IEEJ : March 2015. All Rights Reserved.

SPEECH OF DR. DALE KLEIN TO IEEJ, TOKYO, MARCH 30, 2015
THE LESSONS OF THREE MILE ISLAND
It is a great privilege to be invited to speak to you today.
I want to express my thanks to IEEJ’s Chairman and CEO, Mr. (Masakazu) Toyoda, andto the leadership of this important organization for the wonderful welcome you haveprovided.
This month, we observed the fourth anniversary of the Great Japan Earthquake andtsunami.
For all of us, and especially for the people of Japan, the memory is fresh and for so manyfamilies who lost loved ones or their homes in the earthquake or the tsunami thatfollowed, the loss is profound indeed. Japan’s good friends in the United States stoodwith you after 3/11, and we remain standing with you today, four years later.
The resilience the Japanese people have shown in recovering has been impressive andinspiring.
I have been honored to play a small role in the effort to recover from 3/11. As you know, I
am the chairman of the independent advisory group that was assembled to monitor
TEPCO’s progress under the Nuclear Safety Reform Plan it adopted back in 2012. We
meet on a regular basis to review TEPCO’s progress and provide our views, providing
praise for progress when it has been earned, and pressing for more progress when webelieve TEPCO needs to be pushed a little harder.
Most often, there is a bit of both, which, frankly, is to be expected when confronted witha task as complex as remediating Fukushima Daiichi while at the same time preparing
the Kashiwazaki-Kariwa facility to be restarted.

As Japan progresses in the Fukushima cleanup and wrestles with the role that nuclearwill play in its future, it will need to sort through many of the same political, regulatory,
economic, and technical issues that we faced in the United States after the accident at

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our Three Mile Island facility in 1979.
For that reason, I have been asked to share with you my reflections on the TMI
experience and how they may inform the answers to the questions you are dealing withtoday.
I realize that TMI wasn’t as severe as the Fukushima accident – it has been rated a“five” on the International Nuclear Event Scale, while Fukushima has been rated a 7.
But many of those issues that we faced are, in fact, similar to the ones Japan has faced
and continues to address.
The Three Mile Island Accident
Almost all accidents – whether involving nuclear power plants, airplane crashes, oranything else – are the result of a cascading series of failures.
Certainly that was true at Fukushima, and it was also true at Three Mile Island. Bothaccidents ultimately involved a failure of cooling systems, but the road to that failure
was quite different.

At Fukushima, of course, the accident was preceded by, and caused by, a massive
natural disaster with tragic consequences – the Great Japan Earthquake and thetsunami it spawned. But the Three Mile Island accident had its genesis in a remarkably
everyday event: the cleaning of a filter.
The filter itself wasn’t part of the cooling system, rather it was part of the water andsteam loop in one of TMI’s two pressurized water reactors. This was a routine task, but
as luck would have it that night, the filter proved especially difficult to clean. One thing
led to another and a small amount of water found its way into an instrument airline.
This, in turn, led the feedwater pumps that delivered water to the steam generators toshut down, shutting the turbines themselves down. To handle the decay heat that was
still being generated by the reactor, three auxiliary pumps activated automatically. But– and this was critical – valves had been closed for routine maintenance and those
pumps couldn’t pump any water.
Heat and pressure increased as a result and a relief valve that should have managed

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this event malfunctioned leading to a partial meltdown of the reactor core.
The failure of the auxiliary pumps because of the valve closure was later cited as amajor factor, and it was a violation of existing regulations.
The Nuclear Regulatory Commission’s rules had required the reactor to have been shut
down if all three of the valves were shut for maintenance. But there were also humanerrors and, as it was later discovered, problems in the design of the user interface that
led to operational confusion about what was happening, making an effective response
more difficult.
It was not until 165 minutes after the start of the problem – nearly three hours – thatradiation alarms activated as contaminated water reached detectors. By that time,radiation levels in the coolant water were around 300 times expected levels.

Communication with the public and with local governments by the local utility becamea source of criticism – I know this will sound familiar to you, and it is one of the reasons
our Nuclear Reform Monitoring Committee has made improving communications anintegral part of our recommendations.
Information was shared in a fragmented way, and claims that no radiation had beenreleased were contradicted by instruments both at the plant and off-site. So, eventhough the radiation levels were unlikely to threaten public health, trust andconfidence were severely eroded.
Indeed, the NRC in Washington DC had some difficulty obtaining accurate information,
and an NRC historian has written that the degree of core melting wasn’t known foryears.
One problem TMI avoided that Fukushima unfortunately has had to deal with was ahydrogen explosion.
Although a hydrogen bubble formed in the dome of the pressure vessel, it was managed
in several ways, part of which included very controversial venting into the atmosphere.

