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Meeting Regulatory Needs

Weber, Michael Fred

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doi: 10.1097/HP.0000000000000620
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Abstract

INTRODUCTION

GOOD AFTERNOON. On behalf of the U.S. Nuclear Regulatory Commission (NRC), allow me to add my greetings to this Annual Meeting of the National Council on Radiation Protection and Measurements (NCRP). It is a pleasure to be here with you in Bethesda and to focus on the topic of “Meeting the Needs of the Nation for Radiation Protection.” I thank NCRP for the opportunity to share my perspectives with you.

In addition, I also commend the NCRP for your close coordination and collaboration with the NRC. You are ably represented before the Commission by President Boice, distinguished members of the committees and subcommittees, and staff. As one of your partners in radiation protection, the NRC significantly values our close cooperation with NCRP. We value your recommendations and informed opinions and often base our regulations and guidance, at least in part, on the thoughtful decisions of the NCRP. We also look forward to participating in this annual meeting of the Council to network, discuss current topics, and hear feedback on how well we are doing in meeting the needs of the Nation for radiation protection. After all, protecting people and the environment is our mission.

In 2014, the NRC began a project called Aim. The purpose of the Project is to transform the NRC and improve our service to the Nation. I will describe the Project in more detail, but first allow me to review the current and projected environment that has driven the Project.

DYNAMIC ENVIRONMENT

The world is experiencing change at an unprecedented pace, as reflected in social, cultural, economic, political, and technological advances around the globe. Experts on societal change have noted that the first decade of the 21st century has experienced as much change as all of the previous century combined. I have even heard one estimate that the 21st century alone will produce about “10,000 years’ worth of changes.” “Game-changing” products and services that historically appeared every 5 y or more now are introduced every few months. Mobile devices, communications software, and other tools to support the demands and pace of modern society are constantly being refreshed and enhanced. This rate of change is unlikely to slow down any time soon. Consequently, it is important for us to monitor the changing environment, consider the implications of these changes on our operating environment and workload, and proactively achieve our safety and security mission.

In case you doubt the pace of change, talk with our colleagues of the Millennial generation (born between 1982 and 2000) about what life was like “way back when” before cellular communications, the internet, and laptop computers and tablets. Besides technology and generational changes, other long-term trends and changes are reshaping our operating environment, both positively and negatively, including:

  • increases in cyber threats, crimes, and vulnerabilities to exploitation;
  • proliferation of weapons of mass destruction;
  • increases in the accessibility and lethality of robotics;
  • changes in the composition and diversity of the workforce;
  • migration of the U.S. population to smaller cities and rural locations in the south, while urbanization accelerates in many parts of the world;
  • emergence of China and India, along with other nations, as economic powerhouses;
  • tightening constraints on U.S. federal funding associated with growth of entitlement programs and increase in the national debt;
  • globalizing commerce and governance;
  • increasing global political instability; and
  • growing distrust and dissatisfaction in large institutions.

In 2014, the NRC experienced a convergence of forces that prompted Project Aim. These included the impact of the lessons learned from the Fukushima-Daiichi accident, the increase in operating nuclear power plant licensing backlog, growth in annual fees for licensees without a commensurate improvement in the quality of service, and reduction in demand for licensing and regulating new nuclear facilities. These forces followed changes that NRC experienced over the preceding 5 y, including the early closure of operating nuclear power plants, a court-ordered revisiting of the Waste Confidence decision and associated rulemaking, the shutdown and subsequent restart of the Yucca Mountain repository licensing review, the centralization of corporate functions in our corporate offices, and the shutdown of the NRC for the first time in its 40‐y history. The NRC has repeatedly proven its ability to adjust to significant changes; we successfully navigated change in establishing the agency, responding to the accidents at Three Mile Island, Chernobyl, and Fukushima Daiichi, revamping the reactor oversight process, reinventing the materials program, and strengthening security and incident response after the terrorist attacks on 11 September 2001. Seen through the lens of today’s internal and external stakeholders, NRC actions just seem to take too long and are too costly. This combination of external and internal factors helped to crystallize the need for Project Aim.

