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{{#Wiki_filter:Efforts to Improve Rulemaking Tracking and ReportingU.S. Nuclear Regulatory Commission Public Meeting March 11, 2016Comments of Scott D. PortzlineSecurity Consultant to Three Mile Island AlertHarrisburg PA The NRC is to be commended for their effort to assist the public and stakeholders in rulemaking by taking advantage of modern tools to access the docketed records in a timely manner.The proposed improvements would be consistent with the Commission's objectives as stated by the NRC in "Public Participation in NRC's Rulemaking Process."June 12, 2008 2
{{#Wiki_filter:Efforts to Improve Rulemaking Tracking and Reporting U.S. Nuclear Regulatory Commission Public Meeting March 11, 2016 Comments of Scott D. Portzline Security Consultant to Three Mile Island Alert Harrisburg PA
in communication and decision makingoFacilitates public understanding oProvides an opportunity for affected people to participate in the processoIncreases credibilityand cooperationNRC'S slides: "Public Participation in NRC's Rulemaking Process"June 12, 2008 3  
* The NRC is to be commended for their effort to assist the public and stakeholders in rulemaking by taking advantage of modern tools to access the docketed records in a timely manner.
"The NRC rulemaking process is a matureprocess and we welcome suggestions on how to improve it."NRC'S slides: "Public Participation in NRC's Rulemaking Process"June 12, 2008 4
* The proposed improvements would be consistent with the Commissions objectives as stated by the NRC in Public Participation in NRCs Rulemaking Process.
This is what happened to our petition for rulemaking:September 12, 2001
June 12, 2008 2
--TMI Alert filed a petition for rulemaking which would require guards to be posted at the entrances of "owner controlled areas" at nuclear power plants. The timing of the filing was coincidental to the 9
 
-11 attacks and had been planned for six weeks prior to our filing.Petition for Rulemaking PRM 115 EXCESSIVE DELAYSThe NRC Repeatedly rescheduled the rulemaking.Offered no explanation for the rescheduling.Showed no accountability when challenged.FAILED TO CORRESPONDOn 13 separate occasions when the NRC rescheduled, we heard nothing.The NRC did not inform us of management changes as to who was handling our petition.INACCURATE INFORMATIONThe NRC incorrectly listed our petition as "completed" for several weeks on its web site until we requested the NRC to correct it.Meeting transcripts mistakenly stated that we were dis-cussing "entrance cards" instead of "entrance guards."
in communication and decision making o Facilitates public understanding o Provides an opportunity for affected people to participate in the process o Increases credibility and cooperation NRCS slides: Public Participation in NRCs Rulemaking Process June 12, 2008 3
* FULL REPORT onhow the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008 http://tinyurl.com/qj2mn3d 6
 
TRIED TO DENY US A SEAT AT THE RULEMAKING TABLEThe NRC did not want to give me the opportunity to speak during the meeting.Our petition and background data was not in the room or on the document handout table.When we complained, the NRC made no attempts to correct the absence of our petition or background information.VANISHING ACTOur petition for rulemaking had disappeared, not only from the meeting, but from the process.There was no mention of our petition in the Power Reactor Security Requirements rulemaking, the rulemaking into which our petition had been supposedly merged.MISLED CONGRESS* NRC letters to congressional leaders stated that entrance guards are "already being considered in the ongoing Power Reactor Security Requirements rulemaking."NRC hid the fact that their staff had decided that entrance guards are not needed and that the "entrance guard petition" had been denied de facto.
The NRC rulemaking process is a mature process and we welcome suggestions on how to improve it.
* July 29, 2008 see ADAMS ML081220609 7
NRCS slides: Public Participation in NRCs Rulemaking Process June 12, 2008 4
SURPRISE ENDINGThe NRC failed to inform us when the petition was closed. NRC staff claimed they could not find my phone number or address. I learned that the petition was closed from the Union of Concerned Scientists.NO DECISIONThe NRC's correspondence only indicated that the petition was "considered resolved and closed."As per guidelines, petitions are decided with a letter clearly indicating:BLATANT DISREGARDActually, there were more than 40 occurrences when the NRC failed to adhere to its principles of openness and clarity, and to follow its procedural guidelines while handling the rulemaking.acceptance,partial acceptance,or denial.
 
