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Project on Government Oversight

Who the Hell is Regulating Who? The NRC's Abdication of Responsibility

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September 1, 1999 | By: Scott H. Amey, J.D.

Why does this issue matter?

The NRC claims that it has improved nuclear safety and regulatory oversight after the accident at the Three Mile Island Unit 2 nuclear power plant in Pennsylvania, on March 28, 1979 -- the most serious nuclear accident in U.S. commercial nuclear power plant operating history. A quantitative analysis of NRC data shows otherwise, with certain "high priority" safety issues remaining open for nearly 20 years. The NRC's pro-industry tilt is very troubling, especially considering that nuclear plants are soon to reach their operating life and the industry is scurrying to obtain extensions of their operating licenses.


Table of Contents

Foreword
Executive Summary
Background
Waiting For Disaster
Partners In Crime: The NRC And The Nuclear Industry Endangering The Public
"Newspeak" At The NRC
389 High Priority Safety Improvements Remain Unverified By The NRC
Safety Problems At Millstone Are Not Unique
Examples Of Safety Issues The NRC Considers "RESOLVED" Or Not Relevant To Safety
    ISSUE 1. Potential For Meltdown
    ISSUE 2. "A Loaded Gun": Tube Ruptures Part I
    ISSUE 3. Diesel Generator Unreliability
    ISSUE 4. Thermo-Lag 330-1: A Combustible Fire Barrier
Plants With Safety Significant Concerns
    CASE 1. TVA: Disastrous Management Of Its Reactors
            TVA Technicians' Job Knowledge Not Up To Utilities' Own Standards
            NRC Failed To Adhere To Its Own Licensing Procedures At Watts Bar
            Tube Ruptures: Part II
            Sequoyah: Unreliable Monitors
    CASE 2. South Texas
"Who the hell is regulating who?"
Results Of This Cozy Relationship
The History Of Categorizing Safety Issues
What Does The Industry Think Of The NRC?
Congressional Proposals: From Restructuring To Abolition
Conclusions And Recommendations
Glossary
Endnotes
Appendix


Foreword

The Project on Government Oversight has catalogued and documented some of the nuclear industry's dirtiest little secrets. Through the acquiescence of government regulators, nuclear reactors throughout the U.S. are avoiding addressing major safety issues. Even when these safety issues are finally "resolved" by the Nuclear Regulatory Commission, corrective actions are rarely implemented expeditiously, if at all. Hence, nuclear reactors operate for years with known safety flaws.

The Project on Government Oversight has documented decades of delay in addressing nuclear safety issues in America's nuclear plants. How have these major nuclear safety issues been allowed to persist? Both the nuclear industry and the agency that regulates it are to blame. In fact, the peculiar relationship between the Nuclear Regulatory Commission and the nuclear industry has led many observers to conclude that the regulator has been captured by the regulated.

The years of obfuscation, and delay, that characterize the NRC's handling of Generic and Unresolved Safety Issues has only been exacerbated by the nuclear industry's unwillingness to implement corrective actions. The Project on Government Oversight's findings are a warning and a wake up call: the nuclear industry cannot be trusted to regulate itself; and the NRC lacks either the resources or the commitment to do the job. During an era of prescriptive regulation, major safety problems are allowed to fester. As the nuclear industry is deregulated, one can only hope that delay in addressing major safety flaws does not lead to disaster.

James Riccio
Staff Attorney
Public Citizen's Critical Mass Energy Project


Executive Summary

The Project on Government Oversight's findings include:

  • All 110 operating nuclear reactors in the U.S. are operating despite documented significant safety problems that have not been fixed or field-verified by the government regulating agency, the Nuclear Regulatory Commission (NRC):

    • The NRC has yet to verify 389 high priority safety improvements that the operators claim to have fixed, or implemented, at every nuclear power plant in the United States.
    • Currently, there are 76 high priority safety improvements that remain unimplemented at a minimum of 62 different nuclear power plants. Some of these issues were "resolved" as far back as 1978 by the NRC, yet these resolutions are known not to have been applied at the nuclear plants.
  • The longer safety issues remain unresolved, unimplemented and unverified by the NRC, the closer the United States gets to another Three Mile Island or Chernobyl:

    • One safety issue that has the potential to melt the nuclear core and/or break the containment of radioactivity, emergency sump performance, has reappeared four times since the issue was "resolved" eleven years ago -- most recently in September 1995. This critical process involves recirculating water through the reactor system to maintain core cooling.
    • Degraded steam generator tubes, a problem "resolved" by the NRC in 1988, have ruptured at six nuclear power plants since its resolution. Steam generator tubes are used to convert water into steam which eventually drives the reactor's turbine-generator. According to a former NRC Commissioner, this problem is " . . . a loaded gun, an accident waiting to happen." This problem caused one plant to shut down in 1994, and caused an alert to be sent out to all nuclear plant-operating licensees in April 1995.
    • In 1990, as a result of diesel generator failures, Plant Vogtle in Waynesboro, Georgia was within hours of a meltdown. These generators are needed to restore power in case of an emergency and keep the reactor from melting down, yet they do not always start when they are needed. The NRC "resolved" this problem in 1993 with no new requirements. However, 89% of the offsite power outages occurring from 1965 to 1989 occurred when the major electrical power source was either already out of service or it failed during the outage.
    • The Thermal-Lag 330-1 Fire Barrier System, which is required to protect safe shutdown equipment, has yet to be replaced at 80 reactors even though the NRC and the industry know that it is actually flammable. Instead, the industry developed "fire watch," a resolution that will only identify a fire but not retard it as required by NRC regulations.
    • In 1993, TVA "... administered an examination to determine the Chemical Technicians current level of basic chemistry knowledge". The mean scores from TVA's three operating facilities ranged from 26% to 42%.
    • Water Hammer, a problem originally identified by the NRC in 1978 and resolved without any corrective requirements for operating plants in 1984, causes vibrations that rupture pipes and can spray radioactive water. Five water hammer events have been documented at Watts Bar (TN) with one recently listed by the plant on March 20, 1996.
    • In 1992, operators of TVA's Sequoy facility (TN) discovered they had been operating the facility despite unreliable radiation monitors for fifteen years -- these monitors are vital to protecting the outside environment. The monitors were not likely to be triggered until a significant amount of radiation had already escaped into the atmosphere.
  • A trend of resolving issues with "No Requirement" exists in which the NRC dismisses high priority safety issues without actually fixing them. From 1984 to the present, more than one-half of 62 high priority Generic Safety Issues (33 high priority GSIs) have been dismissed with "No Requirement". Essentially, the NRC does not require operators to make any safety improvements.
  • In 1985, an NRC Commissioner asserted, " I can think of no other instance in which a regulatory agency has been so eager to stymie its own ability to carry out its responsibilities. . . . the most compelling evidence to date of the Commission majority's open hostility to the regulatory mission of this agency. . . . The Commission has said there is about a 50-50 chance of another severe accident in the next twenty years." The NRC's cavalier handling of high priority safety issues will not reduce this accident risk.
  • The NRC's acquiescence to the nuclear industry is blatant:

    • In 1987, an NRC Chief stated, "Who the hell is regulating who?(sic) . . . In my opinion, the NRC did not have to buckle to industry pressure. . . . As a result, the NRC has essentially left it to the nuclear industry to regulate itself."
    • In 1984, an NRC spokesperson stated, "Generic Safety Issues were developed deliberately as an accommodation to the nuclear power industry" -- in order to get plants licensed without resolving significant safety questions.
    • The NRC allows licensees to decide if they will follow the NRC's requested actions or if they would like to propose their own alternatives. In one case, the NRC management accepted all 25,000 opinions made for new technical specifications by the nuclear industry, despite NRC staff objections.
    • According to a 1993 NRC Inspector General report, NRC Inspectors stated that they were dissuaded from finding violations at nuclear power plants. Inspectors who made this allegation said they were personally penalized if they found violations -- they would not receive rewards or promotions.
  • NRC Chair Shirley Ann Jackson stated in April 1996, " . . . there is the danger that increased competitiveness in the electricity industry may create pressures to minimize expenditures to the point that safety is compromised." Jackson has repeated this theme in other recent speeches.
  • Currently, the NRC lists 11 nuclear reactors on their "Watch List", of plants needing additional oversight or with a declining trend in performance. They are Indian Point 3 (NY), Millstone 1, 2 and 3 (CT), Browns Ferry 1 and 3 (AL), Dresden 2 and 3 (IL), Hope Creek (NJ), Salem 1 and 2 (NJ).
  • When a plant is listed on the "Watch List", time does not force safety to the forefront -- Dresden's reactors have been on the list for nearly ten years.
  • Nuclear power plants do not get any safer as they age. Aging power plants are a significant safety concern and the NRC's proposal to renew operating licenses, up to an additional twenty years past their current forty-year licenses, will only add to this dilemma.

Background

In 1975, the Atomic Energy Commission (AEC) was dismantled due to its inability to distance itself from the industry it was supposed to be regulating. The result was the creation of the Department of Energy, which was charged with promoting nuclear power, and the creation of the Nuclear Regulatory Commission, which was charged with regulating the U.S. nuclear industry. The Nuclear Regulatory Commission is responsible, according to the Atomic Energy Act of 1954, as amended, for licensing and regulating nuclear facilities and materials and conducting related research.

Currently, there are 116 nuclear power plants in 32 states in the United States: 110 operating plants and 6 plants under construction. These nuclear reactors provide nearly 100% of the Nuclear Regulatory Commission's funding through user fees charged to applicants and licensees.

In 1977, the NRC began categorizing safety problems occurring at many nuclear power plants. Public scrutiny forced the NRC to develop a program, referred to as "Unresolved Safety Issues", to investigate and to disclose annually to Congress issues affecting nuclear power plants. Unresolved Safety Issues are the highest priority safety issues because they have the potential to cause the greatest public harm.

In 1982, "Generic Safety Issues" were conceived, and joined "Unresolved Safety Issues" as issues that had the potential to risk public safety. Generic Safety Issues characterize safety concerns that potentially affect all, or many reactors, and facilities. In 1984, the NRC added GSIs to their Annual Report to Congress.

Each year the NRC promises Congress that safety issues will be resolved quickly, usually within the next year. However, it can take nearly twenty years before the Nuclear Regulatory Commission identifies, resolves, implements and verifies significant safety problems and solutions at nuclear power plants. No one notices. No one is held accountable for these delays. Ironically, licensees are not afforded the same time-frame when issues arise. By law, 10 CFR Part 21, licensees are allotted only 60 days to decide if a potential problem is valid, to submit an action plan for correcting the problem or to report the problem to the NRC. Why then does it take the NRC longer than 60 days to study issues that potentially affect all operating plants?

This delay is due to the Nuclear Regulatory Commission's cozy relationship with the nuclear industry. Recent examples prove that the Nuclear Regulatory Commission's behavior parallels that of its predecessor, the Atomic Energy Commission -- an agency that was unable to regulate the nuclear industry.

Due to the NRC's lack of oversight and enforcement of regulations, it is critical to examine industry documents and identify deficiencies that have existed for many years. Shirley Ann Jackson, Chair of the NRC, stated, "The responsibility for safety rests with the industry. . . . Like any other regulatory body, NRC is essentially an auditing agency." Yet, the mission of the NRC is to regulate the nuclear industry and to enforce safety requirements. There are numerous examples of the nuclear industry making public safety a low priority, and the NRC, which has the power to withdraw a plant's license or shut down the plant, instead passively allows it to proceed.

The Project on Government Oversight (POGO) is a watchdog that investigates and exposes abuse of power, mismanagement, and acquiescence to corporate interests by the federal government. The Nuclear Regulatory Commission, a federal government regulating agency, is guilty of all three of these offenses. POGO has relied on the NRC's own documents, memorandums and regulations to examine an agency that cannot be separated from the industry it is intended to regulate.

POGO would like to thank the many individuals who assisted in making this report possible: Jane Fleming, Ann Harris, William Jocher, James Riccio (Staff Attorney, Public Citizen's Critical Mass Energy Project), Bob Pollard, Paul Gunter (Nuclear Information & Resource Service), Peter Stockton, The Safe Energy Communication Council (SECC), the National Nuclear Safety Network (NNSN), NRC staff members who provided us with updated statistics, the entire staff at the NRC Public Document Room, and the many whistleblowers who cannot be mentioned by name. We appreciate the time that everyone has taken in assisting POGO's investigation.


