ML20248H024

Rept of Communications Coordinating Committee W/Recommendations on Public Communications Initiatives

ML20248H024
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Issue date:	03/24/1998
From:	Barrett R, Beecher W, Cameron F NRC, NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
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P,ublic Co,mmunicitions Initiatives ,- http://www.ntc. gov /OPA/cccrpt.htm

.. 4 Public Communications Initiatives Communications Report Page l News and Information l NRC llome Pace l E-mail View / Download document in .pdf format REPORTGF' file COMMUNICATIONS COORDINATING COMMITTEE-WITH RECOMMENDATION!!S ON PUBLIC COMMUNICATIONS INITIATIVES ,

William M. Beeener, co-chair  ;

~

Francis X. Cameron, co-chair Committee Members Richard J. Barrett, AEOD John W. Craig, RES Donnie H. Grimsley, OCIO Wayne D. Lanning, Region I Josephine M. Piccone, NMSS Linda E. Portner, OCA Marylee M. Slosson / John A. Zwolinsky, NRR March 24,1998 L ._- _.

Table of Contents Hackcround j Discussion i

Oveniew I. CLARITY ANI) TIMELINESS OF COMMUNICATIONS issue I A: Make written and spoken language more understandable f

Issue IB: Expand niain Enelish clossary and encourage staff use Issue IC: Treat public as a most important client \

Issue ID: Hecome more proactive in reactine promptly to concerns issue IE: Develop orass roots system for early warnine M {'~~~ l fu u.,

II. Tile PUBLIC INVOLVEMENT PROCESS -- .

g .( 14 - h h C 9906090030 990324 -

PDR COrfts NRCC 1of26 CORRESPONDENCE PDR 06/02/98 15:11:36

P,ublic Coinmunications initiatives http //www.nrc. gov /OPA/ccerpt.htm l Issue IIA: Plan early public involvement in rulemaking issue IIH: Develop comprehensive plan for public involvement Issue IIC: Sr ecial trainine course to increase staff understanding Issue IID: Augment Strateeic Plan to stress public involvment III. RESPONSIVENESS TO PUBLIC INOUIRIES Issue III A: llandle all correspondence in a timelv. responsive manner Issue IIIH: Develop a policy for aandline e-mail IV. PUBLIC ACCESS TO INFORMATION Issue IVA: Update strateev for providine information in electronic age Issue IVH: Reassess what plant information is required V. PUBLIC OUTREACil Issue VA: Educate public without beine promotional Issue VH: Hroaden staff knowledee of the entire agency

SUMMARY

Attachments:

1) DSI-14

2) SRM of March 14.1997

3) Focus croup attendees

4) Curriculum for Proposed Course on Public Involvement Process Backcround:

In the SRM of March 14,1997, the Commission directed the Executive Council to create a coordinating group to develop a plan to implement the Commission's policy guidance in Direction Setting Issue #14, "Public Communications initiatives." This DSI addressed the need to improve the quality, clarity and credibility of communications with all NRC stakeholder, and particularly with the general public. The SRM focused on improvements in the broad areas of more effective written and oral communications  ;

with the public, early identification of public concems, early involvement of the public in NRC i regul.nory decisions of substantial interest or concern, and more effective outreach to the general public on the roles and responsibilities of the NRC. The Executive Council appointed the Communications Coordinating Committee (CCC), co-chaired by William M. Beecher, Director of the Office of Public Affairs, and Francis X. Cameron, Special Counsel for Public Liaison in the Office of General Counsel, and consisting of senior members of several Commission and program offices, to address the issues md offer recommendations. This paper, with its attachments, forwards the requested plan.

Return to Table of Contents Discussion: O 2ef26 06/02/98 15:11:37

http://www.nrs. gov /OPA/cccrpt.btm Public CoJnmunications Initiatives The CCC considered several sources ofinformation in developing its recommendations. They included the experience of other agencies, the report of the Presidential / Congressional Commission on Risk Assessment and Risk Management, comments of and interviews with NRC Office Directors and Regional Administrators, public comments received during Phase II of the Strategic Assessment and Rebaselining process, and views offered by a cross section of stakeholder convened by the Committee on Dec. I1,1997, to discuss a range of public communications issues. The Commission has been provided a transcript from the meeting, which also was posted on NRC's Internet website.

The CCC's basic approach was to evaluate NRC performance in the following broad categories: 1) clarity and timeliness of communications,2) public involvement,3) responsiveness to public inquiries,

4) public access to NRC information and 5) public outreach.

The Committee believes that necessary improvements in these five areas would significantly advance the Commission's goal, which is to foster better public understanding of, and trust and confidence in, the agency's regulatory program and activities. The CCC would further emphasize that another important factor in advancing this goal involves NRC decisions on generic and site specific issues. Public comments on DSI #14, as well as several statements made during the December focus group meeting, stressed that Commission or staff actions which could be perceived as being motivated by concerns for other than public health and safety issues, may undermine public confidence, notwithstanding how much mee clearly the agency may articulate its message. Examples ched during the focus group meeting inchaled: the almost universal den:a! of 2.206 petitions despite the fact that in some cases subsequent NRC decisions appeared to validate the safety issues originally raised in such petitions; the discontinuance of certain previously available reports of safety information; the elimination of the opportunity for an adjudicatory hearing on reactor decommissioning; and the limited opportunity for public involvement in the spent fuel storage cask certification process. Several participants in the full-day focus group session contended that the NRC appears primarily interested in keeping nuclear power plants up and running, nther than in addressirg public concems about safety. The staff would be quick to dispute that, but the perception is out there, particularly in the public interest community.

This is not to suggest the focus grou p was universally critical. The NRC's Internet website was described as one of the best in government and the main Public Document Room as particularly responsive to all comers. Virtually all at the focus session stressed the fundamental obligation of the NRC to tell the truth, what we know and don't know about an event at a licensed facility, and to put it into context. With this the CCC heartily concurs.

There will always be some who will disagree with the NRC's approach, particularly in an area as controversial as the use of radioactive materials. The important thing is to ensure that agency decisions are not only shaped by the safety significance of the issue and considerations of regulatory effectiveness, but also by considerations of public trust and credibility. Ifinterested members of the public have an opportunity to voice their concerns and opinions early in the decision-making process, they will have greater respect for the openness and faimess of the process.

Since its inception the NRC has attempted to foster greater understanding of and confidence in the agency's regulatory oversight, whose fundamental aim is to protect public health and safety in the use of nuclear materials. But the CCC recognizes the need to significantly improve the way the NRC does business, to do no less than change the culture of the agency, in order to adapt to changing needs in l society and in the economy. To accomplish such goals, the Committee underscores the requirement for a l concentrated and persistent effort by the leaders of the agency to stress their determination--up and down the chain of command--to achieve markedly improved communications. It has taken just such an effort to begin to transform the traditional mechanisms by which the NRC evaluates the safety perfonnance of its licensees. No less an effort is called for in the way the agency should convey to all its stakeholder

more clearly how it is carrying out its regulatory responsibilities and to open up the decision-making l process to early suggestions and comments from all interested stakeholder. As a first step in this effort, the Committee recommends that the Chairman issue an "All Employees" statement on the signal importance ofimproved public communications and responsiveness in carrying out our regulatory mission.

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Public Communications initiatives http://www.nrc. gov /OPA/cccrpt.htm Before proceeding to a summary of the CCC's findings and recommendations, there are some overarching issues identified in the SRM, related documents, and comments ofinterested stakeholder--both inside and outside the agency--which ought to be addressed.

One such issue is the question of balance in our reports. In performing our regulatory mission, it is incumbent on the NRC to painstakingly scrutinize the performance of our licensees in order to pinpoint issues that require management attention and correction. We are a public agency and our findings are, of course, discussed in public. In so doing, we do not mince words, for we want licensee management to grasp the seriousness of the need to address problems promptly. And we want the public to have confidence that we are carrying out our health and safety mission without fear or favor. At the same time, we should do a betterjob in putting our findings in clearer perspective, with emphasis on how they relate to safety. In the case of nuclear power plants, f or example, each plant design offers several layers of safety systems to guard against catastrophic failure. If we find that a deficiency threatens to erode one such layer--reducing that margin of safety--we should say so, but also point to the overlapping defenses still in place. That would provide a better yardstick with which to measure risk.