8 "Public confidence in the NRC is eroded each time we fail to resolve issues in a timely, clear, and transparent manner."NRC Commissioner Gregory JaczkoRegulatory Information ConferenceMarch 8, 2006 9
This is what happened to our petition for rulemaking:
September 12, 2001 - - TMI Alert filed a petition for rulemaking which would require guards to be posted at the entrances of owner controlled areas at nuclear power plants. The timing of the filing was coincidental to the 9-11 attacks and had been planned for six weeks prior to our filing.
Petition for Rulemaking PRM-73-11 5
 
FAILED TO          INACCURATE EXCESSIVE DELAYS CORRESPOND          INFORMATION
* The NRC Repeatedly
* On 13 separate
* The NRC incorrectly rescheduled the                           occasions when the   listed our petition as rulemaking.                              NRC rescheduled,     completed for we heard nothing. several weeks on its
* Offered no                                                    web site until we explanation for the
* The NRC did not      requested the NRC rescheduling.                            inform us of        to correct it.
management
* Showed no                                changes as to who
* Meeting transcripts accountability when                      was handling our    mistakenly stated challenged.                              petition.            that we were dis-cussing entrance cards instead of entrance guards.
* FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008                                                 6 http://tinyurl.com/qj2mn3d
 
TRIED TO DENY US A SEAT AT THE           VANISHING ACT            MISLED CONGRESS RULEMAKING TABLE
* The NRC did not want to
* Our petition for      *
* NRC letters to give me the opportunity   rulemaking had          congressional leaders to speak during the       disappeared, not only    stated that entrance guards meeting.                 from the meeting, but    are already being
* Our petition and         from the process.        considered in the ongoing background data was                               Power Reactor Security not in the room or on
* There was no mention     Requirements rulemaking.
the document handout      of our petition in the table.                    Power Reactor Security
* NRC hid the fact that their
* When we complained,      Requirements            staff had decided that the NRC made no          rulemaking, the          entrance guards are not attempts to correct the  rulemaking into which    needed and that the absence of our petition  our petition had been    entrance guard petition or background            supposedly merged.      had been denied de facto.
information.
* July 29, 2008 see ADAMS ML081220609 7
 
SURPRISE ENDING              NO DECISION            BLATANT DISREGARD
* The NRC failed to
* The NRCs correspondence
* Actually, there were inform us when the     only indicated that the        more than 40 petition was closed. petition was considered      occurrences when NRC staff claimed     resolved and closed.          the NRC failed to they could not find                                   adhere to its my phone number
* As per guidelines,             principles of or address.            petitions are decided with     openness and a letter clearly indicating:   clarity, and to follow
* I learned that the                                    its procedural acceptance,                guidelines while petition was closed partial acceptance,       handling the from the Union of Concerned                or denial.                rulemaking.
Scientists.
8
 
Public confidence in the NRC is eroded each time we fail to resolve issues in a timely, clear, and transparent manner.
NRC Commissioner Gregory Jaczko Regulatory Information Conference March 8, 2006 9
 
Unwanted consequences of commenting on proposed rules.
Unwanted consequences of commenting on proposed rules.
10This main entrance gate at Three Mile Island is has been wide open and unguarded for more than a decade.  
This main entrance gate at Three Mile Island is has been wide open and unguarded for more than a decade.
"Approaches: Particular emphasis must be placed on main and alternate entry routes for law
10
-enforcement or other offsite support agencies and the location of control points for marshalling and coordinating response activities."Three Mile IslandThe north bridge is the main entrance for emergency responders
 
