the in-plant instrumentation was displayed to the operators manner of display was in some ways inadequate. Additionall misinterpreted some instrument readings. However, a greate instrument response might have aided the later assessment o damage that occurred.

13. Backfitting

Finding G-8(h), that there is no systematic backfittin plant-by-plant basis of operating plants and plants under appears to take too little account of the NRC's Systematic Program (SEP), initiated more than three years ago. Under operating plants have been categorized by NRC, issues have by NRC, and information about older plants has been supplie the utilities. In a number of cases, physical modification plants have been made in order to comply with updated NRC In some areas, such as that of the up-grading of emergency in the Commission's report, progress does appear to have be slow.

14. Independent Testing by I&E

In Finding G-9(a) and Recommendation ll(d) the recomme of NRC's inspection and auditing of licensee compliance wit and the need for major and unannounced on-site inspections power plants is logical. It calls for NRC to do more of wh does and to do it better. In fact, NRC has, for over a yea full-time inspectors at some operating nuclear power plants plants, unannounced on-site inspections appear to be so fre be commonplace.

The implication that NRC's I&E inspectors should do a amount of independent testing of construction work and shou little reliance on work done by the utility is clearly impr because of the enormous resources which would be required. auditing of industry's testing is the only practicable and approach.

15. Emergency Procedures

In addition to the fact that some of the existing TMIwere unworkable, as indicated in the Commission's report, t did not provide a step-by-step pathway for identifying the

of quantified safety goals and objective. When a safety is postulated, there is no yardstick to judge the adequacy ating measures.

ility to set priorities and to allocate resources in proportion stimated risk to the public. In my view, a disproportionate s being required for some issues which have only a marginal pon risk to the public.

of experienced staff. An undesirably large proportion of f ard management have little or no practical experience in g or operating the equipment which they regulate.

trary requirements. Too many of the NRC requirements are without valid technical back-up and value-impact analysis.

ifling adversary approach. The existing process inhibits rchange of technical information between the NRC and industry. urages innovative engineering solutions.

fective evaluation of operations. NRC has no effective
or evaluating data from operating plants. Data should be
systematically to identify trends and patterns.

of a comprehensive system approach to the whole plant. A rcentage of the NRC staff are specialists focusing upon opics. There are relatively few systems engineers within can integrate individual safety features into an overall and who can place issues into perspective.

verwhelming emphasis on conservative models and assumptions. c analyses are needed to identify the margins of safety and Ompetent decisions.

f Report

t schedule and deadline for the Commissioners' report has
e opportunity for careful review of the Staff reports upon
dings are to be based. Some Staff reports are not yet
here are several parts of some key Staff reports with which
e, particularly the staff report on the NRC.

seriously questioned the state of knowledge of the performan of the larger light-water reactors in this country, an opin: also echoed by some other individuals within NRC. The cited was adopted by the authors of this Staff report. However, report reflects no attempt by the Staff to obtain evidence nuclear industry on this issue, even though the various com nuclear industry are the parties impugned by the cited state

Statements were recently obtained from Saul Levine, Di NRC's Office of Nuclear Regulatory Research, and from two d companies which design light-water reactors and which are n with the TMI-2 accident. It should not be construed from re "economy of scale" that the regulators were being asked to a safety margins. Rather, the growth was largely achieved by fuel assemblies of the same or similar volumetric and linea: density, and by adding more heat transfer loops having the s and hydraulic characteristics as in the plants previously 1: Saul Levine said, "as far as I know, there have been no size factors found in the operation of large reactors to affect the plants adversely. There appears no supportable suggest safety was compromised as a result of the extrapolation of

The unqualified acceptance of the cited testimony in th report is an indicator of insufficient balance in this part investigation.

18.2 Reliance on Books and Magazines

The Staff report relies to a considerable extent upon a book authored by E. Rolph without establishing the author Ms. Rolph did not testify in this investigation. The undue upon this secondary source, without first establishing a pri for its support and without establishing its reliability, is example of insufficient balance in this part of the investig

In my view, the Rolph book does not express a compreher and balanced knowledge of the NRC and of the nuclear indust 19. Concluding Statement

The rather extensive criticism of NRC in the Commission as implied in this supplementary statement, should not obscu

be emphasized that nothing learned from this investigation the nuclear power option should be curtailed or abandoned f the TMI-2 accident.

Thomas H. Pigford

October 25, 1979

Dy the official sources of information. It further conclu press did a creditable ("more reassuring than alarming") j coverage.

In fact, these conclusions are not generally supported reports. There were reliable news sources available. Too was placed on the "what if" rather than the "what is." As public was pulled into a state of terror, of psychological so than any other normal source of news, the evening nation reports by the major networks proved to be the most depress terrifying. Confusion cannot explain away the mismanagema event of this magnitude.

It is requested that the news media undertake a self an individual basis and review their role in this accident limited to equipment damage but also included psychological

ITEM 2:

The undersigned could not support a motion for an unde frame moratorium on all new construction permits because it shown how this could result in a safer plant at TMI nor at standards of safety and performance by the Industry.

A defined period (say two years) to act on this report along with a separate probationary operating period (say f the licensee at TMI could accomplish both the above object: therefore recommended.

Anne D. Trunk

October 25, 1979