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Revitalizing Nuclear Safety Research (1986)

Chapter: Eliminating Barriers to an Effective Program of Nuclear Safety Research

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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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Suggested Citation:"Eliminating Barriers to an Effective Program of Nuclear Safety Research." National Research Council. 1986. Revitalizing Nuclear Safety Research. Washington, DC: The National Academies Press. doi: 10.17226/18442.
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4 Eliminating Barriers to an Effective Program of Nuclear Safety Research The previous chapters of this report explain why nuclear safety research is needed, identify principles for determining who should fund, who should conduct, and who should set the research agenda, and show how those principles might be applied in organizing the nation's future program of safety research. This chapter identifies barriers to an effective program of nuclear safety research that exist within the NRC and in its relations with OMB and the Congress, and it recommends steps that the committee believes must be taken to eliminate the barriers. Most of the committee's recommendations can be imple- mented by administrative changes within the NRC, without any outside action. Some require the support of Congress and the administration. It is hoped that this report will provide the justi- fication for these long overdue administrative reforms. The U.S. nuclear safety research program is widely perceived to be in trouble. This view is based not only on the planned closing of all U.S. facilities for large-scale experimental research related to current commercial reactors and the steadily decreasing budget of the NRC, but also on the increasing difficulty the NRC has in explaining the value of its research program to OMB and to the Congress. The committee has not tried to determine and does not know what the right amount is for nuclear safety research. However, the committee does know that, while stable funding is important, stable funding alone will not produce an effective re- search program. An important source of the problems alluded to 43

44 throughout this report is the management practices and structure of the NRC (see Figure 1). Until the NRC's management prob- lems are addressed, there will be little basis for determining what level of support is the one at which funding should be stabilized. Even though the committee was not in a position to address the question of the "right" dollar amount for the NRC research pro- gram, it strongly believes that whatever the appropriate amount may be, more real value will be attained for each dollar spent on nuclear safety research if the reforms recommended below are implemented. Needless to say, administering a multimillion dollar program of safety research is a formidable challenge. The director of re- search at the NRC is responsible for a staff of more than 200 professionals and for managing a range of activities involving lit- erally hundreds of different participants and organizations. The director is responsible for the following: • Staffing the program (devising and implementing guide- lines and incentives that can be used successfully to recruit and develop a competent and dedicated staff of public ser- vants who are interested in and capable of planning, con- tracting, and communicating the safety research program) • Designing the program (coordinating with users and other research sponsors to set a research agenda that implements a sound safety philosophy) and following through (working with other NRC offices to ensure that the results of research are appropriately used) • Contracting for the research (establishing a process that employs the best available procedures for identifying, hir- ing, and retaining the services of the most qualified re- searchers) • Communicating and securing support for the program (ne- gotiating the scope and direction of the program with the commissioners, the OMB, and the Congress, and explain- ing and justifying the program to the public) The remainder of this chapter looks at nuclear safety research at the NRC from the perspective of the management responsi- bilities of the NRC director of research, the executive director of operations, and the Commission. It identifies a number of man- agement problems that prevent the NRC program from being fully

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46 effective, and it makes recommendations that the committee be- lieves could lead to a more effective program of nuclear safety research. STAFFING THE SAFETY RESEARCH PROGRAM During the last decade some very good work has come out of the NRC research program. Nonetheless, over the same period of time there has been a continuing erosion of research competence within the Office of Research, an erosion that seems to have ac- celerated after the 1981 merger of the Office of Research with the Office of Standards Development. Information presented to the committee indicated that fewer and fewer of the senior NRC re- search staff are experienced in actually doing research, as defined in this report, and that the recruiting of truly first-rate researchers may have become even more difficult for the NRC than for other federal agencies. The committee therefore recommends: 1. The NRC should bring in some high-caliber people with active research experience to bolster top and middle management of the Office of Research. The committee recognizes how difficult this may be. Lack of widespread public support for nuclear power raises the level of uncertainty about career prospects within the field and reduces the pool of prospective researchers and research managers. In im- plementing this recommendation, it would clearly be preferable if the NRC could attract experienced researchers who were willing to make long-term commitments to the agency. One potentially beneficial (albeit unintended) side-effect of the downward trend of funding for nuclear safety research is that it may have made avail- able qualified researchers for agency employment. Nevertheless, experienced researchers may not be willing to make commitments to the NRC. Because the need for experienced research managers is so great, the agency should consider hiring experienced re- searchers even if they are available only for short-term (two-year) leaves of absence from permanent positions elsewhere in or outside the federal government. In 1980 the Commission combined the Offices of Research and Standards Development under the then standards director. Over the ensuing period the research manager positions have been