.11Enhancements To Emergency Preparedness Rulemaking  
Three Mile Island The north bridge is the main entrance for emergency responders.
-2011 TMI Alert filed a comment on this rulemaking noting that without control of the two bridges at Three Mile Island, many aspects of the planned emergency responses could be severely compromised.Rather than address that issue, the NRC droppedthat portion of the proposed Emergency Preparedness Rule. Thisretraction meant that the objectives of the rule can not be ensured at TMI. Our comment for improving emergency preparedness actually served to weaken the rule!Currently, the entrance is wide open and the bridges are not controlled by security forces.
Approaches: Particular emphasis must be placed on main and alternate entry routes for law-enforcement or other offsite support agencies and the location of control points for marshalling and coordinating response activities.
12 NRC REPORT CARDPETITION FOR RULEMAKING 13 More TroubleNRC staffers wanted to use TMI Alert's petition as a quintessential example of NRC petition handling failures. The NRC then failed to invite us to the special public meeting on petition problems as promised.
Enhancements To Emergency Preparedness Rulemaking - 2011 11
14 What TMI Alert believes is needed:Clear rules.Follow the rules.One NRC staffer who will be held accountable for managing and executing a rulemaking, and for timely communications to all involved. A dedicated "grievance" handling officer if the rulemaking manager fails in his/her duties.
* TMI Alert filed a comment on this rulemaking noting that without control of the two bridges at Three Mile Island, many aspects of the planned emergency responses could be severely compromised.
15 end notes 16FULL REPORT on how the NRC bungled an effort to create a new rule     to require entrance guards. 10/31/2008. ADAMS #ML13140A166 or at http://tinyurl.com/qj2mn3dFINAL RULEMAKING  
* Rather than address that issue, the NRC dropped that portion of the proposed Emergency Preparedness Rule. This retraction meant that the objectives of the rule can not be ensured at TMI.
-Power Reactor Security Requirements (RIN 3150-AG63) SECY 0099 July 9, 2008. ADAMS #ML081650474FINAL RULE: Enhancements To Emergency Preparedness Regulations (10 CFR PART 50 AND 10 CFR PART 52) April 8, 2011. ADAMS # ML102150180 Efforts to Improve Rulemaking Tracking and ReportingU.S. Nuclear Regulatory Commission Public Meeting March 11, 2016Comments of Scott D. PortzlineSecurity Consultant to Three Mile Island AlertHarrisburg PA The NRC is to be commended for their effort to assist the public and stakeholders in rulemaking by taking advantage of modern tools to access the docketed records in a timely manner.The proposed improvements would be consistent with the Commission's objectives as stated by the NRC in "Public Participation in NRC's Rulemaking Process."June 12, 2008 2
* Our comment for improving emergency preparedness actually served to weaken the rule!
in communication and decision makingoFacilitates public understanding oProvides an opportunity for affected people to participate in the processoIncreases credibilityand cooperationNRC'S slides: "Public Participation in NRC's Rulemaking Process"June 12, 2008 3  
* Currently, the entrance is wide open and the bridges are not controlled by security forces.
"The NRC rulemaking process is a matureprocess and we welcome suggestions on how to improve it."NRC'S slides: "Public Participation in NRC's Rulemaking Process"June 12, 2008 4
12
This is what happened to our petition for rulemaking:September 12, 2001
 
--TMI Alert filed a petition for rulemaking which would require guards to be posted at the entrances of "owner controlled areas" at nuclear power plants. The timing of the filing was coincidental to the 9
NRC REPORT CARD PETITION FOR RULEMAKING 13
-11 attacks and had been planned for six weeks prior to our filing.Petition for Rulemaking PRM 115 EXCESSIVE DELAYSThe NRC Repeatedly rescheduled the rulemaking.Offered no explanation for the rescheduling.Showed no accountability when challenged.FAILED TO CORRESPONDOn 13 separate occasions when the NRC rescheduled, we heard nothing.The NRC did not inform us of management changes as to who was handling our petition.INACCURATE INFORMATIONThe NRC incorrectly listed our petition as "completed" for several weeks on its web site until we requested the NRC to correct it.Meeting transcripts mistakenly stated that we were dis-cussing "entrance cards" instead of "entrance guards."
 