Another such issue concerns responsibility. Without question it is the licensee's responsibility to ensure the safety of his facility; it was on that basis that a license was granted in the first place. Nonetheless, the public has a right to expect that the NRC will be sufficiently vigilant in its oversight function to insure that serious degradations in equipment, operational procedures, or management command and control are not allowed to occur unchallenged and uncorrected--and in a timely manner. That is one of the overriding lessons of Millstone. The NRC cannot wash its hands of a shared responsibility by pointing to the licensee as ultimately responsible. But in describing problems that arise--to the licensee and to the public--we must be scrupulous m putting events, practices and conditions in proper perspective, neither overstating nor understating the significance of the situation in terms of safety. Safety is our mission; helping to preserve the robust margin of safety designed into every nuclear power plant and into the use of nuclear materials in medicine, research and industry is why we exist. We must achieve a careful balance in describing what we find and what we require.

Another overarching issue concerns costs. From the start of our work nearly a year ago, the Committee was confronted by a dichotomy: Even as the agency's budgetary and manpower resources are shrinking significantly, the Commission directed the CCC, in effect, to think both inside and outside the box about what should be done to improve its communications-- particularly with the general public--but essentially within " existing resources." Every effort was made to avoid unnecessarily costly options. The CCC believes the costs ofits recommendations are relatively modest, often incurred on a one-time basis, and are substantially outweighed by the benefit they could achieve. While some potential savings were identified, the Commission will have to decide which recommendations provide sufficient added value to justify their additional incremental cost.

This is particularly relevant to the Committee's recommendations on the need for specialized training.

The CCC feels that however clearcut and sincere, rhetorical exhortations alone won't change a culture.

Specially tailored training, particularly for supervisors who lead public discussions and oversee the writing of high profile reports, represent a necessary catalyst for change. There is already so heavy a burden of mandatory classes, which perforce take staffers away from hours of regular duties, that an agency-wide effort is underway under the direction of the Executive Council to evaluate the prioritization of training to ensure what's offered is needed and effective. The proposals the CCC makes m this regard will have to pass the value test as compared with the entire spectrum of competing courses.

But the Committee feels it could do no less than propose what it believes will help fulfill the requirement called for in the SRM. You can hardly expect to change an inbred pattern of thinking without some focused, consciousness-raising training.

Policy coordination is another issue that requires greater attention. All too often, one program office will carry its planning quite far before bringing other elements of the agency into the discussion.

Particularly on those issues expected to have a high profile in the public arena, it is important to bring into the discussions from the conceptual stage all relevant parties, both from the staff offices and the Co*nmission-level oflices.

I i

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Public Communications Initiatives http://www.n rc. gov /O PA/ccerpt.htm Still another commanding issue involves the organizational framework for the public communications and public involvement process. In its SRM, the Commission stated that "although there should be centralized planning and coordination of methodology for anticipating and involving the public in regulatory matters and decision-making, responsibility for implementing the methodology should reside with the program offices." The CCC has not recommended any changes in the existing organizational structure, which consists of the Office of Public Affairs as the office primarily responsible for informing the public of NRC activities; the program offices, which have the responsibility for interaction with the public in the context of specific regulatory actions; and the Special Counsel for Public Liaison, who provides assistance to the staffin the design and implementation of public involvement processes.

Ilowever, the Committee has recommended that a standing body somewhat like the CCC be established to provide timely advice and coordination in dealing with budding issues of public concem. And a potential organizational issue arises from a pilot training course, offered for the first time this year, aimed at establishing a cadre of facilitatory to assist the staffin conducting public meetings and workshops. Although it is premature to decide whether this cadre should be placed within one organizational unit or remain in the various program offices, the CCC flags this to the Commission for future reference.

Even as the CCC believes all its recommendations are worthy of serious consideration by the Commission, after consultation with the Executive Council it was decided to offer three categories of packages: the Foundation Path list, actions we feel ought to be implemented without delay; the Enhanced Path list which have high priority but are less urgent; and the Comprehensive Path, which includes the remainder of the proposals. Each is categorized under one of these three headings in this Report.

The Committee believes the thrust and many of the detailed proposals of our recommendations are entirely consistent with that section of the revised Strategic Plan for FY 1998-2003 dealing with Public Confidence. To wit:

"Public confidence in the NRC will be diminished if the information we disseminate is not technically sound, clear, accurate, reliable and timely. Our communications with the public must be designed to foster greater understanding of and confidence in our regulatory program... Our words must be consistent with our actions and priorities... We will emphasize to each employee who prepares written documents or orally communicates with the public that these communications must be technically sound, clear, accurate, and understandable to the public. We will implement this strategy through training, establishing document standards targeted to improve understanding, and encouraging the use of plain English."

Return to Table of Contents OVERVIEW Ask anyone at the NRC what the agency's primary mission is and without hesitation the universal answer is to protect public health and safety. But it is not enough to scrupulously pursue that objective if the public finds it difficult to understand how we carry out our regulatory tasks and why we make the decisions that we do. Representatives of some public interest groups, as underscored during a full day focus group meeting with the CCC in December, said in some communities the NRC must first reestablish its credibility, even as it tries to clarify its message. Furthermore, as an agency we too often are remiss in not explaining problems we uncover in the context of the multiple layers of protection built into every nuclear plant design. Specifics are vital so that problems can be addressed and corrected promptly by the licensee. But so is context, so the public will be provided better perspective with which to assess potential risk.

Most importantly, we must never lose sight of the fact that both the NRC and its licensees are accountable to the public--a public which tends to be inherently nervous about all things nuclear.

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http://www.nrc. gov /OlWcccrpt.htm llublic Communications initiatives In an earlier age, it might have been enough to say: We're the experts. We're on top of this. Trust us.

But the public now wants--and has a right--to be heard, to question, to voice its worries and opinions, belbre decisions are made which can affect the community at large.

Insofar as possible within the constraints of a shrinking budget, we must take a number of steps to improve the ability of NRC supervisors and technical staff to communicate mare clearly and credibly--providing not only transparency to our process, but also balance and context to our findings.

And we must demonstrate greater sensitivity to public concerns. As pointed out in the Presidential / Congressional Assessment and Risk Management report of 1997: " Regulatory agencies should adopt... communications programs that emphasize both the learning and explaining activities of communication." i At the start of our efforts, we canvassed a number of agencies and companies to see whether we could gain useful ideas from their effbrts to improve communications with and service to their customers. '

They included the Consumer Products Safety Commission, the Federal Energy Regulatory Commission, the Federal Trade Commission, the Internal Revenue Service, the Securities and Exchange Commission, the American Red Cross, Adventist Ilealth Care, the National Science Foundation, Washington Gas Light Company, the Brookings Institution, the Department of Energy, the Environmental Protection Agency, and the Department of Transportation.

There are basic differences, of course, between the roles and missions of the NRC and many of those contacted. Several of them are promotional and employ advenising, public relations and marketing firms, using consumer surveys, polls, and promotional newspaper ads, radio and TV spots--which ihr the most part would not be appropriate for the NRC.

Very extensive use of the Internet is being practiced by the IRS, the FTC, the SEC, the Red Cross, and the National Science Foundation. The FTC, for instance, not only puts all its news releases, reference documents, and full case summaries on the Internet, but also provides a plain English analysis of each case to aid public understanding and encourage comment.

The SEC has published a draft " plain English" handbook to encourage the use of clear and simple language Ibr staffers who wrih: opinions, as well as for those who file infonnation with or lodge fbrmal questions to the agency. The draf t was put on its website and comments solicited. Internally, the SEC says it provides constant training to improve the clarity of expression by attorneys and other staffin writing decisions and opinions.

The SEC and the National Science Foundation, in particular, make a major effbrt to seek speaking opportunities belbre civic and other organizations to help educate the public on what they do and the issues they confront, in addition, the Committee reviewed what other agencies have done in the field of public involvement.

As with the NRC, other agencies also are moving away from involving interested members of the public and other stakeholder only at the end of the decisional process toward involving them early where their views can have some impact on decisions. As this trend has evolved, there are fewer large public hearings in favor of focused workshops, advisory groups and one-on-one interviews.

Notable among the programs of other agencies is the Department of Energy's public participation program. It stresses several core values, including accessibility, accountability, accuracy, honesty, respect, fairness, responsiveness and scientific credibility. These values and goals nave been made part of the perfbnnance element of DOE managers. DOE has a well-developed public participation training program ihr managers and staff, as have the Environmental Protection Agency and the Department of Transportation.

In addition to consulting the Presidential / Congressional Commission risk report, we also got soma useful insights from c paper on risk communication in the September 1997 issue ofIlealth Physics by K.L. Ng and D.M. Ilamby. "llistorically," they observed," risk communication was largely a one-way 6 of 26 06/02/98 I5:11:37

1lublic Communications initiatives http://www.nrc. gov /OPA/cccrpt.htm form of communicating, with the public being told what the experts think to be important. The risk communicators have been the interpreters, clarifiers, and simplifiers of technical jargon. This is no longer considered acceptable or sufficient by the public; the public wants to be involved."