47 gradually filled by former members of the standards staff. The original intent of the merger was to provide a better transition from research result to effective regulation. Unfortunately, the result has been more for regulatory formalism to displace technical competence and experience in the management of the research and thereby to diminish the effectiveness of the program. The committee recommends: 2. The NRC should consider separating the functions of stan- dards development and research. The committee acknowledges that there could be some disrup- tion as a result of such a change. However, the committee judges that on balance the price may be worth paying. DESIGNING THE SAFETY RESEARCH PROGRAM AND FOLLOWING THROUGH Designing a program of nuclear safety research is necessarily a complicated, ceaseless, evolutionary process with a number of cen- tral features. The program should be designed through a process that includes the following: • establishing a research philosophy, • developing and implementing long-range strategies, • setting near-term priorities, and • coordinating with others in the design and use of the pro- gram. The last of these is as critical as the other three. To design an effective program, the Office of Research must consult with users of research both inside and outside the agency, including in the former case the Office of Nuclear Reactor Regulation and the commissioners. Coordinating with these various parties is especially important in the design of the program because it is only through this process that the agency's research philosophy, long-range goals, and research priorities can be integrated into a cohesive program. It is at this step in the process that the program will succeed or fail to achieve direction. Establishing a Research Philosophy A program of safety research cannot be properly designed without a research philosophy that supports the mission of the

48 agency to guide it. Yet the current NRC research program ap- pears to lack such a philosophy. Developing such a philosophy is a difficult undertaking, but it is one of the primary responsibilities of the Commission. There cannot be five separate philosophies for the agency, one for each commissioner, without wreaking havoc on the research program. The program requires a consensus philoso- phy that gives direction to research planning, and that provides a framework on which the program can be built, guidelines for es- tablishing priorities and focusing the research effort, and criteria with which to assess whether a given area of research is continuing to serve a useful purpose. For these reasons the committee recommends: 3. The NRC should develop a cogent research philosophy that can be used to direct and assess the effectiveness of the safety research program. If the Commission is unable to reach agreement on a research philosophy, then the chairman must develop one on his or her own. An appropriate philosophy of safety research would make clear that the agency has a commitment both to the continuing review of knowledge gained from operating reactors and from ongoing research and to the revision of existing safety regulations in light of that experience. An example of one of the benefits of having a research philos- ophy is that such a philosophy would make clear what organizing principle or principles are being used to construct the program of research, for example, what determines the balance between re- search on accident prevention and research on accident mitigation. While at a policy level the Commission and Congress need to determine how safe is safe enough, at the research level the philos- ophy must be that sufficient information is available to assure that policy decisions are made on the basis of the best available knowl- edge. Thus, research that is wholly focused on supporting existing or proposed regulations would too narrowly circumscribe the re- search mission by ignoring the broader need to acquire knowledge to identify and anticipate the unexpected. Similarly, research that tends to challenge existing wisdom about nuclear plants— either suggesting the need for more or less regulation—cannot be restricted or kept from the public eye merely because such infor- mation may be used by others to urge the Commission to alter its regulations or otherwise change its view of how safe is safe enough.