* FULL REPORT onhow the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008 http://tinyurl.com/qj2mn3d 6
More Trouble
TRIED TO DENY US A SEAT AT THE RULEMAKING TABLEThe NRC did not want to give me the opportunity to speak during the meeting.Our petition and background data was not in the room or on the document handout table.When we complained, the NRC made no attempts to correct the absence of our petition or background information.VANISHING ACTOur petition for rulemaking had disappeared, not only from the meeting, but from the process.There was no mention of our petition in the Power Reactor Security Requirements rulemaking, the rulemaking into which our petition had been supposedly merged.MISLED CONGRESS* NRC letters to congressional leaders stated that entrance guards are "already being considered in the ongoing Power Reactor Security Requirements rulemaking."NRC hid the fact that their staff had decided that entrance guards are not needed and that the "entrance guard petition" had been denied de facto.
* NRC staffers wanted to use TMI Alerts petition as a quintessential example of NRC petition handling failures.
* July 29, 2008 see ADAMS ML081220609 7
* The NRC then failed to invite us to the special public meeting on petition problems as promised.
SURPRISE ENDINGThe NRC failed to inform us when the petition was closed. NRC staff claimed they could not find my phone number or address. I learned that the petition was closed from the Union of Concerned Scientists.NO DECISIONThe NRC's correspondence only indicated that the petition was "considered resolved and closed."As per guidelines, petitions are decided with a letter clearly indicating:BLATANT DISREGARDActually, there were more than 40 occurrences when the NRC failed to adhere to its principles of openness and clarity, and to follow its procedural guidelines while handling the rulemaking.acceptance,partial acceptance,or denial.
14
8 "Public confidence in the NRC is eroded each time we fail to resolve issues in a timely, clear, and transparent manner."NRC Commissioner Gregory JaczkoRegulatory Information ConferenceMarch 8, 2006 9
 
What TMI Alert believes is needed:
* Clear rules.
* Follow the rules.
* One NRC staffer who will be held accountable for managing and executing a rulemaking, and for timely communications to all involved.
* A dedicated grievance handling officer if the rulemaking manager fails in his/her duties.
15
 
end notes FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008. ADAMS #ML13140A166 or at http://tinyurl.com/qj2mn3d FINAL RULEMAKING - Power Reactor Security Requirements (RIN 3150-AG63) SECY-08-0099 July 9, 2008. ADAMS #ML081650474 FINAL RULE: Enhancements To Emergency Preparedness Regulations (10 CFR PART 50 AND 10 CFR PART 52) April 8, 2011.
ADAMS # ML102150180 16
 
Efforts to Improve Rulemaking Tracking and Reporting U.S. Nuclear Regulatory Commission Public Meeting March 11, 2016 Comments of Scott D. Portzline Security Consultant to Three Mile Island Alert Harrisburg PA
* The NRC is to be commended for their effort to assist the public and stakeholders in rulemaking by taking advantage of modern tools to access the docketed records in a timely manner.
* The proposed improvements would be consistent with the Commissions objectives as stated by the NRC in Public Participation in NRCs Rulemaking Process.
June 12, 2008 2
 
in communication and decision making o Facilitates public understanding o Provides an opportunity for affected people to participate in the process o Increases credibility and cooperation NRCS slides: Public Participation in NRCs Rulemaking Process June 12, 2008 3
 
The NRC rulemaking process is a mature process and we welcome suggestions on how to improve it.
NRCS slides: Public Participation in NRCs Rulemaking Process June 12, 2008 4
 
This is what happened to our petition for rulemaking:
September 12, 2001 - - TMI Alert filed a petition for rulemaking which would require guards to be posted at the entrances of owner controlled areas at nuclear power plants. The timing of the filing was coincidental to the 9-11 attacks and had been planned for six weeks prior to our filing.
Petition for Rulemaking PRM-73-11 5
 
FAILED TO          INACCURATE EXCESSIVE DELAYS CORRESPOND          INFORMATION
* The NRC Repeatedly
* On 13 separate
* The NRC incorrectly rescheduled the                           occasions when the   listed our petition as rulemaking.                              NRC rescheduled,     completed for we heard nothing. several weeks on its
* Offered no                                                    web site until we explanation for the
* The NRC did not      requested the NRC rescheduling.                            inform us of        to correct it.
management
* Showed no                                changes as to who
* Meeting transcripts accountability when                      was handling our    mistakenly stated challenged.                              petition.            that we were dis-cussing entrance cards instead of entrance guards.
* FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008                                                 6 http://tinyurl.com/qj2mn3d
 