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I want to share with you three other important aspects of the Three Mile Island
accident before sharing with you my thoughts on their implications for the challenges
Japan is dealing with today: the question of evacuating the local population, thecleanup effort, and estimates of the health impact.
In large part because of the mistrust and poor information that was provided, thegovernor of Pennsylvania, on the advice of then-NRC Chairman Joseph Hendrie,advised evacuation of pregnant women within a five-mile radius of the facility, and thatwas soon extended to 20 miles.
Approximately 140,000 people left the area, but more than half remained and 98
percent returned within three weeks.
As for the cleanup, the reactor was decommissioned and officially not completed until
1993 – 14 years after the accident. It helps us understand why the Fukushima
decommissioning time scale is measured in decades.
Epidemiological studies have concluded that the accident has had no observablelong-term health effects due to any radioactive releases. As you know, activism, politics,
and the inherent uncertainties of statistical analysis means that some people will
always believe that the health impacts were greater than they were. But the reputablestudies say otherwise.
I do not want to dismiss the impact of emotional distress that people may have suffered
but the fact remains that the radioactive releases from TMI had no discernable healtheffects.
The Impact, and Lessons, of Three Mile IslandImpact
I know that you are particularly interested in how our regulatory apparatus andnuclear industry responded to the accident, and I will share that with you in a moment.
But first I want to share with you the impact this accident had on public opinion about
nuclear energy, which in turn was critically important in shaping the governmentalresponse.

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As luck would have it, the accident took place only 12 days after the release of a
Hollywood movie called “The China Syndrome,” starring Jane Fonda and Jack Lemmon– two big movie stars, and Jane Fonda already had a reputation as an anti-nuclear
activist.
The movie’s message was that the industry couldn't be trusted to run these plants safely,
and the TMI accident played directly into that narrative. A large anti-nuclear
movement took shape, with hundreds of thousands of people participating in New York
City, Washington, D.C., and elsewhere.
This, together with a more stringent post-accident regulatory environment and otherfactors led to a steep decline in the U.S. nuclear industry. The number of reactors underconstruction in the U.S. declined every year from 1980 to 1998.
Fifty-one reactor orders were canceled from 1980-1984, and of the 129 nuclear power
plants that had been approved prior to TMI, only 53 were completed.
Perhaps understandably, the regulatory pendulum did indeed swing too far towards
over caution.
At the time, the U.S. Nuclear Regulatory Commission was a relatively new agency,
created by legislation in 1974 that split the functions of the former Atomic Energy
Commission into two separate agencies: The NRC, an independent agency to regulate
safety, and the Energy Research and Development Administration, which ultimately
became the Department of Energy.
The NRC was not created in response to a crisis, but like the JNRA it was a new agency
under considerable pressure to act and to demonstrate its independence and its power.
As it tightened regulatory requirements, in my view it went too far in making
regulations rigid and prescriptive rather than performance-based.
Its regulatory framework was not risk-based and therefore lost sight of what wasimportant. With everything of equal importance and urgency, there was not enoughsense of priority, of focus on what is important to safety and what is not. I find this tobe the current situation in Japan.

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Just for one example, the NRC’s post-TMI regulations required lots of training forpeople who had nothing to do with safety. Now, training is a very important componentof safety. At my time as NRC Chairman, and more recently in my role as chair of theNuclear Reform Monitoring Committee, we have placed a great deal of emphasis ontraining.
Certainly a lesson of TMI was that better training was required to increase skills andclarify accountability. But it makes sense to focus that training on the people who are, infact, responsible for safety of the plant and the environment.

Lessons
Ultimately, the NRC recognized that the pendulum had swung too far, and it adjusted
its course. It began to recognize, as I have often said, that “the safest airplane neverflies, and the safest car never moves.” Regulations started to become based on morereasonable risk analysis.
Emphasis was focused on those things that are truly critical, including the total loss ofelectrical power, which as we know is what happened at Fukushima Daiichi.
Second, it is important that the regulator be science-based. This is more difficult than itsounds.
After all, we live in democracies where regulatory agencies are answerable, to one
degree or another, to elected officials. And even educated members of the public areliable to be confused by conflicting assertions about the safety of nuclear power or theseverity of a particular event.
It’s worth remembering that neither TMI nor Fukushima Daiichi had significant health
implications related to radiation, but they did have significant impacts on the public’s
emotional stress – and that stress, whether founded on sound science or not, has real
implications both for health and for the political and regulatory environment.
So what can we do to help regulations be science-based? We must understand that for
the general public, radiation is frightening because it is mysterious and invisible. The

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experience at Fukushima has, unfortunately, made this even more so. The answer must
be a sustained informational programs that involve the government, universities, andthe utilities themselves.
What is essential is that there is a source of information that is trusted by the public ashonest and independent. And the information must be presented in ways that can begrasped by non-scientists, comparing radiation exposure levels to experiences in theireveryday lives – for example, their exposure to radiation in an airplane ride or fromeating bananas.
There are some excellent materials that have been produced along these lines, but weneed more, and we need more sustained efforts to get this information to the public.
Japan may have a better chance to keep a scientific focus at its regulatory agencies than
we did in the U.S.
As you may be aware, the regulatory apparatus in the U.S. is very heavily influenced bylawyers and by the potential for litigation. That is a considerably less significant factor
here, and I am hopeful that the scientific rigor and discipline necessary for effective
regulation will prevail.
One of the most important lessons the nuclear industry learned from TMI was to
avoid excessive regulation by sharing best practices and essentially regulating itself.
I know that many may be skeptical that the nuclear industry can self-regulate but I
challenge those skeptics to look at the Institute for Nuclear Power Operations (INPO),
their relationship with the NRC and their common goal of excellence in safety. This is
an area where I believe Japan can do better.
Industry has much more operational knowledge than regulators, and effective
cooperation – under appropriate regulatory supervision – can be a lot more effective
than regulation.

