NUREG-1355,

The Status of Recommendationsof the President's Commission
on the Accident at Three Mile Island
A Ten-Year Review

Manuscript Completed: March 1989
Date Published: March 1989

Executive Director for Operations
U.S. Nuclear Regulatory Commission
Washington, DC 20555

.....:

ABSTRACTThis report summarizes the status of actions taken by the U.S. Nuclear
Regulatory Commission (NRC) in response to recommendations made by the
Presidenti~l Commission on the Accident at Three Mile Island in the 10 years
since the accident occurred in March 1979. It also updates NRC's initial
response to the Presidential Commission's recommendations contained in "NRC
Views and Analysis of the Recommendations of the President's Commission of theAccident at Three Mile Island" (NUREG-0632)t issued in November 1979. The
status of ongoing initiatives for actions not yet complete is also reported
for reference purposes. On the basis of its analysis of NRC and the industry,
the Presidential Commission found many then-current practices i~adequate andin need of improvement. As a result of its recommendations and of guidancefrom other studies, substantial changes have been made in the 10 years since
the accident. This report reflects how, based on Presidential Commission
recommendations and continued work, revised practices and standards are now
being implemented by NRC and throughout the industry.

NUREG-1355

iii

\

CONTENTS
Page
ABSTRACTiii

EXECUTIVE SUMMARY ....................•...............................

1

INTRODUCTION......

S

A.

RECOMMENDATIONS FOR NUCLEAR REGULATORY COMMISSION (NRC)
ORGANIZATION AND MANAGEMENT
A.1 and A.1.a

A.I.b
A.I. c
A.I.d

A.2

A.3.b
A.3.c

NUREG-1355

Appoint a Single Administrator\to
New Agency'

Head the;Grant Substantial Discretionary
the Admi nistrat ion

Authority to

Improve Interagency Communications

9
.

9

.

10

.

11

11

Retain the ACRS and Strengthen Its Role

13

Remove Requirements
App 1icat ions13

for ACRS Review of All License.

Permit ACRS Rulemakihg Initiatives.

Establish Safety-Cost Tradeoffs and Nonsafety Review
Respons ibi 1ities
A.4.a

A.S

Reorganize NRC Into the Executive Branch with aSing~e ~dministrator and Abolish the Five-Member
Commlsslon

Establish an Oversight Committee ....................•......

A.3 and A.3.a

A.4

9

Upgrade Operator and Supervisor Licensing
Requi rements

A.4.b

Better Define Safety Versus Nonsafety Systems

A.4.c

Reevaluate Control Room and Overall Plant
Des ign;

Enforce Higher Standards for Licensee Responsibilities
and Accountability for Safety..............................

v

14
14

.

15
17

.

18

20

CONTENTS (Continued)
Page
A.6

Locate New Power Plants in Remote Areas

21

A.7

Plan for Post-Accident Cleanup and Recovery................

22

A.8 and A.8.a

Assess the Need for New Safety Improvements
and Evaluate New Criteria for Safety Standards....

24

A.8.b

Review Licensee and Operator Qualifications

.

25

A.8.c

Establish Emergency Planning Prerequisites for,New Licenses.

26

Improve Rulemaking and Generic Safety Issues .....

26

A.9.b

Set Deadlines for Safety Issue Resolution

.

27

A.9.c

Conduct Periodic and Systematic Reevaluations ofExisting Rules
~
.

27

A.9.d

Improve Rulemaking Proc~dures.......••...........
-,.:".

28

A.10 Revise Licensing Procedures to Foster Early and Effective
Resolution of Safety Issues~......................

29

A.9 and A.9.a

A.10.aEliminate Duplicative Consideration
During Plant Licensingof Issues
30

A.10.bResolve Recurrent Licensing Issues by Rulemaking .

30

A.10.cCombine Construction Permit and Operating License
Hearings When Possible'...........

31

Eliminate Further Appeal of Appeal Board
Deci sions

31

A.10.eEstablish an Office of Hearing Counsel...........

32

A.lO.fResolve Open Licensing Issues by a Given
Deadl ine

33

A.10.dA.11 and A.11.a

A.11.bNUREG-1355.

,

Increase Emphasis on Systematic Evaluationof Operating Plants and on Inspecti~n and
Enforcement

33

Establish a Program for the Systematic Assessmentof Experience in Operating Reactors .........•....

36

vi

CONTENTS (Continued)

A.H.c

A.H.d

A.H.e
A.H.f

8.

Assess Substantial Penalties for Licensee Failures
to Report Safety Information.

38

Improve Auditing and Conduct Unannounced
Inspect ions of Licensees.

39

Conduct Intensive Reviews of Licensee
Performance
,

.

41

Adopt Criteria for Revocation of Licenses,
Sanctions, and Immediate Plant Shutdowns.

42

RECOMMENDATIONSFOR THE UTILITY AND ITS SUPPLIERS45

8.1 and 8.l.aChange Safety Attitudes and. Establish Specific
Safety Standards

45

8.l. b8.2

Con~u~t.lndependent
Actlvltles

8.3 and 8.3.a

B.3.b
and c .
8.4

Revi ew Operating Experi encefor47

Establish Clearly Defined Roles and Responsibilities
for 80th Operating Procedures and Emergency
Procedures

Increase Operator Qualifications

8.S.d ,

C.

47

Upgrade Management and Technical Qualifications
Design, Construction, Operation, and Emergency
Response Capabilities

c

50

.

Consid~r the Safety Implications of Rate-Making
FOR THE TRAINING OF OPERATING PERSONNEL

NUREG-1355

Reaccredit Training Institute Periodicallyand Require Candidates to Meet Entrance
Requi rements

vii

51
52
55

C.1 and C.l.a and b Establish Agency-Accredited Training
Institutions................................
C.1.c and d

48
49

Emphasize the Review and Evaluation of
Plant Procedures and Improve Operatingand Emergency Procedures .............•.

Diagnose and Resolve Plant Safety Questions
Ear lyRECOMMENDATIONS

46

Reviews of Plant Operational-

8.5 and 8.5.a, band

B.6

.

55

.

56

CONTENTS (Continued)
Page
C.2

Upgrade Training and Examining of Licensed Personnel.......

56

C.3 and t.3.a and b Initiate Operator Retraining Programs andProvide Ongoing, Integrated Training.........

57

C.3.c and d

C.4
D.

Emphasize Diagnosis and Control of Complex
Transients and Require Utility Access to aControl Room Simulator

Improve Simulator Research and Development

RECOMMENDATIONS

58

58

FOR TECHNICAL ASSESSMENT

61

0.1

Improve Control Room Des ign

61

0.2

Correct Design and Maintenance Inadequacies

62

0.3

Record Critical Plant Parameters

63

0.4 and D.4.a, b, c, and d
0.5

Conduct Accident Studies

0.6

Monitor TMI-2 Recovery

D.7

Conduct Accident and Abnormal Event Reviews

E.1 andE.1.a,

E.2
E.3

b, c, d, and e,.

Expand and Better Coordinate
Federal Radiation Effects
Research

66
67

71

71

Establish Department of Health and Human Services Oversightof NRC Activities...........................................

72

Educate State and Local Health Professionals and Emergency
Response Personne 1 ...............................•.........

73

Prepare in Advance for Radiological
Emergenci es.

Make Potassium Iodide Available

RECOMMENDATIONS

74
76

FOR UPGRADING EMERGENCY PLANNING AND RESPONSE ...

77

Upgrade the Role of the Federal
Emergency Management Agency (FEMA)and State and Local Governments .,.

77

F.1 and F.1.a, b, c, and d

NUREG-1355

63

65

FOR WORKER AND PUBLIC HEALTH AND SAFETy.........

E.4 and E.4.a, b, c, and d
E.5.

Research the Chemical Behavior of Radioactive Iodine
in Water

E.RECOMMENDATIONS

F.

.

viii

CONTENTS (Continued)

F.2 Base Emergency Response Plans on Potential Plant-SpecificClasses of Accidents~..........................
F.2.a

Tailor Response Plans According to a Variety of
Scenarios.

F.2.b and c

79

Activate Plans According to the Potential
Hazards Identified and Plan to Protect the
Public from Radiation Levels Lower Than
Used in NRC-Prescribed Plans.

80

Provide Local Communities with Funds and TechnicalSupport to Prepare New Plans.

81

F.3 Expand Medical Research on Means of Protecting the Publicfrom Radiation ................•............................

81

F.4 Better Inform the Public About Nuclear Power81

F.5 Study the Costs of Radiation-Related Mass Evacuations

83

F.G Delineate Responsibilities Among Support Organizations

83

RECOMMENDATIONS FOR THE PUBLIC'S RIGHT TO INFORMATION ....•......

85

F.2.d

G.

78

G.1 and G.1.a and b

Prepare a Systematic Public Information
Program ........•............. ".

85

G.2 and G.2.a b, and c Provide Timely and Accurate
Information............................

86

G.3 and G.3.a b and c Provide News Media Personnel a Greater
Understanding of Nuclear Power87

G.4 Create Emergency Broadcast Networks .................•......

S8

G.5 Routinely Inform the Public of Abnormal Radiation
Measurements
0...............

88

t

t

t

NRC TECHNICAL REPORTS REFERENCED IN THIS REPORTNUREG-1355

ix

91

EXECUTIVE SUMMARYOn March 28, 1979, the most serious accident at a U.S. commercial nuclear
power plant oc~urred at Three Mile Island Unit 2 (TMI-2) in Pennsylvania. Two
weeks after the accident, the President of the United States appointed a
12-member Presidential Commission to conduct a comprehensive investigation of
the accident and to make lIappropriate recommendations based upon theCommission's findings.1I
The U.S. Nuclear Regulatory Commission's (NRC) initial response to the
Presidential Commission's recommendations was published in November 1979 as
NUREG-0632, "NRC Views and Analysis of the Recommendations of the President's
Commission on the Accident at Three Mile Island." This report, NUREG-1335,
updates that initial response. It follows the sequence of recommendations in
the Presidential Commission report and, where appropriate, reflects thecommitments and agreements contained in NUREG-0632. The status of ongoingactions not yet complete are reported for reference purposes.
The Presidential Commission found many then-current NRC and industry practices
inadequate and in need of improvement. As a result of their report and other
TMI-2 studies, the NRC established a number of new programs and initiatives andmodified others. The following highlights many of these actions in terms of
the broad areas for improvement identified in the Presidential Commission
recommendations.
A.

NRC Organization and Management

The NRC has reorganized and adopted several new measures to strengthen its
management accountability and to place higher priority attention on the safetyof plant operations. The NRC has consolidated the majority of its staff in asingle location in Rockville, Maryland, to enhance more efficient decision
making and to bring the Commissioners and the staff elements responsible for
operational safety into close proximity. NRC has restructured the licensing
and inspection ,functions to reflect the shift in the nuclear industry fromconstruction to operation; and established a separate Office of Enforcement
to implement a "strengthened enforcement pol icy.
The NRC has also initiated a number of new programs intended to ensure a
improved oversight of licensee performance.
These include the systematic
assessment of licensee performance program, the diagnostic evaluation program,and the perforniance indicator program. The NRC inspection program has been
expanded, particularly through the use of team inspections and by locating
resident inspec;tors at each site. In addition, the Research program has beenredirected to place greater emphasis on severe accidents and risk studies.
These efforts have provided NRC management mor~ detailed knowledge of plant
operating characteristics and daily operational events.

NUREG-1355

1

B.

Utility and Suppliers

The industry has established the Institute of Nuclear Power Operations, theNuclear Safety Analysis Center, and the Nuclear Management and Resources
Council to aid licensees to improve plant performance and safety. Both the NRC
and the industry have placed a high priority on understanding the lessons ofoperational experience, particularly with regard to root causes, and communicating these lessons to all plants, both domestic and foreign. NRC has
verified that responsibilities for plant operations and related plant procedures are clearly defined for both normal and emergency conditions.
,C.

Training of Operating Personnel

All licensees have extensively revised their training programs for licensed
and non-licensed operators. National accreditation of these training programs
is now accomplished under close NRC monitoring.
A systems approach to training
has been established to improve the effectiveness of training programs forplant personnel.
NRC operator examinations now focus on a knowledge of plant
operations, and the passing grade was increased. More stringent initial
operator candidate screening and medical evaluations were instituted.
Licensees were required to have a simulator facility and to provide comprehensive training in the diagnosis of and recovery from possible plant malfunctions
and potential accident conditions.
D.

Technical Assessment

Since the TMI-2 accident, control room instrumentation and layouts have beenreviewed against needed capability to mitigate accidents, and plants have been
modified as necessary. Inadequacies in plant design and hardware have beencorrected. A Safety Parameter Display System has been provided for criticalplant parameters to enhance operators' understanding of the plant1s safety
status. In-depth and comprehensive studies have been, and continue to be,
conducted on severe accident and core melt phenomena, plant equipment performance and reliability, and human performance.
Detailed risk assessment research
activities and studies have characterized potential safety issues. NRC requirements for oral and written reports of operating events have been substantiallyrevised, and a comprehensive operational experience assessment and feedback
program has been established.
Finally, the TMI-2 accident recovery program has
been conducted in a deliberate manner with full documentation to aid in accident
modeling and design studies for advanced reactors.
E.

Worker and Public Health and Safety

In order to promote increased attention to public health and safety, the NRC
has worked to achieve coordination of Federal radiation effects research;adequate training of state and local emergency response personnel; and upgradingof licensee, State, and local radiological emergency response capabilities.
Federal radiation effects research and related matters are now coordinatedthrough the Committee on Interagency.Radiation Research and Policy Coordination.
Licensees are required to provide training to emergency response personnel,
and both NRC and the Federal Emergency Management Agency provide additional
training directly to such personnel. Further, NRC emergency preparedness
regulations have been extensively revised since the TMI-2 accident. Facility

NUREG-1355

2

modifications Ihave been required; periodic emergency response drills areevaluated; and licensee emergency planst facilities, training, and equipment
are routinely inspected. All licensees now maintain radioprotective drugs for
onsite emergency workers.
F.

Emergency Planning and Response

Revised NRC rules and guidance have been issued to provide for improved
capability for a wide "range of accidents. State and local authorities haveupgraded emergency plans, equipment, and training and participate withlicensees in biennial response exercises. Public notification and information
channels have been established and tested. Responsibilities and cooperative
procedures with other agencies have been documented and demonstrated throughtwo Federal Field Exercises involving licensee organizations and Federal,
State, and local officials.
G.

Public Right to Information

To disseminate prompt and accurate information about emergency conditions, a
Joint Public Information Center will be established near the site of any
future accident. These centers have the necessary facilities to support themedia, and will be staffed by Federal, State, local, and utility representatives who can speak authoritatively about the emergency. Arrangements havebeen established for announcements over the Emergency Broadcast System todisseminate information. NRC ensures that the public is informed of events
which are not emergencies through open meetings and widely disseminateddocuments, and on any release of radioactivity to the environment in excess
of NRC limits. Media training is provided on nuclear safety and related
subjects.
In summary, since the TMI-2 accident, significant modifications and improvements
have been made in NRC's and the industry's organization and practices. Training,equipment, and maintenance at nuclear power plants have been upgraded.
Emergency planning has been enhanced. Noteworthy progress has been achieved in
improving the margin of safety inherent in commercial nuclear power reactors.
There is now a heightened safety awareness within the NRC and the nuclear
industry, and an improved understanding of the lessons of experience taught bythis accident.

NUREG-1355

3

(
I

INTRODUCTIONOn March 28, 1979, the most serious accident at a U.S. commercial nuclear power
plant occurred at the Three Mile Island Unit 2 plant in Pennsylvania. Two
weeks after the accident, the President of the United States appointed a
12-member Presidential Commission to conduct a comprehensive investigation of
the accident and. to make "appropriate recommendations based upon the Commission1s
findings. II The resulting recommendations from the Presidential Commission
formed the principal basis for the U.S. Nuclear Regulatory Commission's (NRC's)
Three Mile Island Action Plan. As a result of work performed in response to
the plan, licensed nuclear utilities were required to undertake a range ofactions to implement the lessons learned from the accident at Three Mile
Island.
This report updates the Agency's initial response to Presidential Commission
recommendations contained in "NRC Views and Analysis of the Recommendations of
the President's Commission on the Accident at Three Mile Island" (NUREG-0632)
published inNov~mber 1979. It follows the sequence of recommendations in the
Presidential Commission report. Each verbatim recommendation is followed by asummary of the current status of actions and commitments resulting from thatrecommendation .. Where appropriate, the commitments and agreements contained in
NUREG-0632 are reflected in this report. The status of ongoing initiatives foractions not yet complete are reported for reference purposes.
The Presidential Commission made recommendations
A.

in the following broad areas:

The Nuclear Regulatory Commission

This section included recommendations for statutory changes in the structure of
the Nuclear Regulatory Commission and for policy changes in how the Agency
fulfilled its pr~mary mandate of assuring the safe operation of nuclear powerreactors. This section also recommended Agency changes in rulemaking, in the
adjudication of case-specific safety issues, and in the Agency's inspection andenforcement functions.
B.

The Utility and Its SuppliersThis section recommended ways to improve the design. construction, andoperation of nuclear power plants. These three components -- design,
construction, and operation -- of necessity involved the human element. The
recommendations focused on setting standards for doing things correctly, fordetecting problem areas, and for correcting problems when they occur.
Specifically, the recommendations included items on shifting attitudes, setting
clear safety goals and standards, sharing operating experience, maintaining
technical competence, assuring quality, emphasizing operator qualifications,and upgrading pl~nt procedures.
C.

Training of Operating Personnel

This section addressed several aspects of training. Several recommendations
pertained to the accrediting of training institutions for reactor operators and
NUREG-1355

5

their supervisors and the role of the licensee and the regulatory Agency inassuring adequately trained operators. The recommendations reflected that
operator training was an ongoing concern and that research was necessary tobring added understanding and realism to the dynamic simulation of nuclear
power plant operations.
D.

Technical Assessment

This section included recommendations for the type, arrangement, and display of
the information in the control room to improve the ability of plant operators toprevent and cope with accidents. Another recommendation treated the inadequacies in specific instruments used to cope with the TMI accident. It also
recommended that accident studies, including those for accidents that might
result in melting of the core, be continued. A related recommendation wasthat, to the extent possible, data be obtained from the severely damaged TMI
core for use in safety studies. The results of these studies were to be used
to identify desirable changes to the design of plants. The Presidential
Commission recognized the hazard to the public health and safety that remainedat TMI and recommended continued close monitoring of the cleanup and recovery
from the accident. It also recommended systematic evaluation of operating
experience.
E.

Worker and Public Health and Safety

This section reflected the concerns of the Presidential Commission regarding
uncertainties in the scientific understanding of the health effects ofionizing radiation, the need for public health agency overview of NRC activities, and the shortcomings in State, local, and utility emergency.
preparedness.
F.

Emergency Planning and Response

This section pertained to the review and approval of State emergency responseplans, the assessment of the basis for evaluating State and local government
plans, the coordination between utility and local officials, the upgrading ofState plans, and the role of the Federal Emergency Management Agency (FEMA).
It also included the use of'accident scenarios in developing and activating
emergency response plans, protection of the public from radiation at levels
lower than called for in current plans, and the availability of funds for
emergency response planning at the local level. Education of the public andthe need for study of the benefits and impacts of mass evacuation were also
addressed.
G.

The Public.s Right to Information

This section included recommendations that stressed the need for Federal andState agencies and utilities operating nuclear power plants to make adequate
preparations for a systematic public information program. The Presidential
Commission also stressed that the information must be presented in a form thatis understandable, timely, and accurate.

NUREG-1355

6

This NRC update on the current status of the Presidential Commission recommenda~
tions is another step in NRC's overall effort to use the findings and recommendations made in the many studies of the accident at Three Mile Island. The entire
range of follow-up activities were incorporated into the IINRC Action Plan
Developed as a ,Result of the TMI-2 Accidentll (NUREG-0660).
Subsequent requirements developed for implementation by NRC licensees and holders of construction
permits were compiled in IIClarification of TMI Action Plan Requirementsll(NUREG-0737).
Finally, the status of specific Action Plan initiatives continues to be monitored in NRC's periodical report, IIA Prioritization of Safety
Issuesll (NUREG-0933).

NUREG-13557

RECOMMENDATIONSA.

RECOMMENDATIONSMANAGEMENT,AND ACTIONSFOR NUCLEAR REGULATORY COMMISSION(NRC) ORGANIZATIONAND!

A.l and A.l.aReorganize
NRC into the Executive Branch with a Single
Administrator and Abolish the Five-Member Commission"

Presidential Commission Recommendation
The Nuclear Regulatory Commission should be restructured as a new independentagency in the executive branch. The present five-member Commission should be
abolished.
Status of Actions
The Presidential Commission concluded that the five-member Nuclear Regulatory
Commission (NRC), as constituted, did not possess the organizational andmanagement capa~ilities necessary for the effective pursuit of nuclear safety
goals and recommended that it be abolished. In its stead, the Presidential
Commission called for the establishment of a new Executive Branch Agency,
headed by a single administrator, who would be appointed by and serve at thepleasure of the President.
Four of the five NRC Commissioners then serving indicated that they would notsupport single-administrator legislation.
Instead, to strengthen Agency
management, the Commissioners preferred enactment of modest legislation that,combined with Commission-initiated changes in the Agency's internal practices
and procedures, would clarify the Chairman's authority. Following the issuanceof the Presidential Commission Report, the President proposed a plan to Congressthat would stre~gthen the Chairman1s authority. When Congress did not disapprove
this proposal, Reorganization Plan No.1 of 1980 became law. In the years
after enactment.iof this legislation, the Commission delegated additional authority
to the Chairmaniand to the Executive Director for Operations.
In 1988 the Senate passed legislation that would establish a singleadministrator agency. The House of Representatives did not act on this
proposal. Single-administrator legislation is expected to be introduced thisyear in the 101st Congress. Three of the current NRC Commissioners support
single-administrator legislation with certain qualifications; two do notsupport such legislation.
A.1.b

Appoint ~Single

Administrator

to Head the New Agency

Presidential Commission Recommendation
The new agency should be headed by a single administrator appointed by the
President, subject to the advice and consent of the Senate, to serve a substantial term (not coterminous with that of the President) in order to provide an
expectation of continuity, but at the pleasure of the President to allow
removal when the President deems it necessary. The administrator should be a
person from outside the present agency.

NUREG-1355

9

Status of Actions
Legislation to make NRC a single-administrator Agency is expected to be
introduced in the current session of Congress. Three of the current NRC
Commissioners support single-administrator legislation with certain
qualifications; two do not support such legislation.
A.1.c

Grant Substantial Discretionary Authority to the Administrator

Presidential Commission Recommendation
The administrator should have substantial discretionary authority over theinternal organization and management of the new agency, and over personnel
transfers from the existing NRC. Unlike the present NRC arrangement, theadministrator and major staff components should be located in the same building
or group of buildings.
Status of Actions
As noted previously, the President's Reorganization Plan of 1980 served tostrengthen the authority of the NRC Chairman relative to the other Commissioners.
For example, the Chairman is the official spokesman and principal executive
officer of the Commission and directs and delegates various functions to the
Executive Director for Operations (fDa), who reports to the Chairman on all
matters. The Commission retains responsibility for policy formulation, rulemaking, orders, and adjudication. The Chairman initiates personnel actions,subject to Commission approval, for heads of offices reporting directly to theCommission, including the EDO and the heads of the major program offices
reporting to the EDO. The Chairman directs and delegates to the EDO responsibility for all administrative functions, distribution of business, preparation.of reorganization proposals and budget estimates, allocation of funds, andpersonnel matters other than those affecting the major program offices andcertain other offices reporting to the Commission. The Commission's emergency
response functions were also transferred to its Chairman for defined emergencies.
The fDO position was also strengthened relative to the program staff. For
example, all program offices and regional offices repQrt to the EDO. The fDO
is to be consulted regarding actions affecting the program and regional
offices. The EDO is required to keep the Commission fully and currently
informed through the Chairman.
Since its inception as an independent regulatory Agency, NRC has sought toconsolidate its headquarters' staff in the Washington, D.C. area. Further
emphasis was placed on this effort as a result of the TMI-2 accident. On thebasis of past discussions between senior NRC and General Services Administration (GSA) officials, both agencies acknowledged the benefits of a consolidation and agreed to develop alternative options that would accommodate both
short- and long-term housing solutions. In November 1986, GSA concluded
negotiations.with White Flint North Limited Partnership to purchase an 18-story
building (One White Flint North, 11555 Rockville Pike, Rockville, Maryland) for
NRC's consolidation. This building is now fully occupied and has provided
major improvements in staffing efficiency.