1 i On the issue of public confidence, they declared: " Trust takes time to build, it is fragile--it can be destroyed in an instant. It requires continuous reinforcement and maintenance. It is very important to remain candid and honest; this means being ready, able and willing to be forthcoming and to reveal all that is known or believed about the issue, and that possible controversial information should be quickly distributed. If there is a communications void between the risk communicator and the public, this void will be filled by speculation, rumors or misinformation."

, And, finally, on deali.ig with the press, they said: "It is very important that the following actions be I followed when communicating with the news media: do not disseminate self-serving data; do not make l irrelevant comparisons; do not downplay risk potential; do not use technical jargon; do not employ non-credible or incompetent sources; do not take adversarial postures; do not stonewall or act inaccessible; and do not ignore public concerns. And, most importantly, be proactive establishing dialog

, withjournalists."

1 As an aid to the Commission in its deliberations, the CCC intends at an early and appropriate time to put its report on the Internet for stakeholder information and comment which will be relayed to the Commission expeditiously.

There follows the body of the Committee's report:

Return to Table of Contents CLARITY AND TIMELINESS OF COMh1UNICATIONS While technically proficient and well-motivated, with some notable exceptions NRC people are perceived all too often as doing a less than adequate job in communicating with the public, both in hard-to-understand documents and statements at public meetings. Part of the problem arises naturally from the fact that the NRC deals with highly technical matters. Nonetheless there are separable issues at play that can and should be addressed.

Issue:

While jargon and technical language are our stock and trade, and work l

l reasonably well in dealing with licensees, we often are not very efTective in dealing with our other l

stakeholder, and particularly not with the public at large.

It's not uncommon for NRC public affairs officers around the country to hear complaints that in some instances we don't seem especially anxious for the public to understand what we're dealing with, preferring to keep the dialogue between the regulator and the regulated. But if the public is to trust the agency when it offers assurance that a licensed facility or activity is safe, we must do a betterjob in consistently making more understandable and accessible what we're talking about. We must also demonstrate genuine interest in addressing concerns and assessing differing points of view.

An instructor who teaches those writing courses currently available at the NRC said it's her experience that a fair number of employees seem to know how to write relatively clearly when they first come to the agency, but quickly learn to write reports in a dense bureaucratic style in order to gain concurrence from their supervisors. Part of the answer therefore is remedial education with emphasis initially on supervisors who lead public discussions and oversee the editing of high profile reports. Unless supervisors are persuaded that clarity, understandability and credibility are vital, an effort to reach out to a larger staff population may be largely wasted.

, Goal:

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Public Communic::tions Initiatives http://www.nrc. gov /OPA/cccrpt.htm

(

To make our written and spoken words more understandable to the general public.

Recommendations / Milestones:

l IA1 o Develop a half-day course for the supervisors, managers and certain technical staf'f who together constitute a cadre of communicators and who, by virtue of theirjobs, have a special responsibility to communicate clearly and to ensure their subordinates do so as well. The directors of NRR, NMSS, AEOD and RES and the Regional Administrators may designate who belongs in this cadre estimated at about 300-400 ;xrsons. A lecture-type course could be taught largely by the staff, with limited contract l support. It wou .d have four 1-hour segments. Time would be allowed for a significant amount of l question-and-answer interaction between audience and lecturers. Conceptually, the four segments would feature:

1. The art of simple explanation and clear exposition. (Contractor),

2. Recognition that the public, whose health and safety we are charged to protect, is one of our most important clients and that if we fail to communicate clearly with the public--to include concerned citizens, reporters and allegers--we are not fulfilling an important part of our responsibility.

(OPA--Beecher),

3. Specific examples of text that is impenetrable to the layman with demonstration of how the same material could be handled more understandably. (NRC staff--Coblentz),

4. Ilow to conduct an effective, responsive public meeting (OPA--Greenman).

Course materials would be developed for the instruction (2 months), and afterwards it would be taught quarterly over the course of a year to the cadre of supervisors. [ FOUNDATION PATH]

I A2 o In alternate years, larger numbers of staff, again designated principally by program office directors and regional administrators could be given the same instruction. This would be followed up in these alternate years with small, two-hour sessions for technical staff and their immediate supervisor.

This would be hands-on instruction with word processors. Interactive teleconference capability would enable doubling up some sessions to include one team at headquarters and one in the region.

Course materials would be developed for the 2-hour course (2 months),and then taught two classes per day for 16 days, spread throughout the year. These would be coordinated to follow the 4-hour course every other year. [ENilANCED PATHj Alternatively, if the Commission feels the burden of other mandatory classwork requires, this schedule could be spaced over four years rather than over two. A decision could be made thereafter how often to repeat this cycle.

In addition, this improved communications theme should be incorporated into existing technical training courses.

I A3 o Adopt a format for both technical reports and public meetings that includes a clear Executive Summary. Start off each high profile technical paper, including such things as AITs, with a brief Executive Summary of;xrhaps a page or two, stating the problem and NRC's findings in language the layman can comprehend. Such findings must be put into context, explaining both the safety significance and that the system or component in question is part of an overlapping series of safety measures designed to guard against any harm to the public. Helping people understand the potential degree of risk was one of the major suggestions of the Presidential / Congressional risk report. l FOUNDATION PATH]

By the same token, NRC public meetings with licensees could start with a brief" tutorial" in which the issues about to be discussed in technical detail would be put into context, with their safety significance underlined. From time to time, if the senior NRC official present senses that the public may be lost in the technical maze, he might interrupt very briefly to explain the significance of what's being discussed.

This would not only make it easier for non-techies in the audience to follow the drift of the necessarily 8<f26 06/02/98 15:11:37

Public Communications initiatives http://www.ntc. gov /OPA/cccrpt.htm technical discussion, but would make them feel welcome, make them feel the NRC wants them to understand what's going on while, at the same time, conceding that the agency must deal in technical detail with its licensees on technical issues.[ FOUNDATION PATil]

IA4 o Management Directive 3.5 "Public Attendance at Certain Meetings involving the NRC Staff" and 3.2 " Distribution of Unclassified NRC Staff and Contractor-Generated Documents" would need to be revised to incorporate the change in format for both public meetings and reports. This would be announced in a memorandum from the Executive Director for Operations to employees.[ FOUNDATION PATill (2 months)

Effectiveness Measures:

o Review Executive Summaries to assess their clarity, and see whether newspaper stories based on both public meetings and NRC documents demonstrate that clarity is being achieved.

o Use brief questionnaires on NRC's Web site and at public meetings to get feedback on the effort to make information more accessible.

Costs:

o Estimate approximately four half-day classes of 100 each from headquarters and the regions (the latter participating by videoconferencing) during the first year and four classes of about 200 each for other staffers in headquarters and the regions the second year. Actual numbers, which could be lower, would be designated by the major oflices and the regions.

($12K-contractor for each year; 0.2 FTE-to develop and teach course; and additional FTE,if you count the time away from regular work to attend classes )

o in alternate years, estimate approximately 32 follow-on,2-hour classes of about 25 each in headquarters. Using interactive videoconferencing, several sessions could be simultaneously linked to regional offices.

($6K-contractor,0.2 FTE-course work)

Issue:

We tend to use unnecessarily opaque and ambiguous language, for any number of reasons. Some of this language is "boilerplate," stock phrases and constructions that have been applied to certain situations and findings for years. There is not universal agreement, even within the agency, oi. what each of these expressions means. Some critics contend this demonstrates either disinterest in or disdain for broader accessibility. Some descriptions ap 3 ear to be designed to finesse a troublesome situation without raising public alamt it is important not to 3e alarmist, of course, but also important to be clearer and more precise in our communications so that all stakeholder understand exactly what we are trying to convey.

A question is sometimes raised about the " balance" of our regulatory pronouncements at public meetings assessing the performance oflicensees. In describing an AIT, IIT or SALP report, for instance, do we balance the good with the troubling, or focus inordinately on the latter? Are we consistent among the four regions on this score?

The Committee found that as a rule both Regional Administrators and other senior staff attempt to provide a balanced perspective and context, even while making clear where we feel the licensee has failed to meet regulatory requirements. But there have been isolated instances when this delicate balance has not been achieved.

Goal:

Explain technicaljargon, boiler-plate language, acronyms, and regulatory findings in a balanced way in

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Public Communications Initiatives http //www.nrc. gov /OPA/ccerpt.htm i our writing and speaking so that the public can better understand what we're trying to convey.

