ML19262C596
| ML19262C596 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1979 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-1689, NUDOCS 8002140620 | |
| Download: ML19262C596 (26) | |
Text
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...ne,eting Date:
11/7/79 Date Issued:
12/5/79 MINUTES OF ACRS PROCEDURES SUBCOMMITTEE [~, -..,..'
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MEETING - NOVEM8El 7,1979 if
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Matters discussed at this meeting consisted of:
Puroose:
Proposed procedures for ACRS participation in conrideration 1.
of dissenting professional opinions by NRC Staff members.
2.
Office support provided ACRS members.
Involvement of Congressicnal representatives in ACRS acti-3.
vities regarding development of Quantitative Risk Criteria Attendees:
M. W. Carbon, ACRS Chairman C. P. Siess, Member M. Bender, Member W. Kerr, Member D. Okrent, Member M. Plesset, Member S. 1.awroski, Member D. Moeller, Member R. F. Fraley, Staff Discussion:
ACRS particioation in the process for consideratien of dissentina 1) professional opinions of NRC staff members Members were informed of proposed procedures in NUREG-0567, Proposed Policy and Procedures for Differing Professional Opinions (recently published for connent by NRC). The proposed procedures (Section 6 b) read as follows:
b.
The ACRS If the differing professional opinion relates to a potential safety issue within the purview of the Advisory Committee on Reactor Safeguards, an NRC employee may communicate orally or in writing directly with the Chairman or any member of the The ACRS will ACRS.
Such communication may be anonymous.
append comments, as appropriate, to all written statements of differing professional opinion and will forward these statements for resolution to the appropriate NRC office director.
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AnNRCemployeemayalsoappearbeforethehCRStopresent oral or written statements for consideration by the Comnittee.
The ACRS will assure that all such statements that do not constitute a differing professional opinion are forwarded to the appropriate NRC of fice director for information.
This degree of ACRS involvement seems at variance with the desires of the Comittee as expressed in its letter from the ACRS (M. Bender) to the NRC Chairman (M. A. Rowden) dated February 24,1977 (see Attachment 2).
In this letter the Committee suggests that a forum is needed within the NRC Staff to resolve differing technical opinions. The extent of Committee involvement would be an interest in being kept informed regarding the bases for the judgments reached and a willingness to offer advice on those matters deemed appropriate by the Comission.
Dr. Siess noted that these procedures appear to a large degree consistent with the requirements of FACA nad ACRS procedures to hear coments from mecers of the public including, technical representatives of the nuclear ccmunity who may agree or dissent with a safety related issue.
Concern was expressed by several members, however, that the proposed procedures do establish the degree of ACRS involvement at the discretion of the em-ployee rather than the importance of the issue, the workload of the Comit-tee, etc.
A oroposed revision was agreed to and is reflected in the attached letter to Mr. N. Haller from the ACRS Executive Director (Attachment 3).
- 2) Office succort orovided ACRS members Funds for support of ACRS members " offices" have recently been increased to
$5,000/yr. to cover miscellaneous expenses associated with ACRS activities (see Attachment 4).
It has been suggested that this level of funding be increased to a value
($15-20,000/ year) that would permit members to hire a part-time (approxi-mately h time) secretary, rent office space, etc. as needed to fully sup-port their ACRS activities. The members of the Procedures Subcomittee concluded that since no one has specifically expressed a desire for such funding, the matter need not be pursued further.
- 3) Particioation of Conoressional reoresentatives in ACRS activities regarding develcoment of Guantitative Risk Criteria Dr. Okrent, Chairman of the ACRS Subcommittee assigned this responsibility, has proposed that members of Congress and their staffers with an interest in this subject be informed of ACRS activities related to the development of Quantitative Risk Criteria per the request of NRC and that they be in-vited to attend and participate in related ACRS activities.
4
_ The Office of Congressional Affairs has suggested that any correspondence regarding this matter should include those Congressional. Comittees with NRC oversight responsibilities.
Congressional Affairs did suggest how-ever, that the request to participate should be deleted since it is the responsibility of the ACRS/NRC to develop a proposal which the Congress will eventually consider.
The members agreed and the attached letter was approved (see Attachment 5).
Attachments:
1.
NUREG-0567, " Proposed Policy and Procedures for Differing Professional Opinions" 2.
Ltr. Bender to Rowden dtd. 2/24/77, "Resolu-tion of Differences of Opinion Among the NRC Staff" 3.
Ltr., Fraley to Haller dtd.11/9/79, " Proposed Policy and Procedures for Differing Professional Opinions, NUREG-0567" 4.
ACRS Members Guide for Use of Miscellaneous Expense Funds dtd. 9/79 5.
Ltr. Okrent to Udall dtd. 11/13/79 re.
quantitative safety goals
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Proposec' Po' icy anc rocecures for DiPering Professiona! Opinions For Comment H. J. Watters, R. L. Vandenberg Office of Management and Program Analysis U. S. Nuclear Regulatory Commission gkn mECg 9
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ATTACHMENT 1
TABLE OF CONTENTS Pace Proposed NRC Policy for Differing Professional Opinions.
