ML19305A714
| ML19305A714 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/22/1979 |
| From: | Evans D, Kenneke A NRC - NRC THREE MILE ISLAND TASK FORCE, NRC OFFICE OF POLICY EVALUATIONS (OPE) |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001280529 | |
| Download: ML19305A714 (69) | |
Text
{{#Wiki_filter:, :, l <q o, o i f-- J N U Cl. E A R R E G U i. A T O R 'l C O M M I S S I O N S j ~.) l 1 i I j IN THE MATTER OF: I, THREE MILE ISLAND SPECIAL INQUIRY DEPOSITIONS I DEPOSITION OF ALBERT P. KENNEKE ,~ 'v/ Place - Washington, D. C. Date. Monday, October 22, 1979 Pages 1 - 59 @ n)Ib )f h N[l0 bflIll j flau' La ns n ( v' T.i.ewn.: (202)347-3700 '^) ACE - FEDERAL REPORTERS,INC. OfficalReponers 444 Nenh Capitol Stree6 Q Q 3 g g 0 Washington, D.C. 20001 NATIONWIDE COVERAGE - DAILY /
1 UNITED STATES OF AMERICA i ,i~s() 2 NUCLEAR REGULATORY COMMISSION 3
X 4
In the Matter of: 5 THREE MILE ISLAND 6 SPECIAL INQUIRY DEPOSITIONS
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8 DEPOSITION OF ALBERT P. KENNEKE 9 10 Room 1122 1717 H Street, N.W. 11 Washington, D. C. 12 Monday, October 22, 1979 1:00 p.m. O 13 BEFORE: 14 For the Nuclear Regulatory Commission: 15 DAVID EVANS, ESQ., TMI/NRC Special Inquiry Group 16 C. O. MILLER, TMI/NCR Special Inquiry Group 17 18 19 20 21 - 22 23 24 so Feder-2 Reporters, Inc. - 25 i e I ,..,,.r- -.w
2 i _C O _N _T _E _N _T _S j .O 2 l WITNESS: EXAMINATION i 1, 3 Albert P. Kenneke 4 j. .4 e. 1 i 5 0 _E X _H _I _B _I T _S 7 EXHIBIT NUMBER: IDENTIFIED i 8 1103 8 ii 9 1104 19 10 i 11 } 12 O '3 14 15 16 17 18 19 20 21 0 22 23 O 24 mes-Feder*J Reporters, Inc. 25 l
CR 7828 3 LOU #1 jtf 1 1 MR. EVAN'- This is a deposition of Mr. Albert rm., / 2 Kenneke. It's being conducted by the NRC/TMI Special Inquiry 3 Group. 4 This deposition is being held at the H street offices of 5 the Nuclear Regulatory Commission on October 22nd, 1979. 6 Present, in addition to Mr. Kenneke, are C. O. Miller and 7 David Evans, of the Special Inquiry staff. 8 Mr. Kenneke, did you re.ceive a letter signed by a Mitchell 9 Regovin informing you of this deposition and outlining your 10 legal rights? 11 MR. KENNEKE: Yes. 12 MR. EVANS: Have you had an opportunity to read that () 13 and do you understand its contents? 14 MR. KENNEKE: Yes. 15 MR.' EVANS: Me. Kenneke, do you have an attorney 16 present with you today? 17 MR. KENNEKE: No, I do not. 18 MR. EVANS: Are you willing to proceed without an 19 attorney? 20 MR. KENNEKE: Yes, I am. 21 MR. EVANS: Do you understand that, if at any time ) 22 during this deposition, you would like to have an attorney 23 present, you may recess the deposition until you have obtained 24 counsel? Ace Federal Reporters, Inc. 25 MR. KENNEKE: Yes. l
4 jtf 2 1 MR. EVANS: Will you please stand and raise your (O) 2 right hand. 3 Whereupon, C'J i 4 ALBERT P. KENNEKE 5 was called as a witness and, having been first duly sworn, 6 was examined and testified as follows: 7 BY MR. EVANS: 8 G Mr. Kenneke, have you brought a resume with you today? 9 A Yes, I have. 10 0 I'll show you what has been previously marked as 11 Exhibit 1102. Is that your resume? 12 A Yes, it is. () 13 G Would you please state your full name for the record? 14 A Albert P. Kenneke. 15 MR. EVANS: Mr. Miller. 16 BY MR. MILLER: 17 G Mr. Kenneke, as I mentioned to you by telephone, 18 the area of my inquiry today will be in the general sense of 19 the safety engineering and safety management field. Insofar 20 as you can reference your answer to things as specifically 21 associated with the TMI 2 event, so be it. But we are not () 22 restricting our questioning to that as such. 23 Also, I have had the benefit of reading many documents () 24 associated with TMI 2 and the organization of NRC and, WFederd Reporters, Inc. 25 accordingly, don't hesitate to, rather than search your own 1 ... - - - 1
5 r jtf 3 1 memory for certain things, if you can't think of some documents O \\- 2 that perhaps I have already read or should read which answers 3 the question more clearly than you could at this moment, don't 4 hesitate to call our atention to that, and we'll seek the 5 answers there. 6 Finally, by way of preliminary, if anything in my questions 7 leaves you confused in terms of definitions of the words or 8 any other matter that requres clarification, don't baJitate 9 to ask me to do so. 10 A Fine. 11 G Referring to your personnel resume, I am curious 12 if in any of this background you have had any experience in () 13 what might be called systems management? 14 A I'm not sure what the meaning of the term would be. 15 Why don't you describe it to me. 16 G All right. Systems management that's been applied 17 to the management of relatively complex systems. 18 A Talking about technical system, hardware? 19 G Well, no. Let me explain a little further then 20 because what we're referring to is not only technical systems 21 in the hardware sense, but things which have been known in ~() the trade as software paperwork, if you will -- processes, 22 '23 facilities, the people, as a part of the system. And so when f3 (,) 24 we're talking about systems management, it's a relatively Ace Federd Reporters, Inc. 25 broad context of management that goes well beyond any one of