TRIED TO DENY US A SEAT AT THE           VANISHING ACT            MISLED CONGRESS RULEMAKING TABLE
* The NRC did not want to
* Our petition for      *
* NRC letters to give me the opportunity   rulemaking had          congressional leaders to speak during the       disappeared, not only    stated that entrance guards meeting.                 from the meeting, but    are already being
* Our petition and         from the process.        considered in the ongoing background data was                               Power Reactor Security not in the room or on
* There was no mention     Requirements rulemaking.
the document handout      of our petition in the table.                    Power Reactor Security
* NRC hid the fact that their
* When we complained,      Requirements            staff had decided that the NRC made no          rulemaking, the          entrance guards are not attempts to correct the  rulemaking into which    needed and that the absence of our petition  our petition had been    entrance guard petition or background            supposedly merged.      had been denied de facto.
information.
* July 29, 2008 see ADAMS ML081220609 7
 
SURPRISE ENDING              NO DECISION            BLATANT DISREGARD
* The NRC failed to
* The NRCs correspondence
* Actually, there were inform us when the     only indicated that the        more than 40 petition was closed. petition was considered      occurrences when NRC staff claimed     resolved and closed.          the NRC failed to they could not find                                   adhere to its my phone number
* As per guidelines,             principles of or address.            petitions are decided with     openness and a letter clearly indicating:   clarity, and to follow
* I learned that the                                    its procedural acceptance,                guidelines while petition was closed partial acceptance,       handling the from the Union of Concerned                or denial.                rulemaking.
Scientists.
8
 
Public confidence in the NRC is eroded each time we fail to resolve issues in a timely, clear, and transparent manner.
NRC Commissioner Gregory Jaczko Regulatory Information Conference March 8, 2006 9
 
Unwanted consequences of commenting on proposed rules.
Unwanted consequences of commenting on proposed rules.
10This main entrance gate at Three Mile Island is has been wide open and unguarded for more than a decade.  
This main entrance gate at Three Mile Island is has been wide open and unguarded for more than a decade.
"Approaches: Particular emphasis must be placed on main and alternate entry routes for law
10
-enforcement or other offsite support agencies and the location of control points for marshalling and coordinating response activities."Three Mile IslandThe north bridge is the main entrance for emergency responders
 
.11Enhancements To Emergency Preparedness Rulemaking  
Three Mile Island The north bridge is the main entrance for emergency responders.
-2011 TMI Alert filed a comment on this rulemaking noting that without control of the two bridges at Three Mile Island, many aspects of the planned emergency responses could be severely compromised.Rather than address that issue, the NRC droppedthat portion of the proposed Emergency Preparedness Rule. Thisretraction meant that the objectives of the rule can not be ensured at TMI. Our comment for improving emergency preparedness actually served to weaken the rule!Currently, the entrance is wide open and the bridges are not controlled by security forces.
Approaches: Particular emphasis must be placed on main and alternate entry routes for law-enforcement or other offsite support agencies and the location of control points for marshalling and coordinating response activities.
12 NRC REPORT CARDPETITION FOR RULEMAKING 13 More TroubleNRC staffers wanted to use TMI Alert's petition as a quintessential example of NRC petition handling failures. The NRC then failed to invite us to the special public meeting on petition problems as promised.
Enhancements To Emergency Preparedness Rulemaking - 2011 11
14 What TMI Alert believes is needed:Clear rules.Follow the rules.One NRC staffer who will be held accountable for managing and executing a rulemaking, and for timely communications to all involved. A dedicated "grievance" handling officer if the rulemaking manager fails in his/her duties.
* TMI Alert filed a comment on this rulemaking noting that without control of the two bridges at Three Mile Island, many aspects of the planned emergency responses could be severely compromised.
15 end notes 16FULL REPORT on how the NRC bungled an effort to create a new rule     to require entrance guards. 10/31/2008. ADAMS #ML13140A166 or at http://tinyurl.com/qj2mn3dFINAL RULEMAKING  
* Rather than address that issue, the NRC dropped that portion of the proposed Emergency Preparedness Rule. This retraction meant that the objectives of the rule can not be ensured at TMI.
-Power Reactor Security Requirements (RIN 3150-AG63) SECY 0099 July 9, 2008. ADAMS #ML081650474FINAL RULE: Enhancements To Emergency Preparedness Regulations (10 CFR PART 50 AND 10 CFR PART 52) April 8, 2011. ADAMS # ML102150180}}
* Our comment for improving emergency preparedness actually served to weaken the rule!
* Currently, the entrance is wide open and the bridges are not controlled by security forces.
12
 