1 Proposed NRC Procedures for Differing Professional Opinions.
1 1
I A.
Scope.
2 B.
Objectives.
C.
Procedures.
3 I
NRC POLICY ON DIFFERING PROFESSIONAL OPINIONS the policy of the Nuclear Regulatory Commission, and the responsibility 4-It of all NRC supervisory and managerial personnel, to maintain a working environment that encourages employees to make known their best professional judgments even though they may differ from a prevailing staff view, disagree I
with a management decision or policy position, or take issue with established I
agency practices.
Each differing professional opinion of an NRC employee will be evaluated on its own merit.
Further, each differing professional opinion will be pursued to resolution and the employee's statement of differing professional opinion, together with the agency's final response, will be made available to the public to ensure the openness of NRC decisions that may affect the public.
It is not only the right but the duty of all NRC employees to make known their best professional judgments on any mattar relating to the mission of Moreover, both the general puolic and the Nuclear Regulatory the agency.
Commission benefit when the agency seriously considers differing professional opinions held by HRC e1ployees that concern matters related to the agency's mission. This policy assures all employees the opportunity to express opinions in good faith, to have these opinions heard differing profession I and considered by N1C management, and to be protected against retaliation in any form.
Individual NRC of fices may develop procedures to meet their specific needs.
Office procedures must be consistent with agency policy and procedures.
NRC PROCEDURES FOR DIFFERING PROFESSIONAL OPINIONS A.
SCOPE These procedures for the expression and resolution of differing pro-fessional opinions are for the use of all NRC employees.
They supple-ment other stated rights, duties, and safeguards applicable to all Federal employees who make their views known either within or outside their agencies, including:
the independent right of free speech provided by the First Amendment to the U. S. Constitution; the right of government employees to petition the Congress (5 USC 7102);
the rights of employees to communicate directly with the Congress as outlined in the Code of Ethics for Government Service (10 CFR 0.735 Annex A); and I
. provisions of the 1978 Civil Service Reform Act dealing with pro-hibited personnel practices and the regulations of the Merit System Protection Board.
B.
OBJECTIVES The objectives of NRC's procedures are to:
1.
define differing professional opinions; 2.
distinguish between differing professional opinions and the difference of views and opinions routinely raised and resolved among staff members in the ordinary conduct of agency business; 3.
provide a primary channel for submitting differing professional opinions; 4.
specify the recommended content of a statement of dif fering pro-fessional opinions; 5.
provide reasonable time and reasonable administrative assistance to help employees develop and document their differing professional opinions; 6.
provide alternative channels for expressing a di'fering professional opinion either on the record or anonymously; 7.
provide for acknowledgement of receipt of statements of differing professional opinion and for advising originators of planned actions for resolution; 8.
provide accountability by requiring a written record of all actions taken on differing professior :1 opinions; 9.
provide for resolution within the agency of differing professional
- pinions, if at all possible; 10.
provide disciplinary sanctions against employees who take retaliatory actions that affect the originators of differing professional opinions; 11.
prevent intentional misuse of these procedures; 12.
provide for periodic assessment to ensure that implementation of these procedures accomplishes the stated objectives and to recommend appropriate changes; and 13.
provide recognition to the originators of differing professional opinions if their opinions contribute significantly to achievement of the agency's mission.
C.
PROCEDURES 1.
Definition of Diff-r".4 Proiessional Ooinion A dif fering professional opin:an is a conscientious expression of professional judgment on 6 y matter relating to NRC's mission or organizational activities that differs from the prevailing staff siew within an organization, disagrees with a management decision or policy position, or takes issue with an established agency practice.
Differing professional opinions are not limited to the originator's area of expertise: they may involve technical, management, or For the purpose of tnese procedures, matters that policy issues.
are subject to employee grievance in accordance with NRC Manual Chapter 4157 do not qualify as differing professional opinions.
Normal Differing Views vs. Differino Professional Opinions 2.
A normal differing view, developed in the free and open discussion of work matters, becomes a differing professional opinion only when the originator brings it to NRC management attention in accordance with these procedures.
In the free and open discussion of work matters, professional dif-ferences of opinion are common.
Employees may also develop critical views concerning matters other than their personal work assignments, such as issues under consideration in another part of NRC or relating to an agency practice or position that is neither currently under review nor in the agency's decision-making process.
In both these instances, employees normally try and should be encouraged to resolve their concerns through discussions with their co-workers and immediate supervisors.
In some cases, this may lead to a suggestion as part of the NRC suggestions program (NRC Manual Chapter 4154).
However, these informal discussions may not resolve the matter and an employee may be convinced that the agency and the public would To further pursue be better served if another opinion prevailed.
such concerns, an employee should submit a signed, written statement of differing professional opinion in accordance with these procedures.
