ML19220C985

Forwards Alternative Drafts of Policy Statement for TMI Accident Review

ML19220C985
Person / Time
Site:	Crane
Issue date:	04/11/1979
From:	Ahearne J NRC COMMISSION (OCM)
To:	Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM)
References
NUDOCS 7905160140
Download: ML19220C985 (25)

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April 11, 1979

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.;: ~:n MEMORAICU:1 FOR:

Chairman Hendrie Commissioner Gilinsky Commissioner Kennedy Commissioner Bradford y

FROM:

John Ahearne

SUBJECT:

PROPOSEDTMIACkIDEiTREVIEW As you know, I have been very concerncd that the Commission as rapidly as possible initiate a thorough review of the TMI cccident.

I know all of you share this concern. The April 10th Proposed TMI Inves-tigation memorandum is a start.

However, I have several concerns abcut it and therefore have attached two alternative proposdis.

I believe the ilRC must take several steps:

1.

Develop as complete a picture as possible of how tne TMI accidenc cccurred, including not only the evr:nts surrounding the ac.ual accident, but also prior germane events.

2.

Draw from this review those conlusions that 'te can in as objective and careful a manner as possible.

3.

On the basis of these conclusions, make whatever changes we can in the way we operate, make whatever changes we can in the way power plants are built and operated, and recomrend to the Congress and to uhamever else is appropriate those changes that we believe necessary, but are outside of ou.- authority.

Wi th t' t: existence of the Presidential Commission, some aspects of bread public policy and essential public acceptance of results.iave been taken out o' our hands. We should recognize this.

I see three basic problems with the proposal in the April 10th memorandum.

These are the structure, the focus, and the assurance of competence.

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Structure:

The organization proposed is a mini-Presidential Commission.

The fiRC would choose a Director, and perhaps a Deputy i,

Director, and at that point set him (or her) free to do whatever he 3

wishes.

This is what the Presidential Cc mission will basically do, 3

although instead of the choice of two people, the President will nost

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likely choose a panel, tievertheless, the basic point is that we would i

be replicating on a minor scale that major effort to be initiated by the President.

I believe that will not be a very useful effort. I also i

believe it would reflect an attempt on our part to duplicate the President's effort (rather than the willingness to have a full eximi-nation that I think the authors of this proposal intend it to be) and indicate that we have been unable to structure a more focussed review.

2.

The proposal has been written as though we are hiring a special prosecutor to draw conclusions and make recommendations.

It may be that you agree that is appropriate.

I do not.

I believe what our review iriitially must concentrate on is developing as good an understanding as possible as to what happened at TMI and what happened in the regulatory system that led up to the TMI accident. That requires an examination of facts.

I da not argue with asking whoever develops those facts to then provide us with conclusicns and whatever recommendations they feel a cpropria te.

Mcwever, I believe that we, as Cocmissioners, have the obligation to draw conclusions and recommendations.

In addition, the Congress dnd the President's Commission will draw those conclusions and reccmmendations that are most likely to be the ones affecting the broader sweep of public policy, including any fundamental changes to the i1RC.

I am very concerned that the current draf t is so fccussed on the conclusions and recommendations, which I imagine appear to some to be a much more interesting aspect of the problem, that the more important part - the part that is essential to all these reviews, i.e., examination and laying out in good detail what happened - will not be given adequate attention.

3.

Assurance of Comoetence: The is wes involved in this review are sufficiently complex that major em.ients of the liRC staff must be involved in both examining and explaining the details. The proposed review would appear to have substantial possibflity of being done in-dependently of the staff. This again is appropriate for the Presi-dential review or for Congressional reviews, but I think it is not responsible for us to structure a review that does not utilize the many knowledgeable people in the pertinent areas, namely, the iRC s ta ff. Once again, I conclude that the proposed draft is more ap-propriate for the Presidential Commission review than for ours.

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Therefore, I propose vie consider tv:0 alternatives in addition to the April 10th proposal. These are described in the attached.