NUREG-1355

10

The purchase contract for One White Flint North included an option to lease asecond building of similar size to be constructed on an adjacent portion of the
One White Flint North site. The Government has exercised this option and,following issuance of the necessary State and local permits, construction will
begin, with initial occupancy now forecast for spring 1991. The completion of
the second building at White Flint will provide, for the first time, for the
total consolidation of all NRC headquarters. staff and Commission offices in
one location.
A.l.d

Improve Interagency Communications

Presidential Commission Recommendation

A major role of the administrator

should be assuring that offices within theagency communicate sufficiently so that research, operating experience, andinspection and enforcement affect the overall performance of the agency.
Status of Actions

Although NRC has not been reconstituted as an Agency headed by a single administrator, the intent of this recommendation has been reflected in revisions to
NRC's management structure and operations. These reorganizations were undertaken in large measure to strengthen and improve the performance of the NRC
staff through the consolidation of headquarters' offices.
For example, in April 1987 a major restructuring of NRC headquarters' offices
effectively consolidated NRC responsibilities for licensing and inspecting
operating reactors in a single office; gathered NRC activities for non-reactors
in a single office; raised the level of priority placed on the assessment ofoperating experience; integrated in a single Qffice NRC resources being appliedon generic safety issues and other research activities; placed enforcement
functions in a new office; and created a new Office of Governmental and Public
Affairs in place of previously separate Offices of Public Affairs, Congressional
Affairs, State Programs, and International Programs.
In January 1989, in order to further assist the Executive Director forOperations (EDO), promote integration of staff activities, and to accommodate
the heavy workload of the EDO Office, a second Deputy Executive Director was
appointed. With this appointment, a second Deputy Executive Director position
was filled after a vacancy of over two years. Consequently, at this time, one
Deputy is responsible for the Office of Nuclear Reactor Regulation, Regional
Offices (except non-reactor matters) and the Office of Research, and the newly
appointed Deputy is responsible for the Offices of Nuclear Material Safety and
Safeguards (NMSS), Investigations, Enforcement, Consolidation, Administration,and Information:Resources Management.
A.2

Establish an Oversight Committee

Presidential Commission Recommendation
An oversight committee on nuclear reactor safety should be established.
Itspurpose would be to examine, on a continuing basis, the performance of theagency and of the nuclear industry in addressing and resolving important public
safety issues associated with the construction and operation of nuclear power
plants, and in exploring the overall risks of nuclear power.
NUREG-1355

11

The members of the committee, not to exceed 15 in number, should be appointed
by the President and should include: persons conversant with public health,environmental protection, emergency planning, energy technology and policy,
nuclear power generation, and nuclear safety; one or more state governors; andmembers of the general public.
The committee, assisted by its own staff, should report to the President and to
Congress at l~ast annually.
Status of Actions
The Commission considered the need for an independent board to investigate
nuclear accidents before the TMI-2 accident occurred~ In August 1978, the NRC
Chajrman responded to a series of questions on a nuclear accident board posedby Congress. After the TMI-2 accident, the President established a Nuclear
Safety Oversight Committee by Executive Order 12202 in March 1980. This
Committee, headed by Governor Bruce Babbitt of Arizona, issued a report on thestate of nuclear reactor licensing on July 23, 1981. After issuance of thereport, the Committee was abolished.
In 1984, Congress directed that NRC conduct a study of the need for andfeasibility of an independent organization responsible for conducting investigations of significant safety events at NRC-licensed facilities .. In response,
NRC contracted with Brookhaven National Laboratory (BNL) to conduct the study.
BNL's. final report was submitted to NRC in February 1985.
BNL recommended the establishment of a statutory office of nuclear safety~
headed by a director reporting directly to the Commission. However, the study
stated that NRC investigations of operating events had been conducted in a"proficient and technically competent" manner. Although BNL suggested a numberof improvements for investigating operating events, it was noted that, for themost part, these improvements could be implemented within NRC's then-present
organizational structure. Many of the improvements recommended by BNL havebeen adopted as part of the NRC Incident Investigation Program. On the basisof the Commission's review of the BNL report and of other studies of the issue,
the Commission believed that there were no major deficiencies in the NRC
accident investigation program that would warrant formation of an independent
Board or agency, and that the necessary independent oversight and assessment
could be provided by NRC's Office for Analysis and Evaluation of Operational
Data (AEOD). This Office was established in 1979 in response to the TMI-2
accident, is organizationally independent of the Offices of Nuclear Reactor
Regulation and Nuclear Material Safety and Safeguards, and reports directly to
the Executive Director for Operations.
The Commission continues to receive a substantial amount of external oversight .
.In addition to the oversight from numerous Congressional committees, NRC
receives independent advice from a number of advisory committees, such as theAdvisory Committee on Reactor Safeguards and the newly formed Advisory Committee
on Nuclear Waste.

NUREG-1355

12

A.3 and A.3.a

Retain the ACRS and Strengthen Its Role

Presidential Commission Recommendation
The Advisory Committee on Reactor Safeguards (ACRS) should be retainedt in astrengthened rolet to continue providing an independent technical check onsafety matters. The members of the committee should continue to be part-time
appointees; the Commission believes that the independence and high quality ofthe members might be compromised by making them full-time Federal employees.
The Commission recommends the following changes:
The staff of ACRS should be strengthened to provide increased capacity forindependent analysis. Special consideration should be given to improving ACRS'
capabilities in the field of public health.
Status of Actions
The NRC endorsed a strengthened role for the ACRS in its response to the
Presidential Commission Report: In this regardt the ACRS has been retained as
an independent technical check on safety matters and continues to play animportant role in its capacity as an advisory body reporting directly to theCommissi~n. Furthert the Committee is still composed of part-time appointeestand emphasis has continued on assuring the high quality of the membership.
The Committee hast at presentt ,been limited to a maximum strength of 11 members
from its previous maximum of 15 (established in the Atomic Energy Act). Thischange was associated with the establishment of a four-member independent
advisory group to provide needed advice in the area of waste management. As aresult of declining Agency resourcest the size of the ACRS staff has declined
since the early 1980's.
The ACRS. authority to conduct reviews of specific generic matters or nuclear
safety-related items on its own initiative was codified in July 1978 in NRC's
rules (10 CFR 1.20)~
A.3.b

Remove Requirements for ACRS Review of All License Applications

Presidential Commission Recommendation
The ACRS should not be required to review each license application. When ACRS
chooses to review a license applicationt it should have the, statutory right tointervene in hearings as a party. In particulart the ACRS should be authorized
to raise any safety issue in licensing proceedingst to give reasons and arguments for its viewst and to require formal response by the agency to any
submission it makes. Any member of the ACRS should be authorized to appear andtestify in hearingst but should be exempt from subpoena in any proceedings inwhich he has not previously appeared voluntarily or made an individual written
submission.
Status of Actions
Both NRC and the ACRS agreed with the Presidential Commission recommendationthat the ACRS should be relieved of the burden of reviewing every license
application. Such a proposal was included in several legislative proposals
NUREG-1355

13

from NRC, but has since been dropped as being unnecessary because no new
license applications are now being submitted. Neither the Committee nor theCommission was in favor of a formal litigating role for the ACRS in hearings inlight of their view that such a role would detract from the independent
collegial function of the ACRS. Thus, no such role has been established for
the Committee.
A.3.c

Permit ACRS Rulemaking Initiatives

Presidential Commission Recommendation
ACRS should have similar rights in rulemaking proceedings.
In particular, it
should have the power to initiate a rulemaking proceeding before the agency toresolve any generic safety issue it identifies.
Status of Actions
The ACRS, consistent with its charter under the Atomic Energy Act, reviews andcomments on proposed significant safety-related rules and rule changes.
Moreover, procedures are in place that provide for ACRS participation at earlystages in the development of NRC rules, policy matters, and guidance by thestaff.
NRC regulations provide that the ACRS may recommend rulemaking to the Commission and that the Commission will respond in writing within 90 days stating its
intent to implement, study, or defer action. (Paragraph 2.809 was added toPart 2 of Title 10 of the Code of Federal Regulations by publication in theFederal Register on April 17, 1981.) If the Commission decides to reject therecommendation, or to defer action on it, the rule provides that the Commission
will state its reasons for doing so.
A.4

Establish and Explain Safety-Cost Tradeoffs and Non-Safety Review
Responsibilities

Presidential Commission Recommendation
Included in the agency's general substantive charge should be the requirement
to establish and explain safety-cost trade-offs; where additional safety
improvements are not clearly outweighed by cost considerations, there should bea presumption in favor of the safety change. Transfers of statutory jurisdiction from the NRC should be preceded by a review to identify and remove any
unnecessary responsibilities that are not germane to safety. There should also
be emphasis on the relationship of the new agency's safety activities torelated activities of other agencies. (See recommendations E.2 and F.1.b.)Status of Actions
NRC is in complete accord with the recommendation that there should be apresumption in safety-cost tradeoffs in favor of safety. NRC addressed theissue of safety-cost tradeoffs in its amended backfitting rule (10 CFR 50.109)
which clarified when economic costs may be considered in backfitting
requirements for nuclear power plants (53 Federal Register 20603, June 6,1988). As noted in the background to the rule, the Atomic Energy Act clearly.
specifies that the Commission is to ensure that nuclear power plants provide
NUREG-1355

14

adequate protection to the health and safety of the public. In defining,
redefining, or enforcing this statutory standard of adequate protection, theCommission may not and will not consider economic costs. But, the Commission
is empowered under Section 161 of the Atomic Energy Act to impose additionalsafety requirements beyond those needed for adequate protection and to consider
economic costs in so doing.
NRC's position ,on divestiture of its nonsafety responsibilities remains essentially unchanged from that provided in NUREG-0632. It still does not support
such action. Divesting NRC of nonsafety responsibilities (it is assumed thatdomestic safeguards responsibilities would be retained) would require legislation by the U.S. Congress. In enacting the Nuclear Non-Proliferation Act of
1978, Congress expressed the firm belief that nuclear exports should be
subjected to a thorough review by an independent agency. Furthermore, relieving NRC of its antitrust review responsibilities under the Atomic Energy Act
and of its environmental obligations under the National Environmental Policy
Act and other federal laws for environmental protection, could leave serious
gaps in regulation at the Federal level.
Since the issuance of NUREG-0632, NRC has emphasized the relationship of its
safety authorities with the related activities of other agencies. Numerous
M~moranda of Understanding have been signed with agencies such as the Federal
Emergency Management Agency, the Department of Labor, the Department of Energy,
the Department of Justice, the Environmental Protection Agency, theOccupational Health and Safety Administration, and several States. In 1987 amajor NRC reorganization resulted in the creation of the Office of Governmental
and Public Affairs, which has increased the focus on planning and coordinatingwith other Federal and State entities whose interests are similar to those of
NRC.
A.4.a

Upgrade Operator and Supervisor Licensing Requirements

Presidential Commission Recommendation
The agency should be directed to upgrade its operator and supervisor licensing
functions. These should include the accreditation of training institutions
from which candidates for a license must graduate. Such institutions should be
required to employ qualified instr~ctors, to perform emergency and simulator
training, and to include instruction in basic principles of reactor science,
reactor safety, and the hazards of radiation. The agency should also set
criteria for operator qualifications and background investigations, andstrictly test license candidates for the particular power plant they will
operate. The agency should periodically review and reaccredit all training
programs and relicense individuals on the basis of current information on
experience in reactor operations. (See recommendations C.1 and C.2)
Status of Actions
NRC agreed with this recommendation, and after the TMI-2 accident, initiated anumber of actions to upgrade and strengthen operator licensing. As a result,
nuclear facility training programs are now based on a "Systems Approach toTraining" and each plant-specific operator training program is accredited by
the Institute of Nuclear Power Operations (INPO). Each license candidate mustcomplete the program as part of his/her eligibility to take an NRC license
NUREG-1355

15

examination. Instructors conducting the training of license candidates, prior
to the training program accreditation, were examined and certified by NRC toassure their competence and qualifications. NRC Form 398, "Personal Qualifications Statement," was developed to permit a closer review of an applicant's
training and experience for determining his/her eligibility to take an NRC
license examination. The NRC also adopted the more stringent initial candidate
screening and medical evaluations established by the industry. A "Knowledge
and Abilities Catalog for Nuclear Plant Operators" was developed with major
contributions from INPO to validate examination content and passing criteria totest plant operators on specific pressurized and boiling water reactors.
In addition, NRC revised criteria to upgrade reactor operator (RO) and senior
reactor operator (SRO) training and licensing requirements. Eligibility
requirements for the administration of an NRC examination were clarified andmade more explicit in terms of experience and training requirements. Initiallicensing training programs were modified to include the following: (1) practical application of heat transfer, fluid flow and thermodynamics; (2) use of
installed plant equipment to control or mitigate accidents in which the core isseverely damaged; and (3) increased emphasi5 on reactor and plant transients.
NRC expanded the scope and passing criteria for examinations for both RO andSRO licenses and imposed a time limit for completion of these examinations.
Applicants for SRO licenses are required to pass an operating examination as
well as a written examination. Also, all applicants are required to take asimulator examination in addition to the written and plant oral walkthroughtests.
The content of the requalification program was increased to require instructionin heat transfer, .fluid flow, thermodynamics, and mitigation of degraded coreaccidents. Passing grades were raised to the same criteria for the issuance ofa new license, and programs now require hands-on experience for specificreactivity control manipulations. Also, NRC periodically evaluates facility
requalification programs and administers requalification examinations tocurrent license holders.
Certification by the highest level of corporate management at that facility isrequired of all applicants for RO and SRO licenses as to the need for the
license and the individual.s eligibility and qualifications.
The regulatory upgrade of licensing requirements was initiated through arevision to 10 CFR Part 55 "0perators. Licenses." The regulation was amended
to (1) clarify the regulation for issuing operator licenses; (2) revise thescope of written and operating tests to include simulation facility
requirements; (3) codify NRC requalification examination administration;(4) describe the form and content for license applications; and (5) require
administration of an NRC examination to current license holders prior to therenewal of a license.
"0perator Licensing Examiner Standards (NUREG-102l) was developed to provide
guidance to NRC examiners and establish the procedures for examining andlicensing applicants for NRC license pursuant to 10 CFR Part 55. (Also see
Sections C.l and C.2 of this report.)II

NUREG-1355

16

A.4.bBetter Define Safety Versus Nonsafety Systems

Presidential

Commission

Recommendation

The agency should be directed to employ a broader definition of mattersrelating to safety that considers thoroughly the full range of safety matters,
including, but not limited to, those now identified as "safety-related" items,
which currently receive special attention.
Status of Actions
Following the accident at TMI-2, and in response to this recommendation, thestaff has paid increased attention to nonsafety-related plant equipment.
Consequently, improvements in the reliability of a number of nonsafety-related
systems now provide greater assurance that a safe plant shutdown can beachieved. These improvements were made to systems not required for mitigationof large-break loss-of-coolant accidents, which had previously been the primary
focus of staff attention when defining safety-related systems. There has beena reduction in the number of rapid plant shutdowns and challenges to safetysystems.
Improvements and actions involving nonsafety equipment and systems since the
TMI-2 accident include:oBackup power provided to the pressurizer heaters and pilot-operated
valves from an emergency diesel generator bus.

oChanges in containment building isolation design to maintain adequatecooling water flow to the reactor coolant pump (RCP) seals to improve pumpavailability throughout the course of an accident.

oAn anticipated transient without scram (ATWS) rule instituted to reduce
the probability and the consequences of a transient not followed by a
rapid reactor shutdown. The rule, along with Generic Letter 83-28, hasresulted in increased reliability of rapid shutdown systems and a diversity in mitigation capability.

oAn anticipatory rapid shutdown (trip) capability added to cause thereactor to shut down on low main feedwater flow to reduce the challenge topressurizer safety and relief valves. Previously, a reactor coolant
system high-pressure trip would generally occur to provide this protection, whereupon safety relief valves would actuate.

oThe reques~ that all plants verify by test the reliability and designbases of the instrument air systems and the adequacy of air quality,
training, and maintenance procedures.
A similar request is being issued
for the service water system.

oBalance-of~plant (BOP) inspections performed to determine possible impacts
on personnel safety or on safety-related equipment. A procedure for these1nspections has now been added to the NRC inspection manual.

o

Rapid reactor shutdowns caused by nonsafety~related systems have been
analyzed. It is expected that the BOP inspection procedure will be
updated as a result of this study.

NUREG-1355

17reliefo

The reassessment program for Babcock & Wilcox (B&W) reactors resulted innumerous recommendations for modifications of nonsafety-related systems,
such as main feedwater, main turbine, turbine bypass, and instrument air.
These recommendations were aimed at reducing the frequency of rapid
shutdowns and of the complications associated with BOP system failures
following such shutdowns. Many of these recommendations have already been
implemented at the B&W plants.

Balance-of-plant equipment, normally not safety related, also continues to beassessed for risk significance as part of probabilistic risk assessments.
Further, human factor programs focus on all aspects of human performance andnot just on safety-related activities. Through revised regulatory criteria andsubstantially increased organizational emphasis, all aspects of plant designand human performance, safety- and nonsafety-related, have received increased
scrutiny.
A.4.c

Reevaluate Control Room and Overall Plant Design

Presidential Commission Recommendation
Other safety emphases should include:(i) a ~ystems engineering examination of overall plant design andperformance, including interaction among major systems and increased attention
to the possibility of multiple failures;(ii) review and approval of control room design; the agency should
consider the need for additional instrumentation and for changes in overalldesign to aid understanding of plant status, particularly for response to
emergencies; (see Recommendation 0.1) and(iii) an increased safety research capacity with a broadly defined scopethat includes issues relevant to public health. It is particularly necessary
to coordinate research with the regulatory process in an effort to assure themaximum application of scientific knowledge in the nuclear power industry.
Status of Actions
NRC agreed with this recommendation, and as a result, began a number of major
studies and initiatives. For example, the Agency created a separate branch to
apply reliability and risk assessment techniques and insights to reactor
regulation. Specific plants have been examined extensively through probabilistic risk assessment techniques, specific design studies, plant walkdowns, andanalysis of operating experience. Major studies and programs are sponsored by
the NRC to advance state-of-the-art techniques for assessment of accident
initiators and multiple failures across plant systems. A comprehensive study
was completed on system interaction events and numerous other studies have been
completed on system and component reliabilities. These analyses led to
hardware modifications, procedural improvements, and increased understandingof plant syst~m interactions, dependencies and system/component reliability.
These studies led to plant modifications and procedural improvements, and havebeen reflected in action requests in NRC Bulletins and Generic Letters, andincorporated in the Commission1s severe accident program and the subsequent
Individual Plant Examinations for all operating reactors.
NUREG-1355

18

Further. all licensees and applicants have conducted detailed control roomdesign reviews to determine if their control rooms provide satisfactory
information to allow operators to prevent or cope with accidents. As guidance
for the effort. NRC published "Guidelines for Control Room Design Reviews"(NUREG-0700) in 1981. This document delineated basic human factors analysis
techniques and accepted human factors design principles and criteria. In addition. Chapter 18. "Human Factors Engineering." of liThe Standard Review Plan"(NUREG-0800). was published to provide licensees and applicants with the criteria by which the staff would review their designs for the main control room andcontrol centers outside the main control room.
Part of this effort by each licensee and applicant included a function and task
analysis to determine what tasks the operators were expected to perform andwhat information and control capability was needed to perform them. These
information and control requirements were then compared to the controls anddisplays in the control room to determine the availability and acceptability of
the instrumentation. In addition. each control room was surveyed to identify
deviations from accepted human factors principles for control room layout. theusefulness of audible and visual alarm systems. its information recording andrecall capability. and the control room environment. Each licensee and applicant then submitted a summary report outlining proposed changes and schedules
for their implementation. The report also provided justification for thosesafety-significant human engineering deficiencies that were to be left
uncorrected or partially corrected.
Implementation of control room improvements. including some significant designchanges. is well under way. The NRC has identified no serious significant
design flaws that have not been corrected.
With regard to the coordination of research on public health issues. NRC is anactive participant on the Committee on Interagency Radiation Research andPolicy Coordination (CIRRPC). The CIRRPC has supported. coordinated. andreviewed efforts in the health effects area. including radio-epidemiological.
radiobiological. and dosimetry studies. CIRRPC issued liThe Federal Ionizing
Radiation Research Agenda Related to Low Level Biological Effects: FY 1985.11
which delineates and compares federally supported research efforts in 1981 and1985. Also. CIRRPC directly supports an update of the 1980 comprehensive
report by the National Academy of Sciences (NAS) on the effects of low-level
radiation. This update is being prepared by the NAS Committee on the
Biological Effects of Ionizing Radiation (BEIR). Known as the BEIR V report.
it is expected to be available in the spring of 1989.
NRC's budget fcirstudies on the biological effects of ionizing radiation
represents about 3 percent of all federal expenditures in this area. NRC
support is limited to projects of direct applicability to the Agency's responsibilities that are not sponsored by other agencies. Examples of NRC's
projects incluqe experimental development of models for early mortality andmorbidity due to the accidental inhalation of radionuclides. development ofmodels for assessing the health consequences of reactor accidents. and afeasibility study to better characterize the risks of low-level radiation
through studies on the radiation effects at the molecular and cellular levels.