With the submission of this written statement, the employee's i
differing view becomes a differing professional opinion.
An employee may not use these procedures for differing professional opinions without submitting a written statement.
He may, however, express his concerns orally or in writing to the ACRS and may also discuss these concerns with any NRC manager as provided in the Open Door Policy.
(See Procedure No. 6.)
A manager is an employee who directs the work of an organization, is held accountaDie for the success of specific line or staff programs or activities, and whose primary duties are managerial.
3.
Primary Channel for Expressina Differino Professional Ooinions These procedures are invoked when an employee submits to his immediate supervisor a signed statement of differing professional opinion.
As indicated in the statement of policy, it is not only the right but the duty of all NRC employees to make known their best professional judgments on any matter relating to the mission of the agency.
Before submitting the statement, employees should consult with their immediate supervisors who will aid them in identifying related information and assist them, if requested, in clarifying the issues.
The originator of the differing professional opinion may request agency resources for preparing an adequate written statement of differing professional opinion and such a request will include an estimate of the resources required.
4.
Content of a Written Statement of Differing Professional Opinion Regardiess of its format or style, a written statement of differing professional opinion should be as brief as possible.
It is strongly recommended that the statement include:
a summary of the originator's perception of the prevailing a.
staff view, existing management decision or stated positions, or the established agency practice; b.
a description of the originator's opinions and how they differ from any items discussed in a. above; c.
a statement of the originator's assessment of the resulting consequences if the differing professional opinion is not adopted by the agency; and d.
the status of related efforts with which the originator is familiar and their potential contribution toward resolution of the originator's dif fering opinion.
5.
Resources to Assist Originators of Differing Professional Opinions To assist originators in preparing adequate written statements of differing professional opinion, NRC management may allow a reasonable amount of (a) the originator's work time, (b) time of other NRC
. professional personnel in a consulting capacity, and (c) administra-tive support.
The originator's immediate supervisor, in consulta-tion with his or her manager, will determine the nature and level of resources provided in response to the originator's request for assistance.
i The purpose of this assistance is to ensure that the pertinent issues are clearly and accurately presented, that related matters
)
are considered, and that any relevant documentation is included.
In determining the level of resources to be made available to the employee, consideration will be given to (a) the potential signifi-cance of the proposed differing professional opinion, and (b) the urgency of resolving the differing professional opinion in comparison with other mission-related activities.
As an alternative, employees may prepare a statement of differing professional opinion on their own time and in that statement describe what work, including proposed commitments of their own time, would be needed to resolve the concerns or issues.
6.
Alternate Channels for Expressing Differing Professional Opinions Two alternate channels are available for employees who prefer not to use the primary channel for expressing their differing profes-sional opinions (employees may also bring their concerns to the Office of Inspector and Auditor):
a.
Open Door Policy The Open Door Policy of NRC provides that NRC employees may, on their own initiative, meet with any manager, including a Commissioner or the Cnairman of HRC, to discuss any matter of concern to the employee.
Upon request, the employee's identity will be kept anonymous.
If discussions disclose that an employee's views constitute a differing professional opinion, the contacted manager should encourage the employee to submit a signed, written statement of differing professional opinion in accordance with these procedures.
If the employee insists on remaining anonymous, but wishes to have his or her views considered as a differing profersional opinion, the employee must submit an unsignt statement of differing professional opinion to the manager contacted via the open door and that manager will forward the anonymous statement of differing professional opinion to the office director having programmatic responsibility for the issues raised in the differing professional opinion.
Resolution of the differing professional opinion will then be completed in accordance with these procedures.
To protect an employee's anonymity in such cases, however, acknowledgement of receipt of the differing professional opinion required by Procedure No. 7 will not be possible, nor will originators be provided with reports on resolution required by Procedure No. 9-b.
Hcwever, acknowledgements will be made to the manager contacted and proper reports will be provided.
Differing opinions not expressed in writing shall be considered normal differing views, as discussed in Procedure No. 2, and may not be further pursued using these procedures.
Open Door discussions between employees and managers may also relate to subjects other than normal differing views and differing professional opinions.
In these cases, managers will work to resolve an employee's concerns, to answer any questions, and to honor any request for anonymity.
- However, honoring a request for anonymity may limit a manager's assis-tance to either discussions with the employee or to providing advice and counsel on matters of concern to the employee.
Managers should advise employees of the proper channels to be used for the resolution of concerns that may not be resolved using these procedures for differing professional opinions.
If the contacted manager believes that others should be notifed of issues raised in these discussions, he should notify of fices with programmatic responsibility, the Office of Inspector and Auditor, and others, as appropriate.
Resolu-tion of these matters does not involve use of procedures for differing professional opinions.
b.
The ACRS If the differing professional opinion relates to a potential safety issue within the purview of the Advisory Committee on Reactor Safeguards, an NRC employee may communicate orally or in writing directly with the Chairman or any member of the ACRS.