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ALTERT:ATIVE I: APRIL 10TH PROPOSAL,I'0DIFIED TO FOCUS C!! FACT FIf! DING This modification would utilize the modified scope of the investi-I gation (preferably called Accident Review), with the primary focus upon 2

fact finding.

The major changes to the April 10th memorandum would be j

the following:

ti 1.

The objectives would be modified to be the following: The objectives j

of the accident review are:

1 1

a.

To develop as complete a record as possible of the events during I

the time of the TMI accident, including those at Tfil and immediately preceding it.

This will include both the machine and the operators.

l b.

To develop a record of events which might be relevant to the TMI accident that occurred in the preceding period, to include not only TMI and other similar plants, but also the t

licensing and operating review for TMI.

c.

To develop as detailed record as possible of the emergency response cf the i;RC, including the t'P,C relation with Federal, State, and Local agencies, the licensee, and industry.

The main purpose of this review will be to develop this detailed recor o cf what happened for use of the Co.7 mission and whatever other review may find it useful, for example, the Presidential review.

In addition, following the development and submission of the Director should submit whatever conclusions and reco=endations he believes appropriate for use by the Cc= mission.

Statement of Policy, Scope of Investigation and other attachments relevant to this modification are attached.

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STATEMEt:T OF POLICY Alt i The liuclear Regulatory Commission hereby institutes a rev. e u Special Inquiry to inc;st_;2t: and report on the accident ithich took place beginning on March 28, 1979, at the Three Mile Island Nuclear Station No. 2, in Harrisburg, Pennsylvania.

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,y a their causes,cnd th:1.- Inp'_;;ti:nn, The objectjor the g

Cf inquiry will be to make findings y :1>'irn, 2r' s u : S r ^ e r=r-p m r'-tion to the Co=ission, ar 3;- t:

2rrant e d. - The scope of the inquiry is set forth in detail in attachment 1.

The target date for completion of the inquiry is Iovember 1 1977 i mINOj bsuww.

The inquiry vill be headed by a Director selected from d

outside the Comission.

Thes C1.__.a will be assisted by a t--h,- { y D e.u,, Circotr,

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duration of the inquiry.

The estimated resources necessary are set forth in attachment 2.

The inquiry staff will serve at the pleasure of the Director.

The Director's responsibilities will include periodic

,;L,,. i t.,. l' u. /M bc J ed i, bir 4 interin reports to the C c=i s s i on,'ard-tet. the public.

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It is essential that the Commission be in a position to take appropriate action on matters developed by the inquiry as information becomes available, rather than having to await N

the completion of the entire inquiry.

The Director will have the further responsibility of pD%pfAJ' cooperating with the Presidentially mandated investigation of the events at Three Mile Island, and with such other investigations as may be instituted by committees of the Congress.

Pursuant to Section 161n of the Atomic Energy Act as amended, the Commission vill delegate to the Director of the inquiry 7,h(, authority set forth in Section 161c thereof to conduct this investigation, gather information, and hold meetings as the Director may deem necess'ary and proper to the fulfillment of the objectives of this inquiry.

For the con-duct of the inquiry the Commission will further delegate %$&c authority to administer oaths and affirmations, and by sub-poenas to require any person to appear and testify, or to appear and produce documents, or both, at any designated place.

The Commission will delegate (TO authority, under Section 161f, to utilise the services of personnel of any Government agency or any State or' local government, with the consent of the agency concernedf -a.il. o o uuonu.muj, m.. l; r Rac'ir. 161g, tv iccoe un d

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In order to assure the independence and integrity of the inquiry, the Director and his staff will be requested to maintain records of all discussions with all persons, including Nuclear Regulatory Commission personnel, bearing on the subject matter of the inquiry or th6 inquiry itself.

