Social Scientists in an Adversarial Environment: The Nuclear Regulatory Commission and Organizational Factors Research

This paper examines the Nuclear Regulatory Commission’s (NRC’s) pursuit of social science research that could inform the oversight of nuclear power plant management. Perhaps no nuclear regulator has been as supportive of research on the intersection of organizational factors and reactor safety or as cautious in applying those findings to its regulations.

This dissonance was rooted in the NRC’s long-held conviction that it should regulate power plants not people, which conflicted with its regulatory experience after the 1979 Three Mile Island accident (TMI). Intrusive oversight of a licensee’s “business,” it was believed, would destroy its sense of ownership for safety. TMI challenged that understanding of the NRC’s role, and a series of mishaps at other plants compelled the agency to cross the line between regulation and management. The NRC’s relationship with industry became highly adversarial, and the agency turned to social scientists to help establish an objective basis to judge a licensee’s organizational culture. Behavioral experts joined plant oversight review teams and received generous funding to quantify the contribution of organizational factors to accident risk. Scores of scholars at national laboratories and a dozen universities contributed, but the NRC abandoned the research in the mid-1990s in the face of inconclusive research and industry resistance.

In need of a less controversial oversight program, the NRC abandoned direct assessment of plant management for a more quantitative approach that relied on plant performance indicators. When the 2002 Davis-Besse vessel head erosion event came perilously close to a significant loss-of-coolant accident, it raised questions about the appropriate role for the NRC in assessing a licensee’s safety culture. The NRC revised its oversight program to incorporate qualitative insights from its earlier research while still acknowledging the line between regulation and management. The NRC learned that while there were substantial cultural and technical obstacles to integrating safety culture insights with established management and regulatory practices, it was necessary to overcome them. The agency found stability in its contentious oversight program only when it made appropriate room for safety culture expertise.