STRUCTURE OF THE COMMISSION My last point deals with the Commission's decline as a decisionmaking body. The interaction between the Commissioners has dwindled over the past several years. There is little interchange of ideas or collaborative decisionmaking. The Commission has difficulty in focusing on the important questions. The Commission seldom gives clear guidance to the staff at the close of meetings; unwelcome guidance is often ignored with impunity. Fespect for the Commission has declined and, by default, power has shifted to the staff. A couple of years ago, the Commission agreed to try to focus its activities and enhance its efficiency by giving each Commissioner lead responsibility for an area of the agency's business. The particular areas each Commissioner would handle were agreed to by all. But then, for reasons that remain unclear, the matter was quietly dropped. It should be revived. The Reorganization after the Three Mile Island accident was intended to clarify the roles of the Chairman and Commissioners. It has only succeeded in confusing things further, and in creating new problems. For example, the difficulty in holding top agency managers accountable is very much increased by the Chairman's having been made their direct supervisor by the Reorganization Plan; criticism of the managers' actions is now viewed as criticism of the Chairman. Staff accountability has been further undermined by the new practice of having only the Executive Director's name appear on all documents submitted to the Commission, including technical and scientific ones. He is not held accountable because he is not expected to know the technical material, and the technical experts are not held responsible because they no longer sign the papers. The practical effect is to put more distance between the Commission and responsible staff offices. Thus the unfortunate result of the Reorganization is that the Commission is now more removed from the staff and is less well informed than ever before. The staff demonstrates a certain disdain for the Commission in deciding what to tell it. Sometimes they tell us what is going on and sometimes they don't. For example, last December, the staff issued low power licenses to LaSalle Unit 2 and WNP-2 without prior notification to the Commission. Staff Needs New Blood The NRC's difficulty in adapting to new situations is aggravated by the fact that virtually all the top officials have been with the NRC since its formation. Indeed, almost all of them grew up in the NRC's predecessor, the Atomic Energy Commission. This results in a certain amount of stagnation and unreceptiveness to new ideas. For example, despite the obvious need, the agency has been slow to recruit persons with commercial operating experience. The Senior Executive Service reform, which was intended to introduce some vigor and flexibility at the top personnel levels, has served only to reinforce the status quo. In practice, the bonus system is used to reward conformity. It is worth pointing out that SES bonuses are handed out by an NRC staff board of 15 officials, who award themselves roughly 40 percent of the bonus money available for the 200 SES staff. At the very least, I would have the Commissioners pass on bonuses for the 15 board members and the top staff. It cannot be said too strongly that these personnel matters are not merely housekeeping details. The NRC staff organization plays a far larger role in the agency's decisionmaking than do the staffs at other regulatory bodies. Control of the NRC staff is tantamount to control over the agency's decisions. I want to emphasize that the working level NRC staff members are as good and competent a group as you will find anywhere. We just need to find better ways to guide their efforts. A Three-Member Commission Ultimately, the Commission's performance depends a great deal more on the quality of the individual Commissioners than it does on the details of organization. Still, a fivemember Commission may be too unwieldy for an agency with operational responsibilities. I would recommend a smaller Commission of three members, with each Commissioner having lead responsibility for an area of the agency's activities. This would help focus responsibility while retaining the advantages of a Commission - independence and greater balance. My own experience is that the Commission functioned much more effectively when there were only three Commissioners (either because seats were unfilled or because of disqualifications on particular issues). The Tennessee Valley Authority, which has major operational responsibilities, is run by such a three-person board. In conclusion, I would like to say that I have appreciated the opportunity to appear before this Committee. ADDITIONAL PREPARED QUESTIONS SUBMITTED FOR THE RECORD Chairman HATFIELD. Now, I am going to submit the remaining questions to you for your response for the record. I will excuse you and ask for the principal witness, Raymond J. O'Connor, the Chairman of FERC, to come. Mr. PALLADINO. Thank you, Mr. Chairman, we will provide answers to your questions. [The questions and answers follow:] THREE MILE ISLAND Question. Please give us an update on the TMI-2 reactor cleanup. What progress has been made in the last year? Answer. During calendar year 1983, progress in the cleanup was somewhat limited, in part due to funding constraints and of the need to delay some work until allegations by several licensee and contractor employees about administrative deficiencies in the cleanup were investigated. More recently, however, some significant accomplishments have been made as the licensee focuses cleanup efforts toward the defueling of the