PROJECT AIM

So what is Project Aim? The NRC is conducting Project Aim to improve the NRC’s planning, operational excellence, agility, and performance (USNRC 2015a). The Project team gathered perspectives from internal and external stakeholders to forecast the future workload and operating environment in 2020. Based on analysis of these perspectives and other information, the NRC identified key strategies and recommendations to transform the agency during the next 5 y to improve how NRC accomplishes its safety and security mission. The intent of the Project is to position the agency to be more proactive or “pre-sponsive” to circumstances outside of NRC’s control. After review by the Commission in early 2015 and decision in June 2015, the staff has been diligently implementing these strategies to improve the agency’s performance.

Fig. 1 generally depicts our approach in conducting this Project. We used scenario analysis to think through how the agency can best prepare to fulfill its mission in an uncertain and dynamic future. The development and use of future alternative scenarios was only a means and not an end in itself to improving our planning and budgeting. The real benefit of scenario analysis is fostering greater agility and flexibility and responding more nimbly, flexibly, and promptly when changes are necessary in response to external and internal drivers. This is the primary focus of Project Aim 2020. How can the agency be more agile now, not just several years in the future, but next week or next month when change is warranted and expected? How can we best enhance the agency’s performance while recognizing the benefits that derive from a balanced approach, providing for “dynamic stability” in an uncertain and changing world? After all, we are not interested in changing for the sake of change but rather making strategic and programmatic changes to boost agency performance and responding proactively to our workload and operating environment.

Fig 1
Fig 1:
The approach used by the U.S. NRC in conducting the gap analysis in support of Project Aim (USNRC 2015a).

The centerpiece for the Project was our gap analysis—identifying process changes, strategies, and capabilities needed to accomplish our mission for a range of scenarios and to make the agency more agile, proactive, flexible, effective, and efficient. We identified barriers or other impediments that may prevent the agency from accomplishing its mission unless we change now and in the near future. We collected perspectives through numerous focus group sessions with NRC supervisors, managers, and employees. We conducted similar outreach to external stakeholders and partnered with the National Academy of Public Administration to review our approach and recommendations. Based on all of this input, we distilled the insights into specific recommendations and assessed those recommendations for mission value, relevancy, and effectiveness. The NRC staff provided recommendations to the Commission for consideration in January 2015. After thorough review, the Commission directed the staff to proceed with most of the recommendations in June 2015.

STRATEGIC WORKFORCE PLANNING AND RADIATION PROFESSIONALS

One of the staff’s key recommendations and a key strategy approved by the Commission is improving how NRC conducts strategic workforce planning, to provide high confidence that we will have employees with the right skills and talents at the right time to accomplish the agency’s mission. Based on the work that we have conducted so far, a significant need that we share with the Agreement States, other government agencies, and our international counterparts is ensuring sufficient radiation protection professionals. We have been supporting and following with interest the initiative led by NCRP, with the avid cooperation of the Conference of Radiation Control Programs Directors, the Health Physics Society (HPS), and others. “Where are the radiation professionals?” (WARP) has been a topic of great interest to the NRC for a number of years. Perhaps, this question should be asked with more of a forward focus like: “Where will the radiation professionals be 5 to 10 y from now?” “Will there be enough of them?” And “Will they have the right skills and talents?” The NRC was pleased to see NCRP’s release of Statement No. 12 on 17 December 2015 (NCRP 2015).

Close on the heels of the release of the WARP Statement (NCRP 2015), the NRC conducted a technical session on “Human Capital in Health Physics and Other Technical Areas: Will the United States Meet Domestic and International Needs” at the recent Regulatory Information Conference (RIC) on 9 March 2016. This session aligned well with the observations, findings, and themes featured in the WARP Statement (NCRP 2015). The panel was moderated by Terry Brock of the NRC and included the Nuclear Energy Agency (NEA) Director General William Magwood, Richard Toohey of M.H. Chew and Associates, Jerry Hiatt of the Nuclear Energy Institute (NEI), and Kathryn Higley of Oregon State University.