49 In the fullest sense a sound research program is apolitical and must be committed to the principle of full and complete information. Once such a philosophy is established, the research program can and should rise above the political fray. Developing and Implementing Long-Range Strategies Each year since 1981 the Office of Research has issued a long- range plan. Previously the office occasionally issued planning doc- uments as part of the so-called "Rainbow series" of regulatory activity reports. The principal function that the current long- range plan seems to serve is simply to force interaction between the Office of Research, the other user offices, and the ACRS. Some coordination occurs because of the existence of this mechanism, but it seems almost incidental to the plan itself. The NRC long- range plan is not really a plan so much as a description of current projects. So although many "long-range plans" have been written, there is little long-range planning. (This happens to be true not only at the NRC but within the federal government as a whole.) The purpose of long-range planning ought to be to instill in the en- tire program a sense of its long-range strategies for implementing the agency's research philosophy. It should clarify the connection between the research philosophy and the various elements of the annual budget, but it has no value if it does nothing more than re- count what that budget consists of. In fact, the process is likely to be more important than whatever plan may emerge from it. The point of the exercise is to engender a discussion of the connection between the organizing principle(s) for research and the structure of the future program. For these reasons the committee recommends: 4. The NRC should establish a research program planning process involving all of the relevant offices within the NRC, as well as representatives from industry and the university research com- munity acting as participating advisors. The line responsibility for planning should rest with the director of research. The resulting process can be used to deal with some of the prob- lems discussed below concerning coordination with the user com- munity and other sponsors of research.

50 Setting Priorities (Developing an Annual Budget) The fact that there is virtually no human factors research within the current annual budget of the Office of Research, in spite of the clear indication that research in this area is vital to assuring the safety of operating reactors, indicates that something is seriously wrong with the way the agency goes about structur- ing its program and setting its budget priorities. As noted above, the current process shows little indication of being connected to either a research philosophy or a long-range strategy of research. The annual review of the budget ought to be logically related to a long-range strategy for implementing the research philoso- phy. Effective management of the overall program and effective planning of the annual budget require that the Office of Research review the logic of specific program elements. This should be ac- complished through a process that involves interacting with four different groups: the user community within the agency (includ- ing the other program offices, the Advisory Committee on Reactor Safeguards, and the commissioners); other sponsors of research; an independent group of expert advisors to the Office of Research; and the oversight bodies within the executive branch and the Congress. The annual program that emerges from these interac- tions should be consistent with the agency's long-range strategy for implementing its research philosophy, and it should reflect a consensus on the appropriate priorities for achieving the objectives embedded in that philosophy. There are important management issues that must be addressed in order to establish proper work- ing relationships between the Office of Research and these four groups. The health of these relationships is vital to the health of the research program as a whole. Coordinating with the User Community In the present context, the user community includes the other program offices (Office of Nuclear Reactor Regulation, Inspec- tion and Enforcement, Nuclear Materials Safety and Safeguards), the Advisory Committee on Reactor Safeguards (ACRS), and the commissioners. Unless there is a strong working relationship be- tween the Office of Research, on the one hand, and these other bodies on the other, particularly between the Office of Research and the commissioners, there is little reasonable chance of having a sound research program. A strong working relationship must be

51 developed and sustained in both the planning and the use of the research program. Coordinating with Other NRC Program Offices. Coordinating with the other program offices, particularly with the Office of Nuclear Reactor Regulation (NRR), serves two important functions: to communicate the results of research to those who need it and to refine the design of the program in order to take into account the needs of the user community. Although the existing relationship between the Office of Re- search and NRR may be formally correct, with formalized ar- rangements for interoffice concurrence, the transmission of user request memoranda, and the distribution of research reports, in reality there is insufficient substantive interaction at the level and with the continuity and intensity that is needed for a used and useful research program. In fact, there seems to be little interest in or understanding of the existing research program outside of the Office of Research. In principle, the results of NRC research should be used in regulation, and most (but importantly not all) research should be aimed at solving present or anticipated regulatory problems. This requires a close working relationship between NRR and the Office of Research. However, as noted above, the Office of Research and NRR do not work together effectively, merely formally. The view from NRR is that although the Office of Research sponsors a lot of work, it does little to integrate the results of that research. It does not package it in a form that is useful to NRR or that brings home the significance of the work to the potential user. Research Information Letters (RILs) are supposed to serve this function and are still being written by the Office of Research, but apparently these are either unread or not useful. In any case, while formal synthesis documents have a place, they cannot substitute for continuing dialogues about the evolving plans for and results of the research program. The view from outside the agency is equally critical. The national laboratories complain that not enough integration occurs between NRR and the Office of Research. The industry often appears to be confused by the constant turf battles between the Office of Research and NRR. There is a natural tension between managers of research and those who regulate; it is a variety of the traditional tension between