JANSI – the Japan Nuclear Safety Institute – has an opportunity to help all the nuclear
utilities to share best practices and take on this self-regulatory role.
But, and I say this as a friend, it remains a work in progress. There is too much
mistrust among the various utilities. They are not sharing as much information as

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they should and will not benefit from each other’s lessons learned. I remind you thatthe sequence of events that occurred at TMI was not new and was known.
About 18 months before TMI a very similar accident sequence occurred at the Davis
Besse Plant. The operator recovered from the initial failure and the plant suffered nodamage. But the plant operator did not share this information with the industry andtherefore operators at TMI were not aware and not trained to recover from this type offailure sequence.
When it comes to nuclear safety information there are no barriers, there are no borders,
there is no competition, and there is only the common goal of advancing the safety ofnuclear technology. Japan must embrace this and I hope that some of you will be able tohelp that process.

No matter how effectively we prepare, or how thorough the regulatory regime, nuclear
power plants are complex systems and unexpected events are inevitable. But they neednot become crises. One of the results of the Three Mile Island accident was an evolution
in the way we think about how and why things go wrong.
We have stopped looking at them as isolated equipment malfunctions, operator errors,
or acts of God. We now understand that the prevention of major accidents lies inpreventing the inevitable unexpected event from cascading into a major crisis. So we
now think about “defense in depth.”
While part of that involves multiple layers of backup and technical systems, an effective
organizational and management system can make a decisive difference.

For that reason, the Nuclear Reform Plan that TEPCO is implementing, and whose
progress our Committee is overseeing, focuses extensively on management andorganizational reform.
These reforms, which, taken together constitute what we refer to as a “safety culture,”
are not easy for a large organization to embrace. I believe they are especially difficult forcompanies accustomed to a top-down, rule-oriented management culture.

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To be successful, it is essential that we enable employees to think on their feet and react
quickly and effectively, and empower them to put safety first and to speak up when they
see a problem.
TEPCO is making progress in its adoption of a safety culture, though we have
impressed upon them the importance of not letting up and of ensuring that it extends
throughout the organization and down to the very front lines of the workers.
Conclusion
So those are the lessons that I believe we learned from TMI, and some of theirimplications for Japan as it travels its own journey in deciding on the future of nuclear
power. In many ways our experiences were quite different: Fukushima, aside from beinga more severe accident, followed a major natural catastrophe that led Japan to shut allits other nuclear power plants.
So you face a decision that we did not, which is what to do with the plants you alreadyhave, let alone the ones you might build in the future.
And, 2015 is not 1979.
We now have a greater understanding of the role fossil fuels are playing in climatechange and the beneficial role nuclear power can – I believe must – play if we are goingto meaningfully reduce carbon emissions. Indeed, some of the environmentalists who
were most vocally opposed to nuclear power in the aftermath of TMI now favor it as analternative to fossil fuels.
I have great respect for the fact that this must be a decision for the people of Japanalone. I would not presume to say what Japan should do. But I will say that there are
significant economic, environmental and security implications of that decision, and they
are not limited to Japan.
Japan is one of the most important members of the global economic community andcontinued reliance on fossil fuels imported from other countries will have negative
economic implications for the country, and will contribute to carbon emissions.

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In 2013, Japan significantly scaled back its emissions targets to a 3.8 percent cut by
2020 versus 2005 levels, backing away from the previous target of a 25 percent
reduction. At the time, the shuttering of Japan’s nuclear power plants was cited as themain reason for the less ambitious targets.

Without those nuclear plants, Japan will continue to depend on fluctuating prices forfossil fuels, and dependent upon importing them from some very unstable places. That
represents a security risk for Japan, as well as for its friends in the U.S. and elsewherethat rely on Japan as a country of stability and democracy in this part of the world.
A decline or abandonment of nuclear power in Japan would also send an unfortunate
signal to the rest of the world. It will make fighting climate change more difficult. And it
would have a major effect on the world’s nuclear infrastructure.
Many nuclear components are made here in Japan by such companies as Mitsubishi,Hitachi, Toshiba and Japan Steel Works, which heavily depend on their domesticmarket.
But I remain an optimist. I have been deeply impressed by the resilience anddetermination of the Japanese people.
And I know that your organization will continue to play an indispensable role in
conducting research and providing data, information and reports that are essential forthe formulation of good policy. With the contributions that you and others are making, I
have every confidence that, in the long run, Japan and its people will meet the many
challenges ahead, and prevail.
Thank you very much.

Contact：report@tky.ieej.or.jp