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{LC wU LL' SCOPE OF THE Il Z:T :f.!:;l J

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The obj ectives of the ine: M :;;ti-en are:

(a) t find the facts concerning the origins, j

dev opnent, and consequences of the TMI-2 accident; b

(b) to eval ate those facts and draw fron-them

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(c) to evaluate a..d draw conclusions concerning the energency/\\recponse and conduct of the

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Scope of Fact Findinc The fact finding shall include the following:

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3 3 ( w,. s _m, v.s--.. (d) Emergency %,,A c:c: r::, including: bN" @Q IML(u u-t,,a 6g-Q (j ) N It.L m ( (-1 ' E. '*-"*:.~. vA b y h c w.mk.,L.g., dt (ii) Ee:ren:6 -ld,censee. a (m.4 m..,,____._.,- 44 r. s mm t o e, u. yp,G a & W * " " 4. 3 (iv) Federal / State / local c-c'crlinr; ion. g tv) v a ( ce.,4. U S tL d li O[ ( _s >s ~.a-.. ....... o --...~.-p. (n.y ~ - -. ' --. / s i r. j (vi) O_.s_du ...^.1uenceo O. 4P.0 which n e"_ ced management of the incident. (c) Management and connunicationsj.-ibdhfdd:g+- (1) NNC managenent of the situation. (ii) Information assessment and krl. C L C. reportin by the licensee 7 g .end-a$ other organizations t involved *"'j pllslL.MJ&* (to) h,Lhat2m' hA-M b *, d dDC- ['i "InfOrmation from any source,.thatv kl b k b i r.l.nWcated an.impe.d2.ngfprohlpa/ z j Y';c)o.,) f]!. /l l I.' at van. .*.,s 119 094

4 (iv) Con =unications and chai;q of connand among all organizations involved LLUti *NJ. d rk D .#(fh D M.O C-<6?3PM / (f) Any other natters that in the Director's + S judgment are important to th; ci;;); tim-eLC u l 4 y. a k u g cQMN8 M 4# # (sd *L d U N./:/h!.A c c f t'.- in": : ~d 3 Time Period Covered Esents up to and' including placing the plant in a stable, cold shutdown condition shall be included. Information obtained about the post-shutdown period shall'be considered to the. extent that it bears on the accident, initiating events, design considerations, or management of the pre-cold-shutdown situation. 4. Evaluation of Findings ~~ The evaluation f the findings of fact shall include: (a) Evaluati n of the pe iornance of the licensee; \\ NRC, vendon, / an others. ~ (b) IdentificaYion f factors peculiar to TMI-2 / and t the specific events involved in the \\. TMI-2 accident and the implications of those factors. )\\0

5 (c) Identification of factors relevant to other nuclear power facilities an/d the range of / I such relevance (i.e., all nuclear pouer / facilitiesorcertainc,lassesofsuch facilities); the implications.cf such factors / for design, review, operation, and emergency provisions. (d) 7valuationofeffectivenessofther[gula-tory process. (e) Such other evaluations as required by the obj\\ / ectives of the investigation. Reconnendation\\ / 5 r j / The recommendations may include but need not te linited to the following:\\ i i/ / i (a) Legislative proposals. / i (b) Require,ments imposed on licensees by ~ I \\ regulation or otherwise. I (c) Safety analysis and review. (d) Inspection and enforcement. (e), Qualifications of operating personnel and \\ 2 -/ of operating organizations. ~ (f) Interaction amon5 NRC, the licensee, State and local authorities, 9ther Feder 590,ias,

i 6 (gMIZ'JWr Talling ior u w_Wy. 6. Reports and comm.unications .+he *9 t (a) The Director shall pubnit a fi.._' report to the ?4t4L. Commission within c contps from the beginnine Q c pt.d.-V M ( M m MFo 0 4. of the investigation The report shall set forth g the findings,er-l'-i r, =d _c_v.=.en m io..3, - 9"4

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(b) The Director shall brief the Co=ission on progress and plan's approximately one, three, and five conths after the beginning o. the investigation and at such other times as interim findings or problems warrant. (c) The Director shall provide requested information to -- and otheritise cooperate to the fullest e. possible with Congressional and Presidential investigatiuns of the TrII-2. accident. 119 097

Resources -A/c/ f The Corr.ission anticipates that a work force of up to ,, Q --- @ ^ %.[ M a(il M; r full-time peocle,will be required for,.the investigation) khWri El (ll.fLMW d LC c '(yiuJ tLAL( k died 2/,w _ r The dark force is expected to include uell cualified pro % ", tc.,wf l fessionals in tbn "a "i n" t scien W eni;ineering, an6 C, 3 b -% her -%

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df legal counsel, and administra-tive and clerical suoport.