52 researchers and those charged with applying research. However, what the committee found goes well beyond that and reflects a serious problem within the agency in the management of the relationship between agency users and the Office of Research. In an effective working relationship, the potential users respect the role of the researchers as technical critics, and the user community is intensely involved in setting the research agenda. It is important to note that the NRC needs both formal and informal mechanisms to involve regulators in setting the research agenda, to coordinate research undertaken by the Office of Reseach and technical assistance undertaken by NRR, and to encourage face-to-face discussions of NRR's needs and the Office of Research's programs and results. NRR must have enough competence to understand the technical information available from the Office of Research; and both parties must work together to understand how research results should be applied. What the committee has in mind is a process in which staff at the branch level in NRR and in the Office of Research regularly (at least weekly) meet for an hour or two to informally exchange information about what is happening in each other's areas of responsibility. Each must be able to understand the basic substance and keep track of the progress of the other's work. It is only through this type of constant communication and discussion that some technical transfer takes place; and it is only through such contact that the regulator can effectively assist in setting the research agenda. The committee recommends: 5. The executive director of operations should ensure that much more face-to-face discussion occurs among the NRC program offices at the branch level concerning the philosophy and content of the research program. Utilization of the products of the research program would be facil- itated if NRC initiated a practice of drafting interoffice documents on regulatory issues, with the Office of Research actively partici- pating. These reports should summarize what is known about a particular question and what research is still needed and why. The purpose of these reports would be to assist standard setting and regulation by reaching conclusions on open issues. In addition, these documents would provide guidance to the future research program. Hence, the committee recommends:

53 6. The NRC should adopt the practice of producing interof- fice documents that summarize what is known and what research is still needed, and that reach conclusions about regulatory is- sues. The Office of Research should play an active part in the preparation of such documents. Coordinating with the Advisory Committee on Reactor Safeguards. Because the Advisory Committee on Reactor Safeguards (ACRS) has a statutory role in reviewing applications for nuclear power plant licenses, its institutional relationship to the Office of Re- search is that of a user office. Congress has intervened in that relationship for the apparent purpose of using the ACRS as an independent research advisory group. Thus for the last five years the ACRS has been formally responsible for evaluating the NRC research program on an annual basis and providing comments on the program both to the Commission and to the Congress. In order to conduct these reviews the ACRS established a subcom- mittee that annually hears from members of the research staff. These hearings form the principal bases of the ACRS report. The ACRS reviews have had no apparent impact, and Congress no longer seems to use them. The ACRS has itself asked Congress to relieve it of the obligation to continue to provide them. In the past, the ACRS role was less formal; it simply provided whatever comments it had on the research program whenever it saw fit. Congress should understand that because ACRS is constituted to review license applications it is not properly structured to serve as an independent research advisory group. Active licensee rep- resentatives should, however, be part of such a group; although precluded by Commission policy from serving on the ACRS, they can be valuable participants as major users and performers of research. The committee recommends: 7. The Congress should relieve the ACRS of any formal re- quirement to review the safety research program. Nonetheless, the ACRS contains a substantial amount of expertise on nuclear safety and the Office of Research should continue to coordinate informally with the ACRS or a designated ACRS sub- committee in designing the research program. As research issues arise in the course of reviewing license applications, the ACRS should continue to recommend appropriate avenues of research