Recommendations / Milestones:

lill o Conduct review by the technical staff of the glossary of nuclear expressions that recently was posted on the NRC Website and both expand and enhance it to include ollen-used expressions with clear, agreed definitions in plain English. When a report is being drafted, the technical staff must be aware not only that the licensee must understand, but insofar as possible the public ought to as well. In addition to a clear, plain English Executive Summary, in the body of the report the first time an expression such as "small break LOCA" or "ALARA " is used, it should be spelled out briefly. As it happens, INPO reports, which are not written for the public but for plant management, nonetheless tend to treat technical conclusions in direct, focused, comprehensible prose. The glossary developed by the Presidential / Congressional risk report will be used as a reference. (1 year) [ENII ANCED PATill 1112 o Distribute the glossary to all employees with guidance to limit use ofjargon and encourage use of plain English definitions in writing and speaking to the public. (1 month after glossary is updated)

[ FOUNDATION PATill 1113 o llave both the Commission and topmost NRC management periodically stress to subordinates the need to convey our findings and conclusions not only clearly but in a carefully balanced way, neither overstating nor minimizing our concerns. If, for instance, we conclude that the underlying cause for an event is a lack of effective command and control by management, even though that in itselfis not a specific, enumerated requirement of our regulations, we should state our conclusion and back it up, and then cite the specific derivative infractions that we uncovered. (Periodically as appropriate.)

[ FOUNDATION PATill 1114 o Obtain the appropriate technical staffs initial evaluation and areas of concern before discussing an event with the public or the media. There should be little if any speculation on second and third order possibilities or scenarios in addressing particular NRC concerns about the specific cunt. This must be a two-way exchange, with public affairs officers alerting technical staff to anticipated media questions and public reactions. By the same token, technical staff, in writing about an event in a format that will be posted on the Internet, should discuss their description with a public affairs officer who may be more i sensitive to how their words will be perceived and whether they clearly convey what is intended.

(Ongoing) l FOUNDATION PATil]

Effectiveness Measures:  ;

o Survey the public on the usefulness of the glossary on the Website. If comments come in suggesting the need for additional definitions, add them as appropriate to the glossary, which should be viewed as a living document.

o Survey public at meetings by the use of a short c questionnaire to evaluate the understandability of discussions. Suggestions may be offered that will ielp improve future meetings.

o Review a sample of documents to determine whether use ofjargon has been reduced. Contact appropriate supervisors on those reports that need greater effort in this regard.

o Review a sample of news articles to assess whether the effort at greater clarity appears to be having impact. .

Costs:

o (0.2 FTE for glossary expansion and docment review; 0.2 FTE for coordination between staff and OPA on drafting PN and dealing with press).

Issue:

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Public Communications initiatives http://www.nrc. gov /OPA/ccerpt.htm There is an attitudinal problem underlying some of our communications difficulties that can be attributed to a cultural bias. A limited but not insignificant number of staffers view the licensee as the principal client and others--interested citizens and concerned critics, for example--as an impediment at best. For such staffers there is little incentive to make our communications more understandable to non-licensees. This attitude does not help build or maintain trust on the part of the public, one of our important objectives.

The Commission and top managers need to make absolutely clear to the staff on a regular basis that the public is and should be treated as one of our most important clients. We respect the licensee, we work closely with him, we want him to succeed in carrying out his primary responsibility of ensuring the safe operation of his facility. But we must never lose sight of the fact that both the licensee and the NRC are accountable to the public.

The " Openness" element in the NRC's Principles of Good Regulation underscores the point that " nuclear regulation is the public's business, and it must be transacted publicly and candidly." But actions are needed beyond such positive rhetorical exhortations.

. Goal:

Treat the public as one of our most important clients.

Recommendations / Milestones:

ICI o include in the annual performance appraisal of all appropriate individuals a specific performance element dealing with both the clarity of their communications (written and oral) and their sensitive responsiveness to the public. Senior managers should discuss and underscore the need for both clarity and sensitivity in their one-on-one reviews with employees and make every effort to assure that this perm.mance element is taken seriously in their rating and not just checked off reflexively. (3 months to develop performance element and incorporate into appropriate appraisal forms.) [ENilANCED PATilj IC2 > !ssue a Staff Requirements Memorandum or policy statement, as appmgiate, from the Comraission in which it makes clear its view to semor staff managers and all employees that the fundamental reason we exist as an agency is to protect public health and safety, and that means the general public is one of our most valued clients. (1 month) [ FOUNDATION PATII]

IC3 o Reinforce this message repeatedly up and down the chain of command.

[ENIIANCED PATII]

Effectiveness Measures:

o Periodically check appraisal ratings on the performance element dealing with public communication.

Cost:

0.2 FTE issue:

As an agency, the NRC tends too often to be reactive rather than proactive in dealing with what should be predictable problems relating to public concerns.

Goal:

Provide early identification of public concerns and methods for effectively dealing with them.

Recommendations / Milestones:

1Iof26 06/02/98 15:11:38

)

,l'ublic corninunicciions initiatives hup://www.nrc. gov /ciwcccrpt.htrn IDI o As a regular feature at the lixecutive Director's weekly Friday staff conference, query the agency's top managers for issues of potentially serious public concern looming on the horimn that ought to be considered on an intra agency basis. (Weekly) l FOUNDATION PATIIl l ID2 o listablish something similar to the Conununications Coordinating Committee as a standing body I

to evaluate and develop viable solutions to the issues that require prompt attention. For example, earlier this year, it became apparent that the citizens' proup which had op 30 sed the decommissioning of Yankee flowe in Massachusetts intended to launch a sunilar campaign at t 1e first public meeting on Connecticut Yankee decommissioning . A com archensive NI(C press briefing was conducted several days in advance so the issue would be de med in a 1 its dimensions for the conununity and a multitude of questions l answered befi>re the public meeting Lengthy, balanced news accounts appeared the weekend beli>re the i public meeting, providing understandable technical background of value to the people attending. (!

! month)l FOUNDATION PATill Effectiveness Measures:

o Assess instances of balanced reporting of public concerns.

o livaluate correspondence that identifies NI(C's poor handling of public concerns.

Costs:

(0.12 FTE to organlic group and meet as needed) hm:

Ilow to generate identification ofissues of public concern at the grassroots, fi>r relay to senior managers.

Goal:

liarlier identification of potential issues of public concern.

l(commendations / Milestones:

IEl o Modify existing training courses fi>r license reviewers (I,icensing Practices and Procedures),

inspectors (Fundamentals of inspection, inspection Procedures), and technical project managers to include discussions of the need to bring budding issues of public concern to N1(C management attention at the earliest possible time. License reviewers and inspectors, liir example, have day to-day contact with licensees and members of the public and,in-so-doing, receive early warning ofincipient issues.

(3 months)lENilANCED PATill IE2 o linhance communications with local governments, in the case of a significant event, problem licensee or site of special interest, the NI(C should expand the practice of sending copies of incident reports and enfiircement correspondence to the state, by includmg appropriate local governments on distribution. They are intimately aware of grass roots issues and should be encouraged to pass those along. (2 months) [ FOUNDATION PATIIl Measures of Effectiveness:

Conduct fi)llow-up course evaluation six months aller training to determine from staffs vantage whether they are routinely identifying and forwarding incipient issues of public concern.

Cost:

(I FTE) 12 of 26 06/02/98 15:11:38

l Public Communications initiatives http://www.ntc. gov /OPA/cccrpt.htm TIIE PUBLIC INVOLVEMENT PROCESS The Committee considered several sources ofinformation in developing its recommendations for improving public involvement. They included the experience of other agencies, evolving trends in public involvement programs, the report of the Presidential / Congressional Commission on Risk Assessment and Risk Management, and comments from NRC office directors and regional administrators, as well as from external stakeholder.

The Department of Energy's Public Participation Policy has as its underlying premise that genuine public involvement leads to better, more informed decisions. DOE's goals, similar to those expressed in the NRC's Strategic Plan, are to actively seek and consider public views and concerns in making agency decisions; to ensure the public is informed in a timely manner in order to have an opportunity to fully participate in the decision-making process; and to incorporate credible, effective public participation in the agency's planning and decisions. DOE's policy establishes 15 core values, including accessibility, accountability, accuracy, honesty, respect, fairness, responsiveness and scientific credibility. Such values and goals have been made part of the annual performance evaluation of DOE managers.

In an effort to determine what makes for a successful public participation program, DOE has done several surveys and studies. It concludes that to be effective, program planners must assess whether DOE's decision-making process provides for full and active stakeholder participation; whether the decision-making progress is seen by stakeholder as legitimate; whether the public has trust and confidence in DOE or a specific affected DOE facility; whether key agency decisions are improved by public participation; and whether it serves to help accomplish the agency's mission.