6 jtf 4 1 these variables I just mentioned to you a moment ago. pl tx/ 2 A I don't think I have had experience in. systems 3 management insofar as it applies to technical hardware, but g \\- 4 in terms of the process and particularly the process of 5 regulatory review of applications, I can relate to that. 6 Yes, I have. 7 G Other than your work here at the Nuclear Regulatory 8 Commission, were you involved in any safety work as such? 9 A My resume will show that I have been a health 10 physicist prior to coming to NRC. 11 G I see that your activity at the University of Michigan 12 was -- one of the titles was Deputy Radiation Safety Officer. ,,) 13 A That's Sloan Kettering. ( 14 G I'm sorry. Sloan Kettering Institute. 15 Could you give us a brief description of what that job 16 entailed? 17 A Well, I was the principal health physicist for that 18 institution for some six or nine months while I was there. 19 It involved a hospital anM research organization concerned 20 basically with the development, research and medical uses of 21 radiatian and its application, and I had a small staff of ,cy (_) 22 two people to handle that work. 23 G In that capacity, were you essentially an advisor (. )s 24 in how to eliminate hazards or how it affects safety in this Ace-Federd Reporters, Inc. 25 area?
7 l jtf 5 1 A Yes. Right. O 2 O I want to show you, Mr. Kenneke, some documents here 3 that I'm not going to enter into the record only because I O 4 don't intend to question you on the details, but rather just 5 to see if you recognize them by title. 6 The first one is -- would you please read the title into 7 the record and the date please. 8 A Military Standard Systems Safety Program Requiremente, 9 July 1969. 10 I'm not familiar with it. 11 Q All right. Similarly, would you take this document 12 I hand you and read the title into the record there. O_/ 13 A NASA Safety Manual, Volume 3, Systems. Safety. s 14 I'm not familiar with that. 15 G And let me read this into the record a little closer 16 for you. This is a safety management program developed for 17 ERDA -- e-r-d-a -- with the acronym MORT -- m-o-r-t -- which 18 stands for management oversight risk tree, and this particular 19 book that I show you happens to carry the designation of ERDA 20 77-38, and I ask you if you're familiar in any way with t'.at 21 type of program. P 'J 22 A Yes, I am familiar with that. I recall se'eing a 23 rather thick report labeled the same thing some five or seven g% () 24 years ago, and I did some paging through that, but unfortunately - Aes Federd Reporters, Inc. 25 I was never able to study it in detail. I
8 4 .jtf 6 1 G I take it then, you personally have never gone through \\ 2 any training course associated with this? 3 A No, I have not. 4 G Do you have any association with the MORT program 5 in your current position? 6 A No, I do not. 7 G Do you have any personal familiarity with the Americar 8 Society of Safety Engineers? 9 A No, I do not. 10 G Do you have any personal familiarity with the National 11 Safety Management Society? 12 A No, I do not. i () 13 G Do you have any personal association with the 14 Systems Safety Society? 15 A No. 16 MR. MILLER: I wonder if we could mark this document 17 as an exhibit, please. That's Exhibit 1103. 18 (Exhibit 1103 identified.) 19 MR. MILLER: Permit me, Mr. Kenneke, to identify 1 20 this for the record and then I will ask you in a moment whether 21 you agree with my description of it. O) Exhibit 1103 is an excerpt from the NRC manual, specifically (_ 22 23 Chapter NRC-Oll8, Organization and Functions of Policy () 24 Evaluation. Ace-Feded Coporters, Inc. 25 The e::hibit consists of five pages, numbered for the