NURE~-1355

19

The development of a data base to support epidemiological research on thehealth effects of ionizing radiation will result from requirements included ina proposed revision of Agency regulations (10 CFR Part 20) now before theCommission. The proposed requirements were developed as a result of a request
by the National Cancer Institute (NCI) and followed meetings with NCI staff,
industry groups, labor unions, and others. The data base is to include nuclear
power workers as well as other personnel in the nuclear industry.
A.S

Enforce Higher Standards for Licensee Responsibilities
for Safety

and Accountability

Presidential Commission Recommendation
Responsibility and accountability for safe power plant operations, including
the management of a plant during an accident, should be placed on the licensee
in all circumstances.
It is therefore necessary to assure that licensees arecompetent to discharge this responsibility.
To assure this competency, and inlight of our findings regarding Metropolitan Edison, we recommend that the
Agency establish and enforce higher organizational and management standards forlicensees. Particular attention should be given to such matters as the following: integration of decisionmaking in any organization licensed to construct
or operate a plant; kinds of expertise that must be within the organization;
financial capability; quality assurance programs; operator and supervisor
practices and their periodic reevaluation; plant surveillance and maintenancepractices; and requirements for the analysis and reporting of unusual events.
Status of Actions
NRC fully agreed with this recommendation and shortly after the accident acted
to upgrade organizational, management, and technical capabilities, such as
emergency operating procedures, in order to minimize the potential for futureserious accidents. Further, increased attention has been placed on theoperating plants and the capabilities of licensee management through increased
Commission and staff visits and meetings, including meetings with licensee
Boards of Directors when warranted.
As discussed in a number of responses, the nuclear industry has made considerable progress since the accident at Three Mile Island. There is a heightened
sense of responsibility and accountability for safe plant operations.
Industryorganizations, such as the Institute of Nuclear Power Operations, have actively
encouraged higher organizational and management standards. Additionally, NRC
has established a number of initiatives and elevated the standard of acceptability for licensees. The result has been increased awareness on the part ofboth industry and NRC of the importance of safe plant operations and theevolution of a much lower threshold of sensitivity to what constitutes safe
operation.
The heightened awareness by industry of the importance of safe plant operations
and the constant vigilance by NRC have resulted in substantial improvementsin the integration of decisionmaking; in the acquisition of additional staff
expertise for plant operations; in the implementation of more aggressive andcomprehensive quality assurance programs; and in operator and supervisor
practices. A strong emphasis has been placed on improving maintenance practices
and upgrading requirements for the reporting of abnormal plant operations by
the licensee.
NUREG-1355

20

In 1980, the Systematic Assessment of Licensee Performance (SALP) program wasestablished. The NRC inspection program was also expanded and made moreaggressive. The resident inspector program, for example, was establishedshortly after the TMI-2 accident and resident inspectors are now located at all
reactor sites .. A Diagnostic Evaluation Program was established in 1987 for NRC
to conduct in-depth probes of management capabil ities and plant performance atselected plants. A performance indicator program has been instituted as anadditional tool to assess the performance of each plant. Finally, to integrate
the results of.the many assessment programs, senior NRC managers began holdingsemi-annual meetings in 1986 to analyze plant performance and to identify thoseplants needing additional regulatory attention. All of these efforts havecontributed to a significant strengthening of the management and staff and to ahigh degree of safety awareness at every nuclear plant.
A.6

Locate New Power Plants in Remote Areas

Presidential Commission Recommendation
In order to provide an added contribution
required, to the maximum extent feasible,
remote from concentrations of population.
based on technical assessments of various
place, including those involving releases
recommendation 'F.2.)

to safety, the Agency should be
to locate new power plants in areas
Siting determinations should beclasses of accidents that can takeof low doses of radiation. (See

Status of Actions
Since the TMI-2 accident, NRC has reviewed its siting policy with a view
towards the siting of advanced-design reactors. Although the basic regulations
concerning site location of a nuclear plant (10 CFR Part 100) have not been
modified since the issuance of the Presidential Commission's recommendation,
NRC.s policy remains that nuclear power plants should be located at a reasonable distance from densely populated areas. Technical analysis for a newsiting rule was performed in the early 1980's and showed that NRC's current
regulations and guidance (Regulatory Guide 4.8) result in the selection ofsuitably remote reactor sites. Work on the new siting rule was suspended
pending availability of the results of the Severe Accident Research Program.
The Commission is presently completing a regulation (10 CFR Part 52) to provide
for, among other things, the issuance of early site permits. This regulation
will establish the procedures and procedural requirements that would apply toapplications for nuclear power plant sites on which nuclear power plants ofcertified standardized design could be located. The intent of the regulation
is to provide for an early resolution of environmental and safety licensing
issues associated with nuclear power plant siting before construction begins.
The regulation will require that applicants consider a number of factors
affecting acceptability of the site location that have been included in former
siting reviews, including parameters for the site, the facility, theenvironment, the locale, and the population. An environmental report will be
required that addresses the environmental effects of the construction andoperation of a nuclear power plant (or plants) that have characteristics thatfall within the postulated site and reactor parameters.

NUREG-1355- 21

In additiont an applicant for an early site permit would be required todemonstrate that the area surrounding the site is amenable to emergency planning.
This requirement would provide reasonable assurance that adequate protective
measures could be taken in the event of a radiological emergency at the sitet
and that these measures employ well-established accident analysis techniquest
including consideration of the potential effects of severe and design-basis
accidents upon the surrounding populace and environment.
A.7

Plan for Post-Accident Cleanup and Recovery

Presidential Commission Recommendation
The Agency should be directed to includet as part of its licensing requirements,
plans for the mitigation of the consequences of accidents, including thecleanup and recovery of the contaminated plant. The Agency should be directed
to review existing licenses and to set deadlines for accomplishing any necessary modifications.
(See recommendations 0.2 and 0.4.)
Status of Actions
NRC agreed with the general thrust of this recommendation, and in March 1980
requi red all reactor plant 1icensees to modify 1 icensed operator trai ning
programs to include instructions on the use of installed plant systems tocontrol or mitigate an accident in which the core is severely damaged. Suchplant systems included additional plant shielding to protect safety equipment
and allow access to vital areas, post-accident sampling capabilitYt and reactor
coolant system vents. Further, extensive work has been conducted to better
understand, cope witht and minimize the probability of severe accidents.
Action in this regard continues today and includes training programs, specificplant e~aminationst research in core-melt accident progression and mitigation,and the use of probabilistic risk analysis (PRA) techniques to identify andeliminate design weaknesses.
NRC is conducting major research studies on severe accident phenomena anduncertainties. These studies include (1) the behavior of severely damaged
fuelt including the generation of oxygen and hydrogent (2) the behavior of thecore melt in its interaction with water, concrete, and core-retention materialst and (3) the effect of potential hydrogen burning and/or explosions on
containment structure integrity. Work on the hydrogen control aspect of thisprogram resulted in a Hydrogen Control Rule that was approved by the Commission
and published in the Federal Register (FR) on January 25t 1985.
Severe accidents were addressed in April 1983 by a Policy Statement that set
forth the Commission1s intentions for rulemaking and other regulatory actions
for resolving safety issues related to reactor accidents more severe thandesign-basis accidents (48 FR 16014). Certain severe accident technical issues
will be dealt with for future and existing plants through procedures and ongoing severe accident programs identified in the Policy Statement and described
more fully in NUREG-1070.
Further, in an August 1985 policy statement on severe accidents in nuclear
power plants (50 FR 32138), the Commission proposed to require that eachlicensee perform a systematic examination of its plants to identify any
plant-specific vulnerabilities to severe accidents. This plant-specific
NUREG-1355

22

examination, referred to as the Individual Plant Examination Program (IPE),
was requested in Generic Letter 88-20, dated November 23, 1988. It entails anassessment of all operating plants to identify risks or severe accident vulnerabilities, ~nd is being uridertaken to assess severe accident risk at
operating plants. These studies will be quite comprehensive, focusing on thoseareas which have previously been identified as significant to risk. This
assessment will utilize PRA (or PRA based) techniques and include both fluid/
electrical systems and containment performance and capabilities. Vulnerabilities identified by each utility will be reported to the staff, along with any
planned improvements. The staff met with representatives of all operating
plants in February 1989 to review the IPE program methods and reporting require~ments. Final technical guidance for conducting the program will be transmitted
to the industry by mid-1989. Completion of IPE studies for internal events forall operating plants is expected within three years of that date.
As a result of findings from a recent NRC draft study on reactor risk
(NUREG-1150) which indicated large uncertainties in the ability of some lightwater reactor (LWR) containment buildings to successfully survive certain
severe accident challenges, NRC undertook a new review of reactor containmentbui 1di ng capabi 1ities. Thi s revi ew, called the Containment Performance
Improvement (CPI) program, was initiated in 1987 with a generic review ofboiling water reactor (BWR) Mark I containments.
The objective of this review
is to determine containment building performance in accidents beyond the Design
Basis by evaluating sequences that lead to core melt, reactor vessel failure,and challenges to containment structures, such as the potential for molten
core-melt material to attack the dry well liner. The staff presented its
recommendation on Mark I containment buildings to the NRC Commission in January
1989. The thrust of these recommendations is that Mark I containment buildings
are adequately safe, but that cost-effective safety enhancements have been
identified that would improve safety. The Commission has these staff recommendations under consideration.
The staff 'will report its findings of reviewson other containment types to the NRC Commission over the next year.
Among the difficulties in timely cleanup and decontamination after the TMI
accident was the uncertainty of adequate funding for such a large undertaking.
The licensee had only $300 million in property insurance proceeds available for
accident cleanup. Therefore, the NRC promulgated an interim regulation in 1982
which required each reactor licensee to obtain the maximum amount of property
insurance then available (subject to exemptions for small reactors). A final
property insurance rule was promulgated in 1987 requiring licensees to obtain$1.06 billion in property insurance at each site and requiring that a priority
on decontamination funding be established, subject to review and approval of
the Director, Office of Nuclear Reactor Regulation.Petitions have been received from licensees and the insurance industry to
clarify and perhaps change the nature of the decontamination provision.
Therefore a followup rulemaking dealing with these petitions has been implemented. The NRC would not expect to weaken the public protection now available
with the existing rule.
Finally, the post-accident examination and recovery program at TMI-2 hasprovided valuable lessons in the cleanup and disposal of highly contaminatedwaste. For example, experience with the development and use of robots at TMI-2

NUREG-1355

23

has lead to effective techniques for decontamination and inspection while mlnlmizing the radiation exposure of personnel. The TMI-2 recovery program has
been systematically developed and well documented, and thus serves to identify
the issues and possible approaches to accident recovery. (See also Section
D.6 of this report.)
A.8 and A.8.a

Assess the Need for Safety Improvements and Evaluate New
Criteria for Safety Standards

Presidential Commission Recommendation
Because safety measures to afford better protection for the affected population
can be drawn from the high standards for plant safety recommended in thisreport, the NRC or its successor should, on a case-by-case basis, before
issuing a new construction permit or operating license:.
Assess the need to introduce new safety improvements recommended in thisreport, and in NRC and industry studies.
Status of Actions
NRC agreed with this recommendation. Soon after the accident at Three Mile
Island (TMI) Unit 2, the Commission imposed a moratorium on licensing until new
criteria for safety improvements could be developed. The new licensing
criteria resulted from the "Lessons Learnedll studies of the TMI accident.
These studies resulted in the development of the TMI Action Plan, NUREG~0660,
which provided a comprehensive and integrated plan to improve the safety of
nuclear power plants. Specific items from NUREG-0660 were approved by theCommission in NUREG-0737 for implementation on operating reactors and on
operating reactor license applications. The Commission later established the
additional acceptance criteria for pending construction permit applications ina rule, 10 CFR 50.34(f).
The Commission also studied the lessons of previous experience with plant
construction (NUREG-1055). As a result, additional emphasis is being placed on
inspection of design activities and on the adequacy of control measures for thedesign process.
In August 1985, the Commission published its Severe Accident Policy Statement,
which established the criteria needed for all future applications for construction permits (CP). That policy stated that a new design for a nuclear power
plant can be shown acceptable for severe accident concerns if it meets thefollowing criteria and procedural requirements:
Demonstrati~n of compliance with the procedural requirements and criteriaof the current Commission regulations, including the Three Mile Island
requirements for new plants as reflected in the Construction Permit Rule
(10 CFR 50.34(f));
Demonstration of technical resolution of all applicable Unresolved Safety
Issues and the medium- and high-priority Generic Safety Issues, including a
special focus on assuring the reliability of decay heat removal systems
and the reliability of both ac and dc electrical supply systems;

NUREG-1355

24

Completio'n of a probabil istic risk assessment (PRA) study and consideration of severe accident vulnerabilities that the PRA exposes, along with
the insights it may add to assurance of no undue risk to public health andsafety; a:ndCompletion of the staff review of the design with a conclusion of safety
acceptability using an approach that stresses deterministic engineering
analysis and judgement complemented by PRA.
A.B.b

Review licensee and Operator Qualifications

Presidential Commission Recommendation
Review, considering the recommendations set forth in this report, thecompetency of .itheprospective ope rat ing 1icensee to manage the plant and theadequacy of its training program for operating personnel.
Status of Actions
NRC agreed with the intent of this recommendation.
Requirements for assuring
the competency of a prospective operating licensee to manage the plant and theadequacy of its training program for operating personnel have been developed
for new operating plants and for the licensing ,of future advanced plants.
Several Agency" documents have been written and a number of initiatives havebeen developed to address the issue. For example, the inspection program now
involves evaluations of licensee readiness to operate a plant for both a newlicensee and for a lice_nsee starting up a plant after a prolonged shutdown.
These inspection requirements are normally satisfied by different team inspections, including the construction appraisal for new plants and operational
readiness review team inspections. These inspections closely scrutinize thequality of construction, management capability, and the turnover process fromconstruction management to operations management. The readiness of the new
management to safely operate the plant is comprehensively assessed and includes
detailed requirements for startup observations to gain a sense of operational
competence.
'
The industry has also become increasingly sensitive to the need for increased
competence at the start of new plant testing and operations and has embarked on
an extensive startup lessons-learned information exchange program. This effort
was accomplished, in part, by industry support groups, such as the Institute of,Nuclear Power Operations and the Nuclear Utility Management and Resources
Council, individual utility initiatives, and nuclear steam supply vendors.
(See also Sections B.3.b and c of this report.)
Both the industry and NRC have initiated programs to assess the adequacy of alicensee's training program for operating personnel. A major role in assuring
operator readiness to operate a new plant is filled by plant-specific simulators that have' been built or ordered for most of the plants in the country.
Further, utilities have established an extensive training program in manydifferent areas and, upon review and demonstration of acceptability, receive
accreditation of their program. The operator training and NRC examination
process have also been upgraded. (See also Sections C.1, C.2, and C.3 of thisreport.)NUREG-1355

25

A.8.cEstablish Emergency Planning Prerequisites for New Licenses

Presidential Commission Recommendation
Condition licensing upon review and approval of the state and local emergency
plans.
Status of Actions
NRC agreed with this recommendation.
For all plants licensed to operate since
the effective date of the revised emergency planning requirements (November 3,1980), NRC has requested and received from the Federal Emergency Management
Agency (FEMA) either formal approval or interim findings that State and local
offsite plans and preparedness are adequate and capable of implementation,prior to full-power operation. For plants licensed before this date, the same
FEMA findings were based primarily on observations made during field exercises
and on the existence of upgraded plans.
In those situations where State and local governments have refused tocooperate in the planning effort, utilities may develop and submit offsite
emergency response plans to NRC. These plans substitute utility resources for
those of the State and local governments. In its evaluation of those utility
offsite emergency response plans, NRC will assume that State and local
governments will, in an actual event, use their best efforts to protect the
public health and safety in responding to the emergency and will generally
follow the utility's plan. If the utility offsite plan and the assumption of"realism" are not adequate to meet all the emergency planning requirements,
FEMA has developed regulations, as directed by Executive Order, to provide
Federal support and assistance in order to assure that utility plans areadequate to meet NRC licensing requirements.
To further assure that State and local governments receive adequate support,
in responding to a Severe radiological accident, a comprehensive Federal
Radiological Emergency Response Plan (FRERP) has been developed. This plan,
published in final form in 1985, provides the means for organizing Federal
resources in a coordinated manner to support State and local authorities.
A.9 and A.9.a

Improve Rulemaking and Generic Safety Issues

Presidential Commission Recommendation
The agency.s authorization to make general rules affecting safety should
require the development of a public agenda according to which rules will be
formulated.
Status of Actions
The NRC agreed with this recommendation and, as required by Executive Order
12044, established a semiannual agenda for significant rulemaking actions.
Starting in October 1981, this regulatory agenda has been published as
NUREG-0936 and is routinely noticed in the Federal Register. This agenda
describes the need and legal basis for each regulation and indicates the statusof each regulation on the agenda (or previous editions of the agenda) until theissuance of final rules.
NUREG-1355

26

A.9.b

Set Deadlines for Safety Issue Resolution

Presidential Commission Recommendation
The Agency's authorization to make general rules affecting safety should
require the agency to set deadlines for resolving generic safety issues.
Status of Actions
Soon after the TMI-2 accident, NRC established deadlines for resolution of the
Unresolved Safety Issues that existed at that time and for their implementation'
on a plant-by-plant basis. NRC agreed that setting such deadlines was
essential to assuring the staff and industry commitment to these importanttasks. Unresolved Safety Issues are by definition the most significant
sub-category of generic licensing issues. Each generic licensing issue has
been ranked according to its assessed safety significance, and genericcorrespondence has been issued to licensees for those issues that have been
resolved.
The early identification, assessment. and resolution of safety issues continue
to be high priority activities within NRC. As these issues are resolved and as
plants are modified, new issues continue to be identified through the assessment of domestic and foreign operating experience, design and safety analysis
reviews, and research programs. In order to assure that new generic issues areproperly characterized as to their safety importance. and that high priority
issues are resolved through timely plant modifications, in April 1987 NRC
consolidated all work on generic issues in the Office of Nuclear Regulatory
Research under a Deputy Director for Generic Issue Resolution. A strong
incentive for this reorganization was to assure that generic issues receive
dedicated attention by an NRC senior manager. and that the path to resolutionof each issue was carefully formulated and available for Commission review. In
this. regard, periodic Commission meetings are held to discuss the status andthe timetable for resolution of priority issues.
A.9.c

Conduct Periodic and Systematic Reevaluations of Existing Rules

Presidential Commission Recommendation
The Agency's authorization to make general rules affecting safety should
require a periodic and systematic reevaluation of the agency's existing rules.
Status of Actions
NRC agreed with this recommendation and initiated action to assure that its
regulations were reviewed for cohtext and structure. Subsequently. Executive
Order 12044 was issued requiring a periodic and systematic reevaluation ofexisting rules and that regulations be written in plain English. NRC initiateda review of its rules for content, quality, and clarity and placed initialpriority on areas where rules may be affected by the accident at Three Mile
Island.
The NRC rules most directly associated with TMI accident issues include
operator training, emergency planning. environmental monitoring, radiation
protection. hydrogen control. and consistent treatment of fission product
NUREG-1355

27

releases from failures of fuel cladding. The rules in these areas have beenreviewed and actions taken as needed. Systematic reviews of other regulations
also have been carried out or are under way for several programs throughout the
Agency.
Additionally, in 1984 the NRC Office of Nuclear Regulatory Research (RES)
initiated a program to review selected existing regulatory requirements interms of risk effectiveness. The results of the review were issued in a
two-volume report (NUREG/CR-4330, Volumes 1 and 2) was published in 1986.
Volume 1 summarized the results of a survey to identify regulatory requirementsthat may have marginal importance to safety, and Volume 2 provided the resultsof a detailed evaluation in terms of risk, dose, and cost for assumed changes
in requirements for three regulatory areas. Rule changes are being initiatedas appropriate.
Another program was initiated in 1984 by the NRC Executive Director forOperations (EDO) to identify inconsistencies among safeguards (security)
regulations, Regulatory Guides, inspection procedures, licensing criteria, andother Agency guidance. This effort was conducted by a Safeguards Interoffice
Review Group that issued a series of reports documenting follow-up staff
actions for the minor inconsistencies identified.
A program initiated in 1985 to systematically review and modify plant-specificTechnical Specifications identified ways to improve their efficiency andeffectiveness. These approaches are being implemented by the Technical
Specifications Coordination Branch, Division of Human Factors Technology,
Office of Nuclear Reactor Regulation.
Thus,-a number of ongoing NRC programs have been established to systematicallyevaluate existing rules and to take appropriate action to eliminate or revise
rules found to be overlapping, inconsistent, or unnecessary.
A.9.d

Improve Rulemaking Procedures

Presidential Commission Recommendation
The Agency's authorization to make general rules affecting safety should define
rulemaking procedures designed to create a process that provides a meaningful
opportunity for participation by interested persons, that ensures carefulconsideration and explanation of rules adopted by the agency, and that includes
appropriate provision for the application of new rules to existing plants. In
particular, the agency should: accompany newly proposed rules with an analysisof the issues they raise and provide an indication of the technical materials
that are relevant; provide a sufficient opportunity for interested persons toevaluate and rebut materials relied on by the agency or submitted by others;
explain its final rules fully, including responses to principal comments by the
public, the ACRS, and other agencies on proposed rules; impose when necessary
special interim safeguards for operating plants affected by generic safety
rulemaking; and conduct systematic reviews of operating plants to assess theneed for retroactive application of new safety requirements.

NUREG-1355

28

Status of Actions
NRC has implemented a number of procedures to provide meaningful participationin its rulemaking activities by interested persons. NRC publishes an agenda ofrulemakings under development and issues advance notices of proposed rulemaking
and proposed rules for comment. Analyses of comments on proposed rules and .
discussion of their resolution are made public. Public hearings or meetings
are held on rulemaking actions of particular interest and importance andimportant rulemaking actions are discussed in open NRC meetings. The Agency
also permits the public to petition NRC to issue, revise, or withdraw a rule.
Careful consideration and explanation of rules adopted by NRC are assured byproviding that proposed and final rules sent to the NRC Commissioners forconsideration are accompanied by a staff paper that identifies the concerns,
presents alternatives to the proposed action, discusses the value and impact ofeach alternative, and summarizes comments received and their resolution (final
rules).
The rulemaking process was also reviewed to ensure that it is properly focusedon resolving important safety issues and that the procedures are clear, understandab 1e, efti cient, and well documented. Several means to enhance theCommission's rulemaking efforts were addressed in NUREG-0499, including
Supplement 1, and through delegation of some rulemaking authority to the
Executive Director for Operations. In addition, the Office of Nuclear
Regulatory Research has been assigned the responsibility of investigating andevaluating possible changes to the process as an ongoing activity.
In order to assure that new requirements are applied to operating plants in asystematic manner, NRC has modified its regulation on backfit (10 CFR 50.109),
established a program to give direction and guidance on the application ofplant-specific backfits (NRC Manual Chapter 0520), and established theCommittee to Review Generic Requirements in 1981 to assure a thorough review ofindustry-wide requirements before their issuance.
A.10

Revise licensing Procedures to Foster Early and Effective Resolution of
Safety Issues

Presidential Commission Recommendation
licensing procedures should foster early and meaningful resolution of safetyissues before major financial commitments in construction can occur. In orderto ensure that safety receives primary emphasis in licensing, and to eliminate
repetitive consideration of some issues in that process, the Commission recommends the following [actions.] (See following Sections A.IO.a through A.10.f.)
Status of Actions
Even before these recommendations were made by the Presidential Commission, NRC
had in place a large body of regulations that gave applicants for construction
permits and operating licenses opportunities to seek early resolution of bothsite issues (Subpart F of 10 CFR Part 2 and Appendix Q to 10 CFR Part 50) anddesign issues (Appendices M, N, and 0 to 10 CFR Part 50).