PRC will provide as much of this ~ 450%k ctl'AGd /dQ/ uork fore as desired by the Director. d(number of persons I%,. %/ on the estigation team are expected to be drawn from "2y u s outside I!RC. 664P(h" +'% w As a further part of the resources that nay be utilized,y>. the Director will have available to him the results of ongoing detailed investigations of the TMI-2 incident by ?!RC staff offices. The Director is, in addition, authorised to utilice outside support -- from other Government agencies or under contract. On the basis 'of preliminary estimates, the Com-mission plans to set aside up to $1,000,000 for the piirpose of such contracts. 119 090

f. T t :. ! c 10 -- Erie rt:/ - /\\ / t l CliAI'TER I -- ?!'!CLT:AR REfLi.ATORY C0 :':f CCIO:.' PART 1 -- STATiG'E'.T OF GRG/.:!IZ ATIO!; A?iD Gr **.:R AI. T:!PORMATIO: _..t at l...;h i nc t.he Th r'.z e '7 l le l a] an:. 3;'e cial Inquir; By vir'.ue of the autho:l',y ver,ted in the Commission by 42 U.S.C. 2201(c), there = hereby established in the Commission the Three Mile island Special Inquiry, to be headed by a Director. Accordingly, par.t 1 of chapter 1 of title 10, Code of Federal Regulations, is amended by adding a new subpart B-1 irr.edi'ately after subpart 3, to read as follows: Subpart E-1 -- Three Mile Island Special Inquiry 31.70 General functions. The Three Mile Island Special Inquiry shall be under the direction of a Director who shall be appointed by the Commission. The duties and responsibilities of the Director are set forth in the attached Appendix A. The detailed scope of the inquiry is set forth in the attached Appendix B. Both appendices are incorporated and made a part hereof. This order is effective as of April 1979 . Dated April 1979 For the Co:malucion: S AMlli'.l..I. C il 1 1.i. "ec re t.a ry PQO \\\\9 0ii

API'Ei!D D A DUTIK.,,,;;D !!i.".NX!"lBILITIES OF THE DIRECTOP Th.. D i re c t.o r. -- There is appoint.ed lthin the Com:al:, :! an a Director to whom the Commins ton shall delerectt.<- (IGy authoritics and provide the staff and other resources described below. The Director shall have authority to investigate the accident which took place beginning on March 28, 1979, at the Three Mile Island Muclear g' ration No.% % 4 a p &,'.d2]4 M , in Harrisburg, 2 0 Pennsylvania. T '~ ' N,r '. r.,- w i l l examine the actual events l ^ which occurred (ptheir causes, ar" t'._/ ~ " ? 0 2' ' m The A Kum-detailed scope of the ir,2 ry is at f' orth in Appendix B. hU t The Director shall make findings f-yc.;lui: c ;. _ lu c ir:., 2:.2 )3 c _a.'t'or~ t o t h e Co:nmi s s ion,, a h ; n.1,, d.cr-

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The Director's responsibilities shall include periodic interim reports to the Commission and to the public. Should the Director determine that matters beyond the scope of his mandate require further invest 15ation or st,udy, he shall so advice the Commission. The Director shall have the full authority pursuant to section 161c of the Atomic Energy Act to conduct the inquiry, gather information and hold mcetings as he may dec:a necessary and proper to the accomplish!nent. of t.he ob, lect ives of the Special Inquiry, including the authority to ad:al n l st.er oaths and a!'fi rmat ion., nnd by subpoena to 119 100

