Former Reed Reactor Director Cleared to Work Following Federal Investigation
Dr. Melinda Krahenbuhl, the former Director of the Reed Research Reactor, was allowed in mid-March to return to U.S. Nuclear Regulatory Commission (NRC)-related activities after a year-long ban which resulted from infractions surrounding the certification of two Reed Reactor Operators with mental health issues. Over the past year, she has worked with the NRC to update the regulations surrounding mental health among Research Reactor Operators that led to her suspension and her departure from Reed College.
“The college does not believe its employees engaged in any willful violations of regulations. None of the NRC’s apparent violations involved any public safety concerns.”
One year ago, on March 16, 2020, Dr. Krahenbuhl received a notice from the U.S. Nuclear Regulatory Commission that her license to participate in NRC-related activities was suspended for three years, effective immediately. “The NRC staff determined that [Dr. Krahenbuhl] appeared to have deliberately provided information to the NRC on multiple occasions that was not complete and accurate in all material respects,” the document read.
The notice was a culmination of two investigations spanning from 2016 to 2019, as well as a hearing between Dr. Krahenbuhl and the NRC, which scrutinized two incidents of alleged “deliberate misconduct” by Dr. Krahenbuhl. Both incidents took place during the first half of 2015, and both involved Dr. Krahenbuhl failing to disclose potentially disqualifying medical information to the NRC on behalf of two students looking to become certified as Reactor Operators (RO).
In the first incident, a student was assessed by a medical professional, and it was found that they needed to undergo further psychological evaluation before they could be qualified to take the exam to be certified as a Reactor Operator. Dr. Krahenbuhl left this information out of the student’s NRC application form and the student never received the necessary further assessment. They ultimately were certified as an RO despite their lack of qualification.
In the second incident, a different student who was already certified as an RO went on medical leave of absence, and subsequently, Dr. Krahenbuhl had a conversation with the student in which she learned of medical information that could have potentially disqualified them from the upcoming Senior Reactor Operator (SRO) exam. Dr. Krahenbuhl did not inform the NRC of this information and allowed the student to take the SRO exam, and they ultimately were certified. Furthermore, when the student went on medical leave, their unescorted access to the reactor was revoked; for the test, they received a key to the reactor which allowed such access despite their lack of authorization to have it.
Both students’ medical issues were related to their mental health. In both cases, Dr. Krahenbuhl did not disclose comprehensive medical information to the assigned NRC examiner despite ample opportunity to do so, and in the first case, evaded attempts by the examiner to obtain the missing medical information. As a result, the NRC didn’t find out about these breaks in proper conduct until after both students were certified, when Dr. Krahenbuhl finally submitted complete medical records. According to the NRC, this behavior was deliberate.
“Given the significance of the underlying issues, Dr. Krahenbuhl’s position within the Reed College organization, and the deliberate nature of her actions, the NRC lacks the requisite reasonable assurance that Dr. Krahenbuhl can conduct licensed activities in compliance with the Commission's requirements and that the health and safety of the public will be protected if Dr. Krahenbuhl were permitted at this time to be involved in NRC-licensed activities,” the NRC wrote. Whether or not the students would have been qualified, the fact that Dr. Krahenbuhl circumvented regulation to see them certified was itself problematic for the NRC.
“We need to engage the next generations of students to ensure the future of nuclear research and nuclear energy… To accomplish that, we need to meet the new generations where they stand, rather than expecting their mental health to mirror that of our parents.”
Prior to these offenses, Dr. Krahenbuhl had a storied career as a nuclear engineer. Before she came to Reed, she spent three years as the Director of the University of Utah’s reactor and another three as the Director of the Dow Chemical Research Reactor. From 1998 to 2008, she was part of a project with the Joint Coordinating Council for Radiation Effects Research, which analyzed plutonium exposure in Russian weapons development workers; at one point, she was arrested by the Russian government for her inspection work with the Council. And in 2013, she became the first woman to chair the National Organization of Test, Research, and Training Reactors (TRTR).
What brought her to Reed was a passion for education. “The enthusiasm that students have about life makes a huge difference in your life,” she said in an article for Reed Magazine. As Reactor Director, Dr. Krahenbuhl was— and still is— liked by her students and coworkers. Despite the NRC’s investigation and her departure from Reed, one source who works within the reactor said Reactor Operators’ sentiment towards her is still relatively positive.
As the Director of the Reed Research Reactor, Dr. Krahenbuhl’s responsibilities included managing the reactor and keeping it in compliance with regulation, overseeing student research, and communicating with the NRC— responsibilities which, according to the NRC’s investigations, she failed to fulfill.
During the time of the incidents under NRC scrutiny, Dr. Krahenbuhl was saddled with even more responsibilities than those of a normal Reactor Director. In a newsletter article for the TRTR reflecting on the incident, she wrote, “During the problematic spring of 2015, I was running the Reed Research Reactor without a Reactor Operations Manager (ROM). (During this same time period, I also was attempting to care for an ailing parent out of state.) My very capable ROM had been hired by another program and no qualified replacements who applied were willing to accept the salary offered.”