NUREG-1355

29

In response to this recommendation, NRC revised its "immediate effectiveness"procedures (10 CFR 2.764) so that no operating license would become effective
until the NRC Commissioners had an opportunity to ensure that significant andrelevant TMI-related issues were resolved before operation. In addition, it
was originally assumed that legislation was needed to give the Agency clear
authority to carry early resolution of issues further, including the authority
to issue licenses combining a construction permit and an operating license. The
NRC has since concluded that it already has sufficient authority to issue suchlicenses, and the Commissioners have before them now a draft final rule thatprovides for site permits issued apart from construction permits, certificationsof standard designs, and combined construction permits and operating licenses,
all aimed toward very early and meaningful resolution of safety issues before
major financial commitments are made.
A.10.aEliminate Duplicative Considerationof Issues During Plant Licensing-Presidential Commission Recommendation
Duplicative consideration of issues in several stages of one plant1s licensing
should, wherever possible, be reduced by allocating particular issues (such as
the need for power) to a single stage of the proceedings.
Status of Actions
Since this recommendation was provided by the Presidential Commission, NRC has
promulgated a number of rules designed to impose reasonable limits on duplicative consideration of issues. For instance, 10 CFR 51.106 bars considerationof the need for power or alternative sites in operating license hearings;
10 CFR 2.734 codifies and refines the NRC case law on the reopening of hearings;
the Agency's "backfitrule,1I 10 CFR 50.109, assures that licensing action willproceed even though backfits not required for adequate protection of the publichealth and safety are under consideration.
Finally, the draft final rule on standardization and combined licenses (10 CFRPart 52) gives significant finality to the issue resolutions embodied in site
permits and design certifications.
In general, those issues will not bereconsidered during the term of the permit or certification unless adequate
protection requires some change to the terms ~f the permit or certification.
Thus, except in rare instances, applicants for construction permits oroperating licenses that reference a site permit or design certification will
not face duplicative consideration of issues resolved in the permit or
certification.
A.10.bResolve Recurrent Licensing Issues by Rulemaking

Presidential Commissi~n Recommendation
Issues that recur in many licensings should be resolved by rulemaking.
Status of Actions
NRC agreed with this recommendation and in fact noted that this procedure wascurrent practice in 1979 and remains so today. A large portion of the Agency's
efforts are devoted to developing generic resolutions for safety issues.
NUREG-1355

30

Noteworthy examples of generic resolutions promulgated since the Presidential
Commission's recommendation are the NRC rules on fire protection, environmental
qualification of electrical equipment, reduction of risk from anticipatedtransients without scram, and reduction of risk from loss of offsite power.
The final rule on standardization and combined licenses, if adopted by theCommission, should help further the process of generic resolution. One impediment to generic resolution has been the enormous variety of designs among U.S.
power reactors. Widespread use of standardized designs should reduce this
impediment.
A.I0.cCombine Construction
Possible

Presidential

Permit and Operating

License Hearings When

Commission Recommendation

The agency should be authorized to conduct a combined construction permit andoperating license hearing whenever plans can be made sufficiently complete at
the construction permit stage.
Status of Actions
The NRC agreed with this recommendation.
However, the Agency had initial
doubts about both the NRC.s legal authority to issue such a license and thetechnical feasibility of completing the design before construction.
Today, however, the Agency is confident both of its own authority and thedesigners' abilities to complete the detailed design before construction.
The
draft final rule (10 CFR Part 52) now before the Commission provides for single
licenses that combine construction permits and licenses to operate. The
preamble to the draft rule notes that Section 161h of the Atomic Energy Act
gives the Agency the authority to issue such combined licenses, and that noother section of the Act denies it. The draft rule requires applicants for a
combined license to bring forward complete design information.
The combined
license would incorporate the tests and inspections that would show that theplant had been built in conformance with the license. Also resolved before
construction would be emergency planning issues. Under the draft rule, there
would be no hearing between construction and operation unless an affected
member of the public made a prima facie showing that the construction did notconform to the license, and that the issue was not exempt from adjudication
under the provision in the Administrative Procedures Act which exempts fromadjudication decisions that rest on clear-cut tests and inspections.
It is believed that the Commission's proposed 10 CFR Part 52 will foster earlyand meaningful 'resolution of safety and environmental issues; provide primaryemphasis on the safety of nuclear plant designs; and eliminate repetitive
consideration of issues through its provisions for early siting, for design
certification tulemaking for standard designs, and for the issuance of combined
licenses.
A.I0.dEliminate Further Appeal of Appeal Board Decisions

Presidential Commission

Recommendation

There should be provis~on for the initial adjudication of license ~pplications
and for appeal to a board whose decisions would not be subject to further
NUREG-1355

31

appeal to the administrator. Both initial adjudicators and appeal boards
should have a clear mandate to pursue any safety issue, whether or not it israised by a party.
Status of Actions
Even before these recommendations were made by the Presidential Commission, the
NRC had promulgated a rule, 10 CFR 2.786(b)(4), that greatly limited thegrounds on which parties could seek further Agency review of an Appeal Board
decision. However, in responding to these recommendations in 1979, NRC
expressed significant doubts about closing off all further Agency review. The
Agency believed then, and still believes, that if this recommendation were
followed it would remove the NRC Commissioners from an important dimension of
nuclear regulation.
Also, the NRC was reluctant in 1979, and still is, to give Agency adjudicators
a IIclear mandate to pursue any safety issue.1I This recommendation, although
it may seem consistent with Recommendation A.10's emphasis on safety, iscontrary to the same recommendation's emphasis on elimination of repetitive
consideration of issues in licensing proceedings. In 1979, the Agency
expressed its desire to continue to constrain adjudicators from pursuit of any
uncontested issue that wasn't a IIserious matter,1I but the Agency did say thatit had decided to eliminate language in the regulations that said that thissua sponte authority should be exercised IIsparinglylland only in lIextraordinary
rncumstances.1I This language was removed in late 1979 (see, for example,
10 CFR 2.760a). On June 30, 1981 the Commission issued a memorandum to its
Licensing and Appeal Panels relating to the raising of issues sua seonte in
Agency adjudicatory proceedings. The Commission stated that if a Llcensing or
Appeal Board raises an issue ~sponte in an operating license proceeding, it
shall issue a separate order making the requisite findings and briefly state
its reasons for raising the issue. A copy of any such order is to be provided
to NRC's Office of the General Counsel who advises the Commission on adjudicatory
matters. If the Commission determines that the issue raised can best be
resolved outside of the adjudicatory process, it will issue an order providing
an alternative means for addressing the issue.
A.10.eEstablish an Office of Hearing Counsel

Presidential Commission Recommendation
An Office of Hearing Counsel should be established in the agency. This officewould nQt engage in the informal negotiations between other staff andapplicants that typically precede formal hearings on construction permits.
Instead, it would participate in the formal hearings as an objective party,
seeking to assure that vital safety issues are addressed and resolved. The
office should report directly to the administrator and should be empowered toappeal any adverse licensing board determination to the appeal board.
Status of Actions
NRC studied the need for a separate office that could be viewed as an additional
representative of the public interest in nuclear safety. In addition, theAgency committed to consider a pilot program for intervenor funding.

NUREG-1355

32

Subsequently, NRC established a limited program of intervenor funding thatconsisted of providing intervenors to NRC proceedings with copies of hearing
transcripts. Congress responded by including in our appropriations legislation
every year, beginning in 1981, a provision that bars the Agency from paying theexpenses of, or otherwise compensating, intervenors in Agency proceedings.
Because of NRC's open regulatory process and the opportunities for public
involvement, an Office of Hearing Council was judged not to be needed.
A.10.fResolve Open Licensing Issues by a Given Deadline

Presidential Commission Recommendation
Any specific safety issue left open in licensing proceedings
by a deadline.

should be resolved

Status of Actions
In 1979, NRC agreed that plant-specific safety issues left open at the time oflicensing had to be resolved by deadlines incorporated as conditions in eachlicense. This practice continues.
NRC also agreed to consider whether each operating license should be conditioned
with deadlines for resolution and implementation of the Unresolved Safety
Issues (USI) applicable to each plant design. Although such license conditions
were not subsequently put in force, the Agency took a number of steps to assurethat plants licensed pending resolution of USIs and other generic issues
provide adequate protection to public health and safety. Even before the reportof the Presidential Commission, Congress required that NRC submit a plan,
including timetables, for the resolution of USls (PL 95-209, Sec. 210,
December 13, 1977). As USIs are resolved, deadlines for plant-specific implementation of the resolutions are established (for example, the new "station
blackout" rule, 10 CFR 50.63). Pending resolution of these issues, NRC has
carefully evaluated whether current regulations provide adequate protection in
the light of these issues (see NUREG-0649), and the NRC staff's Safety Evaluation Report for each plant under construction carefully considers the impact onthat plant of each USI.
As to future plants, it is NRC policy, as expressed in its Policy Statement on
Severe Reactor Accidents (50 Federal ReQister 32138, August 8, 1985), that any
new design must incorporate des;gn-speclf;c resolutions of all the technicallyapplicable USIs and medium- and high-priority generic issues. The draft final
rule on standardization and one-step licensing incorporates this policy as arequirement for all applicants for design certification and combined licenses.
A.11 and A.11.a
Presidential

Increase Emphasis on Systematic Evaluation of Operating
Plants and on Inspection and Enforcement

Commission Recommendation

The Agency's inspection and enforcement functions must receive increased
emphasis and improved management, including the following elements:
There should be an improved program for the systematic safety evaluation ofcurrently operating plants in order to assess compliance with current
NUREG-1355

33

requirements, to assess the need to make new requirements retroactive to otherplants, and to identify new safety issues.
Status of Actions
At the time of the accident at TMI-2, NRC had in place the Systematic Evaluation
Program (SEP). The SEP was initiated by NRC in 1977 to review the designs ofolder operating nuclear power plants to reconfirm and document their safety.
The review provided (1) an assessment of the significance of differences
between current technical positions on safety issues and those that existed
when a particular plant was licensed, (2) a basis for deciding how thosedifferences should be resolved in an integrated plant review, and (3) adocumented evaluation of plant safety.
The review of each plant by the SEP compared the as-built design with current
review criteria in 137 separate technical areas. These criteria were definedin Appendix A of NUREG-0820. The review revealed that certain aspects of plantdesign differed from current criteria. These discrepancies were considered in
the integrated assessment of the plant, which consisted of evaluating thesafety significance and other factors of the differences identified fromcurrent design criteria to arrive at decisions on whether backfitting wasnecessary for plant safety. To arrive at these decisions, engineering judgment
and a limited probabilistic risk assessment study were used.
From 1982 through 1984, NRC issued reports NUREG-0820 through NUREG-0828 to
document the SEP review and recommendations for 9 of the 10 subject plants.
(NUREG-0829 for the, 1ast SEP plant was issued in 1986 after a 1engthy plant (shutdown.) NRC distilled the experience gained from the SEP and concluded
that there were 27 technical areas where most of the plants reviewed deviatedin some manner from current acceptance criteria. The final SEP phase was toevaluate all plants against these 27 technical areas.
In 1980, Congress enacted Public Law 96-295 (the NRC Authorization Bill for
Fiscal Year 1980). Section 110 of that law required that NRC develop a program
for the systematic safety evaluation of operating reactors. The program
proposal would have extended the SEP to require licensees to compare theirplant design to the acceptance criteria in NRC's IIStandard Review P1anll(NUREG-0800). That program was not implemented for operating reactors.
Instead, the Commission determined, and the Congress agreed, that the scope of
the program was too broad to evaluate the safety of operating reactors
efficiently. Congress later specified in subsequent authorization bills thatfunds should not be spent to implement that program. However, those activities
were useful in that they focused attention on the needs and difficulties
associated with the systematic safety evaluation of operating reactors as they
relate to a constantly changing technology and the increasing scope of regulatory requirements.
Following the accident at TMI-2, NRC developed the TMI Action Plan (NUREG-0660)
from the safety lessons learned. The TMI Action Plan identified a large numberof correctiv~ actions to be implemented by operating plants. In 1981, NRC
senior management officials became concerned that the many new TMI-related
requirements that had been identified were being implemented in a fashion that
could adversely affect safety at the operating plants. They concluded that an
improved process was needed for ranking and imposing new requirements. The
NUREG-135534

Commission addressed this concern by creating in October 1981 the Committee to
Review Generic Requirements (CRGR). The CRGR imposed a disciplined review of
all new generic requirements. This new process provided for a more orderly andthorough assessment of the relative safety significance and/or cost benefit of
new generic requirements identified (1) to assure the expeditious implementation of improvements needed for safety, and (2) to more effectively apply thelimited resources of both operating plant licensees and NRC in implementing
improvements not required for adequate safety but which significantly reducerisk in operatijng plants. Analogous procedures for plant-specific actions werealso developed: and implemented by issuance of NRC Manual Chapter 0514. In
1985, the Commission approved a new rule for control of backfitting, 10 CFR
50.109, to codjfy the improved backfit control process which by that time had
proven effective in practice.
The TMI Action Plan also initiated the Interim Reliability Evaluation Program(IREP) in whlch plant-specific probabilistic risk assessment (PRA) studies were
to be performed to supplement the experience in NRC's "Reactor Safety Study"(WASH-1400).
One of the most significant conclusions drawn from SEP and IREP is that issues
related to the safety of nuclear power plants can be implemented more effectively
and efficiently in an integrated, plant-specific review. In addition, theexperience learned from SEP served to focus on the set of current licensing
criteria which should be evaluated for operating plants. Experience from IREP
has defined the methodology used to conduct a plant-specific PRA so thatconsistent, comparable results can be obtained to enhance an integrated plantsafety assessment.
Historically, licensing issues have been evaluated generically and guidelines
for any necessary corrective actions have been applied uniformly to all plants.
Although this approach has provided an effective means to ensure resolution ofthese issues, the generic. implementation has not given sufficient attention toplant-specific characteristics that have a direct bearing on the appropriatenessof the corrective action and the relative importance of the issue in relation
to an overall plan for any necessary plant improvements.
In some cases,
focusing on plant-specific characteristics identified alternative corrective
actions to provide an equivalent or greater measure of safety, often at lesscost to a licensee.
Consequently, NRC initiated a pilot program in 1985 to conduct integrated
assessments of two operating reactors using the combined experience of SEP and
IREP. Called the Integrated Safety Assessment Program (ISAP), it was intended
to be comprehensive in that it consisted of deterministic, probabilistic, andoperating experience evaluations of operating nuclear power plants. The issues
raised during the evaluation were integrated with all pending licensing
actions, unresolved generic issues, and licensee-initiated plant improvements.
The final outcome of ISAP was an integrated implementation schedule for theseissues, which would be updated periodically using the ISAP methodology
documented in the licensee's operating license.
In 1987 and 1988, NRC reviewed the ISAP pilot program experience in order todevelop a comparable program for all operating power reactors. The benefits of
the ISAP pilot program included: (1) finding common elements in separate review

NUREG-1355

35

areas and proposing a single integrated resolution; (2) addressing pending
requirements on a plant-specific basis; (3) dropping issues from further
consideration because of low safety significance; and (4) implementing plantmodifications having high safety significance on an expedited schedule.
Integrated Safety Assessment, the follow-on to ISAP, was incorporated as
an option for licensees into NRC's Severe Accident Program Individual Plant
Examination (IPE, Generic Letter 88-20).

A.n.b

Establish a Program for the Systematic Assessment of Experiencein Operating Reactors

Presidential Commission Recommendation
There should be a program for the systematic assessment of experience inoperating reactors, with special emphasis on discovering patterns in abnormal
occurrences~ An overall quality assurance measurement and reporting system
based on this systematic assessment shall be developed to provide: (1) ameasure of the overall improvement or decline in safety, and (2) a base for
specific programs aimed at curing deficiencies and improving safety. Licensees
must receive clear instructions on reporting requirements and clear communications summarizing the lessons of experience at other reactors.
Status of Actions
NRC agreed strongly with this recommendation. As a result, a number ofsignificant organizational and program requirements were modified to establish
a systematic and comprehensive process to collect, assess, and disseminate
operational experience.
In mid-1979, NRC established the Office for Analysis and Evaluation of Operational Data (AEOD) to initiate a broad, coordinated program within major NRC
program offices to assess operating experience. This was one of the Commission's
earliest major steps toward improving the use of licensee operating experience
to identify and resolve problems with potential safety-related implications.
AEOD's focus and role are to provide a strong capability for the analysis ofoperating experience, independent of the routine regulatory activities associated with licensing, inspection and enforcement, and to disseminate thelessons learned to NRC, the nuclear industry (domestic and international), andthe public. AEOD serves as a focal point for interaction with outside andforeign organizations performing similar work.
By 1989, AEOD had grown to encompass additional responsibilities for the incident response, investigation, and diagnostic evaluation programs, plus theagency's Technical Training Center. These areas all relate to assessing
operating experience and applying the lessons learned.
Some of the major accomplishments of AEOD since 1979 include:
1.

Feedback of lessons learned from operating experience through the issuanceof 35 case studies, 180 engineering evaluations, 24 special studies, and
117 technical reviews. Case studies such as those on motor-operated valve
problems, air system problems, and loss of the decay heat removal function
resulted in considerable activity by NRC and licensees to assure the

NUREG-1355

36

safety of operations. These documents are widely disseminated to NRC
offices. industry. and to the public.
2.

Codification of the reporting requirements for events that expanded thescope and content of reporting for safety-related events. while eliminating the reporting of events of lesser importance. to better focus regulatory actions. These revised requirements (10 CFR 50.73) were clearlycommunicated to licensees in a series of documents (NUREG-I022 and Supplements 1 and 2) and discussed in a number of workshops.

3.

Assessment of trends and patterns of operational experiences. such as
rapid plant shutdowns. engineered safety system actuations. technicalspecification violations. and safety system failures. Focus is routinely
placed on data from individual plants. from the industry as a whole. andfrom specific vendors. Abnormal plant occurrences are reported quarterly
to Congress. In addition. special focus is devoted to trends from newplants (that is. those with less than 24 months of operational experience).
with the Ifeedback of 1essons 1earned provi ded to subsequent new plants andplants resuming operations after extended outages.

4.

Use of anew technique for storing and retrieving the information reported
in Licen~ee Event Reports (that is. the coding of the sequences of occurrences that constitute an event). as well as development of specialized
data bases for trends and patterns and performance indicators. These
actions improve the Commission1s ability to identify areas warranting
regulatory attention and also provide a measure of the industry1s overall
improvement or decline.

5.

Increased assessment of foreign operating experience and initiation ofactions to enhance or assure the safety of operations for U.S. reactors.
Also. active participation in the creation and implementation of international incident reporting systems. including major contributions from.
U.S. experience to the world wide base of information.

6.

Investigation of events at operating plants that are most significant tosafety using a team evaluation approach. including complete reports offindings on incidents and their root causes. Three such team investigations have been conducted to date.

7.

Diagnostic evaluations of licensee performance in a safety-related framework to identify the root causes of performance adversely affecting plantsafety.
Four such evaluations have been conducted to date. with thelessons learned being made available to others and corrective actions
implemented as appropriate by the various parties involved (for example.
the licensee. the NRC regional office. or the program office).

In addition to AEOD activities. significant attention and resources weredirected by other NRC offices. notably the Office of Nuclear Reactor Regulationand the Regions. on the review and assessment of operating events. The immediate notification reports (10 eFR 50.72) are carefully reviewed daily andweekly to identify potential generic concerns and significant plant-specificitems requiring additional regulatory attention and followup. This effort iscoordinated within the Agency and its results are incorporated into thelonger-range studies conducted by AEOD. Additionally, the overall performancetrends and adequacy of event followup and problem resolution are evaluated as
NUREG-1355

37

part of the Systematic Assessment of Licensee Performance (SALP) process.
These periodic SALP reports provide an overall perspective and rating ofoperating plants in seven functional areas approximately every 15 months.
Industry has also initiated responsive actions. A Nuclear Safety Analysis
Center has been established to conduct systematic reviews of available plant
event reports and data; to identify possible precursor events, trends, andproblem areas; to perform failure analyses; and follow up with utilities on
identified problem areas. The electric utility industry has established an
Institute of Nuclear Power Operations, whose charter includes review of nuclear
power operating experiences for analysis and feedback to utilities; incorporation of lessons learned from such reviews into training programs; and coordi~ation of reporting and analysis with other organizations.
Each reactor
manufacturer also improved its programs for review and feedback of operating
experience to enhance operational safety and plant availability and to integrate their programs with thQse of other organizations.
The Commission's' increased attention to the systematic assessment and feedbackof lessons learned from operating experience, plus increased emphasis on implementing actions to lessen the recurrence of such events, has undoubtedly
contributed to recent trends indicating industry-wide improvements. The trends
show decreases in the frequency of rapid reactor shutdowns and some otherreportable occurrences and marked improvements in on-line performance.
A.ll.cAssess Substantial Penalties for Licensee Failures to Report Safety
Information

Presidential Commission Recommendation
The agency should be authorized and directed to assess substantial penalties
for licensee failure to report new IIsafety-relatedll information or forviolations of rules defining practices or conditions already known to beunsafe.
Status of Actions
NRC agreed with this recommendation. At the time of the Three Mile Island
accident, NRC's authority to impose civil penalties was limited by the Atomic
Energy Act to $5,000 per-violation-per-day, with a maximum penalty of $25,000
for all violations within a 30-day period. The Atomic Energy Act of 1954 was
subsequently amended at NRC's request to provide civil penalties of up to$100,000 per-violation-per-day without any maximum cap.
In addition to increasing the statutory amount of a civil penalty, theCommission has adopted an enforcement policy. At the time of the accident, thestaff had developed enforcement guidance, but the Commission had not expressly
approved the guidance. In 1980 the Commission promulgated IIpolicy and Procedurefor Enforcement Action,lI which has since been periodically updated to reflect
experience in applying the policy, and is codified at 10 CFR Part 2, Appendix
C, of the Commission's regulations. The policy provides guidance on characterizing the severity of a range of violations by providing examples in eight subject
areas, including plant operations, transportation, health physics, safeguards,
and emergency planning. The policy also provides guidance on when to issue acitation, a civil penalty, or an order, and on important factors to include in
NUREG-1355

38

assessing a penalty, including who identified the violation, the extensivenessof corrective actions, any relevant prior performance, prior notice of thepotential for a violation, number of examples involved, and duration of theviolations. Applying these factors results in higher civil penalties for poor
performance and, conversely, reduces penalties for licensees who promptly
identify and correct violations. The failure of licensees to report violations
and not respond to potential safety conditions may result in civil penalties.
Civil penaltie~ have increased since the TMI-2 accident both in the number ofactions and in the amounts of penalties. For example, NRC issued four penalties
totaling $58,000 for reactors in 1977, while issuing 52 penalties totaling$3,585,500 in 1987.
A.ll.dImprove Auditing and Conduct Unannounced

Inspections of Licensees

Presidential Commission Recommendation
The Agency sho'uld be directed to require its enforcement personnel to perform
improved, inspection and auditing of licensee compliance with regulations and to
conduct major 'and unannounced ons itei nspect ions of particular plants.
"

Status of Acti'ons
NRC inspectio~ and enforcement activities have been significantly expanded,
strength~ned, and made more aggressive since the TMI-2 accident. Over the past
decade, Resident Inspectors (RIs) have been located at all reactor sites. In
fact, most siies have more than one RI. The RIs are the eyes and ears of the
Agency, alerti'ng NRC and plant personnel to possible emerging safety problems,in additjon t~ providing assurance that NRC regulations are being strictly
observed. Further, the inspection and auditing of licensing activities havebeen greatly expanded by the use of team inspections. Finally, NRC has shifted
its enforcement function into a separate Office of Enforcement.
The use of inspection teams made up of members from various disciplines havestrengthened onsite plant inspections to evaluate the effectiveness of licensee
programs and systems. NRC has instituted a variety of team inspections at
nuclear power ,plants, including:1.

Safety Sy'stem Functional Inspection (SSFI) - An in-depth engineering
review of the design configuration, maintenance, testing, and operation ofreactor systems, their components, and their supporting systems. The
inspection is performed by making a IIvertical slicell review of a particular safety system and following the potential generic significance ofthe findings to other plant systems.

2.

Safety S~stems Outage Modifications Ins~ection (SSOMI) - An in-depth
engineenng examination of system functlonality, oriented toward thesafety inipact of modifications that are made to safety systems during aparticular plant outage. This inspection focuses on how the modifications
have altered the original design considerations and safety margins, on
observations of the quality of the installation work on the modified
systems, and on the adequacy of full functional testing of the modified
systems.

NUREG-1355

39

3.

Operational Safety Team Inspection (OSTI) - An in-depth review of plant
operational programs, including maintenance, operations, surveillance
testing, corrective actions, management oversight, and safety review. The
inspection typically includes about 72 hours of round-the-clock in-plant
coverage, with emphasis on observation of control room operations andsurveillance activities. If appropriate, some aspects of the SSFI
inspection may be added to the scope of this inspection.

4.

0eerational Readiness Assessment (ORA) - A formal assessment of thellcensee1s readiness to operate a nuclear power' plant. It is a comprehensive evaluation of the licensee's program for design, construction, andpre-operational activities, so that issues and problems are identified ina timely manner.

5.

Emergency Operating Procedures (EOP) Team Inspection - An integrated
regional and Office of Nuclear Reactor Regulation team inspection of alicensee'-s EOPs to determine if they are technically correct and can be
performed in the plant by the staff. EOP team inspections have been
completed for 26 plants. The results are being reviewed to determine theextent to which additional inspection resources should be expended on thiseffort and to determine the need for updating EOP guidance to thelicensees.

6.

Regulatory Effectiveness Review (RER) - A program conducted by the staff
wlth the assistance of U. S. Army Special Forces personnel to evaluate thepractical effectiveness of physical security measures at operating reactors.
The program includes challenges to the licensee's physical security system.

7.

Augmented Inspection Team (AIT) - A systematic and thorough inspection ofa significant operational event. The purpose of an AIT is to diagnose a
specific event to determine the cause(s), conditions, and circumstances
relevant to that event and to communicate findings, safety concerns, andrecommendations to NRC management.
-

8.