54 to the NRC chairman, and the chairman should ensure that the Office of Research gives them serious consideration. Coordinating with the Commissioners. It would come as a surprise to almost anyone who was unfamiliar with the management of the NRC how little coordination occurs between the Office of Research and the putative head of the agency, the Commission. In theory the five commissioners manage the agency and the agency staff, yet in practice they do little policy formulation, program planning, or staff guidance and do not appear to understand the program as it now exists. This is one of the principal reasons why the research program lacks adequate direction. It became obvious to the committee that the issue of manag- ing safety research is really part of the larger issue of managing the agency. Establishing a research philosophy for planning research, identifying and correcting weaknesses in research management, holding the research director accountable—these are basic func- tions of the head of any agency that conducts research. Yet the commissioners do not now provide this leadership. The structure of the Commission and the somewhat self-imposed constraints un- der which the Commission operates seem to make it impossible for it to carry out the intense, interactive, critical, and self-critical, communication with the staff, advisory groups, other research sponsors, and among the commissioners themselves that is re- quired in order to formulate, execute, and use the results of a first- rate research program. The essence of what is needed is intense, informal, sometimes combative communication—both within the agency and with those outside who can help shape the program. The current mode of operating has the effect of preventing just such communication, and thus preventing the development of a research program that makes real and obvious contributions to safety. The research management problems that the committee has found might stand a better chance of being resolved were there a single administrator with management responsibility for the NRC. The committee hastens to add, however, that it has not fully con- sidered all the ramifications of moving to a single administrator; such a step would encompass a much broader set of issues than merely how to manage research more effectively. The committee is equally aware that a single administrator would not necessarily be better; it depends on the person.

55 The committee therefore recommends: 8. Options for restructuring the NRC to restore leadership to nuclear safety research at the NRC should be reexamined. A reexamination of the kind needed is beyond the scope of the NRC, and is something for Congress and the administration to consider. Restructuring the agency in any significant way is a major step that would require congressional action. In lieu of that, and given the fact that the research program constitutes almost a third of the NRC budget, the committee recommends that the following steps be taken: 9. The NRC chairman should assign a member of his or her staff to devote full time to monitoring research, including visiting researchers, talking with the Office of Research personnel, and sitting in on all meetings devoted to research in order to keep the chairman informed. In particular, if the ACRS continues to review formally the safety research program, this person should attend all ACRS subcom- mittee and committee meetings leading up to the ACRS report on the research budget. This is essential in order to be able to interpret the ACRS report. The committee recommends: 10. The chairman should require periodic review of the status of major research projects. This will provide a mechanism for determining whether projects are completed, whether knowledge and technology should be trans- ferred to a user, or whether and what further research is needed. Finally, the committee recommends: 11. The chairman should develop an understanding of the research program and then personally defend the program before OMB and the Congress. Successful defense before OMB and the Congress requires bat- tle by a knowledgeable agency head. It cannot be delegated to subordinates. Coordinating with Sponsors and with Those Who Do Research The agency needs to coordinate its program not only with the user community within the agency but also with others who

. 56 sponsor and perform research, including the contract research community, the national laboratories, industry, DOE, and perhaps other federal agencies when appropriate. Currently there is far too little coordination or interchange between NRC and DOE in the area of nuclear safety research. However, cooperation is not just an NRC responsibility; DOE can and should do more on its own initiative. The committee recommends: 12. Both DOE and NRC should collaborate to establish insti- tutional mechanisms for periodically sharing appropriate results of their respective programs of nuclear safety research, including any applicable results from the naval reactor and defense production reactor programs. Establishing an Independent Research Advisory Group The NRC needs a formal mechanism for acquiring external advice on the philosophy, management and content of its research program. The committee therefore recommends: 13. The NRC should empanel an independent advisory group, reporting to the director of research, with expertise in the range of disciplines relevant to nuclear safety research. The group should be charged with independently reviewing for the director of research, from the perspective of the general principles cited in this report, the overall structure and thrust of the research program. The group should consist of members drawn from the contract research community (including the universities) and from industry. Involving industry increases the probability that the group will ask some tough yet important questions, including "Is the benefit worth the cost?" Involving industry will also require viewing industry as adversarial partners, rather than merely as adversaries. Selection of the membership of the advisory group should be based on scientific and engineering competence and should provide breadth of coverage across the major categories of nuclear safety research. The group should reflect a balance of views in order to minimize bias.