The question of whether the pipeline of radiation protection professionals is adequate to meet national needs is not new. Toohey (USNRC 2016) highlighted in his RIC presentation that Dade Moeller and Rolf Ellason predicted a 50% shortfall in the number of health physics graduates by 1980. In 1988, Ken Mossman and John Poston reported current and projected shortages (Mossman and Poston 1988) of health physicists in the civilian nuclear industry through about 2005. The HPS alarmed us all about the dwindling number of radiation professionals in a position statement in 2001 (HPS 2001), just before the terrorist attacks in New York City, Washington, and Pennsylvania. The Society updated the position statement in 2005 (HPS 2005) and again in 2013 (HPS 2013). That position statement recognized the declining number of U.S. citizens enrolling in science and technology graduate degree programs between 1993 and 1999, especially in the fields of math, engineering, and the physical sciences. In health physics, in particular, the number of graduates decreased by 55% at all levels between 1995 and 2002, as the number of health physics programs constricted in U.S. universities. The HPS summarized the results of their analysis in its Human Capital Crisis Task Force Report of July 2004 (HPS 2004).

The Task Force report featured an entire chapter on the existing and projected workforce needs for state radiation protection programs. Based on responses to a survey from state agencies (56% response rate), the Task Force estimated that state programs employ over a thousand radiation protection specialists and had a relatively small percentage (1.5%) of vacancies at the time of the survey in 2003. The largest number of these specialists was devoted to radioactive materials regulation. About 93% of these positions were desired to be filled with individuals who had at least a 4 y radiation safety degree, yet only about half of the people filling the positions (55%) had such a degree. The state agency results of the 2004 Task Force report were generally consistent with similar projected gaps in other sectors of the radiation protection field, including the energy sector, federal government, research and development, academia, and medicine.

Kathy Pryor, Past President of the HPS, shared the results of a more recent survey in the February 2014 edition of the HPS Health Physics News (Pryor 2014). The HPS inserted specific questions in its 2013 annual survey of Society members to support NCRP’s WARP initiative (NCRP 2015). Although the survey response rate was relatively low (14%), the results of this survey were even more troubling in warning of a potential gap of radiation protection professionals in the near future. Approximately 10% of respondents indicated that they planned to leave the health physics workforce in the next 5 y; 51% responded that they plan to retire within the next 10 y. The survey also found that a few employment sectors are dominated by older workers who might be expected to retire within a shorter time horizon. This was particularly the case for health physicists employed in the federal and state government sectors. In the next 10 y, 52 and 70% of respondents indicated their intent to retire from federal and state government agencies, respectively. In fact, every employment sector indicated a greater than 30% projected retirement rate in the next 10 y, with the exception of government contractors (71% self-employed, 51% national laboratories, 66% nuclear power utilities). The HPS concluded based on the 2013 survey that a focused federal effort must be supported to expand and fund academic programs to train radiation professionals. To this end, in fact, the NRC has been conducting the Integrated University Program for about a decade, including grants to support academic programs to train radiation and other professionals in nuclear science and engineering and related fields. More information about this program can be accessed at http://www.nrc.gov/about-nrc/grants.html#nep (NRC 2015b).

The HPS conducted a follow-up survey in 2014 led by Stephen Bump of Dade Moeller and released the results in December 2014 in the HPS Newsletter (Bump 2014). The survey was focused on full-time radiation protection professionals. Survey responses were considerably fewer than in the prior year’s survey, with only about 200 respondents. This survey showed that health physicists and radiation protection professionals were compensated reasonably well with an average salary of about one hundred thousand dollars and a $30,000 boost for certification.

Projected retirements without qualified personnel waiting in the wings to replace them in the state and federal agencies can be particularly troublesome and disruptive. Throughout my career at the NRC, I have observed many times how the loss of a handful of experienced and competent radiation professionals can destabilize a regulatory program and substantially weaken program performance. But a handful is far less than the nearly 700 projected retirees from state programs over the next 10 y. As with many surveys, it is important to recognize that these projections are based on a low response rate and not all state and federal radiation professionals are members of the HPS. On the other hand, the survey reflects the intent of HPS members to retire within the next 10 y and does not reflect other losses that could exacerbate the projections, such as involuntary separations, promotions, and transfers. Although the numbers may be soft, they certainly warrant prompt attention and beg the question of whether we are collectively doing enough to prepare our agencies to succeed in the future by supplying one of the most basic resources required to regulate and achieve radiation safety—the skilled, talented, competent, and experienced professionals we rely on daily to accomplish our mission.