Such communication may be anonymous.
The ACRS will append comments, as appropriate, to all written statements of differing professional opinion and will forward these statements for resolution to the appropriate NRC of fice director.
An NRC employee may also appear before the ACRS to present oral or written statements for consideration by the Committee.
The ACRS will assure that all such statements that do not constitute a differing professional opinion are forwarded to the appropriate NRC office director for information.
7.
Acknowledgement of Differing Professional Opinions The immediate supervisor, upon receiving a written statement of differing professional opinion, should discuss the statement with In addition, the originator if this has not previously been done.
the immediate supervisor must, within one calendar week, acknowledge receipt by a memorandum to the originator. This memorandum will also indicate the actions that will be taken to resolve the differing professional opinion.
If the immediate upervisor determines that the written statement g
deals with matter, excluded from the definition of a differing professional opinion, he shall note this in his memorandum -- citing the specific exclusion -- and return the statement to the employee.
The memorandum will indicate that no further action will be taken using dif fering professional opinion procedures and will inform the employee of the appropriate procedures for dealing with his An employee may appeal to the next higher level of concerns.
supervision an immediate supervisor's decision that his written statement deals with matters that may not be resolved using the procedures for differing professional opinion.
Upon receipt, statements of differing professional opinion will be incorporated into the receiving organization's normal work tracking system. This tracking should assure that the status of each differing professive,al opinion is regularly reviewed, aid in its prompt resolution, and provide a systematic basis for keeping the originator informed.
Written Record of Actions on Differing Professional Opinions 8.
Once a signed differing professional opinion has been submitted, a written record must be maintained to provide accountability for all subsequent actions taken to resolve that differing professional opinion on its merits.
This record will consist of signed notations of all supervisory and managerial determinations and actions based upon the differing professional opinion.
All pertinent documentation must be preserved.
Changes in the original documentation that are requested by the originator will also be made a part of this written record.
To the extent necessary, these procedures should permit anonymity to the extent requested by the originator.
9.
Resolution of Differing Professional Opinions a.
Definition of Resolution A differing professional opinion is considered resolved by the NRC when:
(1) NRC management adopts the views expressed in the originator's written statement of differing professional opinion, or i
an
. (2) NRC management adopts a part of the judgments expressed in the originator's written statement of differing professional opinion and informs the originator of the reasons for not adopting the remainder, or (3) The responsible office director determines that evaluation of the differing professional opinion fails to justify modification of a management decision, policy position, or an existing agency practice, or (4) The responsible office director determines that the impact of the potential consequences stated in the differing professional opinion is insufficient to justify a detailed evaluation of the differing pro-fessional opinion.
In each of the preceding cases, resolution occurs only when the originator has been informed of the decision or action of NRC management and, consistent with security classification policy, both the statement of differing professional opinion and the response of NRC management have been placed in NRC's Public Document Room.
Resolution of a differing professional opinion by NRC management in accordance with these procedures may not be appealed within the agency.
However, an originator who is dissatisfied with a management resolution may express his concerns via either the Open Door or the ACRS.
b.
Resolution Process Upon receiving a statement of differing professional opinion from the originator, the immediate supervisor will forward it to his or her office director for action.
The immediate supervisor and others in the chain-of-command may append their views concerning matters discussed in the differing professional opinion.
The office director will forward the differing professional opinion within 10 working days of its submission either to the appropriate manager within his own office or to the director of another responsible office.
If transferred to another office for resolution, the differing professional opinion must be assigned to the responsible program manager within 14 working days after its submission by the originator.
The responsible Office Director will, within 14 working days after its submittion by an originator, inform the boards of any differing professional opinion that relates to issues pending before them or scheduled for '. heir consideration.
The responsible manager will incorporate the statement of differing professional opinion into the organization's normal work tracking system and, until the differing professional opinion has been resolved, shall provide the originator with brief monthly status reports.
Copies of these reports should also be provided to the responsible Office Director.
The y
responsible manager will also inform the originator if other differing professional opinions are received that conflict with that submittad by the originator.
The responsible office director will notify the originator of final resolu-tion of the differing professional opinion and shall provide him with a copy of the record that will be placed in NRC's Public Document Room.
c.
Reports to the Commission The Office of Management and Program Analysis (MPA) shall provide the Commission with quarterly reports identifying all Differing Professional Opinions submitted and specifying the actions that have been taken to achieve their resolution.
This information shall be provided by the responsible Office Directors who shall, within five working days after each calendar quarter, provide MPA with a Differing Professional Opinion Status Report that contains a listing and description of all Differing Professional Opinions received together with a brief status report of all efforts efforts that have been taken to achieve their resoluation.
Items shall be reported and summarized in the following three categories:
1-Differing Professional Opinions submitted since suemission of the last quarterly status report.
2-Differing Professisnal Opinions previously identified but not yet resolved.
3-Differing Professional Opinions previously identified that were resolved on (date).
