NRC Public Comment Period
Friday, December the 6th marks the end of NRC’s public comment period exploring the role of Community Advisory Boards (CABs) and the decommissioning of commercial nuclear power plants. The Commission will then distill and synthesize comments and deliver, by July 2020, a report to Congress on best practices and lessons learned when it comes to CABs.
A review of public comments submitted to date suggests that, much like Goldilocks and the Three Bears, there are a range of opinions when it comes to CABs: some work, some do not, and a few are “just right.” Given this input, the challenge to NRC will be to define a “Just Right CAB.”
The good news is that getting to a Just Right CAB is well within the means of any set of decommissioning stakeholders (e.g., the local community, state and federal representatives and the licensee). The challenge, however, is that each Just Right CAB is unique in its composition and function. The only way to build a Just Right CAB is to include stakeholders from the very beginning. The lesson here is that process matters: How the destination is reached is as important as the final goal.
Roles, Responsibilities, and Resources
In creating a Just Right CAB, the most important issue to consider is the role the CAB will play in the decommissioning process. Is a passive advisory role desired? If so, who is being advised? Will they listen? Or, is there a call for more proactive involvement. When, where and why does “advisory” become “decision-making”?
Any discussion of roles and responsibilities quickly grows to include the availability of resources. Are board members compensated for their time? Are external experts or funds made available to the Board? If so, by whom? And under what conditions?
Recalling the process matters lesson, answers to these questions are not the purview of any one entity, be it the licensee, the host community or the state. Rather, the asking and answering of these fundamental questions is best accomplished through a collective stakeholder engagement effort grounded in collaboration and the pursuit of common goals.
Regardless of its shape and function, the success of a CAB centers on how it adds value to a decommissioning project.
Local community members are prone to perceiving CABs in a positive light. They view CABs as an avenue for meaningful input and involvement in a large project that will significantly affect their local communities. In general, however, industry tends not to share this view. This antipathy comes from the common belief that CABs do not deliver business value.
Decommissioning Project Risk Reduction
To more fully explore this dynamic, consider the two reciprocal drivers of value: (i) a decrease in the amount of a particular “bad”; and, (ii) an increase in the amount of a certain “good.” Regarding the former, business value is realized through a reduction in project risk. For example, a Just Right CAB at a decommissioning project allows for early identification of stakeholder expectations and considerations. Accordingly, cost-effective course corrections can be made resulting in timely and more efficient permitting. As a result, business risk is reduced along with schedule and cost savings.
The converse is also true: failure to meaningfully engage stakeholders increases business risk. In the decommissioning arena, one needs to look no further than the present litigation sponsored by the Attorney General of Massachusetts whose office is actively appealing the NRC’s transfer of Pilgrim’s license from Entergy to Holtec.
Improving Decommissioning Outcomes
When discussing this concept with NRC licensees, the traditional response is, “Nobody is going to tell me how to segment my reactor vessel.” But that misses the point. Decommissioning stakeholders desire input into issues that matter to them. In general, reactor vessel segmentation does not. What does matter to stakeholders are issues such as spent fuel disposition, cleanup levels, site redevelopment and the mitigation of the socioeconomic impacts from plant closure.
While some of these issues fall outside the strict scope of work required to terminate a plant’s NRC license, it is prudent to realize that all are inside stakeholders’ definition of decommissioning. The “problem” if you will, is that given the current regulatory landscape, there is no forum or opportunity for stakeholders to engage meaningfully on issues that matter to them. This is an opportunity.
By working with a Just Right CAB, stakeholders decide, based on available resources, which issues are worth addressing, along with a discussion of possible outcomes. This buy-in is an essential component. Fears of such an undertaking opening Pandora’s box are unfounded. Experience demonstrates that stakeholders value the opportunity to engage on issues that they deem meaningful. Doing so strengthens and improves decommissioning project outcomes.
CABs Are Good Business
NRC’s increased focus on CABs is a clear signal. Local stakeholders are asking for more of a say in decommissioning projects. Congress is taking notice. Savvy licensees will profit by realizing that CABs are a strategic opportunity, and not some burdensome administrative obligation. A Just Right CAB is Just Good Business.