In December 2015, NCRP issued the WARP Statement No. 12 (NCRP 2015) and concluded that the United States is on the verge of a severe shortfall of radiation professionals. Based on this finding, the statement recommends several courses of action to preclude and mitigate negative outcomes of such a shortfall, including:

  • Education: enlargement of university programs to build science, technology, engineering, and mathematics capabilities;
  • Research: restoration of research funding to resolve crucial issues, such as assessing the health effects of low-dose radiation exposures;
  • Training: support for formal academic education for radiation professionals, as well as internships, practicums, post-doctoral positions, and similar post-graduate training programs. This includes developmental assignments at national laboratories and with federal agencies. It also includes training grants to develop surge capacity of radiation professionals in emergency response; and
  • Continued monitoring and advocacy: establishment of NCRP Council Committee 2 to monitor and advocate for radiation professionals and provide advice to the federal government consistent with NCRP’s Congressional Charter.

The workshop that supported the development of the WARP Statement (NCRP 2015) featured insights from a broad cross section of federal and state government agencies, academia, industry, and national laboratories. Each participant used quadrant charts to describe mission along with the organization’s needs for radiation professionals. Information presented by Dave Allard of Pennsylvania (Allard 2013) and federal agency counterparts indicates that the most common needs among the agencies are filling immediate vacancies for radiation professionals (82%), succession planning in preparation for known and projected retirements (71%), and building surge capacity for responding to radiological incidents (47%).

These results were generally confirmed in a separate workforce survey conducted by NEI in 2015 and presented by Jerry Hiatt at the RIC (USNRC 2016). Participants in that survey included representatives of 23 nuclear utilities along with the large vendors who supply services to the civilian nuclear power industry. NEI examined workforce needs by sectors, including nuclear utilities, nuclear suppliers, national laboratories, U.S. Department of Energy contractors, defense nuclear programs, and the NRC. Although not explicitly addressed in the NEI Workforce Survey, other sectors would include academia, other non-nuclear power industrial users of radioactive material, and other federal, state, and local agencies that employ radiation professionals. The NEI Workforce Survey concluded that the radiation professional workforce in the United States is aging and that the workforce is currently sufficient (notwithstanding seasonal shortfalls associated with outages). The industry has instituted a variety of coping mechanisms to support the workforce, including deferred retirements, transfers of radiation protection professionals from shutdown sites, knowledge transfer programs, and continued hiring and development of college graduates.

That same RIC session featured a presentation by NEA Director General Bill Magwood, including results of a recent international survey of nuclear regulatory agencies of the 31 member countries who participate in the NEA (USNRC 2016). Director General Magwood noted that projected growth of the nuclear industry and regulation in the member countries will only increase the demand for qualified radiation professionals for the foreseeable future, not only for nuclear power but also for the expanding uses of radioactive materials in medical, industrial, and research applications. The survey documented shrinkage of university programs offering health physics degrees or significant coursework over the last 20 y, with a decline of 36 to 22 in the United States, relative stability in many other nations, and significant increases in Japan (3 to 14) and the United Kingdom (1 to 6). Most survey respondents indicated a strong negative response to a question about whether the regulatory agency would be able to hire a sufficient number of radiation protection experts over the next 10 y. The size of these national agencies varied significantly in terms of the number of radiation protection experts from 5 to 170 (NRC was the largest). In addition, survey respondents indicated concerns that the newly hired radiation professionals are not ready for work assignments without additional training, many lack practical field experience, years of training are required to qualify the employees as radiation protection experts, and that all countries who responded are concerned that there are not enough radiation professionals in the pipeline.

LOOKING FORWARD

As repeated surveys have shown during the last several decades in the United States and more recently overseas, there is a growing concern that the current and projected retirements of radiation professionals will likely create a shortfall in qualified professionals in regulatory agencies at the federal, state, and local levels. In addition, the complexities and demands on the radiation professionals are forecast to increase as a result of technological advances in the uses of radiation and radioactive materials, constrained budgets, and increased expectations of elected officials and the public.

In the U.S. and international regulatory framework, users of radioactive material have the primary responsibility to ensure that the material is used safely and securely. Consequently, operators of nuclear facilities and radioactive material users require competent radiation professionals. Similar needs exist in the vendor community, government agencies, and academia. Regulatory agencies also have a role to play in overseeing such use to confirm safety and security. In today’s increasingly networked and interdependent environment, each of these sectors requires capable and competent radiation professionals.