10.
Prevention of Retaliation Against Individuals Who Express Differing Professional Opinions Any NRC employee who retaliates against another employee for submitting a differing professional opinion is subject to disci-plinary action in accordance with NRC Manual Chapter 4171 (Separa-tions and Adverse Actions).
This applies to retaliatory actions described in a. below and to all prohibited personnel practices specified in Section 2302, Title 5, U.S. Code, as amended by the Civil Service Reform Act of 1978.
at
. a.
Definition of Retaliation Retaliation consists of undesired or injurious actions taken against the originator of a differing professional opinion that would not have been taken if he had not submitted the differing professional opinion.
Retaliation includes, but is not limited to, form?1 disciplinary actions and subtle forms of informal harassment either by co-workers, supervisory personnel, or managers.
Retaliation may involve transfer; detail; ostracism; loss of staff assistance, space, or equip-ment; physical isolation; the absence of assignments involving substantive work; or denial of promotion, in-step increases, attendance at professional society meetings, or appropriate and justified training.
b.
Resolution of Alleged Retaliation Employees who allege that retaliatory actions have been taken because of their submission of a differing professional opinion may seek redress through NRC's grievance procedures described in Manual Chapter 4157 (Employee Grievances).
Note:
The Division of Organization and Personnel has been requested to modify Manual Chapter 4157 by incorporat-ing specific provisions for resolving allegations of retaliation that result from the submission of a differing professional opinion.
11.
Prevent Intantional Misuse of Procedures for Differing Professional Opinions NRC's policy on differing professional opinions assumes that the integrity, personal commitment, and professionalism of NRC employees will preclude the intentional misuse of these procedures developed to implement that policy.
Examples of intentional misuse of these procedures would include, for example, the frivolous submission of a differing professional opinion or repeated attempts to use these procedures to obtain resolution of views that do not satisfy the criteria for differing professional opinions.
12.
Special Review Panel for Follcw-up on Functioning of Differing Professional Opinion Procedures Each year, the Executive Director for Operations will appoint a Special Review Panel to evaluate and report on the functioning of the differing professional opinion procedures.
Four members of the Special Review Panel will be NRC employees (two managers and two non-managers) and the fifth member will be from outside the NRC.
Membership shall not be limited to scientific or engineering
. personnel.
All NRC employees will receive a copy of the letter appointing members of the Special Review Panel.
The forwarding memorandum may also solicit employee comments on these procedures to be considered by the Special Review Panel.
Employee recommen-dations for membership of subsequent Special Review Panels will also be solicitec'.
The Special Review Panel will study NRC's experience in handling differing professional opinions, evaluate the functioning of the differing professional opinion procedures by assessing the degree to which the objectives listed in Section B are accomplished, and make appropriate recommendations for change.
The Special Review Panel may recommend decreasing the frequency of these reviews when evaluations indicate the NRC procedures for differing professional opinions are functioning effectively.
The findings and recommendations of the Special Review Panel will be reported to the EDO, the Commissioners, and to all NRC employees, and the report will be made public.
13.
Recognition of Originators of Significant Differing Professional Opinions In addition, ecch year the Special Review Panel (described above) will review all differing professional opinions submitted during the prior year to identify employees whose differing professional opinions made significant contributions to the agency or to public safety but who had not been recognized by his or her supervisor.
It is anticipated that individuals who provide significant contri-butions to the agency or to public health and safety will be recognized for appropriate awards by their immediate supervisors.
Where award recommendations have not been made, they may be made by the panel in accordance with provisions of NRC's Incentive Awards Program (Manual Chapter 4154).
Copies of these recommen-dations will be included in the Special Review Panel's written report to the EDO and the Commissioners.
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ATTACHMENT 2 4
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UNITED STATES y
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NUCLEAR REGULATORY COMMISSION 3
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,8 ADVISORY COMMITTEE ON RE ACTOR S AFEGUARDS f
g WASHWGTON, D C. 20655 E
't February 24, 1977 l
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Honorable Marcus A. Powden Chaire.an U. S. Nuclear Regulatory Comission Washington, DC 20555
SUBJECT:
RESOLUTION OF DIFFE:#EES OF OPINICN A.40!K3 'IHE NRC STAFF 1
Dear Mr. Rowden:
g During the past few months, the ACRS has, in response to the request in your letter of Novem1:er 5,1976, reviewed 27 technical issues raised
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by members of the NRC Staff.
Many of these issues arose from differing g
subjective judgments concerning safety significance or priorities, 'abile others represented differences of opinion concerning accepted NRC Staff approaches.
The Comittee believes that much benefit can accrue to the NPC Staff from I
the discussion of differing opinions before an impartial but knowledge-able and interested panel, but that it would be preferable to establish a forum for this purpose within the framework of the Comission and the NRC Staff itself.