DOE has a well-developed public participation training program for its senior managers and pertinent staff. The Environmental Protection Agency requires those involved in Superfund site-specific projects to take specialized training. The Department of Transportation has a mandatory course in public involvement techniques for its senior decision-makers.

The Commission on Risk Assessment emphasized that stakeholder involvement is critical in making and implementing " sound, cost-effective, informed management decisions." It held that decisions made in collaboration with interested stakeholder are more effective and durable and that such stakeholder bring to the discussion important information, knowledge, expertise and insights. Collaborative efforts, the Commission fbund, help to bridge gaps in understanding, values and perceptions and provide essential help " enabling all parties to make informed decisions about reducing risks."

Significantly, the Commission stressed that " collaboration does not require consensus, but it does require that all parties listen to, consider and respect each other's opinions, ideas and contributions."

i The Commission recommended that such stakeholder participation be made part of a regulatory agency's {

mission by: l 4

o Creating an office that supports stakeholder processes; I o Seeking guidance from experts in the field; o Training risk managers to participate in such stakeholder involvement I

efforts; o Building on the experience of other agencies and community partnerships; o Emphasizing that such activity is of necessity a teaming process.

The NRC's recent public involvement initiatives have demonstrated growth and maturity. We have been moving away from allowing peoplejust to be heard at the end of the process towards involving them 13 of 26 06/02/98 iS:t 1:38

Public Communications Initiatives http://www.nrc. gov /OPA/cccrpt.htm early enough to have some impact on decisions; away from exclusively soliciting comments from a broad, undifferentiated public towards programs targeted at the most affected and interested groups; away from huge public hearings toward advisory groups, workshops, working groups and one-on-one interviews.

There has been a dramatic change in the NRC's public involvement process over the last several years.

Beginning with the rulernaking on the radiological criteria for decommissioning in 1993, the Commission has attempted to provide for the early and active involvement of the public in its decision making process, including the broad spectrum of stakeholder affected by the proposed regulatory action. In addition to the radiological criteria rulemaking, the Commission has held numerous public workshops on other generic regulatory and policy issues, such as the regulation of fuel cycle facilities, the Agreement State compatibility policy, the regulation of generally licensed radioactive source and devices, and the development of the Strateg.c Plan. The NRC has also established "public ii. formation roundtables" at selected decommissioning sites to involve the local communities more closely in that process. These public involvement efforts have not only provided the Commission with valuable mformation for use in its decision making process, but also have enhanced the credibility of the openness of the Commission's regulatory process. In addition, the NRC has an "open meetings" policy to give public access to staff meetings with heensees.

The Commission also has undertaken other novel public involvement projects designed to use state-of-the-art computer technology to maximize communications between the NRC and the public.

One is the RuleNet project which represents a step toward combining two public participation approaches: early public comment and interaction on enhanced participatory rulemaking using Internet.

It permits interested parties to communicate with one another and with the NRC with the aim of further defining issues, eliminating possible misunderstandings and finding areas of common ground. In addition, the agency has established other public involvement procedures, such as its "open meetings" policy, and various office procedures on environmentaljustice in implementing the National Environmental Protection Act.

Despite NRC cfforts to improve the public involvement process, it was clear from the December focus group meeting that some public interest and community groups are distrustful of the NRC's regulatory process. Concerns were expressed that the NRC staff seemed more interested in helping licensees lower operating costs and keeping plants "on line" than addressing what some critics insist are more pressing health and safety issues. One repeated criticism focused on the 2.206 petition process where it was asserted that petitions were often dismissed for " legalistic" reasons with little effort to consult with petitioners to see whether there might be some merit in the underlying concern. Another complaint was of efforts to diminish or even eliminate public involvement in such things as spent fuel cask certification and reactor decommissioning.

The fundamental goal of public involvement activities is to increase opponunities for the public to influence agency decisions. Not that all stakeholder can or should be pleased at all times by all NRC decisions. But, ideally. the NRC should strive for a process wherein even those who disagree with a decision will feel the process was fair, open, and that time was taken to solicit the views of all interested parties. This is a goal the Committee endorses and offers its recommendations with that objective in mind.

The CCC believes the NRC must be scrupulous in examining new rulemaking and policy proposals to ensure that meaningful public participation opportunities are not eliminated from the present regulatory framework in the name of efliciency. The reduction, elimination or disregard for public participation in one area of major public concern could undermine the credibility gained by considerable effort to introduce effective public isolvement in other areas.

Issue: Early identification of public involvement needs in some cases public involvement considerations are not thought of until late in the decision making process. This may leave insufficient time for careful planning or the budgeting of the necessary resources. Consequently the public involvement process at best, is not used to the NRC's advantage, or 14 of 26 06/02/98 15:11:38

Public Communications Initiatives http://www.nrc. gov /OPA/cccrpt.htm at worst, imorly designed and implemented. Thoughtful, advance planning is necessary to ensure the proper fonnat is developed; that suitable facil; ties are booked; that stakeholder are adequately represented; that sufficient, timely notice has been provided; and that understandable background material has been developed and distributed early.

Goal:

To identify public involvement needs early enough to ensure effective planning and implementation.

Recommendations /Milestom:

II AI o Greater attention should be given to public involvement needs in drawing up Rulemaking Plans. And when it is determined to provide such expanded effort, the plan should provide more detail on planning time and resources necessary to conduct the effort effectively. (0.25 FTE annually) l FOUNDATION PATilj II A2 o The EDO's Feb. 12,1996, memorandum (codified in Management Directive 3.5, "Public Attendance at Certain Meetings Involving the NRC Staff") established criteria for when a public meeting may be appropriate for a specific facility or site. It emphasized the benefit of considering this option very early m the process. The Management Directive should be revised to require all division directors to periodically assess whether a public meeting is needed to focus on particular issues at a specific facility. (0.25 FTE annually) [ENIIANCED PATil]

o Actions or events which may necessitate additional public involvement efforts should be routinely explored at the weekly EDO staff meetings.

(negligible FTE) [ FOUNDATION PATilj Measures of Effectiveness:

o Assess Rulemaking Plans to determine whether the criteria for special public involvement needs had been ap plied, and whether the information provided in the Plan relative to special public involvement needs had J ed to better planning and implementation of the public involvement process.

o Track the number ofinstances where a " crisis" atmosphere would likely not have emerged had the agency anticipated the need for special public involvement processes.

o Track the instances in which significant public criticism directed at the Commission would have been less likely had a sr .al public involvement process been utilized.

o Evaluate periodic assessments under Management Directive 3.5.

Costs:

FTE costs associated with the above actions are provided in parentheses after each Milestone.

Issue: Effective design and implementation of public involvement proecsses l

Inadequate implementation involves more than simply a lack of sufficient time and resources. For example, the appropriate stakeholder interests may not be represented in the process, adequate notice may not be provided; meeting locations and facilities may be inappropriate; proper background material ,

may be lacking; and meeting agendas may be poorly structured. Fmally, well-designed and properly j I

1 15 of 26 06/02/98 15:11:38 l

Public Communic:tions Initiahves http //www.nre. gov /OPA/ccerpt.htm implemented public involvement processes are not uniform across the agency.

Goal:

To ensure that the public involvement processes are effectively and efficiently planned and implemented uniformly throughout the NRC.

Recommendations / Milestones:

IIH1 o Major initiatives, such as a proposed reactor decommissioning, should require preparation of a public involvement plan. Essential elements would include the objectives of public involvement; the need to identify interested stakeholder; developing a game plan on whether to include broad public meetings, workshops, meetings with local officials and journalists; and consideration of special arrangements. The plan should be coordinated among appropriate offices and approved by senior management for both policy and resource reasons. Any Rulemaking plans which identified the need for special public involvement and special public meetings identified as part of the periodic assessment discussed above would need to address the same agenda ofissues. [ FOUNDATION PATH]

IIH2 o Develop a Public Involvement Handbook for the stafT for use both in a new training course (discussed below) and as a handy reference in implementing public involvement activities. The handbook should include basic conceptual issues such as designing a particular public involvement plan to the agency's specific objectives, and "how to" guidance on booking an appropriate meeting place, issuing public notices, and insuring the availability and advance distribution on background material.

The cost would be a necessary part of the cost of developing the training course. In addition, an attempt will be made to harmonize all of the individual office procedures related to public involvement.

[ FOUNDATION PATH]

IIH3 o Compile specialized lists of stakeholder contacts with interest in various NRC regulatory activities, categorized by types ofinterests (such as citizen groups concerned about decommissioning or storage of spent fuel) and by types of regulatory actions (such as oversight over medical uses of radionuclides, fuel cycle facilities, DOE installations). [ ENHANCED PATH]

IIH4 o Apply uniformly in all regions public involvement initiatives that have proven successful in one.

