A friend on Facebook differed with a statement on unswerving compliance with regulation that I had made in yesterday's post and that necessitated a revision. The conversation we had is reproduced below for the reader's benefit. My friend is correct. I should have explained that I hate hearing the statement, "We're gonna' push back on the Regulator because we know better." Can't you hear the egotistical arrogant pride in that declaration? Now should we have regulations changed that are frankly stupid and out of date? You bet, and as you will see from reading below, there are sadly plenty of them! But you don't get to defy the Regulator with that arrogant hubris which so often typifies today's genius liberal progressive feminist graduates from Academia in the northeast and on the left coast. There is a process for changing regulation, and if that means going to your senator and congressman and following the process available in a free Republic, then do so. That's your civic duty. But you don't get to defy lawful authority, and like it or not, the US NRC is lawful authority when it comes to commercial nuclear energy. 1st Peter 2:13-17 says the following, and this was written when an evil Emperor - Nero Claudius Caesar Augustus Germanicus - was on the throne persecuting Christians throughout the Empire (for those who think Donald Trump is bad, he's got nothing on Nero):
13 Be subject for the Lord’s sake to every human institution, whether it be to the emperor as supreme, 14 or to governors as sent by him to punish those who do wrong and to praise those who do right. 15 For it is God’s will that by doing right you should put to silence the ignorance of foolish men. 16 Live as free men, yet without using your freedom as a pretext for evil; but live as servants of God. 17 Honor all men. Love the brotherhood. Fear God. Honor the emperor.
Now without further delay here is the conversation that my friend and I had.
FRIEND
Working in the industry “requires unswerving compliance with regulation”? I beg to differ.
If the deterministic regulatory model continues to be adopted (lack of attrition in the Staff demonstrates this to be so), then the industry will never compete with the rest of the power industry which either has little to no regulation, or which works to the risk-informed, performance-based model of functional safety. I think the higher-ups at the NRC understand the traps with this mode of thinking, but because you cannot get rid of a government employee without a simultaneous act of God and Congress, their hands are tied to the consistency with the poor standards promulgated by the IEEE, whose focus on personnel protection from the hazards of electricity, but whose consistent understanding of functionality I find sorely lacking.
Even if the NRC has influence over the IEEE committee standards, they are one lone voice on the respective committees... and I have found the understanding of functional safety and of modeling the real world to be sorely lacking from the balance of committees. What good is it that standards dictate a design, rather than a design process? Such standards need to be dumped in favor of letting the engineering process itself be conducted in conformance with its consensus standard. It is only when standards are adopted as consensus with the rest of the industry that the regulatory playing field will be leveled, and the diverse energy sources can truly compete with each other.
MYSELF
You have a valid point. I should reword my statement. I should have said that you don't get to disobediently thumb your nose at the regulations, and if they're wrong, then there is a process for changing them. But many are based on decades of experience where people screwed up and the Regulator responded. But these millennial must stop being ego-driven know-it-alls exempt from Regulatory compliance. Otherwise, good point.
FRIEND
I completely agree to your point above, my friend — “that’s the way we’ve always done it” has never flown well with me when the logic to why we’ve always done it this way has severe flaws to it. Unfortunately, revising the regulatory framework will take years. Has the Staff/Commission followed up on that revision to the regulatory framework since 2016? I’ve been badly out of touch since I’ve been working on building plants for other industries.
MYSELF
The NRC us a glacier immune to global warming. The Reg Framework revision typifies glacial pace of improvement.
FRIEND
In other words, IEEE 603-2018 will be 10-15 years old by the time they reject endorsement of that standard, and those who were born in the year of the endorsed standard (1991) will be approaching their 40’s.
MYSELF
IEEE std 1008-1987 endorsed in RG-1.170 was around when you were a child and I was a nuke newbee.
FRIEND
Truth. There are standards with 30 years of industry experience which need to be accounted for.
Working in the industry “requires unswerving compliance with regulation”? I beg to differ.
If the deterministic regulatory model continues to be adopted (lack of attrition in the Staff demonstrates this to be so), then the industry will never compete with the rest of the power industry which either has little to no regulation, or which works to the risk-informed, performance-based model of functional safety. I think the higher-ups at the NRC understand the traps with this mode of thinking, but because you cannot get rid of a government employee without a simultaneous act of God and Congress, their hands are tied to the consistency with the poor standards promulgated by the IEEE, whose focus on personnel protection from the hazards of electricity, but whose consistent understanding of functionality I find sorely lacking.
Even if the NRC has influence over the IEEE committee standards, they are one lone voice on the respective committees... and I have found the understanding of functional safety and of modeling the real world to be sorely lacking from the balance of committees. What good is it that standards dictate a design, rather than a design process? Such standards need to be dumped in favor of letting the engineering process itself be conducted in conformance with its consensus standard. It is only when standards are adopted as consensus with the rest of the industry that the regulatory playing field will be leveled, and the diverse energy sources can truly compete with each other.
MYSELF
You have a valid point. I should reword my statement. I should have said that you don't get to disobediently thumb your nose at the regulations, and if they're wrong, then there is a process for changing them. But many are based on decades of experience where people screwed up and the Regulator responded. But these millennial must stop being ego-driven know-it-alls exempt from Regulatory compliance. Otherwise, good point.
FRIEND
I completely agree to your point above, my friend — “that’s the way we’ve always done it” has never flown well with me when the logic to why we’ve always done it this way has severe flaws to it. Unfortunately, revising the regulatory framework will take years. Has the Staff/Commission followed up on that revision to the regulatory framework since 2016? I’ve been badly out of touch since I’ve been working on building plants for other industries.
MYSELF
The NRC us a glacier immune to global warming. The Reg Framework revision typifies glacial pace of improvement.
In other words, IEEE 603-2018 will be 10-15 years old by the time they reject endorsement of that standard, and those who were born in the year of the endorsed standard (1991) will be approaching their 40’s.
IEEE std 1008-1987 endorsed in RG-1.170 was around when you were a child and I was a nuke newbee.
FRIEND
Truth. There are standards with 30 years of industry experience which need to be accounted for.
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