Waiting For Disaster

During the 1970's and 1980's, the Three Mile Island (TMI) and the Chernobyl accidents failed to act as wake up calls to the hazards posed by the nuclear industry. Today, the American public is largely passive with regards to the industry's looming dangers. Currently, 76 high priority safety improvements that remain unimplemented exist at a minimum of 62 different nuclear power plants -- including one safety issue that brought a reactor within hours of a meltdown. The regulating body of the industry in the U.S., the Nuclear Regulatory Commission (NRC), has acquiesced to industry demands since its inception in 1975. Through the years, the nuclear industry effectively has controlled the NRC: regulations have been watered down or eliminated and licensees (or plant operators) have been given the power to regulate themselves. The relationship between the NRC and the industry has caused high priority safety issues to remain unresolved for more than ten years before changes are made or, more commonly, before issues are dismissed with no required changes. The impact of this cozy relationship has devastating potential. As incidents veer closer to meltdowns, the frequency of safety problems is likely to rise as power plants renew, up to an additional twenty years, their current forty-year licenses.


Partners In Crime: The NRC And The Nuclear Industry Endangering The Public

Decades ago, the NRC developed two programs to list and prioritize safety problems that are occurring at many, if not all, nuclear reactors: Unresolved Safety Issues (USI) and Generic Safety Issues (GSI). Unfortunately, these programs have not made nuclear reactors safer. Issues languish on safety lists for more than ten years, and many issues are considered "resolved" without ever making changes. For example, one issue that was listed as a high priority safety issue in 1984 remains unresolved today. Another issue listed in 1984 was finally resolved in 1994 though no safety improvements were required. Still, another safety issue was resolved in 1985, yet four incidents occurred following its "resolution". Former NRC Chairman Ivan Selin believes the nuclear industry is at fault for problems in handling safety issues:

"As I suggested earlier, a related area in which the industry must do better is in anticipating generic problems and in solving them early. This need will become more acute as the universe of regulated reactors gets older and new generic aging issues emerge. Motor-operated valve issues were initially poorly handled by the industry and stand as an example of how we should not deal with emerging issues. When confronted with the problem, the industry's response was to deny its existence without investigation, forcing the NRC to spend much time and resources to prove the problem's existence. We were often limited in our ability to scope the problem accurately without industry cooperation. Later, when the NRC was able to prove that its concern was valid, both of us found ourselves in a position where a safety issue had been known for several years, but corrective action had not been taken. A similar pattern has sometimes been seen in the way industry has handled steam generator tube issues and the [Boiling Water Reactor] level instrument problems. When generic problems such as these are not promptly and fully addressed, both the NRC and the industry find themselves under justifiable criticism. Additionally, unnecessary financial and organizational resources are often required to deal effectively with such long-festering problems."1 (emphasis added) (APPENDIX A)

It is astonishing that the NRC, the federal agency that regulates one of the most hazardous industries in the world, relies on that industry for even the most basic information. A recent GAO report stated that the NRC's reliance on the nuclear industry will not subside in the future:

"Although one purpose of the NRC's inspection program is to prevent significant events at plants, in practice NRC rarely detects such events before its licensees do. All 16 significant events that the NRC reported for 1993, including the event in South Texas, were initially identified by the licensees rather than by NRC. This situation is unlikely to change because, according to NRC, it has initiatives under way to rely more heavily on licensees to identify and correct problems at nuclear plants."2 (emphasis added)

While Selin blames the licensees for the problematic safety program, the program has also struggled due to a lack of NRC oversight. According to Inside NRC, a trade publication, " . . . the agency has not tracked and processed generic issues as well as it could in the past . . . . "3 GAO found that the NRC's role in overseeing the nuclear industry is restricted:

"Specifically, NRC said that the licensees are responsible for the safe operation of their plants and implied that the intent of its inspection program is limited to ensuring that the licensees identify and resolve potential safety issues before they result in significant problems. . . . Because the licensees are ultimately responsible for the safe operation of their facilities, NRC relies heavily on them to identify and report problems at their facilities. However, NRC inspects a small portion of each licensee's activities to provide independent assurance that the licensees are operating their facilities safely."4 (emphasis added)

The NRC's reliance on the nuclear industry has developed over the years into a blind trust of the nuclear industry that is neither justified nor warranted. Watts Bar Nuclear Plant is a perfect example of why nuclear power plant operators cannot be trusted. In 1988, Ann Harris, a Tennessee Valley Authority (TVA) employee, reported 24 allegations to the NRC -- of which 23 were confirmed by the NRC. These allegations included falsification of documentation, tampering with documentation and covering-up improprieties. The NRC responded to one of the allegations with the following, "The completeness, accuracy, and adequacy of QA documentation is a long standing, documented problem at Watts Bar."5 If the NRC knew this to be a " . . . long standing, documented problem", then why didn't they impose severe fines against those who were involved and send out a message that the NRC will not tolerate improper behavior of any kind? Instead, the NRC has defaulted on its responsibility by giving the nuclear industry more power to regulate itself and, in some areas, is " . . . reducing the regulatory burden on licensees."6

Why has the NRC developed this position? Industry pressure. In a recent speech Commissioner Kenneth C. Rogers stated:

"During a meeting last December, the opinion of those representatives [Federal Energy Regulatory Commission and the National Association of Regulatory Utility Commissioners] was that the Commission should be careful to not pursue regulatory action too quickly because of the general uncertainty about restructuring and deregulation and because a premature regulatory action may have a potentially harmful impact on the industry."7 (emphasis added)

However, the NRC already understands the nuclear industry's motives. In a recent speech, James M. Taylor, NRC Executive Director for Operations, explained the reasons why the industry often operates outside requirements:

"These factors include a very narrowly focused approach to technical issues and their resolution, little evidence of a questioning attitude, limited tracking and trending tools to assess performance and program effectiveness, lack of respect for the [Final Safety Analysis Report], inadequate resolution of identified problems and ineffective quality assurance programs that failed to identify or bring this pattern to management's attention.8" (emphasis added)


"Newspeak" At The NRC

In his novel 1984, George Orwell coined the word "newspeak" to mean the deliberate use of ambiguous and deceptive talk, as by government officials, in seeking to mold public opinion. NRC has taken this definition to new levels. According to the NRC, a safety issue can be "resolved" without requiring any safety improvements. An NRC document revealed:

" . . . about half of the HIGH-priority issues resulted in decisions to take regulatory action, i.e., in retrospect, it appears that resources had been devoted to resolving a large number of issues with no resulting safety improvement."9 (emphasis added)

From 1984 to the present, more than one-half of 62 high priority Generic Safety Issues (33 high priority GSIs) have been dismissed with "No Requirement" or "no resulting safety improvement". The trend of resolving issues with "No Requirement" has allowed the NRC to dismiss high priority safety issues without fixing them. Simply put, listing an issue as a GSI is a convenient way for the NRC to stall and later dismiss safety problems within the nuclear industry, even those categorized as high priority.

Remarkably, a substantial number of high priority issues, which raise important safety concerns or point to elevated risks, are "resolved" without any improvements or changes. What does the NRC mean when it claims a safety issue is "resolved"?

"An issue is considered resolved . . . when its resolution has resulted in either: (a) the establishment of regulatory requirements or guidance (by Rule, SRP change, or equivalent); or (b) a documented authoritative decision that no change in requirements is warranted."10

A General Accounting Office investigation concluded more than a decade ago that:

"NRC considers a generic issue 'resolved' when it identifies and approves a solution to the issue. However, this does not mean that the deficiency has been corrected. Neither NRC nor utilities need to make required changes for an issue to be considered resolved. . . . a resolved issue (i.e., one for which a solution has been identified and approved but not carried out)."11

In 1979, Max Carbon, Chairman of the NRC's Advisory Committee on Reactor Safeguards (ACRS), stated:

"In some cases an item has been resolved in an administrative sense, recognizing that technical evaluation and satisfactory implementation are yet to be completed. . . . In other instances, the resolution has been accomplished in a narrow or specific sense, recognizing that further steps are desirable, as practical, or that different aspects of the problem require further investigation."12

This process remains true today -- merely reaching the so-called "resolution" of a safety issue can take ten or more years. (APPENDIX B -- Table 1 and Table 2) After an issue is considered "resolved", the industry can still delay for years before actually making changes, if any, to the plant.

Congress receives an NRC Annual Report, disclosing all safety issues and the dates they are scheduled for "resolution". However, Congress does not hold the NRC accountable if a safety issue remains unresolved past the expected "resolution" date. Congress accepts the NRC's standard promise that safety issues, especially those considered the highest priority, will be resolved rapidly -- often, by the following year. As seen in Table 1 and Table 2, these dates routinely are extended each year, yet no one holds the NRC accountable.

The industry's use of the word "implement" does not always mean a problem has been corrected. A resolution is considered implemented once the licensee notifies the NRC that they have made the corrective change. Since many corrective actions are not required to be verified by the NRC, and considering industry's poor record on safety issues, one can hardly be assured that "implemented" actually means fixed.

Not only does the NRC use misleading definitions for "resolved" and "implemented" but also, when an accident does occur, the NRC appears to camouflage willingly its occurrence. The NRC limits the use of "accident", which carries a very negative connotation, and, instead, uses terms such as "abnormal occurrence", "event", "failure" and "incident" to describe accidents at nuclear power plants. This clever technique allows the NRC to calm the fears that many people hold concerning this industry. In this manner, the American public and Congress have been duped into believing that the nuclear industry no longer poses a great danger and that there have been no accidents since TMI.13


389 High Priority Safety Improvements Remain Unverified By The NRC

Currently, 76 high priority safety improvements that remain unimplemented exist in at least 62 of the 110 operating nuclear power plants. (APPENDIX B -- Table 3 and Table 4) Even though the NRC "resolved" these issues as far back as 1978, more than half of all power plants have yet to implement the required changes. Presently, seven unimplemented USIs account for 70 of the changes and three GSIs account for 6 of the changes that remain unimplemented. All of these issues were identified more than a decade ago.

There exist today a total of 91 USI's and low, medium and high priority GSI's that remain unimplemented, the vast majority of which are high priority. (APPENDIX B-Table 5) The 76 unimplemented high priority safety improvements account for 84% of all unimplemented USIs and GSIs. Therefore, the issues that remain unattended to are those that pose the greatest danger to the public. The nuclear industry previously stated that, due to limited resources, " . . . plants must balance benefits against cost when setting priorities" and they must choose NRC priorities over their own. But, in the case of high priority issues, the industry leans more on the cost side of the equation by not implementing required safety changes.

This problem is hampered further because plants which have actually "implemented" changes have not been "verified" by the NRC to ensure that the corrective actions have, in fact, taken place and meet requirements. The NRC has not verified a total of 389 high priority changes that have been "implemented" at the 110 power plants. (APPENDIX B-Table 3) Remarkably, many of these safety actions are high priority and, according to the NRC's own standards, potentially carry an extremely elevated public safety risk. Not only do safety issues commonly take more than ten years to be "resolved" but also an additional five to eighteen years are needed before nuclear power plants implement the required safety improvements and receive verification from the NRC.

In May 1995, the NRC introduced a new tracking system intended to improve the management of safety issues. The NRC admitted its old system was inefficient. An NRC spokesman stated that the licensees are not as responsive to safety issues as they should be. According to the spokesman, ". . . licensing activities (on generic issues) are things like Thermo-Lag. These are things identified by the NRC and there's not the same motivation by the licensees to close them out."14 (emphasis added) Interestingly, the licensees are responsible under federal law and under the terms of their licenses for the safe operation of their facilities. It is revealing that the NRC feels that the licensees are unmotivated when it comes to resolving safety issues, yet it permits industry's inattention to persist. The NRC's Executive Director for Operations, James Taylor, recently added:

"I find it very disturbing when I tour a facility and see numerous out-of-service tags, or if I become aware that a substantial amount of equipment is out of service or in a degraded status. These are clear warning signs that a licensee is not providing adequate attention to its material condition and is putting unnecessary burdens on its operators. I am concerned about plants in this condition because they are reducing their safety margin and if not corrected, sooner or later it will have an adverse impact."15

These out-of-service tags are analogous to the number of high priority safety issues that remain unimplemented and unverified by the NRC. It appears that power plants accept degraded status much like the NRC accepts lack of progress on resolving high priority safety issues.

While the NRC's new plan may improve the existing safety system to some extent, the NRC itself recognizes it is not getting to the heart of the problem by requiring real repairs before issues are listed as "resolved". The new system does not examine issues that have been "resolved" without requiring corrective changes to equipment or procedures. Other factors have also been ignored: the length of time it takes the NRC to find solutions for safety issues, if any; the length of time it takes an issue to be corrected at all facilities; and the time it takes the NRC to verify changes. The NRC faces many challenges in attempting to assure the American public that risks associated with the nuclear industry are being corrected. Though the new management plan for safety issues may solve the NRC's inability to track safety issues at individual plants, it does not make these aging reactors safer.