For example, Region 11 invites local and state officials to meetings at which SALP reports are discussed with licensees. After the public meeting is concluded, the Regional Administrator meets privately with these officials to address any questions or concerns they may have. Such good practices should be sought out and replicated. [ ENHANCED PATH]

Measures of Effectiveness:

o Conduct periodic surveys of project managers as to the usefulness of the handbook.

o Make periodic assessment by the Special Counsel for Liaison on whether there is a reduced need to assist staffin the design and implementation of public involvement activities.

o Track major problems that might arise and make course corrections, as appropriate.

o Ensure that stakeholder who complain they have been left off a particular invitation list are added to appropriate lists.

l Costs:

The expense of developing a handbook would be subsumed under the cost of developing a public involvement training course tailored to NRC's needs and responsibilities. (0.25 FfEs to compile stakeholder lists and 0.01 FTEs to update annually) 16 cf 26 06/02/98 15:11:38

~

Public Communications Initiatives h ttp://www.nrc.go v/OPA/cccrpt.htm Issue: Increased staff understanding of public involvement process l At the December focus group meeting, some stakeholder complained that the demeanor of certain staff at public meetings was counterproductive to what the NRC was trying to accomplish, because of insensitivity to public concems, speaking largely in difficult to comprehend technical terms, or exhibiting impatience with questions or even arrogance. This was certainly not a universal condemnation. Other senior NRC staff, they said, conducted themselves in an exemplary manner. The point is there is wide variance in the staff on how to conduct themselves at public meetings.

Goal: To ensure the staffis aware of the need for and value of public involvement in the regulatory process and that it is knowledgeable about planning and carrying out such responsibilities.

Recommendations / Milestones:

IICI o The Commission should cstablish an NRC-specific training course on the objectives, design, and implementation of public involvement processes. The course would explore the benefits of public involvement and attempt to provide an understanding of what motivates particular stakeholder interests, including the general public. IIands-on techniques would be used to prepare staff for addressing a number of situations they might encounter in a public meeting. The course would also cover the considerations that must be addressed in the design and implementation of an effective public involvement process. Several agencies, including DOE, DOT, and EPA routinely offer this type of training (tailored to their individual missions). As noted in the Presidential / Congressional Commission risk report, one of the primary ways to ensure that stakeholder involvement is made part of the agency's regulatory mission is by " training risk managers to take part in stakeholder involvement efforts." The Committee would note that a specialized pilot course for NRC staff on facilitating external stakeholder meetings will be offered in June. [ FOUNDATION PATil]

Measures of Effectiveness:

o Course evaluations.

o Conduct periodic surveys of students who have taken the course to assess the extent to which they have applied the knowledge provided in the course.

Costs:

The approximate cost Mdeveloping the course material and providing instructional services for the initial pilot would be approximately 565,000. This would include the development of a standardized l

Instructor's Guide and Participant Workbook that would enable the course to be routinely replicated for future offerings. Each session would cost approximately $5,000. A outline for the course is attached.

(0.02 FTE)

Issue: Overall Performance Measures Although the Strategic Plan contains a broad goal touching on public confidence--i.e., to " provide the public, those (they) regulate, and other stakeholder in the national community, with clear and accurate mformation about, and a meaningful role in, NRC's regulatory program..."--the Committee suggests the Commission consider more specific objectives. These would help the staff develop public involvement programs and serve as a baseline against which progress could be measured.

Goal:

To ensure the NRC's public involvement efforts provide value and credibility to the decision making process.

Recommendations / Milestones:

17 of 26 06/02/98 15:11:38

http://www.nrc. gov /OPA/ccerpt.htm Public Communications Initiatives .

IIDI o Incorporate the following objectives into the Strategic Plan:

[ FOUNDATION PATHJ

1) The public has a right to have a say in decisions about NRC actions that affect them.

2) Public involvement should provide confidence that public opinions and concerns are seriously considered in the decision-making process.

3) The NRC should actively seek out and facilitate meaningful involvement of those potentially affected by NRC actions.

4) Participants in such meetings should be provided useful background material in advance to facilitate their meaningful involvement.

IID2 o Initiate a 3rocurement with a firm specializing in survey design and public participation to develop and concuct a survey of active NRC stakeholder. [ COMPREHENSIVE PATHj llD3 o Revise Management Directive 6.3,"The Rulemaking Process," to require all rulemaking plans specifically address timely public involvement in the decision-making process. [ ENHANCED PATHj IID4 o Annual public meeting with stakeholder. [ ENHANCED PATHj The survey would be designed to clarify NRC stakeholder views on the credibility of the agency; gauge awareness of the breadth of NRC public involvement activities; and solicit suggestions for improving how the NRC interacts with stakeholder groups. Stakeholder include environmental and other public interest groups, private citizens living near NRC licensed facilities or activities, private sector i companies, officials of other federal agencies, state and local governments, and representatives of Native

! Americans.

Measures of' Effectiveness:

o An evaluation survey should be prepared and administered for every major public involvement process the Commission conducts, o The NRC should convene a periodic meetmg, perhaps annually, with a small group of the representatives of the various categories of stakeholder affected by Commission regulatory actions. The purpose would be to review the status of the Commission's public involvement etion6, splying the performance measures to the attributes, and making recommendations for improvement.

Costs:

The development and implementation of the survey would cost an estimated $40,000. This assumes inte views with about 200 stakeholder representatives. NRC officials would help design the survey to ensare it captures all critical baseline infonnation, a sampling plan that ensures the data will be representatives of key stakeholder groups, and a data analysis plan that meets agency program needs.

Any follow-up trackmg surveys would cost an estimated $20,000. (0.01 FTE to help develop survey format; periodic meetings with stakeholder would require 0.3 FTE and about $5,000 annually)

RESPONSIVENESS TO PUBLIC INQUIRIES The NRC recognizes the need to provide timely and accurate responses to inquiries from members of Congress, the public and other stakeholder. They have every right to prompt, courteous and responsive answers. To be frank, however, some of tiie busy staff regard answering the mail as a distraction from other important duties.

Over the years, the agency has placed great emphasis on answering correspondence expeditiously. We 18 of 26 06/02/98 15:11:38

Public communications initiatives http://www.nrc. gov /OPA/cccrpt.htm have improved in this area, and based on a staff survey a few years ago, the timeliness of NRC's responses compares favorably with several other comparable government agencies. This is particularly true for correspondence tracked by the offices of the Secretary to the Commission (SECY) and of the .

Executive Director for Operations (EDO).

Ilowever, for a variety of reasons, roughly 25 percer,t of formal correspondence cannot be answered as quickly as the rest. This is an issue the CCC addressed to see what improvements were possible.

Additionally, the use of e-mails by NRC stakeholder to pose questions, request documents or state positions is rising rapidly. For example, while OPA received more than 400 such e-mails in 1996, the total more than tripled in 1997, to over 1300. Other offices throughout the NRC are also experiencing a significant increase, and the volume is bound to continue to mount. While many staff tend to think of e-mail requests as similar to informal phone inquiries, in fact, they have different standing. They are subject to being accessed under the Freedom ofInformation Act and cou!d be said to represent official NRC positions,just as do formal letters.

The Committee has identified the following issues in order to further improve our efforts in this area:

Issue:

Some stakeholder have complained they have had to wait months for responses to their letters of inquiry.

Goal:

Ensure that all correspondence is handled in as timely a manner as possible. A greater effort is needed to handle tiie " outliers" -- correspondence where it is not possible to answer in the established time frames.

In those cases, the NRC should contact the writer to explain that it will take some time to respond in detail, briefly explain why, and try to provide some idea of when a response can be expected.

I Recommendations / Milestones:

lil Al o Ensure there is f or mal track ng for all correspondence, where necessary beyond what already exists for the offices of the Secretary and of the Executive Director. Some correspondence could be tracked at a management level of office director or below.(Spring 1998) [COMPREllENSIVE PATil]

III A2 o Require that in the case of Commission correspondence on substantive issut , vhen a significant delay is deemed necessary, that the party who wrote the letter cfinquiry should be informed by phone, mail or e-mail of a delay, given an explanation, and provided a best estimate on when to expect a response. Management Directive 3.57 " Principal Correspondence" should be amended to include this requirement, including a mechanism for requesting extensions when necessary. (3 months)

[COMPREllENSIVE PATil]

Measure of Effectiveness:

o Monitor and evaluate letters and calls of complaint. The number should decline.

Costs:

(Negligible)

Issue:

On the one hand, e-mails should be encourageo as they represent a simple, quick way for members of the public and other stakeholder to communicate with the NRC. But the agency lacks a comprehensive policy on how to deal with them. E-mails frequently don't identify the affiliation of the writer, provide a mailing address or phone number, or define the issue as crisply as in many formal letters.