Incident Investigation-Team (IIT) - A team composed of technical experts
who have not had previous significant involvement with licensing andinspection activities at the specific plant investigated. The team is led
by a senior NRC manager and performs detailed investigations of significant
operational events. The team reports directly to NRC's Executive Director
for Operations (EDO) and is independent of regional and headquarters I
office management.

9.

Diagnostic Evaluation Team (DET) - The Diagnostic Evaluation Program
described in NRC Manual Chapter 0520 is used as directed by the EDO in
implementing a diagnostic evaluation of a few selected licensed reactor
facilities each year. When used, the Diagnostic Evaluation Team effort isincorporated into the regional office's site-specific inspection plan andserves to complement the overall reactor inspection program. The DET
provides for an independent, multi-discipline followup evaluation of NRC
management-identified issues at licensed reactor facilities. It consistsof an in-depth technical and man~gement review associated with identifiedor perceived areas of concern, with emphasis placed on root cause determinations for identified weaknesses or problem areas. The overall goal of a
DET is to improve licensee performance and public health and safety.

NUREG-1355

40

10.

Maintenance Team Inspection (MTI) - This inspection is part of the Mandatory Team Inspection program within the Fundamental Inspection Program inwhich a specific subject area is selected as the focus for team inspection.
The program is currently being performed once at each site. The Maintenance Team Inspections focus on all elements of the licensee1s organization involved in supporting or conducting plant maintenance.
It isintendedito assess overall corporate management practices and theireffectiv~ness in ensuring safe nuclear operations.

As a general policy, NRC continues to conduct unannounced inspections byregion-based and onsite Resident Inspectors. Inspection Manual Chapter (IMC)
0300, IIUnannounced Inspections,1I was issued on January 1, 1983, to describe the
NRC policy concerning unannounced inspections. In this regard, NRC has
recently modiJied its regulations (10 CFR 50.70) to strengthen its ability
to conduct effective unannounced inspections. However, with the advent of performance-baseq specialized and mandatory team inspections, the licensee isusually made aware of team inspections in advance of the actual inspection, sothat licensee' personnel wi 11 be avai lab 1e to respond to team members for thei r
specific areas of interest. Performance-based team inspections go into agreater level' of detail and involve more inspection personnel than either
resident or regional routine inspections. Therefore, it is more efficient,from a time and cost perspective, to ensure the availability of licensee information and personnel by notifying the licensee in advance of the actual teaminspection. lMC 0300 is currently being revised to reflect this change ininspection policy.
A.H.e

Conduct Intensive Reviews of Licensee Performance

Presidential~ommission

Recommendation

Each operating licensee should be subject periodically to intensive and open
review of its performance according to the requirements of its license andapplicable regulations.
Status of Act'ions
Following the'TM! accident, NRC focused attention on the importance of soundcorporate and plant management. Subsequently, the Agency undertook a moreaggressive approach to evaluating licensee performance.
In 1980, NRC initiatedits program o,f Systematic Assessment of Licensee Performance (SALP). SALP is
an integrated Agency effort to collect and analyze available Agency insights,
data, and other information about a plant in a structured manner in order toassess and better understand the reasons for a licensee1s performance.
The
SALP program is a mechanism to assess the quality of licensee activities andthe degree to which a licensee is committed to superior performance.
Under this program, each operating nuclear power plant is assessed
approximatel~ every 15 months in seven specific functional areas:
o
o
o
o
o

NUREG-1355

Plant operations
Radiological controls
Maintenance and surveillanceEm~rgency preparedness
Physical security
41

o
o

Engineering and technical support
Safety assessment and quality verification

For example, the engineering and technical support organizations are carefully
assessed to assure that their activities are involved with the operations
staff, and that coordination and resources are adequate to identify and resolve
problems affecting plant operations.
Following issuance of NRC's SALP assessment, a meeting is held with thelicensee's management to discuss it. These meetings are open to State andlocal government officials and members of the public.
Additionally, NRC established a Diagnostic Evaluation Program to conduct
in-depth probes of performance at selected plants. Greatly expanded teaminspections have analyzed such areas as engineering, system functional
capability, emergency operating procedures, and plant maintenance. The NRC
inspection program is now performance-oriented as well as safety-oriented, anddiagnoses how well licensees are operating their nuclear plants.
In order to provide a more objective measure of licensee performance, NRC
instituted a Performance Indicator Program in 1986 as another tool for assessing the performance of each operating reactor. These indicators supplement.information about licensee performance from other sources. Taken together,
they help NRC assess the direction and level of effectiveness of its regulatory
programs.
To integrate the results of these assessment programs, senior NRC managers
began holding semiannual meetings in 1986 to analyze those plants identified
as, or perceived to be, poor performers. As a result of these meetings, plants
are singled out for additional regulatory attention. Their top managers arethen informed of this significant level of NRC concern. This process andresulting licensee action have produced positive results in plant performance.
A.11.fAdopt Criteria for Revocation of Licenses, Sanctions, and Immediate
Plant Shutdowns

Presidential Commission Recommendation
The agency should be directed to adopt criteria for revocation of licenses,
sanctions short of revocation such as probationary status, and kinds of safety
violations requiring immediate plant shutdown or o~her operational safeguards.
Status of Actions
The Commission has approved a specific enforcement policy that includes
guidance on when to issue a citation, a civil penalty, or an order. An order,
for example, would normally be the mechanism to effect an immediate plant
shutdown because of operational safety concerns. (See also Section A.11.c.)Through experience, NRC has found that additional criteria beyond thosecontained in the enforcement policy and associated procedures are not needed.
Enforcement actions involving the entire range of sanctions are routinely takenon the basis of specific plant conditions and situations. Additionally,
enforcement actions, along with Systematic Assessment of Licensee Performance
NUREG-1355

42

(SALP) findings, performance indicators, and results of inspections are considered at semiannual meetings of senior NRC managers to identify poor performance and to determine which plants should have increased inspection andregulatory resources. In between these meetings, orders and Confirmatory
Action Letters are issued when necessary to assure that only plants thatprovide reasonable assurance of safe operations continue to operate.
Further, a separate Office of Enforcement has been established to manage the
NRC enforcement program. The staffing associated with enforcement has substantially increased since the TMI-2 accident. Senior regional and Office of
Nuclear Reactor Regulation management personnel are regularly involved in
enforcement actions to assure consistent Agency-wide decisions. Enforcement isan essential regulatory tool that is routinely used to improve compliance withsafety requirements.

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43

B.

RECOMMENDATIONS

B.1 and B.1.a

FOR THE UTILITY AND ITS SUPPLIERS

Change Safety Attitudes and Establish Specific Safety Standards

Presidential Commission Recommendations
To the extent that the industrial institutions we have examined are representative of the nuclear industry, the nuclear industry must dramatically change its
attitudes towa~d safety and regulations. The Commission has recommended thatthe new regulatory Agency prescribe strict standards. At the same time, theCommission recqgnizes that merely meeting the requirements of a government
regulation does not guarantee safety. Therefore, the industry must also set
and police its own standards of excellence to ensure the effective management
and safe operation of nuclear power plants ..
The industry should establish a program that specifies appropriate safety
standards including those for management, quality assurance, and operatingprocedures and practices, and that conducts independent evaluations.
The
recently created Institute of Nuclear Power Operations, or some similarorganization, may be an appropriate vehicle for establishing and implementing
this program.
Status of Actions
In the years since the Presidential Commission, the industry has taken steps toupgrade its programs that specify appropriate safety standards for management,
quality assurance, operations, and independent evaluations. The industry's
Institute of N4clear-Power Operations (INPO), whose charter includes review of
nuclear power operating experiences for analysis and feedback to utilities,
incorporation of lessons learned from those reviews into training programs, andcoordination of reporting and analysis with other organizations, has been
especially active in the areas of operations, maintenance, and training. The
industry also has established a Nuclear Safety Analysis Center to systematicallyreview plant event reports and data, identify precursor events, perform failure
analyses, and follow up with utilities on identified problem areas. A statement of understanding between INPO and NRC was signed, and both organizations
are working independently with the common objective of improving nuclear plantsafety.
NRC has upgraded its requirements for licensee technical and management support
capabilities; operat6r qualification and training; licensed operators on shift;and for use of the quality assurance function. NRC certainly agrees that there
is a continuing need for a high degree of safety awareness within NRC and at
every nuclear power plant to assure that the public will be protected. Nuclear
power demands diligence and vigilance, a high degree of discipline, and aprofessional and systematic approach. Although there have been noteworthy
improvements in the operating record of the industry, vigilance and attention
to safety must ri;continue.
[I

NUREG-1355

45

B.1.b

Review Operating Experience

Presidential Commission Recommendation
There must be a systematic gatheringt reviewt and analysis of operating
experience at all nuclear power plants coupled with an industry-wide
international communications network to facilitate the speedy flow of thisinformation to affected parties. If such experiences indicate the need formodifications in design or operation such changes should be implemented
according to realistic deadlines.
t

Status of Actions
Both NRC and the industry strongly agreed with this recommendation. As aresultt extensive efforts have been made to systematically collect and assess
feedback and to act on the lessons of experience.
One of the earliest actions taken by the Commission in response to the TMI
accident was the establishment of the Office for Analysis and Evaluation of
Operational Data (AEOD) within NRC. AEOD reviews and evaluates operating
experience to identify (1) significant events and their associated safetyconcerns and root causest (2) trends and patterns revealed by thesesignificant events (3) the adequacy of corrective actions taken to address
safety concernst and (4) the generic applicability of these events and concerns
to other nuclear power plants.
t

AEODt other NRC officest and the industry have continued to place a highpriority on ensuring that operational events are thoroughly understood -particularly with regard to root causes -- and communicating the lessons ofthese events to all users of nuclear powert both foreign and domestict who may
experience similar conditions. Weaknesses in design fabrication andconstruction continue to be identified through the study of operating
experience. These findings coupled with the results from probabilistic risk
assessment (PRA) and other analytical safety analyses have led to major
improvements in reliability and overall plant safety.
t

t

t

t

Systematic programs to review operating experience have also been establishedby industry organizations including the Institute of Nuclear Power Operations
the reactor vendorst the Electric Power Research Institutet and owners' groups.
These effortst together with NRC's programst constitute a comprehensive
industry-wide system for the dissemination of operating experience. Moreovercooperative international activities continue to provide enhanced knowledge ofsafety concerns identified from operating experience. The International Atomic
Energy Agency and the Nuclear Energy Agency have expanded programs in thegeneric analysis of operating experience. NRC is an active participant inthese cooperative international efforts.
ttt

In addition NRC. has required each licensee to establish an engineering staff
capability to assess and report pertinent operating experience. It is NRC's
intent that its assessment programs and those of industry groups, and vendors
will be complemented by and integrated with each licensee's program to assurethat operating experience is available, analyzedt documented, and understood by
the reactor operators and plant technical support staff.
tt

NUREG-1355

46

B.2

Conduct In,dependent Reviews of Plant Operational Activities

Presidential Commission Recommendation
Although the Commission considers the responsibility for safety to be with thetotal organization of the plant, we recommend that each nuclear power plantcompany have a 'separate safety group that reports to high-level management.
Its assignment 'would be to evaluate regularly procedures and general plant
operations from a safety perspective; to assess quality assurance programs; andto develop continuing safety programs.
Status of Actions
NRC agreed that there was a need for an independent safety review group thatwould assess plant operational activities to assure that they are conducted inaccordance with requirements for safety.
As a result, for operating licenses issued after the TMI-2 accident, NRC
required an on~ite independent safety engineering group (ISEG) be establishedto perform independent reviews of plant operations. Their principal function
is to examine plant operating characteristics, NRC issuances, licensing
information service advisories, and other appropriate sources of plant designand operating experience information that may indicate areas for improving
plant safety. The ISEG performs independent reviews and audits of plant
activities, including maintenance, modifications, operational problems, andoperational analysis, to aid the establishment of programmatic requirements forplant activities. The ISEG develops and presents detailed recommendations tocorporate management for such things as revised procedures and equipment
modifications.
It also maintains surveillance of plant operations and maintenance activities to provide independent verification that these activities
are performed correctly and that human errors are reduced as far as practicable.
B.3 and B.3.aUpgrade
Management and Technical Qualifications for Design,
Construction, Operation, and Emergency Response Capabilities
Presidential Commission Recommendation
Integration of :management responsibility at all levels must be achieved consistently throughout this industry. Although there may not be a single optimal
management structure for nuclear power plant operation, there must be a single
accountable organization with the requisite expertise to take responsibility
for the integrated management of the design, construction, operation, andemergency response functions, and the organizational entities that carry themout. Wi thout s'uch demonstrated competence, a power plant ope rat ing company
should not qualify to receive an operating license.
These goals may be obtained at the design stage by (1) contracting for a"turn-key" plant in which the vendor or architect-engineer contracts to supply
a fully operati~nal plant and supervises all planning, construction, andmodification; or (2) assembling expertise ,capable of integrating the design
process. In either case, it is critical that the knowledge and expertise
gained during design and construction of the plant be effectively transferredto those responsible for operating the plant.

NUREG-1355

47

Status of Actions
There was strong agreement with the major point of this recommendation. NRC
believes that the utility-licensee, as the single accountable organization,must have the requisite expertise to take responsibility for the integrated
management of the design, construction, operation, and emergency response
functions.
Under new criteria, NRC reviews the corporate-level management and technicalorganizations of each utility and its major contractors, including the nuclear
steam supply system vendor and architect/engineer for each plant. The-technical resources available to support the nuclear power plant design,
construction, testing, and operation are also assessed. The utility's
emergency planning and response capability are evaluated for conformance to NRC
regulations.
The objective is to assure that the corporate management is involved with,informed about, and dedicated to the safe design, construction, testing, andoperation of the nuclear plant and that sufficient technical resources havebeen, are, and will be provided to meet the objectives.
Because there have been no recent commitments to new nuclear plant construction,utilities have not had the opportunity to contract for a IIturn-key" plant, or
to assemble expertise capable of integrating the design process. However,there are advanced, standardized light-water reactor designs in progress thatare being reviewed by NRC. The utilities, in cooperation with the ElectricPower Research Institute, are preparing a list of design requirements for
future standard nuclear power plant designs.
B.3.b and c Establish Clearly Defined Roles and Responsibilities
Operating Procedures and Emergency Proceduresfor BothPresidential Commission Recommendation
Clearly defined roles and responsibilities for ope~ating procedures and practices must be established to ensure accountability and smooth communication.
Since, under our recommendations, accountability for operations during an
emergency would rest on the licensee, the licensee must prepare clear proce~dures defining management roles and responsibilities in the event of a crisis.
Status of Actions
NRC agreed strongly with the Presidential Commission recommendation concerning
the need for clearly defined roles and resp6nsibilities.
With respect tooperating plants, licensees were required by January 1, 1980, to review andrevise their practices to provide for definitive and clearly articulated
operations command responsibilities and improved administrative procedures andcontrols (to support the command function) for both normal and emergency
conditions.
Specifically, the licensee's safety analysis report (SAR) is to describe theoperating procedures that will be used by the operating organization (plant

NUREG-1355

48

staff) to assure that routine operating, off-normal, and emergency activities
are conducted in a safe manner. The SAR also is to include the structure,functions, responsibilities, and authorities of the onsite organization
established to operate and maintain the plant.
Applicants and licensees are also required to provide specific information in
their SARs in the form of an organization chart that shows the title of eachposition, the minimum number of persons assigned to certain positions, thenumber of operating shift crews, and the positions for which Reactor Operator
and Senior Reactor Operator licenses are required. A description of the functions, responsibilities, and authorities of important plant positions isrequi~ed. The applicant/licensee is required to describe positions that
require interactions with offsite personnel or positions that are identified in
the SAR. These descriptions must include defined lines of reporting responsibilities as well as functional or communication channels, the line of successionof authority and responsibility for station operations in the event of unexpected
contingencies, and the delegation of authority that may be granted to operatorsand shift supervisors. (Emergency operating procedures are discussed in
Sections B.5.a, b, and c of this report. Emergency exercises are discussed in
Sections E and,F.)To further reduce the risk associated with severe accidents, NRC is developingan Accident Management Program aimed at promoting the most effective use ofexisting equipment and resources to prevent and mitigate severe accidents.
The program is expected to provide a framework for evaluating information
developed through conduct of the Individual Plant Examinations, for preparing
and implementing severe accident operating procedures, and for training
operators and managers in these procedures. Also, a reassessment of roles andresponsibilities for decisionmaking during emergencies will provide added
assurance that lines of authority and communications, responsibilities for key
decisions, and authority and criteria for procedural overrides and equipment
modifications during an emergency are clear and well established.
B.4

Increase Operator Qualifications

Presidential Commission Recommendation
It is important to attract highly qualified candidates for the positions ofsenior operator and operator supervisor. Pay scales should be high enough toattract such candidates.
Status of Actions
NRC agreed tha~ it is important to attract highly qualified candidates for the
positions of s~nior operator and operator supervisor and that pay scales should
be high enough' to attract such candidates.
'I

As an initial :~ction, NRC imposed more stringent training requirements for'an NRC senior :bperator's license. At the same time, the Agency increased thescope and passing criteria for the NRC licensing examination. Utilities werethus required ~o recruit more highly qualified applicants in order for these,I

NUREG-1355

49

applicants to be successful in obtaining an NRC senior operator's license.
NRC has also encouraged utilities to recruit and license degreed engineers byallowing utilities to combine the position of Shift Technical Advisor (STA)
with that of a shift Senior Reactor Operator (SRO), if the SRO possesses anappropriate degree.
B.5 and B.5.a, bandc

Emphasize the Review and Evaluation of Plant
Procedures and Improve Operating and Emergency
Procedures

Presidential Commission Recommendation
Substantially more attention and care must be devoted to the writing, reviewing,
and monitoring of plant procedures.
The wording of procedures must be clear and concise.
The content of procedures must reflect both engineering thinking and operating
practicalities.
The format of procedures, particularly those that deal with abnormal conditions
and emergencies, must be especially clear, including clear diagnostic instructions for identifying the particular abnormal conditions confronting theoperators.
Status of Actions
NRC agreed with these recommendations. Following the TMI accident, NRC
established requirements for licensees to upgrade the adequacy of plant procedures, focusing first on emergency operating procedures (EOP); These requirements, specified in Generic letter 82-33, IISupplement 1 to NUREG-0737 Requirements for Emergency Response Capability,1I were issued in December 1982.
Since then, the industry and NRC have improved nuclear power plant procedures,
especially emergency procedures.
In the early 1980's, the four nuclear steam supply system vendors and theirrespective owners. groups, applicants and licensees, reanalyzed planttransients and accidents and developed technical or engineering bases forplants' to-prepare upgraded procedures. The upgraded, or symptom-based, procedures differed from those used during TMI, which relied on the operator firstdiagnosing an event and then selecting the correct procedure to use. Symptombased procedures focus the operator.s attention instead first on maintaining
the ~lant in a stable and safe condition, and then on diagnosing the specific
event or failure.
While industry was revising the technical basis for emergency operating procedures, NRC was developing its long-term plan for upgrading all plant procedures.
In response to the need for devoting attention to the human factors component
in nuclear power plant operations, in August 1982 NRC issued NUREG~0899,
IIGuidelines for the Preparation of Emergency Operating Procedures,1I the initial
product of its long-term human factors plan for upgrading plant procedures.
This document provided the industry with human factors guidelines for preparing,
revising, and maintaining procedures and for training operators in their us~.

NUREG-1355

50

To further upg~ade procedural formats, NRC recently issued a report to theindustry that provides techniques for preparing EOPs in a flowchart format, apresentation style demonstrated to have several advantages over the more
traditional text format. The Institute of Nuclear Power Plant Operations(INPO) also produced several guidance documents on procedure preparation.
The staff's approach to resolving technical concerns regarding the adequacy of
EOPs has been [to conduct an onsite inspection involving reviews of thesimulator and procedures and a walkdown inspection of the plant.
Since the initial implementation of this upgrading process, all plants, except
Browns Ferry, Units 1, 2, and 3, and Fort St. Vrain, have submitted procedureupgrade plans to the NRC. (Browns Ferry Units 1, 2, and 3 are in long-term
shutdown and the Fort St. Vrain licensee has notified NRC that it plans topermanently shut down Fort St. Vrain in 1990.)
As a follow-up; to its long-term program for upgrading plant procedures, NRC
began inspecting emergency operating procedures at all operating plants in
1986. The focus of these inspections is to verify their technical correctness,
the ability of operators to implement them, and the adequacy of the technicaland format guidance for their preparation to ensure that licensees are developing and implementing EOPs of suitable quality.
,

In addition to its efforts to upgrade EOPs, the staff has examined problems
associated with other procedures, such as those for normal and abnormal
operations and maintenance. As a result of these studies, the staff has
issued reports such as "Development, Use and Control of Maintenance Proceduresin Nuclear Power Plants: Problems and Recommendations" (NUREG/CR-3817) and"Study of Operating Procedures in Nuclear Power Plants: Practices andProblems" (NUREG/CR-3968) that provide guidance for improving other plant
procedures.
Through the combined efforts of NRC, the Advisory Committee on Reactor
Safeguards Subcommittee on Human Factors, and various industry groups, such as
INPO and the owners' groups, licensees have received extensive guidance on the
preparation of effective procedures. As a result, power plant procedurescontinue to be significantly upgraded.
B.5.d

Diagnose and Resolve Plant Safety Questions Early

Presidential Commission Recommendation
Manageme~t of both utilities and suppliers must insist on the early diagnosis
and resolution of safety questions that arise in plant operations. They mustalso establish deadlines, impose sanctions for the failure to observe suchdeadlines, and make certain that the results of the diagnoses and any proposed
procedural changes based on them are disseminated to those who need to know
them.
.
Status of Actions
NRC agreed with the need for utilities to give priority attention to safety
questions that arise from plant operations and to the proper dissemination andresolution of such concerns.
NUREG-1355

51

Accordingly. licensees were required to prepare procedures to assure that
operating information pertinent to plant safety originating both within andoutside the utility organization is continually supplied to operators and otherpersonnel and is incorporated into training and retraining programs. The
licensees were required to:1.

Provide means to assure that affected personnel become aware of andunderstand information of sufficient importance that should not wait
before being introduced through routine training and retraining programs;

2.

Assure that plant personnel not routinely receive extraneous andunimportant information on operating experience in such volume that it
would obscure priority information or otherwise detract from overall job
performance and proficiency;

3.

Provide suitable checks to assure that conflicting or contradictory
information is not conveyed to operators and other personnel until
resolution is reached; and4.

Provide periodic internal audits to assure that the feedback program
functions effectively at all levels.

NRC conducted post-implementation reviews for all plants operating at the timeof the TMI-2 accident. Additionally. reviews were conducted as apart of thelicensing process for those plants that received an operating license subsequent to the TMI-2 accident.
B.6

Consider the Safety Implications of Rate-Making

Presidential Commission Recommendation
Utility rate-making agencies should recognize that implementation of new safetymeasures can be inhibited by delay or failure to include the costs of suchmeasures in the utility rate base. The Commission, therefore, recommends thatstate rate-making agencies give explicit attention to the safety implicationsof rate-making when they consider costs based on "safety-related" changes.
Status of Actions
NRC agreed with this recommendation and committed to consider further the
potential adverse impact that utility rate-making agencies may have on theimplementation of new safety measures. This adverse impact may result fromthe failure of State agencies to include the costs of such measures in theutility rate base.
In 1984 NRC conducted a comprehensive study of utility and public utility
commission (PUC) rate-making practices to determine how these might affectnuclear safety concerns. The study included discussions with PUCs and nuclear
utilities and a national survey of rate-making practices. The study formed thebasis for promulgation by NRC of a new financial qualifications rule affecting
its applicants and licensees (49 Federal Register 35747; September 12, 1984).
NRC determined in this rulemaking that, other than in exceptional cases, therate-making process provides adequate funds to utilities for the safe operationof nuclear power plants.
NUREG-1355

52

Economic presspre continues on many reactors, primarily as a result of highconstruction cbsts and from PUC concerns about the impact of these costs on
ratepayers. In many instances, PUCs have disallowed certain construction
costs. However, NRC is not aware of any case where there was a shortage offunds to assure safe operation of the facility.
Since 1983 NRC has been studying the possible safety effects of PUC-establishedeconomic performance incentives. Such economic performance incentives vary
widely from State to State, but typically they provide monetary rewards andpenalties for performance above or below established levels. A common measureof performance is capacity factor. If a utility may be inclined to "push" anuclear unit tp a higher capacity factor threshold in order to earn a reward,
there could possibly be an effect on plant safety. NRC's response to suchpossible safety effects has been to express its concerns to the nuclear utility
industry and tb the pues. In the past, NRC has assisted PUCs to assess whether
newly formulated performance incentives could have negative safety effects.
NRC has published the results of its latest nationwide survey of economic
performance incentives in "Incentive Regulation of Nuclear Power Plants by'State Public Utility Commissions" (NUREG-1256).