NRC REPORT CARD PETITION FOR RULEMAKING 13
 
More Trouble
* NRC staffers wanted to use TMI Alerts petition as a quintessential example of NRC petition handling failures.
* The NRC then failed to invite us to the special public meeting on petition problems as promised.
14
 
What TMI Alert believes is needed:
* Clear rules.
* Follow the rules.
* One NRC staffer who will be held accountable for managing and executing a rulemaking, and for timely communications to all involved.
* A dedicated grievance handling officer if the rulemaking manager fails in his/her duties.
15
 
end notes FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008. ADAMS #ML13140A166 or at http://tinyurl.com/qj2mn3d FINAL RULEMAKING - Power Reactor Security Requirements (RIN 3150-AG63) SECY-08-0099 July 9, 2008. ADAMS #ML081650474 FINAL RULE: Enhancements To Emergency Preparedness Regulations (10 CFR PART 50 AND 10 CFR PART 52) April 8, 2011.
ADAMS # ML102150180 16}}

Latest revision as of 22:59, 30 October 2019

Efforts to Improve Rulemaking Tracking and Reporting
ML16070A115
Person / Time
Site: Three Mile Island  Constellation icon.png
Issue date: 03/11/2016
From: Portzline S
Three Mile Island Alert
To:
NRC/EDO
References
Download: ML16070A115 (16)
v • d • e


Text

Efforts to Improve Rulemaking Tracking and Reporting U.S. Nuclear Regulatory Commission Public Meeting March 11, 2016 Comments of Scott D. Portzline Security Consultant to Three Mile Island Alert Harrisburg PA

  • The NRC is to be commended for their effort to assist the public and stakeholders in rulemaking by taking advantage of modern tools to access the docketed records in a timely manner.
  • The proposed improvements would be consistent with the Commissions objectives as stated by the NRC in Public Participation in NRCs Rulemaking Process.

June 12, 2008 2

in communication and decision making o Facilitates public understanding o Provides an opportunity for affected people to participate in the process o Increases credibility and cooperation NRCS slides: Public Participation in NRCs Rulemaking Process June 12, 2008 3

The NRC rulemaking process is a mature process and we welcome suggestions on how to improve it.

NRCS slides: Public Participation in NRCs Rulemaking Process June 12, 2008 4

This is what happened to our petition for rulemaking:

September 12, 2001 - - TMI Alert filed a petition for rulemaking which would require guards to be posted at the entrances of owner controlled areas at nuclear power plants. The timing of the filing was coincidental to the 9-11 attacks and had been planned for six weeks prior to our filing.

Petition for Rulemaking PRM-73-11 5

FAILED TO INACCURATE EXCESSIVE DELAYS CORRESPOND INFORMATION

  • The NRC Repeatedly
  • On 13 separate
  • The NRC incorrectly rescheduled the occasions when the listed our petition as rulemaking. NRC rescheduled, completed for we heard nothing. several weeks on its
  • Offered no web site until we explanation for the
  • The NRC did not requested the NRC rescheduling. inform us of to correct it.

management

  • Showed no changes as to who
  • Meeting transcripts accountability when was handling our mistakenly stated challenged. petition. that we were dis-cussing entrance cards instead of entrance guards.
  • FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008 6 http://tinyurl.com/qj2mn3d

TRIED TO DENY US A SEAT AT THE VANISHING ACT MISLED CONGRESS RULEMAKING TABLE

  • The NRC did not want to
  • Our petition for *
  • NRC letters to give me the opportunity rulemaking had congressional leaders to speak during the disappeared, not only stated that entrance guards meeting. from the meeting, but are already being
  • Our petition and from the process. considered in the ongoing background data was Power Reactor Security not in the room or on
  • There was no mention Requirements rulemaking.

the document handout of our petition in the table. Power Reactor Security

  • NRC hid the fact that their
  • When we complained, Requirements staff had decided that the NRC made no rulemaking, the entrance guards are not attempts to correct the rulemaking into which needed and that the absence of our petition our petition had been entrance guard petition or background supposedly merged. had been denied de facto.

information.