57 Establishing Peer Review Unless this independent research advisory group has confi- dence in the quality of the work that the agency is sponsoring, the NRC will not be able to gain the benefits that a such a group could provide. The traditional means by which the scientific and engineering communities ensure the quality of research is through peer review. The most effective mechanism is for the agency to establish independent topical peer review groups and to encourage the publication of sponsored research in peer-reviewed technical journals. Peer review would be highly beneficial even if there were no advisory group, because it would foster confidence in the products of NRC research and help maintain high standards of competence in the program. The committee therefore recommends: 14. The NRC should establish independent topical peer re- view groups and encourage the publication of sponsored research results in peer-reviewed professional publications. These indepen- dent review groups should be charged with reviewing all research products of NRC-sponsored research. Some areas of research are sufficiently complex (e.g., large-scale scientific modeling and major experiments) that it is not reason- able to expect volunteers charged with peer reviewing the work to be able to ensure quality. In such cases adequate peer review requires the provision of adequate funds to the peer reviewers. Though peer review is no panacea for the range of structural and other problems currently burdening the safety research program, lack of peer review is an obstacle to the design of a meaningful pro- gram and undermines the confidence in the research of intended users, both regulators and regulated alike. CONTRACTING FOR SAFETY RESEARCH One of the primary responsibilities of the director of research is to select researchers capable of doing a good job in performing the research that the agency needs to have done. The director must establish policies and procedures governing the contractor selection process, including procedures that permit the agency to keep track of a wide range of scientific and engineering disciplines, to know who is conducting research in various fields and to develop an awareness of their availability to the agency. The director

58 must also ensure that the office establishes a rigorous process for acquiring and factoring into the selection process independent appraisals of the quality of the work being completed by agency contractors. There are two basic characteristics of the way the NRC has tended to allocate research among potential contractors: heavy reliance on the national laboratories and minimal support of uni- versity research. Contracting with the DOE National Laboratories From 1975 to 1981 the budget for safety research at the NRC expanded fourfold (in current dollars), partly in response to the accident at Three Mile Island. But in the last five years that trend has turned around and the budget has been progressively cut to where it stands today—half of what it was in 1981. In real buying power the downturn has been even more precipitous. The reduction in funding has been accompanied by substantive changes in the overall program. Nonetheless, NRC contracting patterns have remained basically the same as they were in 1975 when the agency was formed—overwhelmingly concentrated in the national laboratories. NRC contracting has been strongly influenced by circumstances surrounding the birth of the agency; the NRC was, of course, created out of parts of the Atomic Energy Commission, which had charge over the national laboratories that conducted the bulk of the AEC's safety research. Congress precluded the newly established NRC from building its own research facilities and directed the agency to make use of ERDA's (now DOE's) national laboratories. Not surprisingly, therefore, the new NRC came to rely heavily on the national laboratories for the performance of its safety research. The committee is concerned that a valid basis for contracting nearly all of the safety research program through the national laboratories does not exist. The committee concluded that a fair competition among the national laboratories, industry, and the university research community might lead NRC to allocate a larger share of its research to private industry and to contract researchers in the universities. Hence, the committee recommends:

