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Efforts to Improve Rulemaking
Tracking and Reporting
U.S. Nuclear Regulatory Commission Public Meeting
March 11, 2016
Comments of Scott D. Portzline
Security Consultant to Three Mile Island Alert
Harrisburg PA
• The NRC is to be commended for their effort to assist
the public and stakeholders in rulemaking by taking
advantage of modern tools to access the docketed
records in a timely manner.
• The proposed improvements would be consistent with
the Commission’s objectives as stated by the NRC in
“Public Participation in NRC’s Rulemaking Process.”
June 12, 2008
2
in communication and decision
making
o Facilitates public understanding
o Provides an opportunity for affected people to participate in the
process
o Increases credibility
and cooperation
NRC’S slides: “Public Participation in NRC’s Rulemaking Process”
June 12, 2008
3
“The NRC rulemaking process is a mature
process and we welcome suggestions on
how to improve it.”
NRC’S slides: “Public Participation in NRC’s Rulemaking Process”
June 12, 2008
4
This is what happened to our
petition for rulemaking:
September 12, 2001 - - TMI Alert filed a petition for rulemaking which would
require guards to be posted at the entrances of “owner controlled areas” at
nuclear power plants. The timing of the filing was coincidental to the 9-11
attacks and had been planned for six weeks prior to our filing.
Petition for Rulemaking PRM-73-11
5
EXCESSIVE DELAYS
• The NRC Repeatedly
rescheduled the
rulemaking.
• Offered no
explanation for the
rescheduling.
• Showed no
accountability when
challenged.
FAILED TO
CORRESPOND
• On 13 separate
occasions when the
NRC rescheduled,
we heard nothing.
• The NRC did not
inform us of
management
changes as to who
was handling our
petition.
INACCURATE
INFORMATION
• The NRC incorrectly
listed our petition as
“completed” for
several weeks on its
web site until we
requested the NRC
to correct it.
• Meeting transcripts
mistakenly stated
that we were dis-
cussing “entrance
cards” instead of
“entrance guards.”
* FULL REPORT on how the NRC
bungled an effort to create a new rule to
require entrance guards. 10/31/2008
http://tinyurl.com/qj2mn3d
6
TRIED TO DENY US A
SEAT AT THE
RULEMAKING TABLE
• The NRC did not want to
give me the opportunity
to speak during the
meeting.
• Our petition and
background data was
not in the room or on
the document handout
table.
• When we complained,
the NRC made no
attempts to correct the
absence of our petition
or background
information.
VANISHING ACT
• Our petition for
rulemaking had
disappeared, not only
from the meeting, but
from the process.
• There was no mention
of our petition in the
Power Reactor Security
Requirements
rulemaking, the
rulemaking into which
our petition had been
supposedly merged.
MISLED CONGRESS
• * NRC letters to
congressional leaders
stated that entrance guards
are “already being
considered in the ongoing
Power Reactor Security
Requirements rulemaking.”
• NRC hid the fact that their
staff had decided that
entrance guards are not
needed and that the
“entrance guard petition”
had been denied de facto.
* July 29, 2008
see ADAMS ML081220609
7
SURPRISE ENDING
• The NRC failed to
inform us when the
petition was closed.
NRC staff claimed
they could not find
my phone number
or address.
• I learned that the
petition was closed
from the Union of
Concerned
Scientists.
NO DECISION
• The NRC’s correspondence
only indicated that the
petition was “considered
resolved and closed.”
• As per guidelines,
petitions are decided with
a letter clearly indicating:
BLATANT DISREGARD
• Actually, there were
more than 40
occurrences when
the NRC failed to
adhere to its
principles of
openness and
clarity, and to follow
its procedural
guidelines while
handling the
rulemaking.
 acceptance,
 partial acceptance,
 or denial.
8
“Public confidence in the NRC is eroded each time
we fail to resolve issues in a timely, clear, and
transparent manner.”