SURPRISE ENDING NO DECISION BLATANT DISREGARD

  • The NRC failed to
  • The NRCs correspondence
  • Actually, there were inform us when the only indicated that the more than 40 petition was closed. petition was considered occurrences when NRC staff claimed resolved and closed. the NRC failed to they could not find adhere to its my phone number
  • As per guidelines, principles of or address. petitions are decided with openness and a letter clearly indicating: clarity, and to follow
  • I learned that the its procedural acceptance, guidelines while petition was closed partial acceptance, handling the from the Union of Concerned or denial. rulemaking.

Scientists.

8

Public confidence in the NRC is eroded each time we fail to resolve issues in a timely, clear, and transparent manner.

NRC Commissioner Gregory Jaczko Regulatory Information Conference March 8, 2006 9

Unwanted consequences of commenting on proposed rules.

This main entrance gate at Three Mile Island is has been wide open and unguarded for more than a decade.

10

Three Mile Island The north bridge is the main entrance for emergency responders.

Approaches: Particular emphasis must be placed on main and alternate entry routes for law-enforcement or other offsite support agencies and the location of control points for marshalling and coordinating response activities.

Enhancements To Emergency Preparedness Rulemaking - 2011 11

  • TMI Alert filed a comment on this rulemaking noting that without control of the two bridges at Three Mile Island, many aspects of the planned emergency responses could be severely compromised.
  • Rather than address that issue, the NRC dropped that portion of the proposed Emergency Preparedness Rule. This retraction meant that the objectives of the rule can not be ensured at TMI.
  • Currently, the entrance is wide open and the bridges are not controlled by security forces.

12

NRC REPORT CARD PETITION FOR RULEMAKING 13

More Trouble

  • NRC staffers wanted to use TMI Alerts petition as a quintessential example of NRC petition handling failures.
  • The NRC then failed to invite us to the special public meeting on petition problems as promised.

14

What TMI Alert believes is needed:

  • Clear rules.
  • Follow the rules.
  • One NRC staffer who will be held accountable for managing and executing a rulemaking, and for timely communications to all involved.
  • A dedicated grievance handling officer if the rulemaking manager fails in his/her duties.

15

end notes FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008. ADAMS #ML13140A166 or at http://tinyurl.com/qj2mn3d FINAL RULEMAKING - Power Reactor Security Requirements (RIN 3150-AG63) SECY-08-0099 July 9, 2008. ADAMS #ML081650474 FINAL RULE: Enhancements To Emergency Preparedness Regulations (10 CFR PART 50 AND 10 CFR PART 52) April 8, 2011.

ADAMS # ML102150180 16

Efforts to Improve Rulemaking Tracking and Reporting U.S. Nuclear Regulatory Commission Public Meeting March 11, 2016 Comments of Scott D. Portzline Security Consultant to Three Mile Island Alert Harrisburg PA

  • The NRC is to be commended for their effort to assist the public and stakeholders in rulemaking by taking advantage of modern tools to access the docketed records in a timely manner.
  • The proposed improvements would be consistent with the Commissions objectives as stated by the NRC in Public Participation in NRCs Rulemaking Process.

June 12, 2008 2

in communication and decision making o Facilitates public understanding o Provides an opportunity for affected people to participate in the process o Increases credibility and cooperation NRCS slides: Public Participation in NRCs Rulemaking Process June 12, 2008 3

The NRC rulemaking process is a mature process and we welcome suggestions on how to improve it.

NRCS slides: Public Participation in NRCs Rulemaking Process June 12, 2008 4

This is what happened to our petition for rulemaking:

September 12, 2001 - - TMI Alert filed a petition for rulemaking which would require guards to be posted at the entrances of owner controlled areas at nuclear power plants. The timing of the filing was coincidental to the 9-11 attacks and had been planned for six weeks prior to our filing.