Safety Problems At Millstone Are Not Unique

With 110 operating nuclear plants in the United States and our largest accident occurring almost twenty years ago, the public has been lulled into thinking that this industry is safe. However, accidents occur at operating reactors each year. An accident should not have to force the evacuation of residents in the surrounding area, melt the reactor's core or release radiation into the air before the American public examines the hazards that are posed by the NRC's acquiescence to the nuclear industry.

On March 4, 1996, the TIME magazine cover story reported problems at the Millstone Unit 1 plant in Connecticut. However, the prolonged problems that are occurring at Millstone are not unique to that specific plant -- most plants are suffering from the NRC's failure to take corrective or punitive action. Instead, a number of high priority safety issues that the NRC resolved without corrective requirements for the utilities are resurfacing today at plants across the country, and are putting the public at risk. Twice a year, the NRC lists plants that need additional oversight or have seen a declining trend in performance. Currently, the NRC lists 11 nuclear reactors on their "Watch List".16 (APPENDIX C) Watch List Categories are defined:

"Category 1: Plants Removed From The List Of Problem Facilities. Plants in this category have taken effective action to correct identified problems and to implement programs for improved performance. No further NRC special attention is necessary beyond the regional office's current level of monitoring to ensure improvement continues." (The NRC listed no reactors in this category.)

"Category 2: Plants Authorized To Operate That The NRC Will Monitor Closely. Plants in this category are having or have had weaknesses that warrant increased NRC attention from both headquarters and the region office. A plant will remain in this category until the licensee demonstrated a period of improved performance."

Plants in "Category 2" include: Indian Point 3 (NY), Millstone 1, 2 and 3 (CT), Browns Ferry 3 (AL), and Dresden 2 and 3 (IL).

"Category 3: Shutdown Plants Requiring NRC Authorization To Operate And Which The NRC Will Monitor Closely. Plants in this category are having or have had significant weaknesses that warrant maintaining the plant in a shutdown condition until the licensee can demonstrate to the NRC that adequate programs have both been established and implemented to ensure substantial improvement."

Plants in "Category 3" include: Browns Ferry 1 (AL).

"Declining Trend: Plants with safety performance trending downward [but not warranting designation as a Category 2 plant]."

Plants in "Declining Trend" include Hope Creek (NJ), Salem 1 and 2 (NJ).

Due to the NRC's lack of oversight and enforcement of regulations, it is critical to examine industry documents and point out deficiencies that have existed for many years. Shirley Ann Jackson, Chair of the NRC, stated, "The responsibility for safety rests with the industry. . . . Like any other regulatory body, NRC is essentially an auditing agency."17 Yet, their mission is to regulate the nuclear industry. But, there are numerous examples of the nuclear industry not working in the best interests of public safety and the NRC silently watches.


Examples Of Safety Issues The NRC Considers "RESOLVED" Or Not Relevant To Safety

ISSUE 1. Potential For Meltdown

One example of a high priority safety issue resolved with no requirement is Containment Emergency Sump Performance. Containment Emergency Sump Performance involves recirculating water through the reactor system to maintain core cooling. According to the NRC's 1978 Annual Report:

"Loss of the ability to draw water from the emergency sump could disable the emergency core cooling and containment spray systems. The consequences of the resulting inability to cool the reactor core or the containment atmosphere could be melting of the core and/or breaking of the containment."18 (emphasis added)

Despite the potential for core meltdown and loss of containment integrity, this issue was approved for resolution in 1979 and resolved without corrective requirements by the NRC in 1985. However, four incidents have caused the NRC to re-evaluate the issue's previous resolution. Incidents involving clogged sump strainers have occurred at the Perry Unit 1 plant in Ohio in April and November 1993 and, in September 1995, at the Limerick plant in Pennsylvania.19 Clogged sump strainers also caused an "event" at the Barseback 2 plant in Sweden in 1992.20 New tests show " . . . that the potential for strainer clogging may be more significant than was perceived at the time USI A-43 was resolved." 21 The resolution in 1985 did not require changes to operating plants or plants under construction, only to plants applying for new construction permits.22 NRC's Advisory Committee on Reactor Safeguards stated, " . . . we continue to believe that the response of the [NRC] staff and the BWR [Boiling Water Reactor] licensees to this important nuclear safety issue has been unacceptably slow."23 This is just one example of accidents occurring, with the potential " . . . for serious core damage",24 due to the NRC's failure to require industry to make changes in its operating plants.

On February 18, 1994, the NRC circulated "NRC Bulletin 93-02 Supplement 1: Debris Plugging Of Emergency Core Cooling Suction Strainers". This bulletin requested " . . . all holders of operating licenses or construction permits for boiling-water reactors . . . " to take actions that the NRC believed would circumvent an accident from occurring due to strainer clogging. According to the NRC, boiling-water reactors accounted for 38 of the 116 nuclear reactors in the United States.25 However, the NRC allowed the licensees to decide if they would follow the NRC's requested actions or propose their own alternatives -- again, an example of the NRC delegating its authority to the nuclear industry.

"Within 60 days of the date of this bulletin supplement, a report indicating whether or not the addressee intends to comply with the actions . . . If an addressee chooses not to take the requested actions, the report shall contain a description of a proposed alternative course of action . . .".26 (emphasis added)

It is important to note that this bulletin was circulated NINE YEARS AFTER this issue was "resolved" by the NRC. Still, the NRC never returned this issue to its list of USIs. Instead, it was listed as a "multiplant action" -- another category of generic issue that is not reported to Congress.


ISSUE 2. "A Loaded Gun": Tube Ruptures Part I

As former NRC Chairman Ivan Selin stated, the NRC and industry have handled the problem of ruptured steam generator tubes very poorly.27 Despite the fact that the steam generator tube issue was resolved in 1988, an NRC letter dated April 28, 1995 was sent out to all licensees alerting them to the shut down of the Maine Yankee Atomic Power Station in July 1994.28 (APPENDIX D) Leaking steam generator tubes, identified in the 1970's and "resolved" with no requirements in September 1988, caused the Maine plant to shut down. Steam generator tubes are used to convert water into steam which eventually drives the reactor's turbine-generator. "The tubes within [the steam generator] are an integral part of the primary coolant boundary, keeping the radioactive primary coolant in a closed system and isolated from the environment."29 Significant problems have occurred due to steam generator tube ruptures.

Accidents have occurred following the "resolution" of the steam generator tube issue in 1988 -- when the NRC documented that different forms of " . . . degradation have affected at least 40 operating [Pressurized Water Reactors] . . . ."30 Since 1988, Virginia's North Anna Unit 1 had its second occurrence in as many years, Palo Verde Unit 2 (AZ), Arkansas Unit 2, McGuire Units 1 and 2 and Maine Yankee also have experienced steam generator tube ruptures.31 All of these incidents were considered "abnormal occurrences" by the NRC.32

Problems with leaking steam generator tubes have recently arisen because " . . . tube degradation went undiscovered."33 Ruptured tubes resulted from " . . . cracks that were larger than anticipated for the amount of time between the inspections."34 (APPENDIX D) In 1988, Commissioner Kenneth C. Rogers stated, "Degradation would decrease the safety margins so that in essence, we have a 'loaded gun,' an accident waiting to happen." 35 (emphasis added) The "loaded gun" has fired at four reactors since the NRC considered it "resolved" -- fortunately, without harming the workers or the public yet. The potential for danger has been known by the NRC for more than two decades. Tube ruptures in one of the steam generators at Three Mile Island Unit 2 significantly complicated efforts to mitigate the consequences of the most severe reactor accident in U.S. history.

In recent years, fourteen lawsuits have been filed by nuclear plant licensees against the Westinghouse Electric Corporation, the manufacturer of steam generators. According to Public Citizen, a consumer research and advocacy group:

"Many of the suits have been settled and Westinghouse has agreed with the utilities to seal important court documents. Westinghouse has gone to great lengths to keep information regarding steam generators away from other utilities and the public."36

Why has this safety issue re-emerged almost twenty years after it was first identified? Since the NRC failed to act, the issue was "resolved" with no requirements. By stalling and dismissing this issue without requiring changes in 1988, the NRC made nuclear plants more vulnerable to leaking steam generator tubes and other serious problems today.

The industry has argued that nothing can be done to prevent steam generator tubes from degrading, and watchful waiting is the only course of action that can be taken. However, in 1982, TVA's Division of Nuclear Power suggested one action that had the potential to correct this problem. A TVA Division Position Paper, "Copper Alloys in Pressurized Water Reactor Plant Steam, Condensate, and Feedwater Systems", recommended that copper in steam generators was causing corrosion problems. The Position Paper asserted, "Removal of copper by retubing or replacement of these copper alloy components is warranted."37 But, in the industry's opinion, the cost of initiating a true fix for this problem, a fix that will last for a steam generator's entire lifetime, is outweighed by short-term considerations. Profit margins, end-of-the-year bonuses and healthy settlements from Westinghouse have been enough to convince nuclear industry officials that the problem is not worth fixing -- at least not on their watch.

The NRC is fully aware of this money-first attitude. Shirley Ann Jackson recently stated, " . . . there is the danger that increased competitiveness in the electricity industry may create pressures to minimize expenditures to the point that safety is compromised."38

It is telling that a small number of plants, when replacing their copper alloy components, have used non-copper components. However, many reactors are operating with steam generator tubes that have been corroded by copper oxides. Industry has decided that the steam generator tubes need only be watched by insensitive measurement techniques during routine refueling outages -- totally ignoring TVA's Division of Nuclear Power's fourteen year-old recommendation. Tube ruptures will continue to occur as long as the NRC does not close plants when licensees ignore safety requirements.


ISSUE 3. Diesel Generator Unreliability

Another high priority issue that has "slipped between the cracks" is Diesel Reliability. The Diesel Reliability problem refers to the performance of the generators that restore power to a nuclear reactor in case of an emergency. The generators are needed to restore power and keep the reactor from melting down. Unfortunately, however, they do not always start when needed.

In 1990, as a result of diesel generator failures, Plant Vogtle in Waynesboro, Georgia was within hours of a meltdown. On March 20, 1990, a truck accident at the plant caused a loss of offsite power.39 (APPENDIX E) Each reactor is required to have two emergency diesel generators that restore power in case of such an emergency. However, there was only one functional diesel generator at the reactor, the second generator was being fixed at the time of the accident. The functioning generator failed to perform its intended safety function for thirty-six minutes after the plant lost offsite power. During the time that Vogtle Unit 1 was without power, the temperature of the reactor coolant system rose significantly (46 degrees Farenheit in 36 minutes) and was on its way toward meltdown.40

Diesel reliability was identified in the 1970's and originally scheduled for resolution in January 1985. In June 1993, after meeting much resistance from the licensees, the NRC finally resolved diesel reliability with no new corrective actions required. Was the accident at Vogtle unique?

"The incident at Vogtle was neither unique nor without precedent because loss of offsite power events, loss of decay heat removal events, and emergency diesel generator failures due to trip sensor problems have occurred. Precursor events during cold shutdown conditions at other plants involving loss of offsite power occurred 74 times between 1965 and 1989 [as of 1990]. Loss of decay heat removal with the reactor system in a reduced water level condition (near mid-loop) occurred 52 time between 1973 and 1989. Some of these loss of decay heat removal events occurred as a result of losing power. In addition, emergency diesel generator trip sensor calibration problems have occurred 32 times at other nuclear plants and 69 times at Vogtle."41

The NRC released additional data after the Vogtle accident that highlights the importance of diesel generator reliability.

  • "In 89 percent of the loss [of] offsite power events that occurred between 1965 and 1989, either some major electrical power source was out of service before the event and/or some major electrical power source failed during the event."42
  • "The 74 previous loss of offsite power events between 1965 and 1989 occurred with a variety of electrical sources removed from service. . . . In the 64 events for which the equipment conditions are known . . . Thirty-nine (61 percent) involved both equipment that was out of service and equipment failures."43

Despite the near disaster in March 1990 in Georgia and the data that was collected after, NUMARC voiced its opinion in a November 1990 letter to the Commission of the NRC. "We reiterate our belief that industry actions and performance together with existing docketed commitments by individual licensees provide sufficient basis for closure of Generic Issue B-56 [Diesel Reliability]."44 (APPENDIX F) One year later, an internal NRC memo highlighted how authority had eroded within the agency. Using almost identical language as NUMARC, the NRC came to the same conclusion:

"In our view, the proposed rule amendment is unnecessary to ensure adequate diesel generator reliability. We continue to believe that the commitments of the licensees to monitor and maintain diesel generator reliability as specified . . . combined with industry initiatives in this regard, are sufficient."45 (APPENDIX G)

However, industry's track record does not merit such confidence. A month following the near disaster at the Vogtle power plant, the Senior Vice-President of Nuclear Operations at the facility ". . . presented a misleading, incomplete, and inaccurate statement of diesel test results" to the NRC.46 (APPENDIX E) In June and August 1990, two other false statements were submitted by the same plant official.47 In response to the actions of the manager, the NRC fined the utility for providing them with incomplete and inaccurate information. Other sanctions have also been levied to Vogtle's senior management for actions -- harassment and intimidation -- taken against plant employees who notified the NRC that the provided information was inaccurate.