59 15. The NRC should create a fair and competitive process for allocating research among national laboratories, industry, and contract researchers including the universities. It is important to note that Congress made a similar request of the NRC in the past but with little effect. This is not to suggest that the national laboratories do not do high-quality work. They have made substantial contributions to nuclear reactor safety, and can continue to provide not only unique facilities for conducting safety research but a staff that in- cludes some of the most highly competent research scientists and engineers in the world. However, the NRC program's current and previous heavy reliance on these laboratories for more than 80 percent of the work does not appear to be the result of conscious decisions that all of the best people are there or that all of the most important proposals come from the laboratories. The committee concluded that NRC reliance on the laboratories has been carried over from the AEC primarily because of (1) the great ease of trans- ferring funds to federal laboratories as compared with contracting with other research institutions such as industry and the univer- sities, (2) the availability of experimental facilities and qualified research personnel, and (3) the ease of avoiding any appearance of conflict-of-interest, which might result from greater reliance upon industry. Little effort appears to have been expended by the Of- fice of Research to create a truly fair and competitive process for selecting performers of NRC research. The committee recommends: 16. The NRC should charge its contract office to develop procedures to make research contracting with organizations other than the national laboratories an easily available option, not one requiring many months of voluminous paperwork. The committee knows from its own experience that federal reg- ulations have provisions that allow research contracts to be let without using only the most cumbersome and time-consuming procedures in the federal procurement process. The contract of- fices of other major federal funders of research would be good sources of advice in identifying these provisions. The NRC is obligated to use the best contracting procedures that the Congress has made available, but it has not been doing so. In most cases the NRC responds to research proposals from uni- versity researchers by initiating formal, open competitive bidding.

60 However, industry and the universities have profoundly different organizational structures, so much so, in fact, that industry-based and university-based researchers cannot actually compete fairly against one another in competitive bidding situations. On occasion, the NRC has managed to avoid utilizing competi- tive bidding by directing university researchers to go to a particular national laboratory that has a research contract with the NRC, and in turn directing the laboratory to let a subcontract with the university researcher. This practice is of dubious legality and is resented both by the laboratories and the university research community since it turns research managers at the laboratories into middlemen and inserts an unnecessary and burdensome layer of management and bureaucracy between the university faculty member and the sponsor of the research. The NRC is currently considering ways to consolidate work at the national laboratories. In particular, the NRC has decided to consolidate thermal hydraulics research at the Idaho National Engineering Laboratory. The committee recommends that the NRC go further: 17. The NRC should conduct a careful analysis to weigh the relative costs and benefits of various options for consolidating work at the national laboratories. The plan to phase out the large experimental facilities makes con- solidation more feasible. Consolidation might have the benefit of increasing laboratory management attention on NRC programs and might provide a stronger overall corps of researchers both inside and outside the laboratories. Congress might even consider reconstituting one or more of these laboratories as a completely joint government-industry center for nuclear safety research, per- haps modeled to some extent after the Health Effects Research Institute, which is run jointly by industry and the Environmental Protection Agency. The managers of NRC programs at the various national lab- oratories seldom meet to discuss the philosophy, content, and direction of the NRC research program. This means that the laboratories have little opportunity to assist in the design of the program. The committee recommends: 18. The NRC should institute at least an annual review of the program with the principal performers of research, including but

61 not limited to representatives of the national laboratories, EPRI, and managers of other major pieces of the research program. This will help the laboratories understand where their projects fit into the program and will give the NRC the benefit of advice from knowledgeable research managers. Contracting with the Universities In the previous section the committee recommended reeval- uating the amount of reliance on the national laboratories for nuclear safety research. Industrial laboratories and other mem- bers of the contract research community have competent staffs and should be used when they are best qualified to do the work. Universities can also be relied on to do significant research. Yet in the recent past the universities have received inadequate support from the possible sources of funding for nuclear safety research— industry, DOE, the NRC, and the National Science Foundation (NSF). NSF support for nuclear engineering has been reduced to approximately half a million dollars, of which only a fraction is related to nuclear safety. NRC support for university research is a little over $3 million but this is one third what it was five years ago. As previously noted, university research has some clear bene- fits. The universities provide a source of independent thinking as well as "centers-of-excellence" in basic and exploratory research. Dedicated long-term funding of university researchers must be available to ensure retention of a corps of experienced academic researchers in basic science and engineering and to provide a train- ing ground for the future nuclear safety research professionals that will be needed to staff industrial laboratories, contract research organizations, and government agencies. The NRC has indicated that university-based research is highly cost-effective. However, the NRC apparently has had diffi- culty using the universities, in part because of the contract prob- lems discussed earlier and in part because strong links have not been sustained between the universities and the NRC. The committee recommends: 19. The NRC should request that Congress expand NRC's grant authority and then NRC should award more money to uni- versities as grants, rather than as contracts.