I I 2 ~ require any perr.on to appear and testify, or appear and produ:e 'heuments, or both, at any designated place. The { a Di rector shall have full authcrity for determining whether g application shall be made to the Departnent of Justice for 'J, 4 {; approval of a request to seek a grant of ime. unity to any gd ~ witness, consistently with applicable statutory requirements. k ' Y-QC ,f The Director shall have full authority for determining whether\\r N .\\T 4 1r %'y particular matters uarrent referral to the Department of r y,7 . yG J v

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f t Justice as constituting an apparent violation of Federal \\ m V. '%, d .a g d{,\\ ^ mtatute. W .<?';f _..I O.;$ In exercising this authority, the Director shall have lh~ ' / J h m tire greatest 'egree of .[e p e r.d e n c e. The Co-[ission will k ^ fN r c :cx / x ., "- r 't.. .,,3 <not countermand or i terfere :ith the Dir~ctor's decisions i ~ be,,r/ M a emoved from his duties d y or actions. Thepirector will not W l l CxCeDt fo" " M e0P o d *J_ t '7W ETreusdace 13 office. l Staff and resource suoport.--l. Selection of staff.-- The Director shall have.f g authority to organize, celect. and hire 'his own staff of tec~nnical personnel, attorneys, investigators, and supporting personnel, on a full-time or part-time basis, in such numbers and with such qualifi-. cations as he may reasonably require, but not to exceed a ". f (l f(4. y(sM cnt -Lufs'e.~l.6 Pf" proval,o f the Commi maximurn of ')-i persons without the nn i % A n k ilL4 c % Q +-. The b;.. ..u.- shall sect and appoint a Deputy DII:eetor. f. nion a ( r w. e,e g. s M T'. ie Director may request t.h e Co: mal c : ion and ot.her of flecr : o f. L: M <trjj 119 101

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z\\ ,w\\) s. ~ s V .d 'N 's \\ .s.[ ' 4[,y pf C J,f 3 O(,i,f f '.W.e.ff \\ Y! N Qe \\, t he :'uc '.ea r L t.a la t.o t ;/ Co: mission t.o assign such personne1 and to p:' vide such other ansist,ance as he may reasonably requ All pe'rsonnel o f ' the.'IRC shall cooperat,e to the fullest, extent possible with the Director. 2. Budget.-- The Director will be provided with such funds and facilities to carry out his responsibilities as he may reasonably require. He shall have the right to sub-mit budget requests for funds, positions, and other assistance, and such requests shall receive the highest priority. 3 Responsibility.-- The personnel acting as the staff and assistants of the Director shall be responsible only to the Director. Continued Resoonsibilities of '!?.C Office Directors.-- The I'RC Office Directors shall continue to have discretion to pursue such investigations into and take such actions regarding the Three Mile Island accident as may be relevant to their particular spheres of regulatory responsibility. Data developed by the Office D.1 rectors shall be made avail-able to the Director of the Special Inquiry. Applicable Commission Policies.-- Except an otherwise herein specified or as mutually agreed between the Director and the Co:mn i r.c l on, the Director and staff of the Special Inquiry will be s u b,l e c t,