Three years after the accident at the Vogtle power plant, the final resolution for diesel reliability required no changes to existing requirements. In a meeting between the NRC and NUMARC to resolve this issue, an NRC employee indicated, " . . . the resolution of GI B-56 through the issuance of RG 1.9, Rev. 3, will not introduce any regulatory requirements . . .". The NRC employee also stated, " . . . [Emergency Diesel Generator] maintenance problems continue to exist despite reported high levels of EDG reliability (e.g. Vogtle [GA], Cooper [NE], D.C. Cook [MI], Calvert Cliffs [MD], and Zion [IL]). The NRC relies primarily on industry reported EDG performance and availability."48 (APPENDIX H) The NRC accepted the licensee's word despite three documented times when the licensee deliberately provided false statements to it. While the NRC admits that five power plants were having problems with diesel generator reliability, it dismissed the issue as "resolved", and called it a day.

Diesel reliability is closely related to two other issues that have yet to be corrected by the NRC -- Reactor Coolant Pump Seal Failures (GSI 23), scheduled for resolution since 1984, but not yet resolved (APPENDIX B-Table 2); and Station Blackout (USI A-44), one of the seven USIs whose resolution has not been implemented. (APPENDIX B-Table 3) The lack of implementation verification of Station Blackout solutions, the NRC's ten year delay in correcting the Reactor Coolant Pump Seal Failures issue, and the dismissal of Diesel Reliability as being "resolved" should cause concern, as these issues were supposed to have been resolved in coordination with each other. Public safety is at risk because the NRC unnecessarily takes nearly twenty years to examine, solve, implement and verify required safety changes.


ISSUE 4. Thermo-Lag 330-1: A Combustible Fire Barrier

The Thermo-Lag 330-1 Fire Barrier System was widely marketed to the nuclear industry during the 1980's to protect reactor safe shutdown equipment (electrical power, instrumentation and control cable) from being damaged by fire in case of an emergency. The purported fire protection function for this fire barrier was once very important to the NRC:

"When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boiloff."49 (emphasis added)

However, Thermo-Lag 330-1 was declared "inoperable" by the NRC in 1992 after the persistent efforts of an industry whistleblower could no longer be ignored regarding the product's substandard performance for fire resistance. The fire barrier had repeatedly failed fire endurance testing and it was finally determined that the barrier burned like "treated plywood." Yet the NRC continues to drag its feet on Thermo-Lag's major impact on reactor safety. Like most other safety issues, the NRC has not required this issue be fixed -- despite the significant hazard presented by fire, and the fact that Thermo-Lag 330-1 has not provided the level of safety required by current NRC regulations. An internal NRC document states, " . . . fires are a significant contributor to the overall core damage frequency, contributing anywhere from 7 percent to 50 percent of the total".50 The document also asserts, "Based on plant operating experience over the last 20 years, it has been observed that typical nuclear power plants will have three or four significant fires over their operating lifetime."51 (emphasis added) Yet, the NRC has not required the industry to replace this inoperable fire barrier.

Originally, 82 operating U.S. reactors installed Thermo-Lag 330-1 to protect reactor safe shutdown equipment as required by NRC regulations. However, 57 reactors have not yet replaced Thermo-Lag, while other plants have "resolved" the issue by only scheduling resolution.52 (APPENDIX I) Instead of requiring that this safety issue be corrected immediately, the NRC requested all affected plants to implement immediate "compensatory measures" -- continuous fire watch patrols wherever Thermo-Lag is installed in the nuclear power station.

While this may be the cheapest way for the industry to delay removing all Thermo-Lag from their facilities, it is certainly not the answer -- nor even an effective interim measure. Fire watch patrols will only allow a plant to identify a fire after it occurs, they cannot substitute for or "compensate" as an operable fire barrier in the event that human access is impossible , as in the example of a fire associated with high radiation fields. Thermo-Lag's designed function is to suppress, retard and protect the vital safety equipment from fire damage for up to three hours in areas where no fire suppression systems are installed. The NRC's acquiescence to the industry's implementation of fire watch patrols is merely a delay from replacing Thermo-Lag with another fire protection rated barrier that can perform its required safety function.

Additionally, fire watch patrols do not compensate for the inoperable Thermo-Lag 330-1 barrier because patrols have been documented by the NRC to have missed or to have been found sleeping during their watch. As of October 1995, the NRC's Public Document Room in Washington, DC documented thirteen instances of missed fire watch at nuclear power plants. The mere fact that fire watches are missed and Thermo-Lag fails NRC requirements should prompt the regulator to determine a final resolution, replacing Thermo-Lag with an operable fire barrier, and require licensees to implement it without delay. Instead, the NRC leans toward granting plant-specific exemptions to nuclear power plants that will allow them to continue to use fire watch as an interim measure for their inoperable fire barrier.

Plant-specific exemptions are common when the NRC considers fire protection issues. "The NRC has granted more than 1,200 exemptions to specific requirements of the fire protection rule since it was issued in 1981."53 According to James Taylor's April 3, 1996 letter to the Commission, while only a small number of plants have actually "closed out" the issue, 27 plants (over 30%) have submitted exemptions to the NRC concerning the status of Thermo-Lag 330-1 in their respective plant.54 (APPENDIX I) Are the utilities' reasons for submitting these exemptions valid or will this be an example of the NRC failing to enforce its own requirements?

Numerous tests prove that Thermo-Lag 330-1 cannot perform its required safety function. However, this information only came to light after many facilities had installed the fire barrier. The NRC simply did not review, test or verify the manufacturer's procedures or results -- similar to the NRC's blind acceptance that licensees have made required safety corrections without verification. The NRC Inspector General found, " . . . the [NRC] staff did not take any significant action between 1982 and 1991 when reports of problems with Thermo-Lag 330-1 were received."55 Why did it take the NRC nearly 10 years to take action against the industry for having installed a combustible fire barrier?

Hence, the NRC blindly approved a safety-related system that has placed dozens of nuclear power plants in non-compliance with fire protection regulations and that continues to jeopardize public safety by failing to bring the issue to closure with the required installation of operable fire barriers. This is just one more example of poor oversight by the government's regulating agency.

Perhaps the NRC is more interested in shielding the industry than it is in shielding the safe shutdown equipment vital to public health and safety.


Plants With Safety Significant Concerns

CASE 1. TVA: Disastrous Management Of Its Reactors

The Tennessee Valley Authority (TVA) was developed by the federal government in 1933 as a way to build up the economy of the Tennessee River Valley and to provide those in the surrounding area with a source of cheap electric power. Since then, TVA has expanded and now manages four nuclear power facilities: Watts Bar (TN), Sequoyah (TN), Browns Ferry (AL) and Bellefonte (AL). All of these reactors have had many problems that have caused the plants either to shut down or not be completed: Watts Bar 1 took more than twenty years to finally receive its operating license, while construction has discontinued on Unit 2; Sequoyah's reactors were shut down for three years in the mid-1980's; Browns Ferry has three units which were all shut down in the mid-1980's -- units 2 and 3 restarted in 1991 and 1995, respectively, while Unit 1 is not expected to restart; and construction on Bellefonte's two reactors has been halted due to financial constraints.

"In September 1985, the NRC staff issued a letter to the Chairman of the Board of Directors of the Tennessee Valley Authority (TVA), discussing significant continuing weaknesses in TVA performance and stating that management of the TVA nuclear program was ineffective. . . . The number and complexity of relevant issues were not limited to the operating reactors, since questionable construction practices had also been identified at the TVA's Watts Bar (Tenn.) project."56

TVA's weaknesses and ineffectiveness have yet to be corrected. It has been more than ten years since the NRC originally notified TVA of its problems. Currently, the NRC's "Watch List" includes Browns Ferry 3 in "Category 2" and Browns Ferry 1 in "Category 3".


TVA Technicians' Job Knowledge Not Up To Utilities' Own Standards

In 1993, TVA " . . . administered an examination to determine the Chemical Technicians current level of basic chemistry knowledge."57 The test consisted of six sections: "Principles of Chemistry & Basic Nuclear Physics", "Analytical Instrumentation", "Counting Room Instrumentation", "Plant Chemistry", "Gamma Spectroscopy" and "QA/QC". The following are the mean scores from all three TVA facilities:

Table 6. TVA Test Results 58 (APPENDIX J)

 Plant  Section I  Section II  Section III  Section IV  Section V  Section VI
 Browns Ferry  26%  43%  36%  53%  41%  33%
 Sequoyah  51%  34%   34%   42%   44%  36%
 Watts Bar  32%  20%  15%  31%  13%  10%
 Mean Score  36%  32%  28%  42%  33%   26% 

TVA decided that the results of the tests were so poor that they needed " . . . to implement changes intended to strengthen their continuing training program."59 However, this issue was brought to the forefront " . . . as a result of a recent independent audit finding . . . ." In other words, TVA was forced to acknowledge the problem because of internal complaints from whistleblowers who, notwithstanding considerable risk to themselves, appear to be the only semblance of accountability the nuclear industry grudgingly must endure. However, this incident was not the first time that these problems were highlighted. TVA documented the technicians' low job knowledge for five years before it took action. A 1987 internal TVA memorandum highlighted the need to change their training program to include more training on technical issues and past experiences at other facilities.60 The next year, a second TVA memorandum stated, " . . . individuals displayed weak knowledge . . . . "61 In 1989, the problem was again recorded in an internal TVA document, "Deficiencies exist in the expected knowledge of some chemistry personnel."62 But, again, TVA and the individual utilities did nothing to improve their training programs. Where was NRC oversight to ensure that plant employees were trained properly?

The incestuous relationship that has been established between the NRC and the industry, in this case, the TVA, causes both groups to side-step issues that have the potential to cause a backlash against the industry. In this case, changes were finally made to TVA's training program in 1993, which caused training hours to almost double. While the NRC is trying to give more power to the utilities, cases like this one highlight the essential need for an independent body that is not inter-twined with the industry it is supposed to regulate.


NRC Failed To Adhere To Its Own Licensing Procedures At Watts Bar

Watt's Bar Nuclear Plant is promoted by the NRC as "The most inspected plant in the country". Yet, what did these inspections determine? A review of just one safety system indicates that the NRC's hours of inspections produced questionable results.

In October 1995, a means was established between James Taylor, the NRC's Executive Director for Operations, and Watts Bar employees, so that adequate information pertaining to safety concerns would be delivered to the NRC's Office of Nuclear Reactor Regulation (NRR) staff while the identity of the employees remained protected.

One allegation presented to the NRC concerned Watts Bar's radiation monitoring system. Radiation monitors control levels of radioactive gases and liquids discharged from nuclear power plants. If these emissions exceed federally mandated concentrations, the monitors should automatically isolate the waste stream from the environment. Watts Bar's radiation monitors were alleged not to have been calibrated according to requirements.

With only the most preliminary information concerning the allegations available, the NRC licensing staff determined the allegations would have no safety significance and would not affect licensing -- thus granting the plant its low-power license. However, they did continue to collect information and conduct inspections into the allegations after they had licensed the plant. A subsequent NRC inspection proved the validity of the allegations. The validated allegations concerning the plant's radiation monitors resulted in a license amendment. Instead of fixing the system, the NRC issued a license amendment lowering the acceptance criteria of Watts Bar's radiation monitors. Therefore, the staff's earlier premature decision ensured that the allegations did not prevent the plant's licensing.

Simultaneously, an external review of the NRC's primary licensing document (Supplemental Safety Evaluation Report) and the licensee's licensing document (Final Safety Analysis Report) uncovered discrepancies between conclusions within these documents and the results of the NRC inspections. The licensing documents drew the conclusion that radiation monitoring had met all the standards within the NRC's Standard Review Plan, while the inspections established to investigate the allegations found that this conclusion was not accurate.