damaged core. During the past year, the major accomplishments include the following: -The waste water in the reactor coolant system (90,000 gallons) has been processed on a periodic basis to limit the buildup of radioactivity leaking from the damaged core. -Approximately 70 percent of the contaminated areas in the auxiliary building has been decontaminated, but the most contaminated cubicles were bypassed. -Offsite shipments of high specific activity abnormal waste include 50 EPICOR-II prefilters and 15 submerged demineralizer system (SDS) zeolite liners. -Several visual inspections of the damaged core at three different locations have been conducted to determine the nature and extent of the damage and aid in defueling planning. -The reactor building polar crane has been refurbished and load tested and is qualified for lifts up to 170 tons. The polar crane is necessary to lift the reactor vessel head (approximately 163 tons) and plenum (approximately 55 tons). -As an aid to planning for reactor vessel head lift, measurements of the radiological conditions underneath the head were taken and yielded values ranging from 300 to 700 R/hr with the water level lowered to simulate conditions of a dry head lift. For head lift, shielding will be applied, where appropriate, to minimize the radiation levels in areas occupied by workers. -Three dimensional sonar mapping of the core void (i.e., damage) has been done. -Washdowns of contaminated walls, floors, and equipment surfaces in the reactor building have been ongoing in an effort to remove loose or smearable contamination and ultimately lower reactor building atmosphere particulate activity levels. -The licensee launched a multiphase dose reduction program in late 1982. This program includes the shielding of known sources of exposure such as floor drains, hatches, penetrations, the enclosed stairwell, and the elevator shaft. These efforts have resulted in some significant reductions in dose rates in the general areas of the 305-foot and 347-foot elevations. -The reactor vessel studs and associated nuts which bolt the reactor vessel head to the vessel flange have been partially detensioned as the first step in the head removal process. -The licensee has obtained six samples from the core debris bed and the samples have been partially analyzed for their physical and radiological characteristics. As described above, some significant progress has been made in the cleanup and some important milestones have been reached. However, the most complex and difficult work lies ahead as the licensee focuses his efforts on defueling the reactor and placing the plant in a safer condition. The work that remains includes the following: -The reactor vessel studs will be fully detensioned in preparation for head lift. -The planned dry reactor vessel head lift is scheduled for August of this year. -Decontamination of the containment will continue in an effort to reduce particulate activity levels in the reactor building atmosphere. -Continuing dose reduction measures will be employed to lower worker exposure within the containment. -Plenum inspection and subsequent removal will be performed following reactor vessel head lift. Destructive removal of the plenum may be required if the plenum is stuck in place. If the plenum can be removed in one piece, this activity should occur during 1985. If destructive removal is required, the schedule for completion is uncertain. -Fuel removal will begin after plenum removal and should be initiated in 1986. This activity may take a year and a half to complete, depending upon the difficulties encountered during the defueling effort. -The decontamination and subsequent removal of the tanks located in the A fuel pool need to be completed to support the defueling effort. -Efforts to carry out the removal and subsequent shipment of the highly radioactive purification demineralizer resins are ongoing. -Packaging and shipment of fuel and other abnormal waste generated in support of defueling activities will begin after the onset of fuel and fuel debris removal from the reactor systems. -Planning for future decontamination efforts in the auxiliary building is ongoing. -Surface decontamination and internal piping system flushes in the auxiliary building will be performed. This could be done over a period of several years. -Surface decontamination in the reactor building, including the possible scarification of badly contaminated concrete surfaces, might require several years of continuous effort. -Decontamination of the corrosion layer of the piping constituting the reactor coolant system pressure boundary will not begin until the defueling of the reactor vessel and associated piping is complete. -Processed accident water will be utilized for decontamination activities and to support the defueling effort, but will require disposition in the latter stages of cleanup. Since the required funds for completion of the cleanup are not fully committed, any schedular estimates given above are uncertain. Question. As I recall, you indicated last year that a utility and contractor management shakeup was expected to improve the cleanup operations. Have improvements occurred? Answer. In August 1982, the NRC staff approved the licensee's proposed organization which integrated the primary cleanup contractor (Bechtel) into the licensee's organizational structure. Prior to August 1982, there were two separate organizational entities (the licensee and Bechtel) involved in TMI-2 cleanup activities, and, in the Commission's view, the complex relationship between the two organizations was, in part, responsible for identified administrative deficiencies (NRC Office of Investigations |