NUREG-1355

53

C.

RECOMMENDATIONS

C.1 and C.l.a~nd

FOR THE TRAINING OF OPERATING PERSONNEL

b Establish Agency-Accredited

Training Institutions

Presidential Commission Recommendation
The Commission, recommends the establishment of agency-accredited training
institutions for operators and immediate supervisors of operators. These
institutions should have highly qualified instructors, who will maintain highstandards, str~ss understanding of the fundamentals of nuclear power plants andthe possible health effects of nuclear power, and who will train operators to
respond to eme~gencies. (See recommendation A.4.a.)
These institutions could be national, regional, or specific to individual
nuclear steam systems.
Reactor operators should be required to graduate from an accredited training
institution. Exemption should be made only in cases where there is clear,documentary eVldence that the candidate already has the equivalent training.
Status of Actions
Consistent with the Presidential Commission recommendation, a system fornational "accreditation of all facility licensee training programs for licensed
and non-licensed operators was instituted by the Institute of Nuclear PowerOperations (INPO). Additionally, the training programs for maintenancetechnicians (instrumentation and control, mechanical, electrical, chemistry andradiatio~ protection) and technical staff managers are subject to the sameaccreditation scrutiny. The accreditation process is administered by INPO andmonitored by NRC. Further. the NRC staff evaluates. on a sample basis, whether
reactor operator candidates have successfully completed the prescribed training
program. and assesses the adequacy of the training program through an examinatioD of ~ach candidate.
All licensee operator training programs are accredited. A second round of theaccreditation is in progress for all licensee programs to ensure their currency
and that they have implemented improvements. The currency and competence of
the instructors are a part of the accreditation process. For a facility toreceive accreditation it must have implemented what is referred to as performance-based training or the Systems Approach to Training (SAT). The NRC
position ~n performance-based training considers the following five elements
essential to these training programs:
1.

Systematic analysis of the jobs to be performed.

2.

Learning objectives that are derived from the analysis and that. desc~ibe the performance desired after training,3.

Traiping design and implementation,obje~tives.

NUREG-1355

55

that are based on the learning

4.

Evaluation of trainee mastery of the objectives during training,
and5.

Evaluation and revision of the training based on the performance of
trained personnel in the job setting.

Finally, all licensees are members of the National Academy for Nuclear"Training, which is responsible for maintaining the high standards associatedwith the accreditation process.
C.l. c and d

Reaccredit Training Institutes Periodically and Require
Candidates to Meet Entrance Requirements

Presidential Commission Recommendation
The training institutions should be subject to periodic review and reaccreditation by the restructured NRC.
Candidates for the training institute must meet entrance requirements
the curri cul urn.

geared to

Status of Actions
As noted in other responses, NRC has reviewed the accreditation process and"continues to monitor the adequacy and completeness of the training provided
through examinations administered to reactor operators. Criteria for operator
candidates are included in NRC requirements and are part of the accreditation
process.
The Institute of Nuclear Power Operations (INPO) continues to conduct
performance-oriented evaluations of training and qualification programs andreviews and reaccredits each facility's training program every 4 years.
C.2

Upgrade Training and Examining of Licensed Personnel

Presidential Commission Recommendation
Individual utilities should be responsible for training operators who are
graduates of accredited institutions in the specifics of operating a particularplant. These operators should be examined and licensed by the restructured
NRC, both at their initial licensing and at the relicensing stage. In order tobe licensed, operators must pass every portion of the examination.
Supervisorsof operators, at a minimum, should have the same training as operators.
Status of Actions
NRC agreed with this recommendation and, as a result, improvements in training
and operator examinations have been implemented through a revised regulation(10 CFR Part 55) effective in May 1987. All licensees are responsible for.administering a comprehensive Systems-Approach-to-Training(SAT)-based training
program. All applicants for NRC operator licenses must pass all sections of
the NRC comprehensive written examination and operating test pursuant to 10 CFRPart 55. Examinations focus on knowledge and abilities in safety-related areas
identified through job and task analyses. The passing grade for the w~itten
NUREG-1355

56

examination was increased to 80 percent overall and 70 percent for eachexamination section. Passing grades are bas~d on satisfactory performance inselected operator competencies. Senior Reactor Operators, who are responsible
for the supervision of Reactor Operators, receive the reactor operator training
plus addition.l training needed to perform the tasks associated with theiriricrease.dsafety respons ibi 1 ities.
NRC administers all initial licensing examinations and requires all applicants
for license renewal to pass an NRC-administered requalification examination.
C.3 and C.3.a and b

Initiate Operator Retraining Programs and Provide
Ongoing, Integrated Training

Presidential €ommission Recommendation
Training should not end when operators are given their licenses.
Comprehensivelongoing training must be given on a regular basis to maintain
operators' level of knowledge.
'I

Such trainingjmust be continuously integrated with operating experience.
:'

Status of Actions
NRC agreed with these recommendations and revised training program requirements
to place more emphasis on developing and maintaining a high degree of knowledge
concerning plant operations and performance, and on relating operator knowledge
and skill to operational events at the plant or to events that occurred atsimilar plants.
Licensees are required by NRC regulations to provide comprehensive training tolicensed operators that includes a written exa~ination and an annual operating
test to :~nsure operator currency and competency for the facility for which theyhold an NRC license. Requalification programs are a component of the training
required for licensing and are based on a Systems Approach to Training (SAT).
Requalification programs must not exceed 24 consecutive months and must be
followed immediately by another requalification program. These training
programs have.been substantially revised and upgraded as a part of the SAT
process.
Subsequent to the TMI-2 accident, NRC regulations (10 CFR Part 55) were revised
to require that all facility licensees have a simulation facility approved foruse by NRC or a plant-reference simulator that has been certified to the
NRC by the facility licensee. All facilities must be in compliance with thisrule by March.1991. Industry is in the process of complying with this rule .
.1

An integral aspect of the simulator training is the reflection of operational
events and po$sible plant conditions in a realistic setting in order to assurethat the trairning is oriented toward operations and provides comprehensive
training in the diagnosis of and recovery from possible plant transients.

NUREG-1355 .

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C.3.c and d Emphasize Diagnosis and Control of Complex Transients and Require
Utility Access to a Control Room Simulator
Presidential Commission Recommendation
Emphasis must be placed"on diagnosing and controlling complex transients and on
the fundamental understanding of reactor safety.
Each utility should have ready access to a control room simulator. Operatorsand supervisors should be required to train regularly on the simulator. The
holding of operator licenses should be contingent on performance on thesimulator.
Status of Actions
NRC agreed with this recommendation. In order to assure that a substantial
emphasis was placed on diagnosing and controlling complex transients, and toassure realism in operator training programs, simulator training has become an
essential and vital component of all reactor operator training programs.
NRC developed a requirement for nuclear power plants licensed by NRC to have asimulation facility appropriate to conduct operator licensing tests. Thisrequirement is included in the revised regulation (10 CFR Part 55) that became
effective in May 1987. NRC also developed Regulatory Guide 1.149 which
describes an acceptable method of complying with those portions of the regulations regarding certification of a simulation facility, and the applicablerequirements set forth in ANSI/ANS Standard 3.5-1985, IIAmerican National
Standard for Nuclear Power Plant Simulators for Use in Operator Training. II
This standard identifies functional requirements for control room simulators
used for operator training, and specifies the type of operations and malfunctions that the simulator needs to be able to reproduce.
The need to review simulation facilities against the above requirements
resulted in the development of NUREG-1258, IIEvaluation Procedure for Simulation
Facilities Certified Under 10 CFR Part 55.11 An inspection procedure is also
under development to provide further guidance to the NRC staff for implementing
the simulation facility evaluation program.
Nearly all facility licensees have now committed to certifying a plant-referenced
simulator that demonstrates anticipated plant responses to normal, transient,and accident conditions.
C.4

Improve Simulator Research and Development

Presidential Commission Recommendation
Research and development should be carried out on improving simulation andsimulation systems: (a) to establish and sustain a higher level of realism in
the training of operators, including dealing with transients; and (b) to
improve the diagnostics and general knowledge of nuclear power plant systems.
Status of Actions
NRC agreed with this recommendation and instituted a number of actions toimprove simulators and their diagnostic capabilities.
NUREG-1355

58

'.

Considerable research and developm~nt to improve simulators has occurred overthe past decade. Following the TMI accident, initiatives were undertaken toencourage the installation of site-specific simulators at each nuclear plant.
This generation of simulators was slightly modified to allow increased flexibility in the training for and display of certain event scenarios.
Industry initiatives to upgrade simulator performance call for utility simulators
to be certified to an industry standard by March 1991. The certification
criteria are specified in ANSI/ANS-3.5-1985, "Nuclear Power Plant Simulators
for Use in Operator Training"; and Regulatory Guide 1.149, "Nuclear Power Plant
Simulation Facilities for Use in Operator License Examinations." Related
review criteria are contained in NUREG-1258, "Evaluation Procedure forSimulation Facilities Certified under 10 CFR Part 55." These industry initiatives led simulator vendors and other parties to develop computer code enhancements for existing simulators and for those yet to be delivered.
Simulator certification requires a substantial amount of simulator upgrading inmost cases, si~ce each simulator must be able to replicate events that have
happened atth~t facility. Thus, more sophisticated simulator modelling has
been developed:ithan existed on first-generation simulators. For example,
simulator research has resulted in improvements in such areas as engineeringcomputer codes~ best-estimate transient analyses, and operator-perceivablechanges in sim~lated parameters. These improvements are expected to beincorporated into future revisions of the ANSI/ANS-3.5 standard.
NRC has acquired through lease-purchase agreements three full-scope reactor
simulators which are located at its Technical Training Center (TTC) for
training the NRC staff. These simulators are considered typical of first- or
second-generation simulators, as contrasted with the third-generation simulators being delivered at this time. NRC has initiated an upgrade of its
simulators so that they can be used effectively for advanced training anddiagnostic purposes. Additionally, simulator time and the operational expertise of the TTC staff has been made available for simulator research projects
associated with simulator evaluation tests, team skills and behavior evaluation,and value-impact assessment of potential upgrades to control room annunciators.

NUREG-1355

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D.

RECOMMEND~TIONSFOR TECHNICAL ASSESSMENT

0.1

Improve C~ntrol Room Design

Presidential Cbmmission Recommendation
Equipment should be reviewed from the point of view of providing information tooperators to help them prevent accidents and to cope with accidents when theyoccur. Included might be instruments that can provide proper warning anddiagnostic information; for example, the measurement of the full range oftemperatures within the reactor vessel under normal and abnormal conditions,and indication'of the actual position of valves. Computer technology should be
used for the clear display for operators and shift supervisors of key
measurements relevant to accident conditions, together with diagnostic warningsof conditions.
In the interim, consideration should be given to requiring, at TMI and similar
plants, the grouping, of these key measurements, including distinct warning
signals on a single panel available to a specified operator and the providingof a dup 1 icate; pane 1 of these key measurements and warni ngs in the shift~upervisor's office.
Status of Actions
NRC strongly agreed with the recommendations on the need for improved control
rooms and instrumentation. Consequently, all licensees were required to
conduct detailed control room design reviews to determine if their control room
provides satisfactory information to the operators to prevent or cope withaccidents'. As guidance for this review, NRC published "Guidelines for Control
Room Design Reviews" (NUREG-0700) in 1981. This document provided basic humanfactors analysis techniques and accepted human factors design principles andcriteria.; In addition, NUREG-0800, "Standard Review Plan," Chapter 18, "Human
Factors Engineering," provides licensees and applicants with the criteria bywhich the staff reviews the design of the main control room and control centersoutside the main control room.
Part of the effort by each licensee and applicant included a function and task
analysis to determine the tasks operators were expected to perform and theinformation and control capability needed to perform the tasks. These information and control requirements were then compared to the controls and displaysin the control :room to determine availability and acceptability of the instrumentation. In addition, each control room was surveyed to identify deviations
from accepted human factors principles for control room layout, usefulness of
audible and visual alarm systems, information recording and recall capability,
and the control room environment. Each licensee and applicant then submitted asummary report to NRC outlining proposed changes and schedules for theirimplementation., The report also provided justification for safety-significant
human eng~neering deficiencies to be left uncorrected or partially corrected.
Instrumentation to aid operators following an accident has been strengthened
significantly since the TMI-2 accident. Based on guidance in Regulatory Guide
1.97, the reliability and capability of the instrumentation has been improvedat all nuclear power plants. The most important safety parameter instruments
are now located on a single panel and are required to survive the harsh
NUREG-1355

61

environment that could be generated by a range of postulated accidents. This
post-accident monitoring instrumentation will provide operators with theinformation necessary to ensure that all safety systems have operated properly
and to take the action necessary to respond to equipment malfunctions.
Implementation of control room improvements, including some significant designchanges, is well under way. The staff has identified no serious safetysignificant design flaws that have not subsequently been corrected.
D.2

Correct Design and Maintenance Inadequacies

Presidential Commission Recommendation
Equipment design and maintenance inadequacies noted at TMI should be reviewed
from the point of view of mitigating the consequences of accidents.
Inadequacies noted in the following should be corrected: iodine filters, thehydrogen recombiner, the vent gas system, containment isolation, reading ofwater levels in the containment isolation [sic], reading of water levels in thecontainment area, radiation monitoring in the containment building, and thecapability to take and quickly analyze samples of containment atmosphere andwater in various places. (See recommendation A.7.)
Status of Actions
NRC agreed that these inadequacies would be corrected. Six of the seven items
were addressed by TMI Action Plan Requirements (NUREG-0737). However, severalof these requirements proved so difficult to implement that deadlines had to beextended beyond January 1, 1981. The requirements have now been implemented.
Therefore, all operating nuclear power plants (except for Browns Ferry, now inextended shutdown, which will complete these actions before the restart of eachunit) now have, for example, safety-grade, high-range radiation monitors inside
the containment building; enhanced provisions for containment building isolation;and the capability to use a hydrogen recombiner if needed.
The recommendation for the capability to quickly analyze containment building
atmosphere and reactor coolant samples was implemented by the requirement for a
post-accident sampling system (PASS). Although the PASS requirements proved
formidable, every licensee now has the capability to take and analyze samplesof reactor coolant and containment building atmosphere. These samples provide
information about (a) the extent of core damage; (b) the radioactivity released
to the water and to the atmosphere; and (c) the concentration of combustible
gases in the containment building atmosphere.
Progress has been less rapid in correcting inadequacies in iodine filtration
systems because of the complexity of the issue and because other issues weredeemed to have greater safety significance. The necessary research has been
conducted and an appropriate protocol for testing the filtration medium(nuclear-grade charcoal) has been developed (EGG-CS-7131). NRC guidance inthis area (Regulatory Guide 1.52) is being revised on the basis of reported
deficiencies in operating systems.

NUREG-1355

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0.3

Record Critical Plant Parameters

Presidential Commission Recommendation
Monitorind instruments and recording equipment should be provided to record
continuously al~ critical plant measurements and conditions.
I.

Status of.:Actions
NRC was in complete accord with this recommendation for monitoring andrecording initial plant parameters. Accordingly, licensees were required to
install a Safety Parameter Display System (SPDS) in all nuclear plant control
rooms. The objective of the SPDS is to provide a concise display of criticalplant variables to control room operators to aid them in rapidly and reliably
determining the safety status of the plant. Seven basic requirements for the
SPDS were specifi ed as follows:

,

o
o
o

o
o
o

o

Displpy critical plant variables concisely
Be located convenient to control room operators
Conti!nuously di sp 1ay plant safety status
Possess a high degree of reliability
Be h'o 1ated from safety systems
Incorporate accepted human factors principles
Provide minimum information sufficient to determine plant safety withrespe~t to the following functions:
Reactivity control
Reactor core cooling and heat removal
Reactor coolant system integrity
Containment conditions
Procedures and training for actions with and without SPDS

In 1981 t~e sta'ff published "Functional Criteria for Emergency Response
Facilities" (NUREG-0696), which included a chapter on the SPDS. In addition,"StandardliReview Plan" (NUREG-0800), Chapter 18.2, "Safety Parameter Display
System," was published to provide guidance on the criteria by which the staff
would review the SPDS. An SPDS has been installed in all nuclear power plant
control rooms, except for three systems scheduled for installation and one
licensee granted an authorized exemption.
0.4. and D.4.a~ b, c and dConduct Acciderit Studies

Presidential Commission Recommendation
The Commission ~ecommends that continuing in depth studies should be initiatedon the probabi~ities and consequences (onsite and offsite) of nuclear power
plant accidents" including the consequences of meltdown.
:iThese studies Jhould include a variety of small-break loss-of-coolant accidents
and multiple-failure accidents, with particular attention to human failures.
Results of these studies should be used to help plan for recovery and cleanup
following a major accident.

NUREG-1355

63

From these studies may emerge desirable modifications in the design of plantsthat will help prevent accidents and mitigate their consequences. For example:(i) Consideration should be given to equipment that would facilitate thecontrolled safe venting of hydrogen gas from the reactor cooling system.
(ii) Consideration should be given to overall gas-tight enclosure of thelet-down/make-up system with the option of returning gases to the containment building.
Such studies should be conducted by the industry and other qualified organizations and may be sponsored by the restructured NRC and other Federal agencies.
Status of Actions
As a result of the TMI-2 accident and to be responsive to these recommendations,
NRC increased and redirected its research program. The program has been revised
to focus on: more probable transients caused by multiple failures; on experiments and analyses for small-break loss-of-coolant accidents (SBLOCA); on
severe accidents and core-melt phenomena; on probabilistic risk assessment
techniques, including those for specific systems, such as auxiliary feedwater
systems, as well as complete plant designs; on hydrogen generation and its
consequences; on system interaction studies; on component reliability studies
and determination of principal failure causes; on emergency core cooling system
performance and design-basis reliability; and on shutdown heat removal requirements.
In addition, a high level of priority was placed on research involving humanperformance. Activities in this area included research to (1) complete
analysis of field-collected data for human reliability in maintenance andcalibration activities at operating nuclear power plants; (2) review abnormal
occurrence reports, Licensee Event Reports, and compliance reports to identify
areas in which human performance reliability is low; (3) develop probability
models to predict error rates for multiple human errors; and (4) identify
patterns and basic associative factors for human-error rates associated withtest, maintenance, and operator ictions.
The primary goal of the small-break and transient research is to improve
operator performance during off-normal events. The research on developing andassessing analytical methods is directed toward improving current computercodes, developing and applying advanced computer codes for SBLOCA and otheraccident analysis, and developing a fast, easy-to-use, engineering analyzer
capability to provide accurate and sufficient information to operating personnel. Advanced control room and diagnostic instrumentation was used in the
Loss of Fluid Test as part of the augmented operator capabilities program toassess operator needs to mitigate the consequences of loss of coolant accidents
and transient sequences.
NRC is also participating in a joint program with the Department of Energy, theElectric Power Research Institute, and General Public Utilities to acquire,
record, and study data from TMI-2 that relates .to core-melt accident phenomena.
The results will be used to help plan for recovery and cleanup in the highly
unlikely event of a major accident.

NUREG-1355

64

The revised research program includes extensive hydrogen studies to increase
understanding of the formation of hydrogen in a reactor from metal-water reactions, radiolytic decomposition of coolant, and corrosion of metals, and to
determi ne:its consequences in terms of pressure-time hi stori es and hydrogendetonation. This work also includes: (1) the preparation of a compendium of
informatio~ related to hydrogen as it affects reactor safety; (2) analysis ofradiolysis: under accident conditions; (3) a review of hydrogen sampling andanalysis methods; (4) a study of the effects of hydrogen embrittlement ofreactor vessel materials; and (5) a review of the means of handling accidentgenerated hydrogen, with recommendations on improving current methods. The
results of these studies were in support of Unresolved Safety Issue (USI) A-48,
IIHydrogen Control Measures and Effects of Hydrogen Burns on Safety Equipment."
Additional research on hydrogen effects has been conducted as part of theanalyses in IISevere Accident Risks: An Assessment for Five U.S. Nuclear Power
Plants" (NUREG-1l50).
In order to upd~te risk assessment provided in NRC's 1975 "Reactor Safety
Study" (WASH 1400), identify plant-specific vulnerabilities, and provide acurrent risk pe~spective on plant designs and severe accident phenomena, NRC
undertook a majpr assessment of five different plant designs using
probabilistic risk assessment (PRA) methodology.
Known as NUREG-1150, thisassessment provides perspectives on:oissues significant to the frequency, consequences,
severe accidents;orisk uncertaintiesothe potential benefits of a severe accident management program for
redud ng ri sk.

and risks ofsignificant enough to merit further research; andThe draft)NUREG-1150 provides a set of PRA models and results that support
ranking p6tential safety issues and related research. Although not an
estimate Of risks at all U.S. nuclear power plants, NUREG-1l50 is an important
NRC stafflresource document. It provides quantitative and qualitative PRA
information on key severe accident sequences, a means for investigatingwhere safety improvements might best be pursued, the cost-effectiveness of
possible plant modifications, the importance of generic safety issues, and thesensitivity of risks to issues that arise for the five plants studied. The
staff is in the process of resolving comments received on the draft NUREG-1150
and expects to /issue the fina 1 report in 1989.
0.5

Research the Chemical Behavior of Radioactlve Iodine in Water

Presidential Commission Recommendation
A study should ,be made of the chemical behavior and the extensive retention ofradioactive iodine in water, which resulted in the very low release ofradioiodine to'the atmosphere in the TMI-2 accident. This information should
be taken into a<;count in the studies of the consequences of other small-break
accidents.