On January 27, 1996, a challenge to the low-level license was presented requesting a review of the NRC's licensing procedures executed at Watts Bar. NRC staff attempted to make moot the challenge against the low-power license by issuing the plant its full-power license. The Commission intervened and declared the license challenge applicable to the full-power as well as the low-power license. Currently, the license challenge is still open and awaiting a decision by Bill Russell, Director of NRR. The NRC staff preparing a review of the issue for Russell includes some of the major players in the original questionable licensing of the plant.

The lack of initial calibration to the radiation monitoring system remains unchanged from the status originally brought to the attention of the NRC. Now, Watts Bar is operating at 100% power with radiation monitors that have not been calibrated and are often unavailable for use. Watts Bar is an example of the NRC acquiescing to industry demands -- in this case, getting Watts Bar licensed and operating despite NRC regulations and procedures.


Tube Ruptures: Part II

Another safety issue that continues to cause problems at Watts Bar is known as water hammer (USI A-1), which was originally identified by the NRC in 1978 and resolved with no corrective requirements for operating plants in 1984. Water hammer is similar to the sound and vibration in homes that old pipes make when air travels through them. However, unlike your home, a water hammer at a nuclear power plant ruptures pipes and can spray radioactive water. An internal NRC Inspection Report mentions three water hammer "events" that have taken place at Unit 1 -- one "event" occurred on November 22, 1994.63 More recently, two additional Watts Bar Daily Team Meeting reports, dated August 18, 1995 and March 20, 1996, each cited a water hammer event.64

Water hammer is an issue that the NRC has taken very seriously over the years in regulations and by requiring licensees to install systems that will prevent any such event. One NRC regulation, Regulatory Guide 1.68 "Initial Test Programs For Water-Cooled Nuclear Power Plants", specifically addresses the water hammer issue and attempts to prevent any such event from occurring. The regulation states:

"Operability of system pumps, valves, controls, and instrumentation should be demonstrated, and, to the extent practical, testing should provide reasonable assurance that flow instabilities, e.g., "water hammer" will not occur in system components, piping, or inside the steam generators during normal system startup and operation."65 (emphasis added)

If this is true, then why was this requirement obviated at Watts Bar? Three water hammer events have occurred at Watts Bar since 1994, occurring both before and after the plant received its operating license -- none of which are considered acceptable by NRC regulations. Were the NRC's reasons for not following their own regulations valid or is this instance another example of the NRC failing to enforce its own requirements?


Sequoyah: Unreliable Monitors

TVA's Sequoyah Nuclear Plant has also had problems with its safety systems. In 1992, Sequoyah noticed that its radiation monitors had " . . . setpoints calculated in a nonconservative manner."66 (APPENDIX K) In other words, these monitors that detect released radiation were not likely to be triggered until a significant amount of radiation was already in the atmosphere. These are the monitors that were one of the subjects of the licensing challenge at Watts Bar, yet the NRC does not consider them important enough to categorize them as generic.

For nearly fifteen years, the Sequoyah facility was operating with unreliable radiation monitors that went undetected despite audits by NRC and the Institute of Nuclear Power Operations (INPO). INPO evaluates safety issues at nuclear plants but does not make any of its findings available to the public. Radiation monitors are vital to protect the outside environment.67 Where is the regulating body that should be verifying that nuclear power plants are in compliance with the regulations that it has established? What was the NRC looking at if it was not looking at radiation monitors?

The NRC's unwillingness to regulate the nuclear industry can also be observed in a second monitoring system (also referred to as on-line monitors, in-line monitors, process monitors and secondary chemistry instruments) that monitors and controls steam generator tube integrity and corrosion. Problems with this system were cited as early as August 1988 when a TVA Inspector recorded, "A high percentage of the process monitors were observed to be not working or not working properly."68 Warnings about this problem were issued in 1989, 1992 and 1994. In fact, in 1992, it was discovered that some of the calibrations of these monitors had not been performed since 1984.

When brought to the attention of the NRC, the agency ultimately issued a notice of violation for the failure to calibrate instruments necessary for the safe operation of the plant, ostensibly challenging the efficacy of their entire instrument calibration program. Where were INPO and the NRC? What were they inspecting? How could they miss a condition as egregious as this?


CASE 2. South Texas

From February 1993 to May 1994, both reactors at the South Texas Project Electric Generating Station were shut down due to significant safety problems. The first of these problems occurred with the plant's turbine-driven auxiliary feedwater pumps, a system that has had several components listed as High Priority Generic Safety Issues. This safety system preserves the cooling of a reactor in the event of a total loss of offsite power. At the same time, two of the plant's standby diesel generators also were not functioning. This High Priority Safety Issue had been "resolved" by the NRC with no new requirements in 1993. A problem with either one of these safety systems is sufficient to cause a plant to shut down.

The NRC requires that a plant be shut down if the plant's turbine-driven auxiliary feedwater pumps are inoperable for more than three days. In this case, the NRC found, only after the plant had already been shut down, that the pumps had not been working for 40 days -- " . . . or about 37 days beyond the 3-day time frame that requires the reactor's shutdown."69 (APPENDIX L) A similar circumstance occurred when two of the plant's three diesel generators were inoperable for 24 days and 61 hours respectively.70 The diesel generator that was inoperable for 24 days was 21 days beyond the time frame that requires shutdown.71 The GAO reported that the NRC's trust in the power plant was the root of the problem:

"Furthermore, NRC found that it had not ensured that the licensee had corrected identified problems. Instead, according to NRC, it relied on the licensee's programs and commitment to correct recurring problems, which, in retrospect, were not effective. . . . According to NRC, it did not consistently pursue enforcement actions against the licensee because it had developed a 'practice' of providing the licensee with 'additional latitude' to address known problems."72 (emphasis added)

An NRC task force, known as the South Texas Project Task Force, was organized in mid-1994 to evaluate the NRC's inspection program effectiveness at the South Texas plant. Their subsequent report dated March 31, 1995 stated:

"This was also reflected in the [South Texas Plant] inspection history, where individual inspector decisions not to pursue issues that could have resulted in NRC violations at times appeared to have been based upon ongoing licensee corrective action efforts that, in retrospect, were not consistently effective. . . . Several licensee programs that the NRC considered to be functional . . . were not as effective as licensee intentions or commitments would convey. An apparent over-reliance on [Houston Light and Power Co.] commitments for "get well" programs appeared to partially mask declining performance into 1992. . . . However, in the past an over-reliance on the effectiveness of licensee programs and commitments to correct recurrent problems delayed NRC actions in requesting [Houston Light and Power] to resolve the deficiencies in a more timely manner." 73 (emphasis added)

Plant management stated that the risk of an accident during the time that these systems were inoperable was very low. Would you expect any other response from a utility? Risk, however, is the product of the probability of an accident as well as its consequences. Thus, the probability of an accident occurring had not changed but the risk associated with the consequences of an accident increased significantly due to the unavailability of the safety equipment. The NRC fined the power plant $325,000 for not having the safety systems operational as required. Still, the NRC's delegation of authority allowed the licensee to wait more than a month to shut down their plant and notify the NRC about their safety problems.


"Who the hell is regulating who?"

More than any other regulating agency, the NRC has acquiesced to the industry it oversees -- the industry in which accidents have the greatest consequences. For example, an NRC Inspector General investigation that examined allegations that the nuclear industry was " . . . too influential in shaping . . . " the drafting of new technical specifications released a report stating:74 (APPENDIX M)

"In support of his concern that NUMARC has improperly influenced the NRC staff, the alleger asserted that in response to the draft of the new specifications, NUMARC provided the NRC with approximately 25,000 comments which were all accepted by NRC management over objections of the NRC staff . . . . NRC upper management appeared to accept the industry position on the technical specifications program even though the staff developed positions to the contrary."75

While the investigation could not prove that NUMARC and the NRC were in collusion with each other, remarkably, all 25,000 comments made by the nuclear industry were accepted by the NRC. For decades, the industry has curbed regulations that would improve operating procedures. The current relationship between the industry and the NRC parallels the earlier relationship between the industry and the AEC. The pressure cast on the NRC by the industry comes from four influential groups: INPO, which is able to keep their information from the public by skillfully copyrighting documents, making it illegal to reproduce INPO reports without their written consent; the Nuclear Energy Institute (NEI), which acts as the industry's lobbying group and was formed from four different groups including NUMARC; the nuclear reactor manufacturers (i.e. General Electric and Westinghouse); and the individual licensees who provide nearly all NRC funding.

Former NRC Chairman Ivan Selin has criticized "INPO's actions as 'lobbying' on behalf of the nuclear power industry rather than raising safety concerns." 76 (APPENDIX N) The NRC believed that INPO crossed a line when they filed " . . . complaints on behalf of a particular utility against a specific NRC manager, as well as INPO involvement in an industry sponsored study which was critical of the NRC." 77 According to Selin, INPO performed NEI's role as the "lobbyist" for the nuclear industry. However, both groups are assembled by high level officials from individual power plants and the companies that own the plants. More than one-half of INPO's twelve-member Board of Directors also sit on the Board of Directors for NEI. Essentially, the same individuals who are supposed to operate as independent evaluators of safety issues also serve as lobbyists for the nuclear industry. INPO and NEI managed to influence the NRC and dilute proposed NRC regulations for decades before Ivan Selin decided to draw a line between the two groups.

Though the NRC only recently discovered these two industry groups have overstepped their boundaries, many critics have observed the incestuous relationship between the regulator and the regulated since its creation:

  • "In fact it is difficult now to determine . . . where the Commission ends and the industry begins." 78 (regarding the AEC) Senator Abraham Ribicoff - 1974
  • " . . . the NRC has sometimes erred on the side of the industry's convenience rather than carrying out its primary mission of assuring safety. . . . both licensees and vendors often have strong financial disincentive to evaluate and report safety problem that may result in more stringent regulations, at least in part because it is uncertain which entity will ultimately bear the cost of increased safety." 79 (emphasis added) Kemeny Commission Report - 1979
  • "The intimacy between the NRC and the nuclear industry goes beyond what the public and Congress have tolerated at other federal agencies. . . . the NRC has released draft investigation, inspection and evaluation reports to their subjects, and the Commission has consistently failed to take disciplinary action against the responsible officials."80 (emphasis added) Union of Concerned Scientists - 1985
  • "Who the hell is regulating who? In my opinion, the NRC did not have to buckle to industry pressure. . . . As a result, the NRC has essentially left it to the nuclear industry to regulate itself." 81 Loren L. Bush, U.S. Nuclear Regulatory Commission Chief - 1987 (APPENDIX O)
  • " . . . NRC may take from several months to 10 or more years to resolve (identify and approve a solution for) generic issues, including those NRC believes pose the highest safety risk. . . . The longer these issues remain open, the less assurance NRC has that safety standards are up to date and the plants are operating safely."82 (emphasis added) General Accounting Office - 1987
  • " . . . in the long run, lax regulation could lead to an accident which could have disastrous consequences for the American people and for the future of the American nuclear power industry. . . . the NRC has acted as if it were the advocate for, and not the regulator of, the nuclear industry. . . . Time and again the NRC has afforded the relief sought by the industry. . . . the nuclear industry has been extremely successful in obtaining relief from regulatory processes and requirements it deemed burdensome. . . . However, the NRC must distinguish between communication and accommodation."83 (emphasis added) Subcommittee on General Oversight and Investigations of the Committee on Interior and Insular Affairs, U.S. House of Representatives - 1987 (APPENDIX P)
  • "The nuclear regulators appear once again to have exhibited regulatory and oversight passivity and paralysis. . . . Despite their track record, NRC still operates in a manner where it trusts those it regulates."84 (emphasis added) Representative John D. Dingell - 1993

Given the NRC's problems in trying to regulate the most hazardous industry in the world, recent feuds have erupted between the industry, the NRC, the Senate and the President. The NRC is governed by a five-member commission, nominated by the President and approved by the Senate. An example of the industry's influence over the NRC and Congress can be observed in the recent appointments and confirmations of NRC Commissioners. Shirley Ann Jackson, who was appointed as the Chair of the NRC and was a member of INPO's Advisory Council, did not encounter any problems obtaining Senate confirmation. According to the Washington Post, a second appointment to the Commission, Greta Joy Dicus, was recently confirmed because " . . . the Republicans liked her because of her industry support."85 However, Dan Berkovitz's nomination, " . . . blocked by industry opposition . . . ", was stalled in the Senate from January to October 1995. He conceded his NRC appointment by taking a position at the Department of Energy.86 "Industry support" appears to be the difference between Senate confirmation and rejection for NRC nominees.