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4 1 ALTERi%TIVE 2: FACT Fli:DIIS TASK FORCE This alternative would establish a specific task force to develop the fact finding, using the same scope outlined in Alternative 1. The task force would be directly established by us and would have the following membership: Chairperson or From outside. However, this need not be non-Director goverrment, f ar example, we could request Bob Frosch at TMSA to loan us someone for a period of six months more (or less if we believe that possible). Most useful would be a senior MSA official who has had experience with the evalua-tion of ccmplex mission analysis, would preferably be one of the senior managers. Vice Chairperson If the Director is a technically oriented person, or Deputy the Deputy Director should be a lawyer. Again, Director fr~om the outside and if we go to the government for a Director, I would go to one of the public interest groups for the Deputy Director lawyer. The res t of the task force I would recommend would be Eisenhut, (, O'Reilly, Eudnitz, Hanauer, Cummings, end two additional members chosen frcm the outside. This task force would have the specific assignment, to form irediately, to task within the iGC, and to develop the fact finding report within a fixed period of time. They should have access to additional contract funds, which could be used for the laboratories to run particular experiments i f necessary. The fRC people should be assigned full-time to this task force. Since it is a fact finding only, it should be exempt frca the Federal Adviscry Ccmmittee Act. Following the submission of its report, I believe we could take several steps, which need not be decided on at the present time (but could be). These could include: 1. The Ccmmission itself hold a meeting with the task force in which members am asked to corment. 2. The Director and Deputy Director are asked as a separate function to draw up their own conclusions and any possible reco=endations. \\\\9 106

ii y 2 3. The report could be submitted to a separate group formed for the purpose of reviewing the work of the Task Force and drawing conclusions and making recomaendations. 4. The group report cou'd be submitted directly to the Commission and the Comaission could then o.aw its own conclusions and make necessary recommendations or take any necessary actions. A modification of the Statement of Policy and Scope that night be appropriate for this version is attached. e 9 9

p r-O l. I STATEMENT OF POLICY - A / t. 2_ The Nuclear Regulatory Corr.ission herv y institutes a e T%i-F. J4Tc45.W Special,Ing.i./ to investigate and repo c tn the accident /* which took place beginning on March 28, 1979, at the Three Mile Igland Nuclear Station No. 2, in Harrisburg, Pennsylvania. T>tt PbC The ir.q '-7 w ilz. 4pd W%, ill examine the actual events which occurred gq(l./.-:- g their causes, h-d.6-p ftJOAt O/ fM flM$f:;;.Op O n-d t h :1. incl'. at

..e.

~ gl P br.Ec t'OW~ M t.L' inquiry will be to make-findir.;:, concluricrc, 2 n d - c.uc.h-Peer-me n'.t I : r.; h.v.bD fn 'h d.co J.3M ', Q k. ek Q t 24h'e--D:r ' " i ^ n._gr_.r.a; - b ~ '-'"--':" The seope Cud Lt of the i.s 12, is set forth in detail in attachment 1. The target date for completion of the inquiry is November 1, 1979 c( ge.v. L pd d (Q T M b t 6'-" i The 1:.s .j will be headed b-y aVPr,ir ;tc. selected from .,g c ~: ~1nw ~,% c ( y;e outside the Commission. The Dir_^' " *..ill be 1:M - t z d.,, a. .;.,s 4 4.i. ' LuAS.wa 'O. Dy.&Mm Dd ?j W -% Mti s R O L > i _D6"ty D_.r_ Z. .;.4 E3 ( fc.e..u-Q j hy.4, Ce : im1 CcuSsel r-and-otrher-rAa-f4-of-hic-/har_ E'S 0 l hw M, C M ) )._d l c.., _._ _. . - - _ ~ - 4-~-~,, ......~..u. s ' ir. :crr;-in-r"' 'w ~1-,"4 y, e -_4 --471 n ' he-er.c.v.a b.le--by -- n t_h._e nn- '--, n--n' c _ _- m. 0---- - ~,7 u2 '- =- n.c.u' :c.a ca c e% n offica. In a u s 11ir.2--th 2W f f .20 0s sery-Pc_ -t-he--inq+i-ry ;

• Th % 5 % 3 i

t.h : Dic; tcr_Till b^ C"55 Io d"aw up.no_ current-NRC~ staff personnel, consistent with other agency program needs, as 2 well as to recruit persons from outside the agency for the duration of the inquiry. The estimated resources necessary G. t cL m are set forth in attachment 2. The ir.,_ cy staff will serve the pley,sure of the Dirc tar. 7'r2 7/ +. at I <d % % The Ti-^ 'e h responsibilities will include periodic interim reports to the Commission and to the public. 119 106