The ACPS would, of course, like to be advised of the technical matters
(
involved i: such reviews and the bases for the judgments reached, and will continue to be prepared to offer advice on those matters that may 51
)
be deemed appropriate by the Nuclear Regulatory Comission.
i Sincerely yours,
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i M. Bender Chairman
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ATTACHMENT 2
[M "%'c, ATTACHMENT 3 UNITED STATES
~i NUCLEAR REGULATORY COMMISSION
.y7 3-I ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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WASHINGTON, D C. 20555 h"-
gv f November 9, 1979 N. Haller, Director Office of Management and Program Analysis
Subject:
PROPOSED POLICY AND PRTEDURES FCR DIFFERING PRCFESSIO4AL OPINIQiS, NUREG-0567 In accordance with the memorandum from Chairman Hendrie requesting mm-ments on the subject document, the following are provided regarding the p rticipation of the ACRS in this process.
These comments are based on discussion with the Commitree.
Revise paragraph 6.b. to read as follows:
b.
The ACRS If the differing professional opinion relates to a poten-tial safety issue within the parview of the Advisory Com-mittee on Reactor Safeguards, an NRC employee may cornuni-cate orally or in writing directly with the Chairman or any member of the ACRS. Such communication may be anony-Imus. The ACRS will append comments, as appropriate, to all written statements of differing professional opinion and will forward these statements for resolution to the appropriate NRC office director.
An NRC employee may also appear before the ACRS or an ACRS Subcommittee as deemed appropriate by the Ccenittee.
The ACRS will assure that all such statements that do not constitute a differing professional opinion are forwarded to the appropriate NRC of fice director for inforration.
R. F. Fraley Executive Director cc: ACRS Members H. H. E. Plaine ATTACHMENT 3
ATTACHMENT 4 o
ACRS MEMBERS GUIDE FOR USE OF MISCELLANE00S EXPENSE FUNDS SEPTEFEER,1979 ATTACHMENT 4
?ACKCKUD THE AUTHORITY FW ACES IhMBERS USE OF MISCELLNiEOUS EXPENSE FUOS IS CCrHAINED IN ITEM M4 0F "E-PLOYMBH CCf4DITIONS FOR CONSULTNRS NO ADVISORS" ATTACHED TO Y0m If0!VIDlML LETTERS OF APPOINTENT.
ITEM 4 READS AS FOLLOWS:
"YOU ARE AUTFORIZED TO PROCWE FILING EQUIPMENT SUCH AS BOOKCASES NO FILING CABINETS AS NECES-SARY FOR STORAGE OF M LINEAR FEET OF DOClfiENTS NO CORRESPONDENCE, WOODEN OR ETAL FILE BOXES, NO MISCELLN4EOUS EQUIPMalT SUCH AS HOLE PU4CHES, 3 x 5" CARDS, LOOSELEAF NOTEBOOKS, FOLDERS, ETC.
MISCELLN4EOUS EXPDiSES SUCH AS RENTAL FEES FOR SAFE DEPOSIT BOXES, SHIPMa4T OF DOCtFENTS, STENO-GRAPHIC, TYPEWRITING, ENGINEERING AIDE ASSISTANCE NO CLERICAL ASSISTNICE RELATING TO THE PROCESSING, STORAGE MiD/OR COOLIT OF OFFICIAL BUSINESS ARE ALSO AUTHORIZED.
REIMBmSEENT FOR LONG DISTANCE PFONE CALLS Ct10FFICIAL BUSINESS WHEN FIS IS fOT AVAILABLE IS ALSO AUTHORIZED. EXPEf0lT WE FOR THESE ITEMS WILL fOT EXCEED $5,00] IN ANY 01E FISCAL YEAR."
. GUIMLItES FOR LEE CF MISmIMECG ENf6E FUES - ACPS WWERS 1.
EculmE*iT FUiDS CAN BE USED TO PWCHASE FILING Af0 DOCUENT IW4A EQUIPMENT WHICH C#1NOT BE READILY OBTAINED FRm IS MORE ECONOMICAL TO PWCHASE LOCALLY RATER TH/44 THE ACRS OFFICE (BOB ftKINNEY - EESSIE DUOR tlRCS0mCES.
ADVISE YOU ON WHICH IS THE MOST ECCt10MICAL ROUTE.
IF YOU USE THE FU G TO P WCHASE NON-EXPENDABLES SUCH CABINETS, BOOKCASES, MICROFICHE CABINETS, ETC., THE ACf6 0FF WILL PROVIDE YOU WITH NRC PROPERTY TAGS TO AFFIX TO T MENT FOR ACCOUNTABILITY P WPOSES.
AT THE EtO OF YOUR TENURE AS #4 ACRS ftMBER, Nott-EXPEICABLES CAN EITHER BE RETWNED TO NRC OR DONATED TO A LOCAL WIVE OTHER PUBLIC INSTITUTION, IF A NEED EXISTS M4D SHIPPING COSTS FAVOR W IS ALTERNATIVE.