Results Of This Cozy Relationship

One disturbing NRC trend is the subjectiveness of categorizing safety issues. In an effort to lessen the burden on the nuclear industry, the NRC will not categorize safety issues at all or will consider them not relevant to safety. After Three Mile Island, the NRC put itself under a microscope. Thousands of safety issues were identified and scheduled for resolution. Apparently, the NRC is only willing to acknowledge safety issues after an accident has occurred. Now, most issues are considered an "abnormal occurrence" or "plant specific". An example of this shift in focus from generic to plant-specific is Thermo-Lag 330 fire barriers. In this case, the NRC exempts specific nuclear power plants from NRC regulations without having to justify the issue's blanket exemption.

A second problem has surfaced largely because it is impossible to differentiate between the NRC and the nuclear industry. NRC inspectors have stated that they were dissuaded by the NRC from finding violations at nuclear power plants. These inspectors said they were personally penalized if they found violations -- they would not receive rewards or promotions. One inspector stated that they " . . . get a lot of flack on issuing violations even on gross compliance issues."87 Inspections and the reporting of any violations are the primary job of the NRC.

In addition to the inspectors' fears in reporting safety problem, the utilities themselves hesitate to report violations that may cause a backlash for the industry as a whole. According to industry responses, " . . . most utilities fear retribution by the NRC and are, therefore, reluctant to discuss matters openly with the NRC."88 This fear is extraordinary, when even the most egregious negligence of safety requirements usually are met with the proverbial slap on the wrist or no action at all. Unfortunately, no official accepts the responsibility needed to ensure that public safety comes first.

Another internal NRC Inspector General report alleged that " . . . utilities routinely make deliberate false statements to the NRC and inappropriately reinterpret plant design criteria, with full knowledge of . . . the NRC."(sic)89 The NRC's abdication of responsibility is intolerable. The NRC has relinquished authority to an industry that has documented cases of providing the NRC with deliberate false statements, distributing inaccurate information and concealing "events" and information. The nuclear industry has yet to prove that it deserves the trust that the NRC affords it.

A third concern arises from the NRC's use of enforcement discretion in choosing not to penalize a utility for wrongdoing. One method that the NRC utilizes is to rescind any action or fine that had been previously levied against a utility because the plant had made an effort to fix the problem. As any parent knows, this process encourages bad behavior by removing the penalty after the licensee is caught and atones for its misbehavior. A second enforcement discretion method exercised by the NRC appears to be blatant charity. Watts Bar is one example in which a utility did not receive either a Notice of Violation or a civil penalty due to NRC's coziness.

"Because the continuing problems at [Watts Bar Nuclear Plant] are of very significant concern to the NRC, a significant civil penalty would normally be proposed. However, I am not persuaded that such an action can help bring about the necessary changes any more readily than the multitude of program changes [Tennessee Valley Authority] has unsuccessfully implemented at [Watts Bar Nuclear Plant] since its shutdown of its nuclear program in 1985." (emphasis added) 90 (APPENDIX Q)

Another concern arises due to the fact that utilities highlight profit before safety. Shirley Ann Jackson has alluded to this problem in recent speeches, "When we couple the risk of complacency with the economic pressures on utilities to reduce plant operating and maintenance costs, there is a potential for problems to go unnoticed or to be acted upon too slowly".91 (emphasis added)

A final concern involves whistleblowers. TIME's cover story was brought to the forefront by Millstone whistleblowers who wanted to correct problems that had plagued their plant. Whistleblowers throughout the nuclear industry have been instrumental in pointing out its deficiencies. However, concerned nuclear industry whistleblowers are met with staunch criticism, and many of them are harassed, intimidated and fired. One NRC policy did nothing to correct this problem.

In 1991, the NRC entered into a "Memorandum Of Understanding" with the TVA, which allowed TVA to conduct investigations into whistleblower complaints filed with the NRC. The NRC's Office of Inspector General reported that the NRC turned over the identities of TVA employees, who had reported safety concerns and because they feared TVA retaliation, were granted confidentiality, to the TVA. This act was done " . . . without the individuals' consent or knowledge."92 The IG's report stated, "The investigation determined that Region 2 employees are, based on a regional office instruction, misleading allegers as to what degree they can expect their identities to be protected."93

Many times nuclear whistleblowers are labelled as being "anti-nuclear" by those who fear them. Whistleblowers usually are trying to correct safety concerns, terminate wasteful spending practices or remedy mismanagement within their agency because their jobs and their livelihood require that they make nuclear power as safe and efficient as possible. In doing so, sometimes their lives are even at stake. The NRC must better protect nuclear industry whistleblowers who risk everything and receive nothing for initiating oversight over the nuclear industry and its practices.


The History Of Categorizing Safety Issues

The Union of Concerned Scientists (UCS) not only has spoken out against NRC practices but also has forced the regulating agency into action. In 1991, UCS accused the NRC of ignoring violations that occurred at the Yankee Rowe power plant in Massachusetts. UCS's allegation resulted in an NRC Inspector General Investigation and the NRC ". . . subsequently recommended that Yankee Rowe be shut down . . . . "94

In 1977, the NRC secretly began categorizing problems occurring at many nuclear power plants when Bob Pollard, then a NRC Licensing Project Manager, who later worked for UCS, highlighted the NRC's efforts to conceal safety issues. The public scrutiny generated by his revelations forced the NRC to develop a program, referred to as "Unresolved Safety Issues" (USIs), to investigate and to disclose annually to Congress safety issues affecting nuclear power plants.

USIs are the highest priority safety issues because they have the potential to cause the greatest public harm. In 1982, "Generic Safety Issues" were conceived, thus joining "Unresolved Safety Issues" as issues that potentially could cause safety risks. Generic Safety Issues characterize safety concerns that potentially affect all, or many, reactors and facilities, and are prioritized as HIGH, MEDIUM, LOW, or DROP (an issue that is not given further consideration). In 1984, the NRC added GSIs to its Annual Report to Congress. Each year, in its annual report, the NRC extends the resolution dates for generic safety issues, yet no one is penalized.

The NRC has been criticized for labeling issues as "generic" in order to protect the nuclear industry from having to be responsible for correcting the problems. The Kemeny Commission, organized to investigate the 1979 accident at Three Mile Island (PA), found, " . . . the evidence indicates that labeling a problem as 'generic' may provide a convenient way of postponing decision on a difficult question."95 The Union of Concerned Scientists have stated their displeasure with the NRC's GSI program:

"The NRC's schedules for resolution of generic safety issues, including those highest-priority USIs, are among the most flexible to be found in any government agency. Years routinely pass between issue identification, resolution and implementation. In several cases, accidents have occurred in operating reactors that clearly involved one or more generic safety issues."96

During the 1980's, the NRC used GSIs as a tool to allow nuclear power plants to open regardless of unaddressed safety concerns. Once the NRC places a safety issue on the GSI list, an individual plant is no longer responsible for finding a solution to the problem -- that responsibility is shifted to the NRC. This process inevitably causes delay and negatively impacts utilities desiring to operate safe plants. If the industry implements a fix to a generic issue before the NRC comes to a solution, the industry risks that the NRC will not accept its solution. Thus, utilities have been trained to hold off safety corrections until the NRC issues a decision.

The danger with this system is that power plants remain operational while the NRC takes years to find a solution. But, who does this system benefit? It surely does not benefit the public. In 1984, an NRC spokesperson stated, " . . . that system [GSIs] was developed deliberately as an accommodation to the nuclear power industry. It was developed in order to get plants licensed without resolving significant safety questions . . . ."97 This concession was made to the industry under the stipulation that changes would be made " . . . later on without regard to cost".98 In other words, the NRC made licensing nuclear power plants a higher priority than resolving safety issues.

In fact, the retroactive changes, known as the "backfitting rule", that were to follow licensing never occurred. In recent years, the NRC has curtailed the issuance of generic safety issues even though many issues still are being addressed generically by the NRC, indicating that the NRC extended the concept of getting plants licensed to keeping plants running in spite of safety problems.An investigative report by the Subcommittee on General Oversight and Investigations of the Committee on Interior and Insular Affairs stated, "In other words, when the industry says 'Trust us,' the Commission goes along. . . . The Commission is permitting the nuclear industry to regulate the staff of the NRC."99 The NRC had relinquished its ability to solve safety problems that had gone unanswered after a nuclear power plant was built. Former NRC Commissioner Asselstine condemned the rule, stating:

"In adopting this backfitting rule, the Commission continues its inexorable march down the path toward nonregulation of the nuclear industry. . . . I can think of no other instance in which a regulatory agency has been so eager to stymie its own ability to carry out its responsibilities. Indeed, the adoption of this rule is the most compelling evidence to date of the Commission majority's open hostility to the regulatory mission of this agency. . . . I do not believe that there is a need for a formal Commission regulation restricting the Commission's ability to require safety improvements for nuclear power reactors. . . . The consequence of this rule is to limit the NRC staff's and even the Commission's ability to identify and correct safety weaknesses at the nuclear power plants in operation and under construction in this country. As a result, these weaknesses are likely to persist until they cause serious operating events or accidents which pose a direct threat to the health and safety of the public. . . . The Commission has said there is about a 50-50 chance of another severe accident in the next twenty years. The Commission finds that risk so acceptable that it can now, through this rule, put roadblocks in the way of further safety improvements. I find the Commission's actions to be not only unwise but harmful to the public interest and potentially hazardous to the public health and safety."100 (emphasis added)


What Does The Industry Think Of The NRC?

In October 1994, Towers Perrin, a management consulting firm, completed an industry-sponsored study examining the NRC and its practices. This study was undertaken at a time when the NRC, under the leadership of Chair Selin, was cutting many of the "regulatory burdens" it had placed on the nuclear industry. Still, NEI thought the NRC was moving too slowly and decided to pressure the NRC by initiating the Towers Perrin study. The report drew four conclusions101 (APPENDIX R):

1. The nuclear industry has met its goal of protecting public health and safety.

2. The NRC has a number of positive attributes, including its official rules, technical specifications and its efforts " . . . to reduce the regulatory burden . . . " on the industry, to name a few.

3. The NRC has many flaws: "Towers Perrin found that utility CEOs are relatively unfamiliar with the pressures placed on their plant management by NRC personnel and policies; licensees have not consistently raised their concerns with the NRC; licensees consistently have trouble sticking to their agreement in response to NRC pressure; and that the industry and the NRC have not generally worked effectively and efficiently together to resolve important generic issues."

4. Many problems that exist at the NRC are "chronic and persistent."

When asked specific questions pertaining to NRC operations, nuclear industry representatives (including Senior Executives, Chief Executive Officers, Senior Nuclear Executives, Site Executives, Plant Managers and Licensing Directors and or executives or their equivalent) gave responses portraying the NRC as ineffective, inefficient and burdensome.

The report continually threatened the NRC with increased energy rates for the consumer. The nuclear industry complained that it had been placed out of the competitive energy market. This complaint is factually true. However, the reasons the nuclear industry cites -- NRC regulations and processes increase costs -- are not to blame. France and Japan, two countries that provide full government cooperation and support to their respective nuclear programs, face similar problems with safety, rising costs and utility debt. The problems are simple: safety does not increase as nuclear reactors age; and building a nuclear reactor is not cheap.

Many utilities are handicapped with millions of dollars of debt even before one kilowatt of electricity is produced. Watts Bar's recently-completed reactor cost more than $7 billion. The actual production cost of nuclear energy is higher than coal and cheaper than both gas and oil. However, nuclear power plants have experienced many other costs, including higher than anticipated operation and maintenance costs, that have not offset the billions of dollars spent on construction. When these factors are coupled with aging equipment and reactors, costs are destined to rise.

The nuclear industry's discontent with NRC regulations stems from the possibility that they will lose money -- Wall Street money. NRC reports are used by the financial community, thus, the industry complains, affecting the nuclear industry's bond ratings, potential investors, companies' stock prices and a licensee's insurance costs.102 These reasons are the driving forces behind why the nuclear industry clearly is concerned with costs and why it passes them on to the consumer.

How does the industry feel about its relationship with the NRC when it comes to working together to resolve USIs, GSIs and other types of generic issues? A very high percentage (75% to be exact) of the study's respondents disagreed or strongly disagreed with the statement, "NRC and the industry work effectively and efficiently together to resolve generic issues."103 Both the nuclear industry and the NRC have asserted this position, yet no progress has been made to ensure the resolution and correction of these issues.


Congressional Proposals: From Restructuring To Abolition

The NRC has not survived twenty years without staunch criticism. In 1979 and 1987, groups called for an outright restructuring of the NRC: the Kemeny Commission in 1979; and Representatives Denny Smith and James Hansen in 1987. Similarly, in 1988, Senator John Breaux (D-LA) proposed an amendment that would create the Nuclear Safety Agency and abolish the NRC.