NUREG-1355

65

Sta~us of Actions
NRC agreed that additional information was needed on the realistic behavior of
iodine, other radioisotopes, and chemicals in the primary systems of severely
damaged reactors. Accordingly, shortly after the TMI accident, NRC initiated asevere accident research program with a strong emphasis on fission product(so-called "source terms") transport and retention within plant systems.
Special attention was given to the behavior of radioactive iodine and its
ability to be retained on surfaces of the reactor coolant system and in water
pools in the containment building. A group dedicated to this issue was formed
in 1983 to pursue this study, and completed its work in 1986 with publicationof "Reassessment of the Technical Bases for Estimating Source Terms"(NUREG-0956). This study was broadly reviewed by peers within the nuclear
community, by an independent study group of the American Physical Society, andby the general public.
This research program produced a set of analytical tools called the Source Term
Code Package, which has more recently been used in the NUREG-1150 studies.
Results from this study and other aspects of the Severe Accident Research
Program are providing the technical basis for efforts to reach closure on
severe accident issues in accordance with NRC's Integration Plan for Closureof Severe Accident Issues documented in a report to the Commission (SECY-88-147).
Inadequacies in iodine filtration systems have not been fully resolved becauseof the complexity of the issue and because other issues have been deemed tohave greater safety significance. An appropriate protocol for testing thefiltration medium nuclear-grade charcoal has been de,veloped (EGG-CS-7131), andguidance (Regulatory Guide 1.52) is being revised in response to deficiencies
in operating systems that have been identified.
D.6

Monitor TMI-2 Recovery

Presidential Commission Recommendation
Since there are still health hazards associated with the cleanup and disposal
process, which is being carried out for the first time in a commercial nuclear
power plant, the Commission recommends close monitoring of the cleanup process
at TMI and of the transportation and disposal of the large amount ofradioactive material. As much data as possible should be preserved andrecorded about the conditions within the containment building so that these may
be used for future safety analyses.
Status of Actions
NRC agreed with this recommendation and since 1979 has taken a number ofactions to ensure its full and proper implementation. The NRC staff at thesite, which reached a peak of approximately 25 professionals, continues tomonitor, audit, and review the licensee's cleanup and recovery activities.
Today, two project engineers (one at the site), assisted by onsite Resident
Inspectors and other NRC technical experts, are involved with the review andapproval of TMI-2-related activities, including the disposal of wastes.
Over the past 10 years, much progress has been made in facil ity cleanup.
Approximately 75 percent of the estimated 300,000 pounds of fuel and other
NUREG-1355

66

II
'I

debris has been loaded into casks and shipped off site to Department of Energy(DOE) facilities in Idaho. By the end of 1990, the facility is expected toenter the post~defueling, monitored storage phase of the recovery plan. At
that point, the reactor will have been defueled, the radioactive water will
have been disposed of, and decontamination will have been essentially completed
on the major reactor systems and principal buildings. Throughout this period,
offsite radiation monitoring has been conducted by the Environmental Protection
Agency, the State of Pennsylvania, NRC, and the licensee. Public involvement
in all cleanup'~activities has been facilitated through widespread public
meetings and by the establishment of a TMI-2 Advisory Panel made up of area
citizens, public officials, and nuclear scientists.
Throughout thel'cleanup, transportation, and disposal of radioactive, wastematerial, NRC has given close attention to assure that a deliberate andsystematic approach to each step of the cleanup process has been taken.
Priority attention has been paid to the protection of public health and safety,
and to the docwmentation of the condition of the reactor and auxiliary systems.
The as-found condition, the decontamination processes, and the supporting
analyses have been documented in (1) a series of GEND reports (representing
General Public Utilities, the Electric Power Research Institute, NRC, and DOE);(2) a number of NRC technical reports, including an extensive Environmental
Impact Statement (NUREG-0683 and supplements); (3) numerous technical papers
and speeches; and (4) comprehens ive utility reports and documents, inc 1 udi ng
extensiv~ video tapes made of cleanup operations. In November 1988, theAmerican !Nuclear Society sponsored a special technical meeting on TMI-2, where
over 100 ,papers were presented on the acci dent, acci dent sceneri 0, and recovery
program. Thus, the technical data and lessons of experience from the TMI-2
accident have been well documented for use in ongoing safety analyses, accident
modelling, andbdesign studies for advanced reactors.
To ensure thati1the knowledge and lessons of experience from the TMI-2 accident
are widely disseminated, the TMI-2 recovery program has also been the subjectof wide intern~tional cooperation and interest. For example, in 1984 theutility entered into a cooperative arrangement with Japan involving financial
contributions and the long-term assignment of Japanese technical personnel.
Further, NRC has joined with 10 other countries in a comprehensive program tosample and characterize partially melted fuel samples from the lower portionsof the TMI-2 reactor pressure vessel. This latter effort should help validate
NRC.s sa~ety approach and improve the understanding of the current safetymargins ~n U.S; reactors. Additionally, engineers have been assigned, forapproximately 6-month periods, from a number of other countries, including
Belgium, Italy, and Taiwan. Numerous foreign representatives have also visited
the TMI-2 site,;and have been briefed on the recovery program.
D.7

Conduct Accident and Abnormal Event Reviews
Ii

Presidential Commission RecommendationI

The Commission'!recommends that as a part of the formal safety assurance
program, every/accident or every new abnormal event be carefully screened, andwhere appropriate be rigorously investigated, to assess its implications forthe existing system design, computer models of the system, equipment design andquality, operations, operator training, operator training simulators, plant
procedures, safety systems, emergency measures, management, and regulatory
requirem~nts.
NUREG-1355

67/

Status of Actions
Since the TMI-2 accident, NRC has established a comprehensive program forreceiving, screening, analyzing, and thoroughly investigating operational
events.
The first element of this program is the NRC Incident Response Plan, which
includes the NRC Operations Center. The Operations Center receives reports oflicensee events 24 hours a day, 365 days a year; responds to emergencies; andforwards information about potentially significant events to other NRC staff
organizations for screening. The Commission's regulations, 10 CFR 50.72
and 50.73, were revised to require the reporting of the most significant events.
These regulations require licensees to notify the Operations Center immediately
over dedicated telephone lines and to submit detailed written Licensee Event
Reports within 30 days following a reportable event. Since the program wasestablished, the NRC Operations Center equipment, staffing, training, andprocedures have all been enhanced. The staff routinely conducts exercises withlicensees, NRC regional offices, and others to ensure its readiness.
The screening of events received by the Operations Center involves a combinationof efforts. The initial screening is performed by the Headquarters' Operations
Officer (HOO). The HOO is a degreed engineer with extensive training who
ensures that events are as completely described as possible and that the appropriate notifications are made.
Subsequently, events received by the Operations Center are screened each
workday morning in a conference call between two NRC program offices. During
the call, assignments are made to determine which events are of plant-specificsignificance and which are of generic significance. NRC regional offices also
review events soon after they are received by the Operations Center. Further,each week a conference call is held between the Office of Nuclear Reactor
Regulation (NRR) and other NRC offices to review the significant events of theweek. Followup action may be assigned as a result of this review.
Another element of the program, the analysis of events, also combines different
efforts. Short-term analysis based on immediate notifications to the Operations
Center is conducted by NRR at Headquarters and through onsite reviews by
regional inspectors. Longer-term analysis, which is done by the Office forAnalysis and Evaluation of Operational Data (AEOD), can take many forms:
engineering case studies, trends and patterns analyses, performance indicatorstudies, and a variety of reports for the public, Congress, and technicalspecialists. Such analyses often result in the dissemination of important
information to the staff, and to licensees in the form of information notices,bulletins, generic letters, and formal NRC technical reports.
The final element, an Incident Investigation Program (lIP), responds toespecially significant events by activating specially trained investigation
teams. The lIP was established in 1985 by the NRC to assure that investigationsof significant events would be timely, thorough, well coordinated, andformally administered. NRC has developed and implemented detailed proceduresfor the program, selected the most qualified prospective team members from avariety of appropriate technical disciplines, and conducts special training
sessions on a range of investigative techniques and procedures. The scope ofthe lIP includes the investigation of significant operational events involving
NUREG-1355

68

reactors and non-reactor activities licensed by NRC. The lIP's primary objective is to ensure that operational events are investigated in a systematic andtechnicalJy sound manner, to gather all available information pertaining to thecauses o~the events -- including those involving NRC's activities -- and toprovide appropriate feedback regarding the lessons of the events to the NRC,
the industry, and the public.

NUREG-1355

69

.;,<,,1

E.

RECOMMENDATIONS,I","'."'."'~'FOR WORKER AND PUBLIC HEALTH AND SAFETY

E.1 and E.l.a, ti, c, d and e

Expand and Better Coordinate Federal Radiation
Effects Researchij

Presidential Commission Recommendation
The Commission recommends the establishment
health-rel~ted radiation effects research.
not be limited to:of expanded and better coordinatedThis research should include, butbiological effects of low levels of ionizing radiation;!I'I
acceptable~levelsof exposure to ionizing radiation for the general
population and for workers;

development of methods of monitoring and surveillance, including
epidemiologic surveillance to monitor and determine the consequences of
exposure to radiation of various population groups, including workers;
development of approaches to mitigate adverse health effects of exposure
to ionizing rad.~ation; andi~genetic or environmental factors that predispose
susceptibility to adverse effects.

individuals to increased,I

This effort should be coordinated under the National Institutes of
Health --'Iwith an interagency committee of relevant Federal agencies toestablish the agenda for research efforts -- including the commitment of a
portion of the research budget to meet the specific needs of the restructured
NRC.
.
Status of Actions" NRC agree~ with these recommendations.
During 1978 and 1979, the NRC staff
worked with and supported an interagency effort chaired by the Department of
Health, Educati.on and Welfare that arrived at the same conclusion as the
Presidential Commission. As a result, an interagency committee on radiation
research, chai~ed by the National Institutes of Health, was established inearly 1979, onlwhi ch NRC was represented.
The functions of the Interagency Radiation Research Committee subsequently wereassumed by the Committee on Interagency Radiation Research and Policy
Coordinat~on (CIRRPC), established on April 9, 1984 under the Office of Scienceand Technology ;Policy and chartered under the Federal Coordinating Council for
Science, Engineering and Technology.
In addition to assuming the responsibilities of the former Interagency Radiation Research Committee, CIRRPC was also
assigned the responsibilities of the former Radiation Policy Council andreplaced the Committee on Interagency Radiation Policy. Its overall charge
is to coordinate radiation matters among Federal agencies, evaluate radiation
research, and provide advice on the formulation of radiation policy. At thepresent t':ime,there are 18 CIRRPC member agenci es, 14 of whi ch have members on
the CIRRPC Science Panel. Each of these agencies has significant research,
operation:, or policy functions in the area of radiation.
NUREG-1355

71

The CIRRPC has supported. coordinated. and reviewed efforts in radiation healtheffects. including radio-epidemiological. radio-biological. and dosimetry
studies. A major effort resulted in a report on liThe Federal Ionizing
Radiation Research Agenda Related to Low Level Biological Effects: FY 1985.11
This report delineates and compares Federally supported research efforts in1981 and 1985. Also. CIRRPC is directly supporting an update ,of the 1980
comprehensive report by the National Academy of Sciences (NAS) on the effectsof low-level radiation. This update is being prepared by the NAS Committee on
the Biological Effects of Ionizing Radiation (BEIR). Known as the BEIR V
report. it is expected to be available in the spring of 1989.
NRC's budget for studies on the biological effects of ionizing radiation
represents about 3 percent of all Federal expenditures in this area. NRC
support is limited to projects of direct applicability to the agency's
responsibilities that are not sponsored by other agencies. Examples ofprojects sponsored by NRC include experimental development of models forearly mortality and morbidity caused by the accidental inhalation of radionuclides. development of computer code models for assessing the health consequences of reactor accidents. and a feasibility study on the reduction of
uncertainties in low-level radiation risk through research on the effects ofradiation at the molecular and cellular levels.
The development of a data base to support epidemiological research as an aid tounderstanding the health effects of ionizing radiation is expected to result
from requirements included in a revision to 10 CFR Part 20 now before theCommission. These proposed requirements were developed as a result of arequest by the National Cancer Institute (NCI) and followed meetings with NCI
staff. industry groups. labor unions. and others. The data base is to include
nuclear power workers as well as others.
E.2

Establish Department of Health and Human Services Oversight of NRC
Activities

Presidential Commission Recommendation
To ensure the best available review of radiation-related health issues.
including reactor siting issues. policy statements or regulations in that areaof the restructured NRC should be subject to mandatory review and comment by
the Secretary of the Department of Health and Human Services. A time limit for
the review should be established to assure such review is performed in an
expeditious manner.
Status of Actions
NRC agreed with the value of a Federal oversight of NRC activities that affectpublic health. NRC believed that the Federal Radiation Policy Council (FRPC).
established by the President. would provide a more effective and balanced
oversight. Subsequently. the function of the FRPC was transferred to theEnvironmental Protection Agency (EPA). In 1987. EPA published IIRadiation
Protection Guidance to Federal Agencies for Occupational Exposure.1I which wasapproved by the President. These recommendations were developed with EPA
oversight by an interagency working group which included NRC representatives.
It incorporates new concepts developed by the International Commission on
Radiation Protection. NRC has incorporated the Presidential guidance into a
NUREG-1355

72

major reV1Slon of its regulations, 10 CFR Part 20, "Standards for Prote~tion
Against Riidiation" now under consideration by the Commission.
il
.

'I

Additiona~ Federal oversight of NRC activities was provided by the Interagency
Radiation Research Committee, established in early 1979 and chaired by a .
representative of the National Institutes of Health. The functions of thisCommittee were 'later transferred to the Committee on Interagency Radiation
Research and Pqlicy Coordination. established on April 9. 1984. under the
Office of Science and Technology Policy and chartered under the Federal
Coordinating Council for Science. Engineering and Technology.
NRC participates
as a member of'lhis Committee.
E.3 Educate State and Local Health Professionals
Personnel

and Emergency Response

Presidential Commission Recommendation
The Commission :irecommends. as a state and local responsibility, an increased
program for educating health professionals and emergency response personnel inthe vicinity of nuclear power plants.
Status of'Actions
NRC agreed with this recommendation and, although the Presidential Commission
identified this as a State and local responsibility, NRC provides guidance andassistance in implementing this recommendation.
In particular, NRC helps
develop NRC-Env.;ronmental Protection Agency guidance already available toStates on the preparation of emergency response plans and will provide moredetailed guidance on the education and training necessary for personnel who
respond to emergencies at nuclear power plants. In addition, NRC continues tooffer tecbnical assistance to the States in the preparation or upgrading of
emergency response plans.
The Commission has aggressively pursued the upgrading of licensee. State. andlocal radiological emergency-response capabilities.
This upgrading has beenaccomplished, in close coordination with the Federal Emergency Management
Agency (FEMA), ~hrough rulemaking and guidance. Specifically. the regulations
and guidance require that training be provided by the utility and the State andlocal governments to all personnel who are likely to respond to a radiologicalemergency. These individuals are identified in each organization's Radiological
Emergency Response Plan. Training includes classroom work, on-the-job instruction, lectures,,,seminars, drills, and exercises. Biennially, each utility
conducts an emergency preparedness exercise involving State and local personnel.
These exetcises are a primary training tool and serve as a "final exam" for all
those involved in the response program. Following an exercise, each participating organization provides a critique of its own performance, which is followed
by a critique by NRC and FEMA.
I

NRC has prepare~ and distributed to all licensees and States copies of themanuals used to1train NRC personnel on responses to reactor accidents.
These manuals discuss the source of the threat from reactors, the range ofappropriate responses, and their bases. In addition. NRC has supported FEMA's
training 40urses for State and local response personnel. This support has
included developing training material and providing instructors for courses on
NUREG-1355

73

\

reactor systems, reactor accidents, and public protective actions. NRC
developed material on reactor accidents for the FEMA home study course,"Radiological Emergency Management,,' which is available to the public andresponse personnel through FEMA. NRC has supported various ongoing efforts,such as Harvard University's "Planning for Nuclear Emergencies" course and
FEMA-sponsored State workshops to assure that all response organizations have abasic understanding of severe reactor accidents and the appropriate responses
to them. NRC also participates with FEMA on the Education and Training
Subcommittee of the Federal Radiological Preparedness Coordinating Committee todevelop and update training courses for State and local government responders.
Further, NRC regional offices conduct workshops with State and local officials,
licensees, and local Federal officials to discuss responses to severe.
accidents.
In addition to the training provided through regulatory requirements, NRC and
FEMA also provide direct training to State and local personnel. NRC provides
radiological health professionals a 5-week comprehensive course in basic
radiological safety. FEMA provides a number of courses for radiologicalemergency responders in basic emergency response techniques in both classroom
and in-the-field environments. In the past 10 years, NRC has trained
approximately 400, and FEMA has trained approximately 3400, State and local
personnel through these programs.
E.4 and E.4.a, b, c and d

Prepare in Advance for Radiological Emergencies

Presidential Commission Recommendation
Utilities must make sufficient advance preparation for the mitigation of
emergencies:
Radiation monitors should be available for monitoring of routine
operations as well as accident levels.
The emergency control center for health-physics operations and theanalytical laboratory to be used in emergencies should be located in awell-shielded area supplied with uncontaminated air.
There must be a sufficient health-related supply of instruments,
respirators, and other necessary equipment for both routine and emergency
conditions.
There should be an adequate maintenance program for all such healthrelated equipment.
Status of Actions
NRC agreed with this recommendation. To ensure that utilities have madeadequate advance preparations for emergencies, NRC emergency preparedness
regulations have been extensively revised since the TM! accident. Before an
operating licen~e can be issued, NRC requires that utilities develop andimplement detailed onsite and offsite emergency plans and response facilities
to provide reasonable assurance that adequate protective measures can andwill be taken in the event of a radiological emergency.

NUREG-1355

74

Licensees must develop emergency preparedness plans following the guidance andrequi rements fo;r emergency preparedness programs provi ded in the regul a- ,tions, NUREG-0696, NUREG-0396, and NUREG-0654/FEMA-REP-l, Revision 1 andSupplement 1. These plans must be approved by NRC. In addition to submittingthese plans, licensees must provide the necessary facilities, equipment,
personnel~ and training to carry out their plans. Periodic emergency response
dri 11 s anrilexerci ses are requi red, rangi ng in scope from speci ali zed ons ite
drills to;major graded exercises involving all Federal, local, and emergency
response organizations.
,\

Licensees are required to establish emergency action levels (EALs) for a specified variety of emergency conditions and to develop protective action recommendations based on theEALs and other factors.
The readi~ess and adequacy of each licensee's emergency preparedness program
are assessed by NRC personnel during exercises of its plans and during routine
inspect ions by ,'NRCregi ona 1 and headquarters I personnel. They are also
assessed by participating personnel from other Federal and State agencies.
Each newly licensed facility has area and system radiation monitoring instrumentation in accordance with the guidance in NRC's Standard Review Plan
(NUREG-0890). Each facility design and layout is reviewed by NRC staff for thelocation bf these monitors relative to likely release points for radioactive
liquids, gases, and particulates. These monitors perform routine functions andmay perform accident mitigation functions, such as system shutdowns or alarms.
In addition, N~C has required that high-range radiation monitors be installed
in reactor containment structures to monitor possible post-accident conditions
at each power reactor facility. Their installation and maintenance are verified by routine NRC inspection. Other requirements for radiation monitoring
capability have also been implemented in the industry and include a noble gas
effluent radiological monitor and a capability to sample post-accident releasesof iodine~ and particulates.
NRC has inspected power reactor facilities forcompliance with these requirements.
NRC has also r~quired that areas vital to accident control and mitigation meetcertain occupancy requirements that would allow the personnel in these areas toperform their functions within specified dose guidelines. The health physics
control c~nter, as part of the onsite technical support cent~r, must meetthese requirements, which include ventilation filtration and dose rate/airborne
radioactivity monitoring, alarm, and shutdown functions. Other health physics
control centers to which operations may be transferred as an accident
progresses, such as the emergency operations facility, are required tomonitor with appropriate alarm and shutdown functions the dose rate and theairborne activi!ty during an emergency. Facility emergency preparedness plans
are routinely inspected by NRC to verify that areas vital to accident control
and mitigation meet NRC criteria.
Analytica~ laboratories at power reactor facilities that are used for post.accident analyses must meet shielding, occupancy; and sampling time limitations
established in NUREG-0737. These laboratories require low background counting
areas and the consideration of "as-low-as-reasonably-achievable"
doses in thesampling and aryalysis processes. Adequate supplies of instruments,

NUREG-1355-I75

respirators, and other equipment necessary for normal and emergency conditions
are evaluated in the licensing process and verified in the inspection process.
Adequate maintenance of health-related equipment is required by the regulations(10 CFR 50.47 and 10 CFR Part 50, Appendix E) and is further discussed in
NUREG-0696, NUREG-0396, and NUREG-0654. Maintenance programs are part ofemergency response plan reviews by the regions and headquarters, and verified
by routine inspections in radiation protection, emergency preparedness,
instrumentation, and other areas.
E.5

Make Potassium Iodide Available

Presidential Commission Recommendation
An adequate supply of the radiation protective (thyroid blocking) agent,potassium iodide for human use, should be available regionally for distribution
to the general population and workers affected by a radiological emergency.
Status of Actions
NRC agreed with this recommendation for workers and institutionalized persons.
NRC. and the Federal Emergency Management Agency have issued guidance tolicensees of operating nuclear power plants and to State and local authorities(NUREG-0655/FEMA-REP-1) recommending the stockpiling and distribution ofradioprotective drugs for emergency workers and institutionalized persons
during emergencies. Emergency planning implementation inspections by NRC haveconfirmed that nuclear power plant licensees are maintaining supplies ofpotassium iodide (KI) for emergency workers remaining or arriving onsite during
an emergency.
The Federal position with regard to the predistribution or stockpiling of KIfor" use by the general public is that it should not be required. While valid
arguments may be made for the use of KI, the preponderance of information
indicates that a nationwide requirement for the predistribution or stockpilingfor use by the general public would not be worthwhile. This conclusion isbased on plans for evacuation of the general population and the costeffectiveness of a nationwide program which has been analyzed by NRC and by
Department of Energy National Laboratories (NUREG/CR-1433). While the use of
KI can clearly provide additional protection in certain circumstances, theassessment of the effectiveness of KI and other protective actions and theirimplementation problems indicate that the decision to use KI (and/or otherprotective actions) should be made by the States and, if appropriate, local
authorities on a site-specific basis. This position was reflected in a policy
statement published in the Federal Register on July 24, 1985 (50 FR 30258).

NUREG-1355

76

F.