Agencies such as the NRC have increasingly adopted more risk-informed and performance based approaches for regulating nuclear safety and security, which adds complexity and increased demands for expert knowledge in radiation protection as these regulatory approaches displace more simple and straightforward deterministic schemes. NRC identified radiation protection as a core capability in the late 1990s. As we move forward with Project Aim, NRC will be using strategic workforce planning to ensure that we hire, develop, and retain the radiation protection professionals that we need to accomplish NRC’s nuclear safety and security mission. This approach aligns well with the themes of the NCRP’s WARP Statement (NCRP 2015) and other national and international strategies to ensure a healthy pool of qualified radiation professionals for meeting the needs of the Nation for radiation protection.

As we proceed to attract, retain, and develop the radiation protection professionals NRC needs to fulfill its mission, there are also some practical steps that the radiation protection community can take to sustain the pipeline of qualified professionals to meet the Nation’s and world’s needs. These steps include:

  1. Monitoring the availability of professionals and projecting gaps and overages compared with National and international needs;
  2. Encouraging agility and broadening of competencies by shifting positions to match the demand; focusing academic programs and continued education to ensure responsiveness for a range of workforce needs;
  3. Emphasizing acquisition of practical experience in the beginning of and throughout the careers of radiation protection professionals; and
  4. Identifying projects with right-sized resource demands to sustain technical and research progress while reflecting economic constraints.

REFERENCES

Allard DJ. National crisis: where are the radiation professionals? (WARP)—Conference of Radiation Program Directors (CRCPD) and states workshop summary. Bethesda, MD: National Council on Radiation Protection and Measurements; 2013. Available at http://ncrponline.org/wp-content/themes/ncrp/PDFs/WARP_Workshop_Summary.pdf. Accessed 2 September 2016.
Bump SL. The HPS salary survey. Health Phys News 22(12);2014.
Health Physics Society. Human capital crisis in radiation safety. Position statement of the Health Physics Society. McLean, VA: HPS; 2001. Available at http://hps.org/documents/humancapital.pdf. Accessed 2 September 2016.
Health Physics Society. Health physics society human capital crisis task force report. McLean, VA: HPS; 2004. Available at https://hps.org/documents/ManpowerTaskForceReport.pdf. Accessed 2 September 2016.
Health Physics Society. Human capital crisis in radiation safety—position statement of the Health Physics Society, revised. McLean, VA: HPS; 2005. Available at https://hps.org/documents/HumanCapitalCrisis05.pdf. Accessed 2 September 2016.
Health Physics Society. Human capital crisis in radiation safety—position statement of the Health Physics Society, revised. McLean, VA: HPS; 2013. Available at http://hps.org/documents/humancapital_ps015‐3.pdf. Accessed 2 September 2016.
Mossman KL, Poston JW. Education and training in health physics—a look to the future. Health Phys 55:223–227; 1988.
National Council on Radiation Protection and Measurements. Where are the radiation professionals (WARP)? Bethesda, MD: NCRP; Statement No. 12; 2015. Available at http://ncrponline.org/wp-content/themes/ncrp/PDFs/Statement_12.pdf. Accessed 2 September 2016.
Pryor K. HPS WARP survey results. Health Phys News 22(2); 2014.
U.S. Nuclear Regulatory Commission. Project Aim 2020 report and recommendations. Washington, DC: USNRC; SECY 15‐0015; 2015a. Available at www.nrc.gov/docs/ML1502/ML15023A558.html. Accessed 2 September 2016.
U.S. Nuclear Regulatory Commission. Grant opportunities. Washington, DC: USNRC; 2015b. Available at www.nrc.gov/about-nrc/grants.html#nep. Accessed 2 September 2016.
U.S. Nuclear Regulatory Commission. 28th Regulatory Information Conference—human capital challenges in health physics and other technical areas: will the United States meet domestic and international needs? Washington, DC: USNRC; 2016. Available at https://ric.nrc-gateway.gov/docs/abstracts/sessionabstract‐23.htm. Accessed 2 September 2016.
Keywords:

National Council on Radiation Protection and Measurements; radiation protection; regulations; safety standards

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