities at the NRC.

The bulk of the presentation shows how SC is related to and incorporated in the Reactor Oversight Process (ROP).  The starting point is the NRC SC Policy Statement, followed by the Common Language Initiative** which defined 10 SC traits.  The traits are connected to the ROP using 23 SC aspects.  Aspects are “the important characteristics of safety culture which are observable to the NRC staff during inspection and assessment of licensee performance” (p. 13)  Each SC aspect is associated with one of the ROP’s 3 cross-cutting areas: Human Performance (14 aspects), Problem Identification and Resolution (6 aspects) and Safety Conscious Work Environment (3 aspects).  During supplemental and reactive inspections there are an additional 12 SC aspects to be considered.  Each aspect has associated artifacts that indicate the aspect’s presence or absence.  SC aspects can contribute to a cross-cutting theme or, in more serious cases, a substantive cross-cutting issue (SCCI).***

The integration of SC findings into inspection reports is covered in NRC Inspection Manual Chapter 0612 and NINE different NRC Inspection Procedures (IPs). (p. 30)  In practice, the logic chain between a SC aspect and an inspection report is the reverse of the description in the preceding paragraph.  The creation of an inspection report starts with a finding followed by a search for a related SC cross-cutting aspect.  Each finding has one most significant cause and the inspectors should “find the aspect that describes licensee performance that would have prevented or precluded the performance deficiency represented by that cause.” (p. 33)

Our Perspective

This is important stuff.  When NRC inspectors are huddled in their bunker evaluating their data and observations after reviewing your documentation, crawling around your plant and talking with your people, the information in these slides provides the road map for their determination of how one or more alleged SC deficiencies contributed to a performance problem which resulted in an inspection finding.

Think of the SC aspects as pegs on which the inspectors can hang their observations to beef up their theory of why a problem occurred. Under routine conditions, there are 23 pegs; under more stringent inspections, there are 35 pegs.  That’s a lot of pegs and none of them is trivial which means your organization’s response may consume sizable resources.

We’ll finish with a more cheery thought:  If you get to the point where the NRC is going to conduct an independent assessment of your SC, their team will follow the guidance in IP 95003.  But don’t worry about their competence, “IP 95003 inspection teams will receive "just-in-time" training before performing the inspection.” (p. 43)

Bottom line: If it looks like controlling oversight behavior and quacks like a bureaucrat, then it probably is de facto regulation.


*  NRC Training Slides, “Safety Culture Reactor Oversight Process Training” (July 10, 2015).  ADAMS ML15191A253.  The slides include other material, e.g., a summary of the conditions under which the NRC can “request” a licensee to perform a SC assessment, a set of case studies and sample test questions for trainees.

**  The Common Language Initiative led to NUREG-2165, “Safety Culture Common Language” which was published in early 2014 and we reviewed on April 6, 2014.

***  There are some complicated decision rules for determining when a problem is a substantive cross-cutting issue and these are worth reviewing on pp. 27-28.

Notes on Regulatory Capture

NRC Public Meeting

A couple of recent local news items discuss a too-cozy relationship between regulators and the supposedly regulated, to the detriment of ratepayers and ordinary citizens.  Neither is nuclear-related but they may give us some ideas on how regulatory capture might (or does) manifest in the nuclear industry.

PG&E and the CPUC

First up is an article* about Pacific Gas and Electric Co. (PG&E) and the California Public Utilities Commission (CPUC).  PG&E is responsible for the deadly 2010 gas main explosion in San Bruno, CA.  It was later revealed that PG&E was involved in private, i.e., secret, lobbying to get the CPUC judge it wanted to handle the case.  An as investigation later concluded, such ex parte discussions gives the utilities an advantage over other participants in the regulatory process.

The article concentrates on remedial legislation working its way through the system.  One bill would close the loophole that allows secret meetings between the CPUC and a regulated entity under certain conditions.  Another would create an independent inspector general for the agency.

Berkeley Zoning Adjustment Board 

This editorial** focuses on a city zoning board that is stuffed with members whose background is in the development industry.  It quotes at length local resident James McFadden who has some excellent observations about the nature of regulatory capture in this situation.

“Although many people are quick to assume that capture means corruption, they really are different things.

“Capture is more of an aligning of economic world views, not necessarily to any monetary advantage, often just to make one's job easier or more pleasant in dealing with people on a day to day basis . . . .

“Captured individuals . . . don't see their behavior as incorrect.  They have forgotten that their role is to provide oversight and protection to the public . . . Their public meetings evolve into patronizing facades of democracy.

“. . . For the most part, capture is about creating a pleasant working environment with those in industry who they deal with on a daily basis.  It is a slow and insidious process that strikes at the heart of human psychology which allows us to work in groups. . . . When we-the-public show up and complain, we become the opponent to be ignored.

“. . . The [public] meeting becomes a dance of false empowerment where getting through the meeting on time is more important than focusing on important issues or input from the public.”

Our Perspective

Do you see any of the above behavior in the nuclear industry?  Here’s a clue to get you started: the mental model for all federally regulated or controlled activities, viz., the infamous “iron triangle” of special interests, Congress and federal bureaucrats.  In the nuclear space, utility lobbyists and industry organizations encourage/pressure Congress for favorable treatment in exchange for support at election time.  Congress leans on the NRC when job losses are threatened because of a lengthy plant shutdown or costly “over regulation.”  The NRC listens to or cooperates with industry “experts” when it is considering new policies, regulations or interpretations.  We believe the iron triangle is alive and well in the nuclear industry but is nowhere near as scurrilous as, say, the welfare system.

(Now the anti-nukes also lobby Congress and certain members of Congress are relentless critics of the NRC.  Do the scales balance?  And where does the clash of lobbying titans leave Joe Citizen?)

Expanding on one side of the triangle, nuclear utilities make efforts to build organizational, professional and personal relationships with the NRC because it’s in their direct economic interest to do so.  In the other direction, don’t NRC personnel try to get along with utility people they see on a regular basis?  Who wants to alienate everybody all the time?  The NRC tries to avoid being too cozy with the utilities but they can’t completely avoid it.  They are in the same business and speak the same language.  However, it’s far from scandalous, like the relationship between the former Minerals Management Service and the offshore drilling industry.  And there is no overactive revolving door between the NRC and industry.

What about outsiders who try to influence policy?  At the top, gadflies who address agency-wide issues or work with HQ personnel may eventually get a seat at the table.  But in the field, Jane Citizen making a statement at a meeting concerning the local plant probably doesn’t have as much leverage.  Consider how difficult it is for the average whistleblower to have an impact.

The Wikipedia entry on regulatory capture cites Princeton professor Frank von Hippel, Barack Obama, Joe Biden, Greenpeace, the Union of Concerned Scientists and the Associated Press to support the position that the NRC has been “captured.”  Has the NRC been too accommodating to the industry?  You be the judge.

There is an old saying: “Familiarity breeds contempt.”  That’s true in some cases.  In other situations, familiarity breeds—greater familiarity.


*  J. Van Derbeken, “CPUC reform bills on governor’s desk,” San Francisco Chronicle (Sept. 15, 2015).  Questionable conduct flowed both ways.  It also came to light that the then-President of the CPUC appeared to offer his support for PG&E’s (and other utilities’) positions on regulatory cases in return for their contributions to his favorite political causes.  That’s called influence peddling.

**  B. O'Malley, “Berkeley's Zoning Board Slouches Toward Birthing Its Monster,” Berkeley Daily Planet (Sept. 13, 2015).  The Daily Planet is an online progressive (lefty) newspaper in Berkeley, CA.