Senator Joseph R. Biden Jr. (D-DE) has proposed legislation to every Congress since 1987, attempting to create an "Independent Nuclear Safety Board to conduct impartial investigations of events which threaten human health and safety at Nuclear Regulatory Commission licensed facilities."104 On February 29, 1996, Senator Biden sent a letter to Charles Bowsher, Comptroller General of the General Accounting Office, stating:

"I am deeply disturbed by continued reports of regulatory complacency, on the part of NRC, and am troubled by what appears to be a decidedly pro-industry tilt to this most troubled government agency. . . . It is my concern that the NRC's reliance upon individual nuclear power plants for self-regulation may be inherently, and perhaps fatally flawed."105

Senators Breaux and Biden have recognized the urgent need for independence within the NRC. Unfortunately, their pressure has not been enough to force Congressional action. Congress has allowed the NRC to fix its own house -- in a similar fashion, the NRC "oversees" the nuclear industry. Congress has developed a "hands off" approach toward the NRC because the licensees fund nearly 100% of the NRC budget. Thus, the NRC operates without Congress controlling its purse strings.

Despite these recommendations and the findings of the GAO among others, no concrete improvements have been made. Standard operating procedure is essentially the same as it has been since the Atomic Energy Commission's reign.


Conclusions And Recommendations

President Clinton must immediately fill the two vacancies on the NRC's Commission. These members should not come from the industry's pool of bureaucrats, for they will further hamper the NRC's ability to regulate industry. Instead, President Clinton and the Senate should look for two Commissioners who will crack down on the nuclear industry; persons who will put safety first, eliminate industry control and compel the NRC to regulate the nuclear industry to its fullest extent -- perhaps a whistleblower who is familiar with the NRC's relationship with industry. The placement of two hard-nosed regulators on the Commission could reverse the trends that have plagued the NRC and its predecessor, the AEC. The American public needs a government agency that will regulate the nuclear industry, instead of protecting it.

Secondly, correcting and verifying safety issues must become a top priority within the NRC and the utilities. The NRC should not take twenty years to find, to "resolve", and to verify safety issues at nuclear power plants. The NRC should not allow current licensees to renew their forty-year licenses until all safety issues are corrected at each plant. The NRC must stop allowing its "safety" programs to be used for stall tactics that allow the nuclear industry time to influence policy and cut corners.

A third concern is the relationship that the NRC has established with industry groups, INPO in particular. After the accident at Three Mile Island, the nuclear industry created INPO to evaluate and report on safety issues. However, INPO does not release its reports to the public. INPO's notes and reports are turned over to the inspected power plant which consider them proprietary. Often, the NRC relies on INPO's reports when conducting their own investigations. Since INPO documents are considered proprietary and many are even copyrighted, the public cannot receive INPO reports under the Freedom of Information Act, the law that gives the American public access to government documents. What is INPO hiding and why does the NRC protect it? Perhaps, INPO's reports would embarrass or damage an individual utility, the entire nuclear industry or the NRC. Secrecy breeds suspicion, and INPO and the entire nuclear industry can only benefit from opening all records to the public.

Additionally, the NRC must operate independently from the nuclear industry. In the past, certain members of Congress have called for the abolition of the NRC, a total restructuring of the agency, and an independent oversight panel to ensure public safety. Now, someone must step in and hold the NRC, its licensees and the entire nuclear industry accountable. Clearly, the present system is not working. Quite possibly, it is time to recreate a regulating body that is capable of enforcing regulations. The NRC's lack of independence cannot be tolerated by Congress or the American public as nuclear power plants grow older and more threatening.

Current changes to the GSI program appear to be very modest steps toward correcting safety concerns. However, the recent changes do not solve the basic problems the GSI and USI programs are encountering: high priority safety issues will continue to stall for years; issues will be "resolved" without any corrective requirements; safety issues will continue to resurface years after their initial dismissal; and the NRC will approve plant-specific exemptions while, at the same time, continuing to catalogue generic issues as non-safety significant. The NRC must establish schedules requiring issues to be corrected quickly, with strict penalties for any licensee that does not perform the required change within the given timetable. The NRC must terminate its current program which allows the industry to procrastinate in fixing safety issues that were "resolved" by the NRC in the 1970's.

The American public is tired of the status quo when it comes to government lip service. The problems that exist within the NRC are far more insidious than the usual waste and abuse that occurs within government. Problems that occur within the nuclear industry are not as forgiving as other industries. One mistake at a nuclear power plant could melt down in the backyard of the NRC, the Congress, and the American public. The President, the Congress and the NRC must separate the nuclear industry from the NRC. The cozy, incestuous relationship that dates back to the Atomic Energy Commission finally must end -- the NRC can no longer be an extension of the nuclear industry. The Nuclear Regulatory Commission must fulfill its function of regulating the nuclear industry, or there is no purpose to its existence.


Glossary

ACRS NRC -- Advisory Committee on Reactor Safeguards Nuclear Regulatory Commission

AEC -- U.S. Atomic Energy Commission

BWR -- Boiling Water Reactor

CFR -- Code of Federal Regulations

EDG -- Emergency Diesel Generator

FSAR -- Final Safety Analysis Report

GAO -- U.S. Government Accountability Office

GL -- Generic Letter

GSI -- Generic Safety Letter

Implement -- NRC term when a licensee has completed the necessary requirements

IG -- NRC Inspector General

INPO -- Institute of Nuclear Power Operations

Kemeny Commission -- Commission organized to investigate the 1979 accident at Three Mile Island, Pennsylvania

LER -- Licensee Event Report

NEI -- Nuclear Energy Institute

No Requirement -- NRC designation when a safety issue does not require any change to its requirements

NRC -- Nuclear Regulatory Commission

NRR -- NRC Office of Nuclear Reactor Regulation

NUMARC -- Nuclear Management and Resources Council

NUREG -- NRC term for a technical report on a specific issue

PWR -- Pressurized Water Reactor

QA -- Quality Assurance

Resolved -- NRC term for when it has agreed on a resolution or when no changes are required; this term does not require that the issue be corrected

SRP -- Standard Review Plan

TMI -- Three Mile Island

TVA -- Tennessee Valley Authority

UCS -- Union of Concerned Scientists

USI -- Unresolved Safety Issue


Endnotes

1. Ivan Selin, NRC Chairman, Before The Regulatory Information Conference, "The Future of Reactor Regulation", S-95-05, May 9, 1995, p. 7-8.

2. U.S. General Accounting Office, GAO/RCED-96-10, "Nuclear Regulation: Weaknesses in NRC's Inspection Program at a South Texas Nuclear Power Plant", October 1995, p. 5. (Hereinafter, GAO/RCED-96-10.)

3. Stellfox, David. "Russell Moves To Improve Management Of Generic Safety Issues Within NRR", Inside N.R.C., May 15, 1995, p. 7. (Hereinafter, Inside N.R.C.)

4. U.S. General Accounting Office, GAO/RCED-96-10, "Nuclear Regulation: Weaknesses in NRC's Inspection Program at a South Texas Nuclear Power Plant", October 1995, p. 6, 10. (Hereinafter, GAO/RCED-96-10.)

5. U.S. Nuclear Regulatory Commission, Region II, Allegation Evaluation Report, Allegation Number OSP-88-A-0065, "Miscellaneous Concerns In Areas of QA Records and Engineering Evaluations: Twenty-Four Technical Issues", November 16, 1991, p. 5.

6. Dr. Shirley Ann Jackson, NRC Chair, Before The Korea Atomic Industrial Forum, "Nuclear Regulation In The United States: Policy Directions And Future Prospects", April 12, 1996, p. 8.

7. Kenneth C. Rogers, NRC Commissioner, At The NRC Regulatory Information Conference, "Some Important Emerging Regulatory Issues", April 10, 1996, p. 2.

8. James M. Taylor, NRC Executive Director for Operations, at The Regulatory Information Conference, April 9, 1996, p. 5. (Hereinafter, Taylor Speech, April 9, 1996.)

9. U.S. Nuclear Regulatory Commission, NUREG-0933 Revision 5, A Prioritization of Generic Safety Issues, June 30, 1994, p. 2. (Hereinafter, NUREG-0933.)

10. NUREG-0933, p. 10.

11. GAO/RCED-84-149, p. 20.

12. Max Carbon, Chairman ACRS, Letter to Joseph M. Hendrie, NRC Chairman, March 21, 1979, p. 2.

13. Towers Perrin, "Nuclear Regulatory Review Study", October 1994, p. 82. (Hereinafter, Towers Perrin Study)

14. Inside N.R.C., p. 7.

15. Taylor Speech, April 9, 1996, p. 2.

16. NRC, "Periodic Briefing On Operating Reactors And Material Facilities", January 31, 1996, p. 2-4 and http://www.nrc.gov/Rlll/rjs2/probplnt.htm.

17. Pooley, Eric. "Nuclear Warriors", TIME, March 4, 1996, p. 48.

18. U.S. Nuclear Regulatory Commission Annual Report 1978, p. 38.

19. T.S. Kress, Chairman ACRS, Letter to Shirley Ann Jackson, NRC Chair, Press Release No. 96-46, February 26, 1996, p. 1. (Hereinafter, Kress to Jackson, February 26, 1996.)

20. U.S. Nuclear Regulatory Commission Annual Report 1994, p. 49.

21. Ibid.

22. U.S. Nuclear Regulatory Commission Annual Report 1985, p. 31.

23. Kress to Jackson, February 26, 1996, p. 4.

24. Ibid.

25. U.S. Nuclear Regulatory Commission Annual Report 1994, p. 275.

26. U.S. Nuclear Regulatory Commission, "NRC Bulletin 93-02 supplement 1: Debris Plugging Of Emergency Core Cooling Suction Strainers", February 18, 1994, p. 6.

27. Ivan Selin, NRC Chairman, "The Future of Reactor Regulation", Before The Regulatory Information Conference, May 9, 1995, p. 7-8.

28. U.S. Nuclear Regulatory Commission, Generic Letter 95-03: "Circumferential Cracking of Steam Generator Tubes", April 28, 1995, p. 1.

29. U.S. Nuclear Regulatory Commission Annual Report 1978, p. 22.

30. U.S. Nuclear Regulatory Commission, NUREG-0844, "NRC Integrated Program for the Resolution of Unresolved Safety Issue A-3, A-4, and A-5 Regarding Steam Generator Tube Integrity", September 1988, p. 1-1.

31. U.S. Nuclear Regulatory Commission Annual Report 1993, p. 72-75.

32. Ibid, p. 72-75.

33. U.S. Nuclear Regulatory Commission, Generic Letter 95-03: "Circumferential Cracking of Steam Generator Tubes", April 28, 1995, p. 1.

34. Ibid.

35. Kenneth C. Rogers, NRC Commissioner, Before The International Symposium On Nuclear Power Plant Aging, "Nuclear Power Plant Aging: The U.S. Regulatory Perspective", S-9-88, August 30, 1988, p. 2.

36. Public Citizen, "Westinghouse: Leaks and Lawsuits", June 2, 1994, p. 1.

37. TVA Division of Nuclear Power, Division Position Paper, Copper Alloys in Pressurized Water Reactor Plant Steam, Condensate, and Feedwater Systems, March 31, 1982, p. 1.

38. Dr. Shirley Ann Jackson, NRC Chair, Before The Japan Atomic Industrial Forum, "Nuclear Regulation: The Challenges Of Change", S-96-05, April 17, 1996, p. 3.

39. Jeanne Hunt, Office of Investigation, to James C. McKnight, IRM/RMB, May 11, 1994, p. 13.

40. U.S. Nuclear Regulatory Commission, NUREG-1410, "Loss of Vital AC Power and the Residual Heat Removal System During Mid-Loop Operations at Vogtle Unit 1 on March 20, 1990", June 1990, p. iii. (Hereinafter, NUREG-1410.)

41. NUREG-1410, p. 6-1.

42. Ibid.

43. Ibid, p. 6-5.

44. Byron Lee Jr., NUMARC, Letter to Kenneth M. Carr, NRC Chairman, November, 9, 1990, p. 2.

45. David A. Ward, Chairman ACRS, Letter to Ivan Selin, NRC Chairman, December 20, 1991, p. 1.

46. Jeanne Hunt, Office of Investigation, Letter to James C. McKnight, IRM/RMB, May 11, 1994, p. 1.

47. Ibid, p. 1-2.

48. ACRS Meeting Minutes/Summary of the AC/DC Power Systems Reliability Subcommittee, August 8, 1990, p. 4-5.

49. 10 CFR, Part 50, "Appendix R - Fire protection Program For Nuclear Power Facilities Operating Prior to January 1, 1979", January 1, 1991 Edition, p. 672.