RECOMMENDATIONS FOR UPGRADING EMERGENCY PLANNING AND RESPONSE!I'I
F.1 and F:1.a,b, c, and dUpgrade the Role of the Federal Emergency
Management Agency and State and Local
Governments

Presidential Cdmmission Recommendation
Emergency plans must detail clearly and consistently the actions public
officials: and utilities should take in the event of offsite radiation doses
resultinglfrom release of radioactivity. Therefore, the Commission recommends
that:
I,
Before a utility is granted an operating license for a new nuclear power
plant, the sta~e within which that plant is to be sited must have an emergency
response plan neviewed and approved by the Federal Emergency Management Agency(FEMA). The agency should assess the criteria and procedures now used foreval~ating state and local government plans and for determining their ability
to activate the plans. FEMA must assure adequate provision, where necessary,for multi1state planning.
II'

The responsibility at the federal level for radiological emergency
planning, including planning for coping with radiological releases, should restwith FEMA. In this process, FEMA should consult with other agencies, including
the restructured NRC and the appropriate health and environmental agencies.
(See recommendation A.4.)
The ~tate must effectively coordinate its planning with the utility andwith local officials in the area where the plant is to be located.
States with plants already operating must upgrade their plans to therequirements to be set by FEMA. Strict deadlines must be established toaccomplish this goal.
i:
•

!~

Status of Actlons
NRC agreed with this recommendation and has worked closely with FEMA toformally ,document agreements that (1) FEMA should have the lead role at theFederal level for emergency planning for coping'with radiological releases and(2) both FEMA and NRC should concur in State emergency response plans before
NRC issues an operating license.
In late 1979, the President directed that FEMA assume the lead responsibility
in offsite emergency planning and response. The directive, however, did notdeal explicitly'with FEMA's role in the NRC licensing process. To assure theeffective implementation of the President1s directive, NRC and FEMA signed a
Memorandum of Understanding (MOU) on January 14, 1980, describing each agency's
responsibillities in improving emergency preparedness at nuclear plants. ThisMOU was r~visedand updated on November 1, 1980, and again on April 18, 1985.
i;
FEMAls responsibilities in the MOU include making findings and determinations
as to whether State and local emergency plans are adequate and capable of
implementation. ~ The procedures for requesting and reaching administrative
approval of State and local plans by FEMA are set forth in the Code of Federal
77

NUREG-1355'I

Regulations (44 CFR Part 350), which was issued as a proposed rule for commentand interim use on June 24, 1982, and as a final rule on August 19, 1982.
Recognizing that the formal approval process under 44 CFR Part 350 could belengthy, and that it was aFEMA administrative procedure outside the NRC
licensing process, NRC included provisions in the MOU for obtaining timely
submittals of FEMA findings and determinations upon NRC request to support NRC
licensing reviews. Findings and determinations provided under the 44 CFR Part
350 process are known as "formal" findings while those obtained as a result ofan NRC request under the provisions of the MOU are known as "interim" findings.
For all plants licensed to operate since November 3, 1980, NRC has requested
and received from FEMA either formal approval or interim findings thatoffsite
preparedness plans are adequate and capable of implementation prior to
full-power operation. For plants licensed before November 3, 1980, FEMA
findings were based primarily on observations during field exercises and theexistence of upgraded plans.
In those situations where State and local governments have refused tocooperate in the planning effort, utilities may develop and submit offsite
emergency response plans to NRC. These plans substitute utility resources for
those of the State and local governments. In its evaluation of those utility
offsite emergency response plans, NRC will assume that State and local
governments will, in an actual event, use their best efforts to protect the
public health and safety in r.esponding to the emergency and will generally
follow the utility.s plan. If the utility offsite plan and the assumption of
II rea 1ism" arenot adequate to meet all the emergency p 1anni ng requi rements,
FEMA has developed regulations, as directed by Executive Order, to provide
Federal support and assistance in order to assure that utility plans areadequate to meet NRC licensing requirements.
To further assure that State and local governments receive adequate support in
responding to a severe radiological accident, a comprehensive Federal
Radiological Emergency Plan has been developed. This plan, published in final
form in 1985, provides the means for organizing Federal resources in acoordinated manner to support State and local authorities.
F.2

Base Emergency Response Plans on Potential Plant-SpecificAccidents

Classes ofPresidential Commission Recommendation
Plans for protecting the public in the event of offsite radiation releases
should be based on technical assessment of various classes of accidents that
can take place at a given plant.
Status of Actions
NRC agreed with this recommendation.
Accordingly, in November 1980,aftera
formal consideration of the role of emergency planning in ensuring theprotection of public health and safety around nuclear power plant facilities,
NRC issued amended regulations on emergency planning (45 FR 55402). The final
rule required that Emergency Planning Zones (EPZs)of about 10 miles in radius
for plume exposure and about 50 miles in radius for ingestion exposure be
established .. The final rule also specified 16 emergency planning standards
NUREG-1355

78

that must1be met by licensee onsite emergency plans and by State and local
offsite pl!ans. ~Guidance on developing emergency plans to meet the revised
regulations is given in NUREG-0654/FEMA-REP-1. Revision 1. IICriteria for
Preparation and' Evaluation of Radiological Emergency Response Plans andPreparedness
in'Support of Nuclear Power Plants.1I issued in November 1980.
,I
'I

,

The EPZs TIlornuclear power plants are defined as the areas for which planningis needed~to assure that prompt and effective actions can be taken to protect
the public in the event of an accident. The choice of the size of the emergency planning zones represents a judgment on the extent of detailed planningwhich must be performed to assure an adequate response. In a particular emergency. protective actions might well be restricted to a small part of thezones. On the other hand. the response measures established within the 10-mileand 50-mile EPZs can and will be expanded if the conditions of a particular
accident so warrant.
The principal t~chnical documents that describe the process of,defining thesize of the EPZ~ and the planning and protective measures to be taken withinthem are NUREG-0396/EPA 520/1-78-016. IIPlanning Basis for the Development ofState and LocalliGovernment Radiological Emergency Response Plans in Support ofLight-Water NucJear Power Plants.1I December 1978 and NUREG-0654/FEMA-REP-1.
i

F.2.a

Tailor R~sponse Plans According to a Variety of Scenarios

Presidential Commission Recommendation
No single plan based on a fixed set of distances and a fixed set of responses
can be adequate. Planning should involve the identification of several
different 'kinds of accidents with different possible radiation consequences.
For each such scenario, there should be clearly identified criteria for theappropriate responses at various distances. 'including instructing individuals
to stay indoors for a period of time. providing special medication. or ordering
an evacuation.
Status Of~Actions'I

NRC agreed with' this approach. An NRC-Environmental Protection Agency (EPA)
Task Force concluded (in NUREG-0396) that the objective of emergency responseplans is to provide dose savings for a spectrum of accidents that could produce
offsite doses in excess of Protective Actions Guides (PAGs). No single
specific accident sequence was isolated as the one for which to plan because
each accident could have different consequences. both in nature and degree.
Further. the range of options on which to base plans is very large. starting ata point where no planning is required because significant offsite radiologicalconsequences are unlikely to occur, to planning for the worst possible
accident,regarplessof its extremely low likelihood.
III

The NRC/EPA Task Force did not attempt to define a single accident sequence oreven a limited 'humber of sequences. Rather, it identified the parameters forwhi ch p 1 anni ng ~ls recommended. based upon knowl edge of the potential consequences. timing~ and release characteristics of a spectrum of accidents.
Although the selected planning basis is independent of specific accident
sequences. a number of accident descriptions were considered in the developmentof the guidance. including the core-melt accident release categories of the
IIReactor Safety Studyi' (WASH-1400).
NUREG-1355

79

F.2.b and c

Activate Plans According to the Potential Hazards Identified andPlan to Protect the Public from Radiation Levels Lower Than Used
in NRC~Prescribed Plans

Presidential Commission Recommendation
Similarly, response plans should be keyed to various possible scenarios andactivated when the nature and potential hazard of a given accident has been
identified.
Plans should exist for protecting the public at radiation levels lower thanthose currently used in NRC-prescribed plans.
Status of Actions
The emergency planning regulations require licensees to have a standard
emergency classification and action level system. A standardized scheme forclassifying emergencies in an ascending order of seriousness has been
established. The four classes of emergencies and the general meaning of eachof these classifications is provided below:
UNUSUAL EVENT This emergency class provides early and prompt
notification of minor events that could possibly lead to more serious
conditions. It is expected that there would be no threat to the reactor
fuel and there would be no radiolDgical releases above technicalspecification limits.
ALERT Events classified at this level involve an actual or potential
substantial degradation of the level of safety in the plant. Any
radiological releases are expected to be limited to small fractions of
the U.S. Environmental Protection Agency (EPA) Protective Action Guides.
SITE AREA EMERGENCY In this emergency classification, events would be inprogress or have occurred that involve actual or likely major failures ofplant functions needed for protection of the public. Releases are notexpected to exceed EPA Protective Action Guide exposure levels, except
possibly near the site boundary.
GENERAL EMERGENCY This classification indicates that events are in
progress or have occurred that involve actual or imminent substantial coredegradation or melting. Risks of exceeding Protective Action Guide
exposure levels in more than the immediate area are considerably elevated.
A general emergency indicates that plant conditions are substantiallydegraded and, as a result, protective actions are expected.
Each licensee is required to use this emergency classification system and todevelop specific plant instrument readings, referred to as emergency actionlevels which if exceeded would initiate the appropriate emergency class.
Emergency plans must include predetermined protective actions for severe coredamage accidents, including those for evacuation and shelter in the plume
exposure emergency planning zone. Protective actions are taken to minimize
radiation doses to the public based on EPA's protective actions guidelines doselevels.

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80

Provide Local Communities with Funds and Technical Support to Prepare
New Plans

F.2.d

Presidential Commission Recommendation
All local communities should have funds and technical support adequate forpreparing the kiinds of plans described above.
II

Status of Action's
Although NRC has no requirements for funding of State and local governments,
the Agency recognizes that a utility may have an incentive, based on its own
self interest, as well as on its responsibility to provide power, to assist in
supporting,ioffsite response organizations.
Experience has shown that, in thegreat majotity of cases, utilities and offsite organizations have developed
cooperative arrangements for support, including the provision of manpower,
equipment,~training and other resources.
F.3

Expand Medical Research on Means of Protecting the Public from Radiation

Presidential Commission Recommendation
Research should be expanded on medical means of protecting the public against
various levels a~d types of radiation. This research should include exploration of appropri!ate medications that can protect against or counteract
radiation.
Status of Actions
Although this recommendation is beyond the purview of NRC, other agencies
are actively supporting this type of research. For example, since the late
1940s, a large-scale research program on the use of chemical radioprotectors
has been conducted jointly by the Armed Forces Radiobiology Research Instituteand by the Walter Reed Army Medical Center.
In March 1987, these organizations sponsored a symposium on "Perspectives inRadioprotection. II Papers were presented by 42 scientists, including those fromuniversities and hospitals. Sessions focused on whether radioprotectors arefeasible, what protection is needed at the molecular level, protection by
sulfur compounds:',use of immunotherapeutic agents, and enhancement of protection. In additibn to research from animal studies, cancer patients arereceiving radiop"rotectors to shield healthy tissue while they undergo radiotherapy. While a fully effective compound has not yet been developed, researchcontinues in this vital area.
F.4

Better Inform the Public About Nuclear Power"

Presidentiil Commission Recommendation
If emergency planning and response to a radiation-related emergency is to beeffective, the public must be better informed about nuclear power. The
Commission recommends a program to educate the public on how nuclear power

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plants operate, on radiation and its health effects, and on protective actions
against radiation. Those who would be affected by such emergency planning musthave clear information on actions they would be required to take in an
emergency.
Status of Actions
NRC continually emphasizes openness with the press and the public to assurethat they have an opportunity to obtain information through inquiries, review
of NRC documents. and attendance at meetings. Public document rooms areavailable near all nuclear plant sites and in Washington. D.C. Schedules ofpublic meetings are published and available on call-in tape recordings. Public
meetings are conducted across the country on major issues such as Safety Goals
and Standards for Protection Against Radiation. Seminars are conducted inlocal areas for the news media on nuclear power and radiation, and more than
300 reporters and editors have attended these seminars. Further. NRC has
initiated a program in which NRC representatives work with schools and describe
NRC activities. The program also provides speakers to other organizations atthei r request.
-!
Emergency response plans for both onsite and offsite activities require thatutilities make available to the public on a periodic basis information on how
the public will be notified in the event of an accident and what initialactions should be taken. NRC regulations explicitly require that licensees
inform and educate the public: "Information is made available to the public ona periodic basis on how they will be notified and what their initial actions
should be in an emergency (e.g .• listening to a local broadcast station andremaining indoors), the principal points of contact with the news media fordissemination of information during an emergency (including the physical location or locations) are established in advance. and procedures for coordinateddissemination of information to the public are establishedll (Title 10 of theCode of Federal Regulations, 50.47(b)(7».
Thus. licensees are required to disseminate (at least annually) information to
the public regarding how the public will be notified and what actions theyshould take in an emergency. This notification generally takes the form of apublic information brochure which is distributed to all the residents within
the 10-mile emergency planning zone. Residents are also informed through suchmeans as information in local telephone directories. periodic notices in utility
bills. and posters in public areas. The transient population is informed
through signs or other measures (e.g., decals or posted notices placed in
hotels, motels, gasoline stations, and phone booths) with appropriate information that would be helpful if an emergency occurred. Such notices refervisitors to the telephone (directory or other sources of local emergency
information and inform them about radio and television stations that would
carry relevant news. In addition, licensees conduct coordinated programs atleast annually to acquaint news media with their emergency plans. to disseminate information concerning radiation, and to provide points of contact forsources of public information in an emergency.

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F.5

Study the Costs of Radiation-Related

Mass Evacuations

I

Presidential

Commission Recommendation

Ii

commissionl! studies suggest that decision-makers may have over-estimated thehuman costs, in injury and loss of life, in many mass evacuation situations.
The Commission recommends study into the human costs of rac::tiation-relatedmass
evacuationlland the extent, if any, to which the risks in radiation-related
evacuations differ from other types of evacuations.
Such studies should take
into account the effects of improving emergency planning, public awareness ofsuch planning, and costs involved in mass evacuations.
Status of Actions
In response to this recommendation, NRC agreed that further studies should be
made. Accordingly, additional studies of the potential human costs, in injury
and loss of life, for mass evacuations have been completed. They are summarized in NUREG/CR-4726, IIEvaluation of Protective Action Risks" (June 1987),
and incorporate i!anEnvironmental Protection Agency study, "Evacuation Risks An Evaluation. IIII The study found that the key factors for a successful evacuation included an emergency plan, good communications and coordination, practicedri 11 s, and defined 1 inesofauthority.
Few evacuat ionsstudiedusedan
emergency broadcasting system or warning sirens to communicate the need toevacuate. Repor.ts of panic and traffic jams during an evacuation were veryfew.
.
For accidents which result in relatively low projected dose levels, or underhigher risk evacuation conditions (e.g., bad weather), protective actions otherthan evacu?tion, such as sheltering, may reduce the radiation risk to a point
significantly lower than the evacuation risk. During accidents which result inhigher projected doses, the protective action of evacuation would not subject a
population! to a larger risk than the radiation risk.
F.6

Delin~ate Responsibilities

Among Support Organizations'I

Presidential Commission Recommendation
Plans for providing Federal technical support, such as radiological monitoring,should clearly specify the responsibilities of the various support agencies andthe procedures by which those agencies provide assistance.
Existingplansfor
the provision of Federal assistance, particularly the Interagency Radiological
Assi stance Plan and the var.ious memoranda 'of understandi ng among the agenci es,
should be reexamined and revised by the appropriate Federal authoriti-es.in thelight of the experience of the TMI accident, to provide for better coord'inationand more efficient Federal support capability.
Status of Actions
Il
ii

NRC agreed that ,I improvements were needed in thi s area and ini t iated efforts to
examine and revise the then-existing Federal interagency agreements on
emergency assis~ance.
Since the TMI-2,.accident, much has been accomplished in the area of Federal
response coordination.
Through the efforts of organizations such as the
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Federal Radiological Preparedness Coordinating Committee, of which NRC is amember, coordination among members of the Federal community has improved.
Consequently, there is an improved overall Federal response capability toevents at NRC-licensed facilities. On November 8, 1985, the Federal
Radiological Emergency Response Plan (FRERP) was published in the Federal
Register. This document clearly defines the concept of a Cognizant Federal
Agency (CFA) that has lead authority for responding to events at a facility
over which it has jurisdiction. This document also defines the relationship of
the other Federal organizations to the CFA in supporting the response
effort.
In addition, Federal coordination has been responsible for the development of
NUREG-OG54/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological
Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.1I
This document provides Federal guidance for licensee response to events atlicensed facilities. NRC and the Federal Emergency Management Agency havedeveloped response cooperation procedures in NUREG-0981, IINRC/FEMA Operational
Response Procedures for Response to a Commercial Nuclear Reactor Accident.1I In
support of these procedures, NRC has conducted two Federal Field Exercises(FFEs). These exercises, involving the full Federal community, including NRC
headquarters' and regional staffs, and State and local officials, have resulted
in improvements of the response capability of the Federal government byencouraging communications on response issues between licensees, States, andthe federal government. The first FFE took place in March 1984 at the St.
Lucie facility in Florida. Another FFE was conducted at the Zion facilityin Illinois in June 1987. Both exercises were successful in demonstrating that
the FRERP is a functional concept that can be quickly implemented in support oflicensee and State resources. In addition, reports on lessons learned havebeen written and tracked for both of the FFEs, assuring that problem areas
identified through the exercises are corrected.

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G.RECOMMENDATJONSFOR THE PUBLIC'S RIGHT TO INFORMATION~.

G.l and G.l.a and b

Prepare a Systematic Public Information Program

Presidential Commission RecommendatiGns
Federal and state agenciest as well as the utility, should make adequate
preparation for a systematic public information program so that in time of aradiation-related emergencYt they can provide timely and accurate information
to the new~ medi~ and the public in a form that is understandable.
There
should be sufficient division of briefing responsibilities as well asavailability of informed sources to reduce confused and inaccurate information.
The Commission therefore recommends:
Since litheutility must be responsible for the management of the accident,
it should ~lso be primarily responsible for providing information on the statusof the plant to the news media and to the public; but the restructured NRC
should alsO: playa supporting role and be available to provide backgroundinformation and technical briefings.
'I

Since ~he state government is responsible for decisions concerning
protectiveiiactionst including evacuationst a designated state agency should becharged with issuing all information on this subject. This agency is also
charged with the development of and dissemination of accurate and timely
information on offsite radiation doses resulting from releases of radioactivity.
This information should be derived from appropriate sources. (See recommendation F.L)', This agency should also set up the machinery to keep local officials
fully informed of developments and to coordinate briefings to discuss any
federal involvement in evacuation matters.
S~atus of Actions
The procedure in effect prior to the TMI accident was that NRC public affairs
staff members were sent to an accident site to support NRC personnel in dealing
with the news media, but that the utility was in charge of information activities. During the accident, howevert NRC took responsibility for public informationt and it is realistic to expect that both the State and the public will
look to the Federal regulator to talk authoritatively about any future emergency
situation. In view of the differing responsibilities and points of perspectivet
NRC actions have,focused on achieving a Joint Public Information Center (JPIC)
where Federalt Statet and utility officials operate so thatt where the facts
warrantt a coord1nated view of the situation can be presented.
Towards this end, NRC and the Federal Emergency Management Agency (FEMA) haveworked jointly to develop and exercise emergency plans and guidance forcoordinating andildisseminating public information. Workshops and exercises
have been conducted to familiarize all participants with their own role as wellas the roles of others. JPICs have been identified near reactor sites so thatall parties with,iresponsibilities for informing the public can work together toassure that prompt and accurate information is disseminated.
Each party
maintains its owh independence and can speak separately should the situation
warrant. Lead spokespersons having primary responsibility for speaking on agiven topic are designated, and are recognized by all parties. For example,
the utility and NRC are primarily responsible for information about onsite
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status and conditions, while the State is responsible for information relating
to the impact of the emergency on the health and safety of its citizens.
Beyond the JPIC, information will be issued in such places as NRC headquarters,
State capitals, and at Congressional hearings. A broader joint information
system has been developed to coordinate these activities with the JPIC. Thesesystems have been implemented and tested to the extent practical during the twoFederal Field Exercises held at the St. Lucie and Zion operating reactors.
G.2 and G.2.a, b, and c

Provide Timely and Accurate Information

Presidential Commission Recommendation
The provision of accurate and timely information places special responsibilities on the official sources of this information. The effort must meet theneeds of the news medi a for informat ion but wi thout compromis ing the abil ity ofoperational personnel to manage the accident. The Commission therefore
recommends that:Those who brief the news media must have direct access to informed sourcesof information.
Technical li~ison people should be designated to inform the briefers andto serve as a resource for the news media.
The primary official news sources should have plans for the prompt
establishment of press centers reasonably close to the site. These must be
properly equipped, have appropriate visual aids and reference materials, and be
staffed with individuals who are knowledgeable in dealing with the news media.
These press centers must be operational promptly upon the declaration of ageneral emergency or its equivalent.
Status of Actions
The TMI-2 experience made clear the need to implement this recommendation. As
a result, pre-designated Joint Public Information Centers (JPIC) have been
identified near reactor sites that will be operational during a major accident,i.e., a general emergency situation. These JPICs have appropriate visual aids,
reference materials, and communication and reproduction facilities readily
available to meet the needs of the media. Emergency public information plansfor NRC, other Federal agencies, the utility, and the State call for each party
responsible for disseminating information to have a spokesperson at the JPIC
with the appropriate expertise and authority to speak publicly for his or herorganization.
In addition, communication and information approval links between the reactor
site, the JPIC, and various control and support facilities have been establishedto ensure, to the extent practical, timely, consistent, and accurate information. These communication links permit the rapid flow of validated information
to the principal spokesperson of each organization.
Further, NRC, as well asother organizations, have designated selected technical experts to serve asadvisors and briefers at the JPIC.
The JPIC and its support functions has proven effective in a number of major
exercises. The exercises demonstrated that the anticipated needs of the media
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have been accommodated without an undue impact on or interference with accident
management and protective action assessment activities being implemented inother locations.
G.3 and G.3.a, b, and c

Provide News Media Personnel a Greater Understandingof Nuclear Power

Presidential Commission Recommendation
The coverage of nuclear emergencies places special responsibilities on the news
media to provide accurate and timely information. The Commission therefore
recommends that:All major media outlets (wire services, broadcast networks, news magazines,
and metropolitan daily newspapers) hire and train specialists who have morethan a passing familiarity with reactors and the language of radiation. Allother news media~ regardless of their size, located near nuclear power plants
should attempt t? acquire similar knowledge or make plans to secure it during
an emergency.:
Reporters discipline themselves to place complex information in a context
that is understandable to the public and that allows members of the public tomake decisions r~garding their health and safety.
:\

Reporters educate themselves to understand the pitfalls in interpretinganswers to IIwhat;ifll questions. Those covering an accident should have theability to understand uncertainties expressed by sources of information andprobabilities assigned to various possible dangers.
Status of Actions
Although NRC is unable to implement these recommendations, it has supported
the objective by providing training opportunities for members of the media.
This training covers how nuclear power plants operate, the effects of radiation, and the principles of reactor safety. For example, NRC has periodicallyconducted all-day seminars for news media IINuclear Power and Radiation.1I
Such
semi.narshave been conducted in major cities throughout the country, including
at the Technical Training Center in Chattanooga, Tennessee. The seminars
provide baqkground information and terminology useful in covering nuclear power
plants or Qther stories involving radioactive materials. Several utilities
have conducted seminars for the news media in their areas, and NRC has encouraged
professional societies to do the same. On the basis of comments from participants in '!theseseminars, they have been helpful in providing accurate information about ~he design and operation of commercial reactors and associatedsafety pers,lpectives.
NRC and the utilities have also invited the news media, and in some cases
college joJrnalism classes, to participate in emergency exercises.
Suchparticipat~on provides more realism for the exercise, and offers reporters andstudents an opportunity to learn about nuclear plants and radiation.
;j
II
II

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G.4

Create Emergency Broadcast Networks

Presidential Commission Recommendation
State emergency plans should include provision for creation of local broadcast
media networks for emergencies that will supply timely and accurate
information. Arrangements should be made to make available knowledgeable
briefers to go on the air to clear up rumors and explain conditions at theplant. Communications between state officials, the utility, and the network
should be prearranged to handle the possibility of an evacuation announcement.
Status of Actions
NRC agreed that this recommendation had merit and revised its regulations toassure its implementation. As a result, NRC regulations (10 CFR 50.47(b)(5»now state thatllprocedures have been established for notification, by thelicensee, of State and local response organizations and for notification of
emergency personnel by all organizations; the content of initial and followup
messages to organizations and the public has been established; and means toprovide early notification and clear instruction to the populace within theplume exposure pathway Emergency Planning Zone have been established.1I
To implement this requirement, licensees have arranged with State and local
government organizations for announcements to be made over the Emergency
Broadcast System by designated local radio stations in order to disseminate
appropriate information to the public. Information to clear up rumors and to
explain current plant conditions will also be provided during scheduled
briefings of the news media at a Joint Public Information Center (JPIC)
established near the plant site following a serious emergency. State and local
officials will also be present at the JPIC to disseminate information in theirarea of responsibility.
G.5

Routinely Inform the Public of Abnormal Radiation Measurements

Presidential Commission Recommendation
The Commission recommends that the public in the vicinity of a nuclear power
plant be-routinely informed of local radiation measurements that departappreciably from normal background radiatiDn, whether from normal or abnormal
operation of the nuclear power plant, from a radioactivity cleanup operationsuch as that at TMI-2, or from other sources.
Status of Actions
NRC agreed with this recommendation.
It is NRC.s practice to ensure that apublic announcement is issued on any release of radioactivity to the environment from a licensed facility if NRC radiation limits are exceeded. In thisregard, NRC radiation limits are a small additional increment above normal
background radiation levels to assure a low threshold for reporting andassessment purposes.
In addition, NRC encourages licensees to publicly announce any releases ofradiation beyond the site boundary and releases within the site boundary thatare significant in terms of exposure or potential exposure of employees. Most
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utilities !make it a practice to issue such announcements.
Further. licensees
are requil'1edto notify responsible State and local governmental agencies
promptly after declaring an emergency. Such emergencies range from unusual
events, in which usually no radioactivity is released but the potential for adegradation in safety exists, through levels of emergency classifications that
could or do involve radiation releases. NRC also encourages licensees topublicly announce the declaration of such emergency classifications, even whenradiation is not released, and most licensees do.

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