62 The committee also recommends: 20. The NRC should encourage and assist university faculty to do nuclear safety research at the national laboratories. Though it is already possible for university researchers to conduct research at the national laboratories, the NRC and the DOE have not encouraged researchers in the field of nuclear safety to do so. This is why university faculty seldom use the national laborato- ries for nuclear safety research, which is in marked contrast to the high-energy physics community where faculty routinely per- form experiments using federal facilities designed for high-energy physics research. Even if the recommended expansion of grant authority is not implemented, the NRC should use its existing grant authority more aggressively. The committee recommends: 21. The NRC should establish a competitive grant program, using peer review panels for selecting grant recipients. 22. The NRC should assign a staff member the task of over- seeing university research funding. DOE plans in FY 1986 to increase support for university- based nuclear research from a little over $2 million to about $6.6 million. The committee recommends: 23. The Department of Energy should ensure that a portion of its budget for university-based nuclear R&D goes to support safety research of relevance to current reactors. COMMUNICATING WITH THE OFFICE OF MANAGEMENT AND BUDGET AND WITH THE CONGRESS Once a program is designed, the agency must convince OMB and the Congress that its design is sound. A sound research program must be based on a safety research philosophy, a long- range strategy, and a set of near-term priorities, with the priorities linked to the philosophy and strategy in some transparent and meaningful way. It must also have stable funding. This does not mean a guaranteed level of funding, but it does mean sufficient funding committed over a long enough period of time to permit the

63 closure of individual program elements. Constantly changing levels of support, particularly constantly declining levels of support, cripple a research program. They undermine basic and exploratory research, which tend to get squeezed out in favor of short-term needs. And they destroy researcher and staff morale. The NRC is understandably concerned about the continuing reduction in funds for the agency generally and for nuclear safety research in particular. While the Advisory Committee on Reactor Safeguards has repeatedly warned that the continuing erosion of support is jeopardizing the viability of the safety research program, it has been unable to say what would be an appropriate level of funding for nuclear safety research. The committee finds itself in a similar position. It has received estimates from senior NRC staff ranging from the view that the current level of funding is "grossly inadequate" to the view that there probably is a little fat in the program even at current levels. The committee has concluded that it is in no position to say what the right number is or to recommend a specific amount for NRC research. The committee cannot fail to note, however, that the erosion in support for the NRC budget is in this case indicative of a much more substantial problem: the lack of meaningful communication between NRC and OMB and NRC and the Congress. The OMB and the Congress have shown little understanding of or support for the NRC program. The responsibility for this problem lies on both sides. On the one hand, the NRC program is in dire need of reform. By failing to achieve closure of safety issues and thus by denying itself the opportunity to explain fully the role of research in leading to closure, the NRC undermines congressional and administration support. The NRC's failure to use the research program properly to help close outstanding safety issues prevents the Congress and the OMB from playing a constructive role in overseeing the plan- ning and implementation of the research program. On the other side, OMB refuses to recognize the ramifications for nuclear safety research of continually cutting the NRC budget. And Congress is torn between those who want the safety research program to produce tighter constraints on the nuclear power industry and those who look to research to relax the existing regulations. The division in Congress, of course, mirrors national attitudes toward commercial nuclear power; yet merely passing these along to the NRC, without resolving them, exacerbates the agency's difficulties in establishing and maintaining an effective program of research.

64 Nuclear safety research is too important to be continually whip- sawed and debilitated by bad management and the vicissitudes of the political process. It requires competent, responsible leadership from OMB and the Congress, as well as from NRC.

Next: References and Bibliography »
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