I9 of 26 06/02/98 15:11:38

Public Communications Initi:tives http://www.nrc. gov /OPA/cccrpt.htm Goal:

Create an agency-wide policy on how to deal with this budding form of communication.

Recommendations / Milestones:

liiB1 o Establish a screening process to apply when e-mails first come in. If the request is simple and scaightforward and the recipient can answer with factual, publicly available information, he or she should do so promptly. Ifit raises what amounts to an allegation, it should be channeled into the formal allegation process. Ifit requires a formal, agency response, it should be so treated.

[COMPREIIENSIVE PATII]

IIIB2 o If an e-mail is treated as an allegation or tabbed for a written agency response, the recipient should so inform the sender. Also, a mailing address should be requested if one is not provided and, if necessary, a substantive clarification should be sought at that time. [COMPRElIENSIVE PATH]

IIIB3 o Inform other appropriate NRC + .., of the communication - for instance, OCA if the requester is a Congressional staffer, OPA if the questions come from a reporter. [ COMPREHENSIVE PATII]

IIIB4 o If an e-mail comes from a student wanting background information for a school paper, or from someone interested in general information, it could be forwarded to OPA for a response.

[COMPREIIENSIVE PATII]

IIIB5 o Management Directive 3.57 should be revised to incorporate the Commission's policy decisions on the handling of e-mails. The new policy could be announced in a memorandum from the EDO to the staff. [ COMPREHENSIVE PATill Effectiveness Measures:

o Each office should periodically review its files to check on the substance and timeliness of responses and provide an annual report to SECY or the EDO.

o Complaints should be monitored and evaluated, as in the case of responses to mailed inquiries.

Costs:

(0.1FTE to modify management directive and track c-mail responses)

PUBLIC ACCESS TO INFORMATION From the inception of the agency, the practice at the NRC has been ;o provide the public with as much information as possible, on the premise that since protecting public health and safety is our primary mission, by providing full scrutiny of our activities public trust and confidence should be bolstered.

The principal agency guidance is provided in 10 CFR 2.790 which directs that information provided to or received from applicants and licensees, which does not fall within nine exempt categories, is to be made available for public inspection and copying. Further guidance is provided in Management Directive 3.4. In addition, the Atomic Energy Act, as amended, mandates that the NRC make available the results ofits research, while the Freedom ofInformation Act makes clear that rules, policies and staff

. manuals are to be made public.

i An overlapping array of means has emerged over the years for disseminating such information. The NRC uses direct mailing and separate faxing of press releases, speeches and other documents to lists of stakeholder; it places such documents in the main Public Document Itoom in Washington, D.C., and in 86 local Public Document Rooms in the vicinity of nuclear power plants and certain other facilities; a I

20 of26 06/02/98 15:11:38 1

Public C, communications initiatives http://www.nrc. gov /OPA/cccrpt.htm variety of NRC documents are sold by the Government Printing Office and by the National Technical Information Service; a wide array of documents are posted on the NRC website on the Internet; and a variety ofinformation, includin;; the schedule of public meetings, is provided on special electronic bulletin boards with dial-in access.

One result of this overlap is that some stakeholder get multiple access to NRC information. As use of the Internet continues to expand, and as access to computers in homes, schools, offices and public libraries proliferates, a larger number of stakeholder will have quick, easy access to NRC information.

The NRC's commitment to move to an advanced electronic document management systems (ADAMS) in 1999 will further enhance the ready availability of agency documents.

Potentially significant cost savings may be achieved by eliminating duplication and determining what of the public document room operation continues to make sense after the advent of ADAMS.

At a time when we're reviewing how best to disseminate information, it makes sense also to review what is being disseminated, in light of changes brought on by deregulation. For example, both the Nuclear Energy Institute and the Union of Concerned Scientists--organizations that are not often on the same page--have criticized the daily plant status reports which include fluctuating power levels and projected restart dates and are placed on the NRC's Internet website. NEI complains such economic and production data is not safety-rdated and could make it more costly for nuclear power plants to buy replacement power on the spot market, raising prices both for licensees and consumers. UCS says detailed monthly rather than daily reviews should be sufficient to provide early warnings of potential problems. NRC rules do not require licensees to provide such information. Ir' the era when electric rates were fixed by local public utility commissions, publication of such information did not impact on the cost of operations; however, in a deregulated environment when market forces determine the price of electricity, impact could be significant.

The NRC's concern, of course, is safe operations, not profitability ofits licensees. But do we want to continue to request and publish information which in the new economic environment has the unintended effect of burdening licensee resources which otherwise would be available for maintaining safe plant and equipment? J Issue:

Given developments in information technology and the planned deployment of ADAMS, is it time to update the agency's strategy for providing information to the public?

Goal:

To clearly define an updated agency strategy for making information accessible to the public. It should take into consideration the need for an easy way to locate desired information, coupled with the need for the NRC to provide timely access. Given the advances in information technology and the planned implementation of ADAMS, the update strategy should address the future need for and role of the main Public Document Room and of the 86 local public document rooms. The review, to be conducted by the CIO, should address to what extent duplicate mechanisms for making documents available continue to i bejustified. And, with the burgeoning use ofInternet and with the projected capability of ADAMS to l make NRC documents accessible in virtually every public library in the country , the value of the local PDRs should be reexamined. There is a significant potential cost saving here.

Recommendation / Milestone:

IVA1 o Oct. 30,1999: CIO should submit an updated strategy for the Commission to consider.

[ENIIANCED PATil]

Effectiveness Measures:

Perform periodic reviews to ensure that information is being made quickly and easily access'ble in 21 of 26 06/02/98 15:11:38 l . . . _ _

Public Communic:tions Initiatives http://www.nrc. gov /OPA/ccerpt.htm accordance with the policy established by the Commission. Invite users of the NRC's website on the Internet to communicate whether desired infomiation is being made readily available in a timely manner.

Costs:

(1.5 FTE to develop the updated strategy)

Issue:

Given the sea-change in the electric industry, with deregulation and restructuring, should the NRC l reevaluate the continuing need for non-safety related information and what is included in preliminary notification reports and plant status reports?

I Goal:

Have the EDO conduct a review to determine what is required in the way of safety-related licensee reporting and what developments at facilities the staff chooses to include in plant status reports, j Preliminary Notification of Event or Unusual Occurrence reports and other such informational j documents. At the same time, the review should consider whether information not now required and )

made public, ought to be.

Recommendation / Milestone: {

IVH1 o Review the information required oflicensees by the program offices to determine what is required for safety oversight in plant status reports, PNOs and other reports (6 months)

[ FOUNDATION PATHj Effectiveness Measure:

o Periodically appraise impact of revised informational reports to assure they continue to include everything needed to effectively regulate safety at licensed facilities.

Costs:

(0.4 FTE)

PUBLIC OUTREACH The NRC recognizes the need to foster greater public confidence and trust in the way in which the agency conducts its business. The Chernobyl disaster in 1986, together with publicity over lesser events at US and other foreign nuclear facilities, have tended to undermine public confidence in nuclear technology generally. The NRC has been faulted for acts of omission and commission in a few high pro"ile situations, as for example in the case of the Millstone power plants. Furthermore, we live in an age when reassuring statements from any govemment agency are viewed often with skepticism. Finally, some NRC licensees believe the agency either over-regulates or over- reacts to isolated events. In this atmosphere, the NRC has a responsibility to reach out to its various stakeholder to establish trust, address their concerns and allay their fears.

Although the NRC does not promote tSe use of nuclear power or materials, it is appropriate to pursue a more proactive program of encouraging a dialogue with all its stakeholder, and particularly with members of the general public. Ehe responsibilities of the NRC, and the boundaries of its regulatory oversight, are not widely understood by the general public. Thus the agency ought to make a more determined effort to provide information to those who seek it. This responsibility includes developing an understanding of radiation, what it is and what it does, and the uses of NRC-regulated radiation, sufficient to promote public understanding of 22 of 26 06/02/98 15:11:38 m........_. . . . . . . . . . . . . . . . . . . . . _ _ _ . . . . . . . . . . . < . . . . . . . . . . . ..

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Public Communications Initiatives http://www.nrc. gov /OPA/cccrpt.htm the responsibilities of the agency and how they are discharged. The NRC currently engages in some public outreach and education; outstanding examples are the teacher training workshops and the school volunteer program. Such efforts should be expanded.