3 J. e ) 2 It is essential that the Commission be in a position to take ' appropriate action on matters developed by the inquiry as ~ information becomes available, rather than having to auait the completion of the entire inquiry. %d th The D rr:ter will have the further responsibility of l perd.inptingua.'nd' cooperating with the Presidentially mandated t investigation of the events Three Mile Island, and,with such other investigations as n.;y be instituted by committees of the Congress. Pursuant to Section 161n of the Atomic Energy Act as Os-m amended, the Comission will delegate to the Ch a of the . L.h~u k'ir.quir r 1 1-i authority set forth in Section 161c thereof to conduct this investigation, gather information, and hold iv4 k g meetings as the Eir__um. may deen necessary and proper to the fulfillment of the obj ectives of this inquiry. For the con-duct of the inquiry the Commission will further delegate igs authority to administer oaths and affirmations, and by sub-poenas to require any person to appear and testify, or to appear and produce documents, or both,- at any designated place. The Commission will delegate ifn authority, under Section 161f, to utilise the sertices of personnel,of any Government agency or any State or local government, with the consent of the agency concerned; t..;.. m _... sri t s,

.d a r S t. s'._ -. 1 5 1 5, so. Lease anc purenase real ci.. pre,onal

-- M ' PJo d ited States prcp t r t,. n 'egeac o f a-v. )\\0 I

1 3 In order to assure the independence and integrity of T.d PW - D the inquiry, the Dir: _,f and'JW1.s staff.:111 be requested to maintain records o'r all discussions with all

ersons, including Nuclear Regulatory Co: aission personnel, bearing on the subject matter of the inquiry or the inquiry itself.

4 4 D 0 e

l' V/9/?? / f'" SCOPE OF THE INVESTIGATIO.'I / \\ [' Y 'y\\ .. A L \\ ') 8 ~'%,- t i 3 1. Ob.iectives (LL jf The objectives of the investigation are: (a) to find the facts concerning the or gins,, develo me t and consequences of t e TMI-2a\\n, i -i c ident; 1 f (b) to evaluaue those facts and dr._w from-them ^ conclusions with respect to t.e regulation, design, cons ruction, reviev and operation of nuclear po fer facilities /, \\ /; (c) to evaluate and draw con 'lusions concerning the emergency r.sponse a d conduct of the licensee, URC, a d oth "s; and 1 / (d) to make such reco.mendations to the Commission / as the findings anu onclusions warrant, includ-ing any changes in she regulatory process. 2. Scope of Fact Finding The fact finding shall include th_ following: (a) Historical re/iew, in.cluding: (1) Sequence of events, causes, and conseque..ces. (ii) Readiness of TNI-2 for / \\ / various phases 01 initial I power operations. O '~1

4-1 i ii Resources - jf3 1 The Commission anticipates that a ucrk force of up to .), .Nt,ud.d~ hind wm -W full-time people.w-i-1 be recuired for the investigation. A T h c '< v t,. fu. oc n --c ;.p e s W

• o include well cualifiecLp o-n fen -4 n%1e-in-t/ncva. vui Kre6tifi, engineeri% T and -

ojha-A d sc-ip-1-ines-invotved, lept counse', and-adrainistra-tiva n nd-c-1-eri co '- support. MRC uill provide as much of this ~ T.Jt'.,w work force as desired by the Dir::tcr. A number of persons on the investigation team are expected to be drawn from WI2 C iac de :bw-%t t(, k%'l out side H.RC. /_A'1,(pa. y i' c e rt ()y / tcy')J,, As a further part of the resources that may be utilized, the (,n.l,~ g-i r' uill have available tr-^ the result s of,,.d.wr* 4~"- or. going tietailed investigations of the T."I-2 incident by URC staff offices. 9 Tkk The D m T is, in addition, authorised to utilise outside support -- frca other Government agencies or undn-contract. On the basis of prelininary esticates, the Com-nission~ plans to set aside up to $1,000,000 for the purpose of such contracts. .}}