INANYEVENT,ARECORDOFTHEDISPOSI-TION WILL BE REQUIRED. PLEASE CCt4Sil.T WIE 80B ftKINN THWST0t4 FAULDER ON QUESTIONS OF DISPOSIT10N OF EQUIP
N 2.
EWENDAELE SUPPUES_
e AS INDICATED, MISCELLNIE00S FLtOS C#4 BE USED TO PURC THISINCLUDES StPPLIES NECESSARY FOR THE CCNDUCT OF ACRS B ALL THE EXPEtOAPLE SLPPLIES, (PAPER, NOTEBOOKS, PENCI CNIDS, PAPER CLIPS, ETC.) NEEDED FOR YOW LOCAL OPERATIO ALTERNATIVELY - THESE ITEMS C#4 BE OBTAIN CHANNELS - SEE IHWST04 FALLDER NO E WILL EIT DIRECTLY TO YOU OR SHIP THEM TO YOU.
3.
oERSONNELSERVICES AS INDICATED IN THE NOUENT (PAGE 1) YOU ARE AU TO PROCWE PERSONNEL ASSISTN4CE SUCH AS CLERICAL, STD10-THIS IS GRAPHIC, TYPING OR ENGINEERING AIDE ASSISTANCE.
ACCOMPLISHED BY AN ARRANGEMalT DIRECTLY BE THE PERSON PROVIDING THE ASSISTANCE IN WH EMPLOYEE, OBTAINS A RECEIPT WHICH INDICATES THE DAT OF HOWS WORKED AND THE RATE OF PAY, PRESENT (THROUGH BESSIE DLIOR) AND RECEIVES REIM BWSEENT SECTIO 4.
_q_
WITH REGARD TO DETERMINING RATES OF PA'rFENT FOR PERSONNEL SERVICES, THE LOCAL RATE THAT SIMILAR SERVICES CAN BE OBTAINED Of THE OPEN MARKET SH0tLD BE USED.
fG EXN4PLE, IF YOU NEED STEf40 GRAPHIC ASSISTANCE YOU SHOULD PAY AN HOURLY RATE SIMILN TO THAT Belt 4G PAID LOCAL PUBLIC STENOGRAPHERS OR TEMPORARY SECRETARIAL HELP (" KELLY GIRLS", ETC.)
A Nd4EER OF THE PEMBERS HAVE EEEN ABLE.TO OBTAIN FILING AND TYPING ASSISTN4CE FRCti LNIVE?.SITY STUDENTS OR OTHER LOCAL STUDEt4TS AT OR NEAR THE MINIMLJi WAGE, l.E., $3,W - $4,W PER H0lR. OF C0mSE, E)PERIEfJCE FACTORS #4D OTHER C04SIDERAT10NS -
EFFIC IF_NLY, THOROUGHNESS, ATTENTION TO DETAIL - ENTER INTO THE WAGE EQUAT10f4 M4D WE BELIEVE IT IS DESIRABLE TmT THE tEMBERS RETAIN SOff FLEX 1BILITY IN THIS AREA.
OUR EXPERIENCE HAS BEEN THAT THE NRC CONTR0d.ER DOES NOT CLESTIC CLAIMS FOR WAGE PAYMENTS BASEP Cil RATES THAT OTHER PRUDENT EMPLOYERS IN THE LOCAL AREA ARE PAYING FOR SIMILAR SERVICES.
~
1.
4.
PEIN20RSEMENI ftMBER CLAIMS FOR RElf'BWSEER FOR EXPEtOITmES FOR EQUlF*' bit, SUPPLIES ARE FILED ON STNGRD FORM 10%
"PuBuC VOUCHER FOR PmCHASES u O SERVICES" WITH APPROPRIATE RECE! PTS THE RECEIPTS MUST INDICATE #0WT PAID, DATE PAID, CHECK NO.,
ASMPLEWORK OR IF BY CASH, #4D BE SIGNQ BY THE EMBER.
CURREffTLY SHEET NO A FORM 10% ARE ATTACED TO THIS PNPFLET.
CLAIMS FOR PAYMENT ARE BEING PAID APPROXIt%TE BESSIE D.f4DR CAft ASSIST NO PROVIDE GUIDN4CE IN SUBMITTAL.
SUEMITTING CLAIMS.
IN SUBMITTING CLAIMS YOU ARE REMIPOED THAT THE CmRE LIMITATION APPLIES ON A FISCAL YEAR (OCTOB BASIS.
o00
,p a e s g' UNITED STATES
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'J NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS g A4, wasmcros.o c 2csss
%,,,,,J November 13, 1919 The Honorable Morris K. Udall, Clairman Subcommittee on Energy and the Envircreent Comittee on Interior and Insular Affairs United States House of Representatives Washirr3 ton, D. C.