50. U.S. Nuclear Regulatory Commission, NUREG-1150, Vol. 2, "Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants", Appendices A, B, and C, Final Report, October, 1990, p. C-12.

51. Ibid.

52. James M. Taylor, NRC Executive Director for Operations, to Chairman Jackson, Commissioner Rogers and Commissioner Dicus, "Semiannual Report on the Status of the Thermo-Lag Action Plan and Fire Protection Task Action Plan", April 3, 1996, Appendix.

53. Nuclear Energy Institute World Wide Web Site, http://www.nei.org/main/pressrm/facts/fireprot.htm, "Fire Protection: Nuclear Power Plant Fire Protection", Last Revised October 1995, p. 3.

54. James M. Taylor, NRC Executive Director for Operations, to Chairman Jackson, Commissioner Rogers and Commissioner Dicus, "Semiannual Report on the Status of the Thermo-Lag Action Plan and Fire Protection Task Action Plan", April 3, 1996, Appendix.

55. U.S. Nuclear Regulatory Commission, Office Of The Inspector General, "Adequacy of NRC Staff's Acceptance and review of Thermo-Lag 330-1 Fire Barrier Material, 91-04N", August 12, 1996, p. 25.

56. U.S. Nuclear Regulatory Commission Annual Report 1994, p. 16.

57. William E. Cline, NRC Division of Radiation Safety and Safeguards, to Dr. Mark O. Medford, TVA Vice President Technical Support, "NRC Inspection Report Nos. 50-327/93-19 and 50-328/93-19", June 22, 1993, p. 4. (Hereinafter, Cline to Medford, June 22, 1993.)

58. William E. Cline, NRC Division of Radiation Safety and Safeguard, to Dr. mark O. Medford, TVA Vice President Technical Support, "NRC Inspection Report Nos. 50-327/93-19 and 50-328/93-19", June 22, 1993, p. 4 as it relates to TVA's Corporate Training. "Radiochmical Laboratory Analyst Fundamental Assessment Exam" for Browns Ferry, Sequoyah and Watts Bar.

59. Ibid.

60. R. A. Matheny, Operational Readiness Manager Sequoyah Nuclear Plant, to S. A. White, Manager of Nuclear Power TVA, Corporate Operational Readiness Review (CORR) - Final Report and Recommendations, May 28, 1987, p. 0331Y.

61. S. A. White, Manager of Nuclear Power, to Those listed, Operational Readiness Review Report for Sequoyah Nuclear Plant (SQN), January 13, 1988, p. 42.

62. Jim L. Bates, Manager Chemistry and Environmental Protection, to W. R. Lagergren, Operation Manager Sequoyah Nuclear Plant, Results of the Pre-INPO Evaluations of Sequoyah Nuclear Plant (SQN) Chemistry Program, September 6, 1989, p. 3.

63. Johns P. Jaudon, Deputy Director TVA Construction, NRC Division of Reactor Projects Region II, to Oliver D. Kingsley, Jr., President TVA Nuclear and Chief Nuclear Officer, "NRC Inspection Report Nos. 50-390/94-87 and 50-391/94-87", February 9, 1995, p. 2.

64. Watts Bar Nuclear Plant, "Daily Team Meeting", August 18, 1995, p. 113 and Watts Bar Nuclear Plant, "Daily Team Meeting", March 20, 1996, p. 29.

65. U.S. NRC Regulatory Guide 1.68, "Initial Test Program For Water-Cooled Nuclear Power Plants", Revision 2, August 1978, p. 7.

66. Robert A. Fenech, TVA, letter and enclosure to U.S. Nuclear Regulatory Commission, "Tennessee Valley Authority - Sequoyah Nuclear Plant Units 1 and 2 - Docket Nos. 50-327 and 50-328 - Facility Operating Licenses DPR-77 and DPR-79 - Licensee Event Report (LER) 50-327/92019", December 7, 1992, Enclosure p. 3.

67. Ibid, Enclosure p. 2.

68. Jim L. Bates, Sequoyah, letter to Gary Fiser, Sequoyah, "Assessment Of Sequoyah Nuclear Plant (SQN) Chemistry Program", August 8, 1988, Attachment A, p. 3.

69. U.S. General Accounting Office, GAO/RCED-96-10, "Nuclear Regulation: Weaknesses in NRC's Inspection Program at a South Texas Nuclear Power Plant", October 1995, p. 16. (Hereinafter, GAO/RCED-96-10.)

70. Ibid, p. 4.

71. Ibid, p. 16.

72. Ibid, p. 5, 31.

73. "Task Force Report Concerning The Effectiveness of Implementation of the NRC's Inspection Program and Adequacy of the Licensee's Employee Concerns Program at the South Texas Project", Docket Nos: 50-498 and 50-499, March 31, 1995, p. 13-15.

74. U.S. Nuclear Regulatory Commission, Office Of The Inspector General, "Alleged Improper Influence By NUMARC On NRC Standard Technical Specifications Improvement Program (92-72H)", March 10, 1993, p. 1.

75. Ibid.

76. U.S. Nuclear Regulatory Commission, Office Of The Inspector General, "Allegations Of Commission And NRC Staff Retaliation Against INPO For Raising Concerns About NRC Management Intrusiveness (95-21H)", April 3, 1995, p. 7.

77. Ibid.

78. Congressional Record - Senate, Senator Abraham Ribicoff (D-CT), August 13, 1974, p. 28128-28129.

79. Report Of The President's Commission On The Accident At Three Mile Island, October 1979, p. 19, 54. (Hereinafter, Kemeny Commission Report, October 1979.)

80. "Safety Second: A Critical Evaluation of the NRC's First Decade", Union of Concerned Scientists, February 1985, p. 156. (Hereinafter, UCS, February 1985.)

81. Prepared Testimony of Loren L. Bush, Jr., U.S. Nuclear Regulatory Commission, Before the Subcommittee on General Oversight and Investigations of the Committee on Interior and Insular Affairs, U.S. House of Representatives, June 11, 1987, p. 182, 186.

82. U.S. General Accounting Office, GAO/RCED-87-141, "Nuclear Regulation: Efforts To Ensure Nuclear Power Plant Safety Can Be Strengthened", August 1987, p. 3-4.

83. Report by the Subcommittee on General Oversight and Investigations of the Committee on Interior and Insular Affairs, U.S. House of Representatives, "NRC Coziness With Industry: Nuclear Regulatory Commission Fails To Maintain Arms Length Relationship With The Nuclear Industry", December 1987, p. 1, 20. (Hereinafter, NRC Coziness, December 1987.)

84. Subcommittee on Government and Investigations of the Committee on Energy and Commerce, U.S. House of Representatives, Opening Statement of John D. Dingell, Chairman, March 3, 1993, p. 1-3.

85. Al Kamen, "In The Loop". The Washington Post, September 22, 1995, A17.

86. Al Kamen, "In The Loop". The Washington Post, October 16, 1995, A19.

87. U.S. Nuclear Regulatory Commission, Office of Inspector General, File 93-55H, "Region III Management Discouraging The Findings of Violations", September 9, 1993, p. 5.

88. Towers Perrin Study, p. 5.

89. U.S. Nuclear Regulatory Commission, Office of Inspector General, "Inquiry Into Allegations Concerning Safety Systems Functional Inspection - San Onofre (I89-07)", December 14, 1989, p. 2.

90. James M. Taylor, Executive Director for Operations, to Oliver D. Kingsley, Jr., President Generating Group Tennessee Valley Authority, August 26, 1991, p. 1.

91. Dr. Shirley Ann Jackson, NRC Chair, Before The Regulatory Information Conference, "Challenges For The Nuclear Power industry And Its Regulators: The NRC Perspective", April 9, 1996, p. 3.

92. U.S. Nuclear Regulatory Commission, Office of Inspector General, "Investigation of Improper Disclosure of Allegers' Identities by the NRC Office of Investigations (OI) to the Tennessee Valley Authority, Office of the Inspector General (TVA-OIG) (93-65H), July 13, 1994, p. 2.

93. Ibid.

94. U.S. Nuclear Regulatory Commission, Office of Inspector General, File 91-N-05, "Staff's Acquiescence To Regulatory Violations At Yankee-Rowe", November 29, 1991, p. 1.

95. Kemeny Commission Report, October 1979, p. 20.

96. UCS, February 1985, p. 25.

97. Commission Meeting Transcript, "Discussion of Proposed Rule on Backfitting Public Meeting", May 22, 1984, p. 29.

98. Ibid, p. 30.

99. NRC Coziness, December 1987, p. 18.

100. Federal Register, Vol. 50, No. 183, "Separate Views of Commissioner Asselstine", September 20, 1985, p. 38106-38110.

101. Towers Perrin Study, p. 1-2.

102. Ibid, p. 33.

103. Ibid, Exhibit II-5.

104. Joseph R. Biden Jr., U.S. Senator, Letter to William J. Clinton, United States President, June 30, 1994.

105. Joseph R. Biden, Jr., United States Senator, to The Honorable Charles A. Bowsher, Comptroller General GAO, February 29, 1996, p. 1.


 Appendix

Appendix A: Ivan Selin, NRC Chairman, Remarks before the Regulatory Information Conference S-95-05, "The Future of Reactor Regulation", May 9, 1995.

Appendix B:

Table 1. Status of Unresolved Safety Issues

Table 2. Status of Recent High Priority Generic Safety Issues

Table 3. Unimplemented and Unverified High Priority Safety Issues

Table 4. Outstanding USIs and High Priority GSIs by Plant

Table 5. Status of All Outstanding USIs and GSIs by Plant

Appendix C: NRC, "Periodic Briefing On Operating Reactors And Material Facilities", January 31, 1996, and http://www.nrc.gov/Rlll/rjs2/probplnt.htm.

Appendix D: U.S. Nuclear Regulatory Commission, Generic Letter 95-03: "Circumferential Cracking of Steam Generator Tubes", April 28, 1995.

Appendix E: Jeanne Hunt, Office of Investigation, to James C. McKnight, IRM/RMB, May 11, 1994.

Appendix F: Byron Lee Jr., NUMARC, to Kenneth M. Carr, NRC Chairman, November, 9, 1990.

Appendix G: David A. Ward, Chairman ACRS, to Ivan Selin, NRC Chairman, December 20, 1991.

Appendix H: ARCS Meeting Minutes/Summary of the AC/DC Power Systems Reliability Subcommittee, August 8, 1990.

Appendix I: James M. Taylor, NRC Executive Director for Operations, to Chairman Jackson, Commissioner Rogers and Commissioner Dicus, "Semiannual Report on the Status of the Thermo-Lag Action Plan and Fire Protection Task action Plan", April 3, 1996, Appendix.

Appendix J: TVA's Corporate Training, "Radiochemical Laboratory Analyst Fundamental Assessment Exam" for Browns Ferry, Sequoyah and Watts Bar.

Appendix K: Robert A. Fenech, TVA, letter and enclosure to U.S. Nuclear Regulatory Commission, "Tennessee Valley Authority - Sequoyah Nuclear Plant Units 1 and 2 - Docket Nos. 50-327 and 50-328 - Facility Operating Licenses DPR-77 and DPR-79 - Licensee Event Report (LER) 50-327/92019", December 7, 1992.

Appendix L: U.S. General Accounting Office, GAO/RCED-96-10, "Nuclear Regulation: Weaknesses in NRC's Inspection Program at a South Texas Nuclear Power Plant", October 1995.

Appendix M: U.S. Nuclear Regulatory Commission, Office Of The Inspector General, "Alleged Improper Influence By NUMARC On NRC Standard Technical Specifications Improvement Program (92-72H)", March 10, 1993.

Appendix N: U.S. Nuclear Regulatory Commission, Office Of The Inspector General, "Allegations Of Commission And NRC Staff Retaliation Against INPO For Raising Concerns About NRC Management Intrusiveness (95-21H)", April 3, 1995.

Appendix O: Prepared Testimony of Loren L. Bush, Jr., U.S. Nuclear Regulatory Commission Before the Subcommittee on General Oversight and Investigations of the Committee on Interior and Insular Affairs, U.S. House of Representatives, June 11, 1987.

Appendix P: Report by the Subcommittee on General Oversight and Investigations of the Committee on Interior and Insular Affairs, U.S. House of Representatives, "NRC Coziness With Industry: Nuclear Regulatory Commission Fails To Maintain Arms Length Relationship With The Nuclear Industry", December 1987.

Appendix Q: James M. Taylor, NRC Executive Director for Operations, to Oliver D. Kingsley, Jr., President Generating Group Tennessee Valley Authority, August 26, 1991.

Appendix R: Towers Perrin, "Nuclear Regulatory Review Study", October 1994.

 

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