Another area where the NRC has undertaken an extensive initiative to foster understanding and strong community relations is in incident response. Over the last seven years, the Office for Analysis and Evaluation of Operational Data (AEOD) has conducted a highly successful State Outreach program, bringing together states, licensees and other federal agencies in exercises and interactive dialogue on the incident response program. The objective is to promote the planning, procedures and working relationships that will be crucial in the event of

]~ a serious accident. AEOD's goalis to interact with each utility and each state having a nuclear power plant within its 10 mile emergency planning zone on a five year cycle.

In addition to existing initiatives, the Committee identified two issues where improvements could contribute to a better public understanding of the roles and responsibilities of the NRC. A discussion of each issue is provided below.

Issue:

There is a perceived fine line between promotion and education and their relationship to regulation. Some of the agency's technical staff are hesitant to provide information to or answer questions from the public, beyond the specific individual regulatory confines of their jobs, in order to avoid the appearance of engaging in promotion.

Goal:

Facilitate open dialogue between the agency and the public without creating the perception of promoting the use of nuclear power and nuclear materials.

Recommendations / Milestones:

val o Clearly delineate NRC's educational responsibility and limits through the development of standard presentations and infonnational publications maintained at NRC headquarters. (10 months to develop) [COMPREllENSIVE PATill VA2 o Establish a central audiovisual library at NRC Headquarters to serve the entire agency, including the field offices, in implementing a more proactive outreach program. Develop and maintain standardized presentations and informational publications and other associated materials w include photographs, slides, view graphs, and diagrams of nuclear power plants, fuel facilities, major materials facilities, and material devices and uses. Presentation topics should include: what we do and do not regulate; licensing and enforcement; radiation basics; and response to emergencies. (12 months)

[ENIIANCED PATill VA3 o Continue current efforts in the development of standardized publications and presentations. OPA has ,roduced a number ofinformational brochures on general and specific uses of radiation and proc uced an updated informational video on the NRC. These efforts should be updated and expanded, and attempts should be made to make the public more aware of the availability of such material, perhaps by notices on the NRC website. (Ongoing) [ENIIANCED PATIIj VA4 o Expand the award-winning student corner of the website. (Ongoing)

[COMPREllENSIVE PATII]

VA5 o Establish a Speaker's Bureau to arrange presentations to local groups such as the League of Women Voters, PTAs, Rotary and Lions Clubs, etc. Use materials contained in the audio-visual library.

(12 months) [ENIIANCED PATil] {

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Public Communications Initiatives http://www.nrc. gov /OPA/cccrpt.htm VA6 o Provide early and substantial communications with the public, particularly local government officials and citizen groups, at "special interest" sites, such as fuel facilities, decommissioning sites, reactors and waste disposal sites. This ought to include increased involvement by NRC resident inspectors or program managers in developing contacts with and answering questions oflocal community leaders. (ongoing) [ENIIANCED PATil]

VA*/ o Encourage use of audio-visual materials: during media briefings on events; in public announcements and meetings; under emergency situations; and during other appropriate briefings, training, and speaking opportunities. These presentations should be proactive and responsive to issues about which there is active or incipient public concern. One such example is the concern of the public over the transport of spent fuel, described by some critics as " mobile Chernobyls." The expectation is that public opposition will mount with increased transportation of spent fuel to an interim or permanent storage site. An informational transportation video, which provides a balanced, factual discussion of the precautions provided during transport, the high standards required of transpart containers, and worldwide experience in the transpoit of radioactive material, would help address public questions and concerns. (Video projected and budgeted for FY 2000) [ENIIANCED PATHj l

Measures of Effectiveness: l l o Collect data on u. age of prepared presentations from staff.

Identify and provide recognition to offices and regions that have prepared effective new materials; evaluate office-wide and regional commitment to implementation of proactive public outreach programs.

o Continue to analyze presentation data to determine whether information remains current; e.g., establish a review group to review new presentations and evaluate existing materials.

o Monitor feedback from meetings both formally, as in meeting evaluation sheets, and informally, through post-meeting discussions with participants; review media coverage of NRC activities to determine whether NRC position has been clearly articulated.

o Evaluate public responsiveness to availability of NRC's Speaker's Bureau.

Costs:

o (Establishing audio-visual library,0.02 FTE and $15,000 for contractor support in scanning 2,000 images onto special computer discs and to developand organize catalogfue of presentation titles and descriptions for reference.) The catalogue would also be incorporated into the NRC's Internal Website.

o Following initial set up, the library would be managed by the audiovisual staff, with help from OPA and the technical offices, in collecting and developing material for agency-wide distribution and use.

Costs for maintaining an audiovisual library, once established, should be minimal; copies of files would be provided to any NRC staff requesting them.

o Estimated cost ofinitiating Speakers' Bureau: 0.2 FTE. Transportation costs would be additional.

o Estimate for producing a Transportation Video: 5100,000 for development of a 20-30 minute video (already budgeted) and 0.03 FTE for OPA for two years.

Issue:

Some NRC technical staff are hesitant to interact with the public due to unfamiliarity with agency issues and responsibilities outside the scope of their immediate responsibilities.

Goal:

Ensure technical stafris fainiliar with all aspects of agency operations 24 of 26 06/02/98 15:11:38

Public Communications Initiatives http://www.nrc. gov /OPA/cccrpt.htm Recommendation / Milestone:

VH1 o Encourage initial and refresher training for NRC technical staff on "NRC: What It is and What It Does." Also, encourage staff to read the NRC Annual Report and Information Digest. (Yellow Announcement to all staff-1 month) [COMPREIIENSIVE PATIIl Measure of Effectiveness:

o Review training data to determine levels of attendance at regularly scheduled "NRC: What It is and What it Does" courses. Develop course evaluation to include question related to participants' confidence in discussing NRC responsibilities that are outside the participants' routine work-related activities.

Costs:

o The existing "NRC: What It Is and What it Does" course is conducted in- house. To run the course a second time cach would add $5,000 for contractor support.

SUMMARY

In its choice ofissues to highlight and potential solutions to advance, the Committee spent considerable time deciding what to include and exclude in making its recommendations. It is the consideredjudgment j of the Committee that the objectives 1 stated by the Commission in the SRM of March 14,1997, would be well served by adopting the entire  ;

plan.

But we recognize that in the current climate of shrinking resources, the Commission will want to make choices. Thus we have categorized each recommendation under one of three headings: Foundation Path for those actions believed in need of earliest implementation; Enhanced Path for those elements thought  !

to be important but not as urgent; and Comprehensive Path to embrace the remainder of the proposals.

]

We further believe the Commission was absolutely correct in determining that improvements in the quality, clarity and credibility of the NRC's communications with the general public, that anticipating and addressing public concerns earlier, and that involving all our stakeholder as early as possible in the formulation of the NRC's evolving rules and practices together constitute an imperative of transcending importance if the NRC is to bolster oublic confidence that the agency truly regards its regulatory mission

~

of protecting public health and safety as preeminent.

In addition, the Committee feels it similarly imperative that any disparity between stated policies and actual actions be confronte/ and, insofar as possible, eliminated.

With all respect, in closing, we would quote once again from the pertinent study by Ng and Hamby, cited earlier, to wit:

"To have a successful risk communication program, management support must be strong.

Management...must be willing to commit resources; money and personnel, incentives and training.

Management must be committed to the idea that informing and involving the public are legitimate activities. This commitment has to be communicated to all staff who may have the opportunity to interact with the public. Communicating with the public is part of everyone's job and not just the job of the spokesperson."

Attachments:

Direction Settina Isssue-14 l Staff Requirements Memorandum (COMSECY-96-063)-- March 14,1997 '

Cross Section of Stakeholder Focus Group 25 cf 26 06/02/98 15:11:38 J

Public Communiccions initiatives http://www.nrc. gov /OPA/cccrpt.htm 4

1

j. Curriculum for Proposed Course on Public br>'lvment Process CROSS SECTION OF STAKEHOLDER: FOCUS GROUP December 11,1997 -

Don Beck, The Gallup Organization Paul M. Blanch, Northeast Utilities consultant Pat Bryant, Nuclear Energy Institute -

Paul Choiniere, New London (Conn.) Day Scott Denman, Safe Energy Communications Council Ralph DeSantis, GPU Nuclear Corporation Dan Greenberg, science writer Paul Gunter, Nuclear Information and Resource Service David A. Lochbaum, Union of Concerned Scientists Judith Johnsrud, Environmental Coalition on Nuclear Power Pamela Newman-Barnett, Energy Daily David Nichols, Society af Nuclear Medicine James Norvelle, Virginia Electric & Power Company Jim Riccio, Critical Mass Energy Project, Public Citizen David Stellfox, McGraw-Ilill Publications Terry Strong, Washington State Department of11ealth I

26cf26 06/02/98 15:11:39

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