NRC Commissioner Gregory Jaczko
Regulatory Information Conference
March 8, 2006
9
Unwanted consequences of
commenting on proposed rules.
10
This main entrance gate at Three Mile Island is has been
wide open and unguarded for more than a decade.
“Approaches: Particular emphasis must be placed on main
and alternate entry routes for law-enforcement or other
offsite support agencies and the location of control points for
marshalling and coordinating response activities.”
Three Mile Island
The north bridge is the main entrance for emergency responders.
11
Enhancements To Emergency Preparedness Rulemaking - 2011
• TMI Alert filed a comment on this rulemaking noting that
without control of the two bridges at Three Mile Island, many
aspects of the planned emergency responses could be severely
compromised.
• Rather than address that issue, the NRC dropped that portion of
the proposed Emergency Preparedness Rule. This retraction
meant that the objectives of the rule can not be ensured at TMI.
• Our comment for improving emergency preparedness actually
served to weaken the rule!
• Currently, the entrance is wide open and the bridges are not
controlled by security forces.
12
NRC REPORT CARD
PETITION FOR RULEMAKING
13
More Trouble
• NRC staffers wanted to use TMI Alert’s petition as a
quintessential example of NRC petition handling
failures.
• The NRC then failed to invite us to the special public
meeting on petition problems as promised.
14
What TMI Alert believes is needed:
• Clear rules.
• Follow the rules.
• One NRC staffer who will be held accountable for
managing and executing a rulemaking, and for
timely communications to all involved.
• A dedicated “grievance” handling officer if the
rulemaking manager fails in his/her duties.
15
end notes
16
 FULL REPORT on how the NRC bungled an effort to create a new rule
to require entrance guards. 10/31/2008. ADAMS #ML13140A166 or
at http://tinyurl.com/qj2mn3d
 FINAL RULEMAKING - Power Reactor Security Requirements (RIN
3150-AG63) SECY-08-0099 July 9, 2008. ADAMS #ML081650474
 FINAL RULE: Enhancements To Emergency Preparedness Regulations
(10 CFR PART 50 AND 10 CFR PART 52) April 8, 2011.
ADAMS # ML102150180

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NRC efforts to improve rulemaking tracking and reporting

  • 1. Efforts to Improve Rulemaking Tracking and Reporting U.S. Nuclear Regulatory Commission Public Meeting March 11, 2016 Comments of Scott D. Portzline Security Consultant to Three Mile Island Alert Harrisburg PA
  • 2. • The NRC is to be commended for their effort to assist the public and stakeholders in rulemaking by taking advantage of modern tools to access the docketed records in a timely manner. • The proposed improvements would be consistent with the Commission’s objectives as stated by the NRC in “Public Participation in NRC’s Rulemaking Process.” June 12, 2008 2
  • 3. in communication and decision making o Facilitates public understanding o Provides an opportunity for affected people to participate in the process o Increases credibility and cooperation NRC’S slides: “Public Participation in NRC’s Rulemaking Process” June 12, 2008 3
  • 4. “The NRC rulemaking process is a mature process and we welcome suggestions on how to improve it.” NRC’S slides: “Public Participation in NRC’s Rulemaking Process” June 12, 2008 4
  • 5. This is what happened to our petition for rulemaking: September 12, 2001 - - TMI Alert filed a petition for rulemaking which would require guards to be posted at the entrances of “owner controlled areas” at nuclear power plants. The timing of the filing was coincidental to the 9-11 attacks and had been planned for six weeks prior to our filing. Petition for Rulemaking PRM-73-11 5
  • 6. EXCESSIVE DELAYS • The NRC Repeatedly rescheduled the rulemaking. • Offered no explanation for the rescheduling. • Showed no accountability when challenged. FAILED TO CORRESPOND • On 13 separate occasions when the NRC rescheduled, we heard nothing. • The NRC did not inform us of management changes as to who was handling our petition. INACCURATE INFORMATION • The NRC incorrectly listed our petition as “completed” for several weeks on its web site until we requested the NRC to correct it. • Meeting transcripts mistakenly stated that we were dis- cussing “entrance cards” instead of “entrance guards.” * FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008 http://tinyurl.com/qj2mn3d 6