9 jtf 7 1 purposes of this deposition, in the lower right-hand corner. 2 Such numbers are encircled. 3 The exhibit summarizes the functions of the office of 4 policy evaluation. 5 BY MR. MILLER: 6 G Mr. Kenneke, would you agree that that is a reasonable 7 description of these five pages? 8 A Yes. 9 G To your knowledge, is this date on here, August 19, 10 1975, the most current version? 11 A I believe it-is. 12 g With reference to this exhibit, and as you wish and O ia certaiatr, vreferabtv 1a voor owa woras, ar xeaaexe, oou1a 14 you give us a summary of your general duties and functions of 15 the office of policy evaluation. 16 A Primarily to assist the commissioners in their 17 process of evaluating the policy proposals reaching decisions. 18 It involves review of staff papers, providing independent views 19 when that seems advisable, providing specific analyses as 20 requested by the commissioners and, on occasion, a long-range 21 project of greater or lesser dimensions to provide additional 22 technical input. 23 4 Am I correct, you are the acting director of this ) 24 office of policy evaluation at the present time? Ace-Feder;l Coporters, Inc. 25 A That's right. t-
10 jtf 8 1 G How many people are under your supervision? g (_) 2 A At the moment we have 13, 3 0 And what are the general qualifications or scope of f K/ 4 qualifications of the people that are in this office? 5 A They include technical people, include administrative 6 people, people with some degree of management background, 7 writers, writing backgrounds, primarily technical backgrounds 8 related to nuclear engineering, economics, radiation protection 9 and related matters related to NRC stuff. 10 G Calling your attention to this Exhibit 1103, let me 11 ask you in a few questions about specific paragraphs in each. 12 A This is'now the manual chapter, 1103? f) 13 G Yes. In each instance I would -- I will, I guess 14 the first one here, I've got to get the clarification of a 15 word that I don't understand. I call your attention to 021, 16 the left-hand column of the first page, which reads as follows: 17 "provides an independent evaluation for the Commission of 18 Program Policy Objectives, incorporating an assessment of such 19 ftvors as governmental policy and objectives, and their 20 .,r.; n o m i c, technical and societal impact." 21 A I believe that should say " factors." I hadn't g(,) 22 noticed that. 23 G Thank you. That was my question. 24 A .Never noticed it before. A* eowet ceponne, w. l 25 O Could you, with reference to that paragraph 021, i L
11 jtf 9 1 give us an example of something that has been dc..c unich fits () 2 that description? 3 A I'm trying to think of the most recent, but one that (-(_) 4 comes back goes back quite a long way and was something I did 5 I think the first year of OPA, which was comments on a staff 6 proposals to begin the systematic evaluation, what is now 7 called systematic evaluation program. It involved basically ctats? 8 a commentary on the stats proposal and asking a number of 9 questions about the feasibility of the planning of it. 10 G Does that systematic program evaluation program 11 you mentioned have any other title? 12 A I believe that's the current title used by the (~} 13 office of NRR. It's centralized, primarily, in DOR. There is, v 14 in fact, I think, a system evaluation program branch. 15 G Does it carry a new reg or similar designation, 16 to your recollection? 17 A No, it's a program. They're re-examining, I believe, 18 it's 12 of the original power plants licensed for operation. 19 G Is there any particular memorandum or document that 20 describes this? 21 A There were a series of staff papers, at least one I') 22 in each of the years '76cthrough '78, I believe. At least G 23 three staff papers on the subject informing the commission 24 of what was proposed, keeping them up-to-date on the status Am#- wW Reorters, lrc 25 of the proposal. j l
12 f 10 1 0 Would it be possible for you to sup,ty for the record 2 a representative, one of those -- perhaps the most recent staf f 3 paper that summarizes this? ps (_/ 4 A Surely. 5 G Thank you. Calling your attention next to the right-hand column on page one, paragraph 032, which reads as follows -l-6 7 and chis is under " delegation of authority to the director" -- 8 "032" reads: " recommend to the commission, following 9 independent evaluation of program policy objectives, alternative 10 policies and positions and their impact upon the objectives of 11 NRC." 12 Does any particular example come to your mind that is (7 \\_/ 13 ill".strative of this duty? 14 A My mind goes blank within the context but, yes, very 15 frequently we offer separate views as to where to go on a 16 particular staff proposal. In particular, we might suggest 17 where there appears to be a spectrum of views, a middle course. 18 We might propose something quite different than is being 19 proposed and frequently we will simply offer an adjustment 20 to a proposal. 21 G Are these independent evaluations and assessments ('N t t x/ 22 a matter of technical -- meaning nuclear engineering technical -- 23 nature or are they associated with management or perhaps a (; U! 24 combination thereof? Ace Federal Reporters, Iric. 25 A I would say mostly a combination. Occasionally in I