20515
Dear Mr. Chairman:
The Advisory Committee on Reactor Safeguards (ACRS) Subcommittee on Relia-bility and Probabilistic Assessment is conducting a program to discuss the establishment of quantitative safety goals for the overall safety of nuclear power reactors. This will include discussions of views on the suitability of goals and criteria for the safety of nuclear plants as related to goals and criteria for the safety of other aspects in our technological society.
The next general meeting of the ACRS Subcommittee will be held on December 5,1979 in Washington, D. C. and will consist of presentations and round-table discussions by representatives of several Goverraent agencies and other groups that have used or considered quantitative risk assessment methods in their decision making process (See enclosed presentation schedule).
Information discussed during this and succeeding meetings will be used by the ACRS as one basis for the develognent of recommendations regarding quantitative safety goals and criteria for nuclear power reactors for considerativa by the NRC.
If successful, it is hoped that these and other effortr will lead to develognent of risk acceptance criteria or goals that the NRC could publish for com.ent and ultimately present to the U. S.
Congress for its consideration.
This letter is to invite members of your Subcommittee or its staff to attend this meeting or future meetings on this subject.
Please inform Mr. Gary Quittschreiber, ACRS Staff, Washington, D. C.
20555, regarding your plans to attend (202/634-3267).
Sincerely, DM Nl b,
David Okrent Chairman, ACRS Subcommittee on Reliability and Probabilistic Assessment Enclosure. As stated cc: Henry Mfers
+
/
NThe Honorable Paul N. McCloskey, Jr.
Subcommittee on Environment, Energy, and Natural Resources Comittee on Government Operations United States House of Representatives Washington, D. C.
20515 n e Honorable Morris K. Udall, Gairman Subcomittee on Energy and the Environment ec: Henry Myers Comittee on Interior and Insular Affairs United States House of Representatives Washirgton, D. C.
20515 The Honorable George E. Brown, Chairman ec: John D. Holmfeld Succommittee on Science, Research, and Technology Comittee on Science and Technology United States House of Representatives Washington, D. C.
20515 The Honorable John D. Dingell, Chairman Subcommittee on Energy and Power cc: Mike Ward Committee on Interstate and Foreign Commerce United States House of Representatives Washington, D. C.
10515 The Honorable Clarence J. Bro'on Subcommittee on Energy and Power Committee on Interstate and Foreign Commerce United States House of Representatives Washington, D. C.
20515 The Honorable Dan Ritter Subcomittee on Science, Research, and Technology Bob Leach-an Comittee on Science and Technology cc.
U't.ted States House of Representatives
'mshington, D. C.
20515 The Honorable Anthony T. Moffett, G airman Subcommittee on Environment, Energy, and Natural Resources cc*
Bob Brown Committee on Government Cperations United States House of Representatives Washington, D. C.
20515 he Honorable Steven Syms R. Terrell Subccr:nittee on Energy and the Environment ec:
Comittee on Interior ard Insular Affairs E. 01akoff United States House of Representatives Washington, D. C.
20515 The Honorable Alan Simpson Subcomittee on Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, D. C.
20510 The Honorable Gary Hart, Gairman Subcommittee on Nuclear Regulation Mr. Gus Speth Committee on Environment and Public Works United States Senate Council on Environmental Quality 722 Jackson Place, N. W.
Washington, D. C.
20510 Washington, D. C.
20006
is>* ** %
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/
UNITED STATES J **
NUCLEAR REGULATORY COMMISSION I
5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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W ASHINGToN O C. 20555 Nove-te r 13, 1979 Mr. Gus Speth Council on Envirornental Quality 722 Jackson Place, N. W.
Washington, D. C.
20006
Dear Mr. Speth:
The Advisory Cornittee on Reactor Safeguards (ACRS) Subcorcittee on Relia-bility and Probabilistic Assessment is conducting a program to discuss the establishment of quantitative safety goals for the overall safety of nuclear powr reactors. This will include discussions of views on the suitability of goals and criteria for the safety of nuclear plam as related to goals and criteria for the safety of other aspects in our technological society.
The next general meeting of the ACRS Subcoccittee will be held on December 5,1979 in Washingtc.', D. C. and will consist of presentations and round-table discussions by representatives of several Government agencies and other groups that have used or considered quantitative risk assessment methods in their decision making process (See enclosed presentation schedule).
Infomation discusred during this and succeeding meetings will be used by the ACRS as one easis for the development of recomcendations regarding quantitative safet.y goals and criteria for nuclear power reactors for consideration by the NRC.
If successful, it is hoped that these and other efforts will lead to develo; rent of risk acceptance criteria or goals that the NRC could publish for comment and ultimately present to the U. S.
Congress for its consideration.
This letter is to invite members of your Council or staff to attend this meeting or future meetires on this subject.
Please infor n Mr. Gary Ouittschreiber, ACRS Staff, Washirston, D. C.
20555, regarding your plans to attend (202/634-3267).
Sincerely, David Okrent Chairman, ACRS Subcommittee on Reliability and Probabilistic Assessment
Enclosure:
As statd
. - _ _