  • 7. TRIED TO DENY US A SEAT AT THE RULEMAKING TABLE • The NRC did not want to give me the opportunity to speak during the meeting. • Our petition and background data was not in the room or on the document handout table. • When we complained, the NRC made no attempts to correct the absence of our petition or background information. VANISHING ACT • Our petition for rulemaking had disappeared, not only from the meeting, but from the process. • There was no mention of our petition in the Power Reactor Security Requirements rulemaking, the rulemaking into which our petition had been supposedly merged. MISLED CONGRESS • * NRC letters to congressional leaders stated that entrance guards are “already being considered in the ongoing Power Reactor Security Requirements rulemaking.” • NRC hid the fact that their staff had decided that entrance guards are not needed and that the “entrance guard petition” had been denied de facto. * July 29, 2008 see ADAMS ML081220609 7
  • 8. SURPRISE ENDING • The NRC failed to inform us when the petition was closed. NRC staff claimed they could not find my phone number or address. • I learned that the petition was closed from the Union of Concerned Scientists. NO DECISION • The NRC’s correspondence only indicated that the petition was “considered resolved and closed.” • As per guidelines, petitions are decided with a letter clearly indicating: BLATANT DISREGARD • Actually, there were more than 40 occurrences when the NRC failed to adhere to its principles of openness and clarity, and to follow its procedural guidelines while handling the rulemaking.  acceptance,  partial acceptance,  or denial. 8
  • 9. “Public confidence in the NRC is eroded each time we fail to resolve issues in a timely, clear, and transparent manner.” NRC Commissioner Gregory Jaczko Regulatory Information Conference March 8, 2006 9
  • 10. Unwanted consequences of commenting on proposed rules. 10 This main entrance gate at Three Mile Island is has been wide open and unguarded for more than a decade.
  • 11. “Approaches: Particular emphasis must be placed on main and alternate entry routes for law-enforcement or other offsite support agencies and the location of control points for marshalling and coordinating response activities.” Three Mile Island The north bridge is the main entrance for emergency responders. 11 Enhancements To Emergency Preparedness Rulemaking - 2011
  • 12. • TMI Alert filed a comment on this rulemaking noting that without control of the two bridges at Three Mile Island, many aspects of the planned emergency responses could be severely compromised. • Rather than address that issue, the NRC dropped that portion of the proposed Emergency Preparedness Rule. This retraction meant that the objectives of the rule can not be ensured at TMI. • Our comment for improving emergency preparedness actually served to weaken the rule! • Currently, the entrance is wide open and the bridges are not controlled by security forces. 12
  • 13. NRC REPORT CARD PETITION FOR RULEMAKING 13
  • 14. More Trouble • NRC staffers wanted to use TMI Alert’s petition as a quintessential example of NRC petition handling failures. • The NRC then failed to invite us to the special public meeting on petition problems as promised. 14
  • 15. What TMI Alert believes is needed: • Clear rules. • Follow the rules. • One NRC staffer who will be held accountable for managing and executing a rulemaking, and for timely communications to all involved. • A dedicated “grievance” handling officer if the rulemaking manager fails in his/her duties. 15
  • 16. end notes 16  FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008. ADAMS #ML13140A166 or at http://tinyurl.com/qj2mn3d  FINAL RULEMAKING - Power Reactor Security Requirements (RIN 3150-AG63) SECY-08-0099 July 9, 2008. ADAMS #ML081650474  FINAL RULE: Enhancements To Emergency Preparedness Regulations (10 CFR PART 50 AND 10 CFR PART 52) April 8, 2011. ADAMS # ML102150180