13 jtf 11 1 the context of policy development. Usually it's more of the 2 policy angle, but it's approached from a background of technical 3 experience, nuclear engineering included. O 4 0 I call your attention to this exhibit, page three 5 circled in the lower right-hand corner and particularly one 6 of the first things shown that is described under Section B 7 "the assistant director for policy review," which reads as 8 follows: " brings significant policy issues to the attention 9 of the Commission in a timely fashion." 10 First of all, am I correct that this could be bringing a 11 policy issue to the attention of the Commission which is 12 generated from within your office as distinct from having () 13 been sent to you by somebody else? 14 A I can't think of one, but I believe that would be 15 true, that we do originate some. The closest one I can recall, 16 for example, would be one on radiography, where we felt that 17 there had been a series, over the years, of over-exposures 18 to radiographers and people working around them, and we very 19 strongly recommended to the Commission t. hat something had to be 20 cdone about the design of the radiography devices, as opposed to 21 the staff's previous emphasis which had been primarily on the OV 22 training of operators.. 23 g You have already answered my next question, because () 24 I was going to ask you for examples, and you just gave me one. Aco-Federal Reporters, Inc. 25 Let's go on to B-4, which reads as follows: " initiates and
14 jtf 12 1 prepares at Commission request, issue papers addressing major p) (_ 2 policy interests." And I wonder if you could give us an 3 example of one of those, if it comes to mind. ~() \\_/ 4 A I don't have a ready example, but I'm sure there 5 are some. My mind is blank at the moment. I'd have to think 6 a little bit more about that one. 7 G Again, if it wouldn't be too much trouble, would you, 8 in submitting some material to us after this, just a paragraph 9 describing an example of B-4, 10 A Sure. 11 G All right. Let's now look in the right-hand column 12 on that same page three, wherein the functions here are listed ('~D 13 under the assistant director for special projects. And I LJ 14 wonder if we could get an example of, if possible, of each of 15 the first three. And let me read the first one into the 16 record here: " initiates and conducts studies that are of 17 special interest to the Commission which, because of their 18 non-recurring or sensitive nature, are best performed at the 19 Commission level." 20 Any projects that you can think of that illustrate that 21 function? [; 22 A Well, the closest one that comes to mind -- but it x_s 23 .k s not been exclusively in the Commission level, by any means, [) 24 is the NASAP. Ace-Fed'erJ Reporters, Inc. 25 G And would you explain that for the record? I
15 jtf 13 1 A That has to do with the developing alternative ((/ 2 systems for nuclear power plant systems that would be more 3 proliferation resistant. There are a number of areas in 4 which the Commission relies very strongly on OPE and 5 particularly in the international area. And, not being as 6 familiar with that as some others, I don't have a specific 7 on that, but that's a frequent occasion. 8 G Well, in connection with that item, is it reasonable 9 to conclude that, based on these words of the sensitive nature, 10 that there are certain policy matters which understandably are 11 kept pretty c.'ose to the Commission until resolved, and your 12 office would be the one that would handle such a matter? () 13 A That's right. Along with the office of general 14 counsel. 15 Let me come back to y'our item B-4. Over the years OPE has i 16 written a number of papers on the subject, for example, of 17 intervener funding, a subject of some concern in the years 18 before. I would say, in general, however, policy items that 19 we might independently write on more often than not are not 20 fundamentally technical. In other words, we would not -- 21 well, I guess I have to narrow that even further, when I think ,m() 22 about it. Reactor safety-wise, I think there's very heavy 23 reliance on the staff for its technical comments. h 24 The exceptions to -that are pretty rare, and one of them A*r.o.r; n.pon.n, inc. 25 I can think of is safeguards. OPE's history is such that there i
16 jtf 14 1 has been heavy technical input from OPE on matters of safe-V 2 guards and safeguard policy -- domestic safeguards. 3 (L How would you define safeguards as it is used here? () V 4 A. I'm talking about the control of nuclear materials 5 to protect it from being either used as a direct hazard to c.t.