Petition for Rulemaking PRM-73-11 5

FAILED TO INACCURATE EXCESSIVE DELAYS CORRESPOND INFORMATION

  • The NRC Repeatedly
  • On 13 separate
  • The NRC incorrectly rescheduled the occasions when the listed our petition as rulemaking. NRC rescheduled, completed for we heard nothing. several weeks on its
  • Offered no web site until we explanation for the
  • The NRC did not requested the NRC rescheduling. inform us of to correct it.

management

  • Showed no changes as to who
  • Meeting transcripts accountability when was handling our mistakenly stated challenged. petition. that we were dis-cussing entrance cards instead of entrance guards.
  • FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008 6 http://tinyurl.com/qj2mn3d

TRIED TO DENY US A SEAT AT THE VANISHING ACT MISLED CONGRESS RULEMAKING TABLE

  • The NRC did not want to
  • Our petition for *
  • NRC letters to give me the opportunity rulemaking had congressional leaders to speak during the disappeared, not only stated that entrance guards meeting. from the meeting, but are already being
  • Our petition and from the process. considered in the ongoing background data was Power Reactor Security not in the room or on
  • There was no mention Requirements rulemaking.

the document handout of our petition in the table. Power Reactor Security

  • NRC hid the fact that their
  • When we complained, Requirements staff had decided that the NRC made no rulemaking, the entrance guards are not attempts to correct the rulemaking into which needed and that the absence of our petition our petition had been entrance guard petition or background supposedly merged. had been denied de facto.

information.

SURPRISE ENDING NO DECISION BLATANT DISREGARD

  • The NRC failed to
  • The NRCs correspondence
  • Actually, there were inform us when the only indicated that the more than 40 petition was closed. petition was considered occurrences when NRC staff claimed resolved and closed. the NRC failed to they could not find adhere to its my phone number
  • As per guidelines, principles of or address. petitions are decided with openness and a letter clearly indicating: clarity, and to follow
  • I learned that the its procedural acceptance, guidelines while petition was closed partial acceptance, handling the from the Union of Concerned or denial. rulemaking.

Scientists.

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Public confidence in the NRC is eroded each time we fail to resolve issues in a timely, clear, and transparent manner.

NRC Commissioner Gregory Jaczko Regulatory Information Conference March 8, 2006 9

Unwanted consequences of commenting on proposed rules.

This main entrance gate at Three Mile Island is has been wide open and unguarded for more than a decade.

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Three Mile Island The north bridge is the main entrance for emergency responders.

Approaches: Particular emphasis must be placed on main and alternate entry routes for law-enforcement or other offsite support agencies and the location of control points for marshalling and coordinating response activities.

Enhancements To Emergency Preparedness Rulemaking - 2011 11

  • TMI Alert filed a comment on this rulemaking noting that without control of the two bridges at Three Mile Island, many aspects of the planned emergency responses could be severely compromised.
  • Rather than address that issue, the NRC dropped that portion of the proposed Emergency Preparedness Rule. This retraction meant that the objectives of the rule can not be ensured at TMI.
  • Currently, the entrance is wide open and the bridges are not controlled by security forces.

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NRC REPORT CARD PETITION FOR RULEMAKING 13

More Trouble

  • NRC staffers wanted to use TMI Alerts petition as a quintessential example of NRC petition handling failures.
  • The NRC then failed to invite us to the special public meeting on petition problems as promised.

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What TMI Alert believes is needed:

  • Clear rules.
  • Follow the rules.
  • One NRC staffer who will be held accountable for managing and executing a rulemaking, and for timely communications to all involved.
  • A dedicated grievance handling officer if the rulemaking manager fails in his/her duties.

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end notes FULL REPORT on how the NRC bungled an effort to create a new rule to require entrance guards. 10/31/2008. ADAMS #ML13140A166 or at http://tinyurl.com/qj2mn3d FINAL RULEMAKING - Power Reactor Security Requirements (RIN 3150-AG63) SECY-08-0099 July 9, 2008. ADAMS #ML081650474 FINAL RULE: Enhancements To Emergency Preparedness Regulations (10 CFR PART 50 AND 10 CFR PART 52) April 8, 2011.

ADAMS # ML102150180 16

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