Dr. Krahenbuhl was first notified of the investigation’s conclusions in a September 2019 letter; at that time, Reed College President Audrey Bilger also received a letter which explained that the Reed Research Reactor was out of compliance with NRC regulation and that Reed College could face penalization as a result. Both Dr. Krahenbuhl and Reed College were provided multiple ways to respond to the NRC’s claims.
Reed College responded to the NRC by requesting Alternative Dispute Resolution, or ADR. ADR is an informal process of mediation during which two opposing parties use a neutral mediator to help them resolve their disagreements. Via this process, the NRC and Reed College came to an accord; as described in a Confirmatory Order which outlined the terms, Reed would institute policy changes that would make it harder for Dr. Krahenbuhl’s mistakes to be repeated, and the NRC would not otherwise punish the college for failing to comply with regulation.
One stipulation of the order was that the NRC and Reed College would “agree to disagree regarding the willfulness of the apparent violations,” for which Dr. Krahenbuhl was punished.
According to Kevin Myers, the Director of Communications & Media Relations at Reed, “The college does not believe its employees engaged in any willful violations of regulations. None of the NRC's apparent violations involved any public safety concerns.”
He continued, “Our cooperation with the NRC reflects Reed’s commitment to public safety and full regulatory compliance in operating the reactor.”
Dr Krahenbuhl, on the other hand, requested that a Predecisional Enforcement Conference, or PEC, be held in response to the NRC; in January 2020, she and her attorney went to Rockville, Maryland to dispute the NRC’s claims against her. According to NRC documentation, “During the PEC, Dr. Krahenbuhl acknowledged (through her representative) that the information regarding Student #1 and Student #2 that she provided to the NRC was not complete and accurate in all material respects; however, she stated that she did not intend to deliberately mislead the NRC.”
Despite her disputes, after the PEC the NRC ultimately found that Dr. Krahenbuhl was guilty of providing incomplete information to the NRC, engaging in deliberate misconduct, and violating facility access control procedures. Thus, in March 2020, Dr. Krahenbuhl’s license was suspended for a duration of three years, and she was barred from engaging in any NRC-related activities for that time; furthermore, she was required to notify the NRC the first time she engaged in NRC-related activity following the three year probation.
At that point, Dr. Krahenbuhl chose to request ADR, and in June 2020, arbitration took place. Ultimately, she and the NRC were able to come to an agreement about what happened, and what consequences were necessary. Both Dr. Krahenbuhl and the NRC agreed that the infractions occurred, and that they should not have occurred. Dr. Krahenbuhl’s license was reinstated, and she was only barred from participating in NRC-related activities for one year counting from the March suspension. In exchange for giving her license back, the NRC had Dr. Krahenbuhl partake in a variety of activities related to rehabilitating herself, which included speaking regularly with an “executive coach,” as well as writing a newsletter article and making a PowerPoint presentation reflecting on the mistakes she made.
Additionally, the NRC accepted an offer she gave to rewrite the regulations surrounding mental health in Research Reactor Operators—the very same regulations which ultimately led to her infractions.
For the NRC-mandated TRTR Newsletter article which outlined the changes, Dr. Krahenbuhl emphasized the importance of updating mental health standards to reflect an increased candidness about mental health in society, writing, “Most of us and most of the U.S. NRC staff grew up in a society in which even an admission of depression or anxiety could be considered shameful and a sign of weakness. Our new operators have grown up during a time when the discussion and treatment of mental health is accepted, and openness is encouraged as a healthy way to develop and thrive.”
“We need to engage the next generations of students to ensure the future of nuclear research and nuclear energy,” she continued. “To accomplish that, we need to meet the new generations where they stand, rather than expecting their mental health to mirror that of our parents.”
According to recent documents, an updated version of Dr. Krahenbuhl’s regulatory reforms are currently making their way through NRC committees for review and potential approval.
And now that the year has passed, it seems that Dr. Krahenbuhl intends to return to her old line of work. A review of the previous year’s activities stated that, “She is immediately slated to resume service on committees that address NRC licensed activities.”
But none of those activities will be at the Reed Research Reactor. In October, Reed College brought on Jerry Newhouse as her replacement. Her departure is still a sensitive subject amongst colleagues and students who respected her. Reactor Trainee Henry J. told the Quest that there was “a sense of awkwardness” surrounding the matter.
Both Reactor Operations Manager Toria Ellis and Operations Supervisor Kees Benkendorfer declined to answer the Quest’s request for comment, forwarding all inquiries to Reed’s Public Relations office.
A Slack message was also sent out to Reactor Operators and trainees telling them not to speak to the Quest about Dr. Krahenbuhl’s departure, a source within the reactor confirmed. “We’d like to preserve Melinda’s privacy since she isn’t here to answer these questions herself,” it read. (Henry spoke to the Quest before the notice went out). According to an anonymous source, the fact that Reactor staff and employees have a sense of respect for Dr. Krahenbuhl is “definitely a big reason why we’re so hesitant” to answer the Quest’s questions.
Despite our best efforts, the Quest was unable to reach Dr. Krahenbuhl for comment.
Henry J. added that “It feels like a weird event that we’re not done processing.”