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people or used to make nuclear weapons. 7 8 9 10 11 12 t ') 13 V 14 15 s 16 17 18 19 20 21 ,sm 23 9 24 Am oderd Reporters, Inc. 25 1 l
1 CR 7828 WAIBEL i t-2 mte 1 I G Referring back to the right-hand column on page 3, s 2 Item C.2., wherein the Assistant Director for Special Projects, 3 p quote, " manages studies and projects involving personnel d drawn from other NRC offices, especially in cases where the 5 subject matter of the activity cuts across normal organiza-6 tional boundaries and interests," do any particular i.njects 7 come to your mind there that illustrate that function? 8 A. No. If that's happened, it has been a very rare 9 case, but we have in fact managed it. There was a study of 10 the functions of -- I think it was called the so-called 11 " Inspection Study" the first year, 1975 to 1976 or thereabouts, 12 where OPE had a very heavy role. But my recollection was that 13 it was not managed by OPE as such, but OPE had a very strong role in it. G And just below that we have the function odescribed 16 as, quote, " participates in studies being conducted and I7 managed by other NRC offices or outside agencies where these 18 studies are of broad policy relevance and direct representa-19 tion from the Commission level is deemed useful." 20 A. Hold on a minute. I answered earlier your question 21 -and I thought you were more referring to C.3 at that time. Can we take that answer now to be my answer to C.l? 3 Let me start over again. I was answering a different 24 go, question. Let me try C.1 and C.3 in order. 25 I think you did ask about C.1 before, didn't you? And I l l
mto 2 18 1 thought you were referring to C.3. When I was looking at it, .-m 2 my eye caught C.3. 3 g Let me interrupt you and just for clarification of 4 the record, just take them one, two, three, in that order. 5 A Under C7 4 6 G Right. 7 A Okay. I'd say the number 1, C, most of the studies 8 that have been done would be in the international area and 9 the so-called domestic safeguards that I just mentioned.
- Now, 10 that quote, "are best performed at the Commission level," is 11 not necessarily the case.
I'm trying to think of both combi-12 nations. () 13 I don't have a specific that would have both aspects 14 involved. 15 Number two, that would be the I&E study, except that I 16 think that while OPE had a major role, it was not the manager 17 of the study. The Inspection Study -- I don't call that the 18 I&E study, I call it the Inspection Study. 19 Number three would be NASAP. 20 Number four -- you want four? 21 g No. (~h \\_) 22 A Okay. 23 g How do you view the Office of Policy Evaluation as , () 24 compared to the Office of Management and Program Analysis Aes. Federal Repo,io,s, Inc. 25 reporting to Mr. Gossick?
mto 3 19 1 A I think MPA is more concerned with -- as all of the () 2 staff --with the program implementation, policy and implementa-3
- tion, Jeporting, identifying, tracking program evaluation, (GJ 4
program development. OPE's role, I think, is much more of a 5 broad perspective to integrate, more of a longer-range nature; 6 one that is more directly sensitive to the Commissioners 7 individually and with an attempt to try and find the center 8 of that Commission. This is not easily done by the staff. 9 0 Are there any routine contacts you have with the 10 Office of Management and Program Analysis through staff meetings 11 or whatever? 12 A We do talk with them regularly on specific matters () 13 that occur from time to time. Coordination of various pieces Id of staff work. Their functions -- and they cover quite an 15 umbrella of different functions, and this has happened on a 16 fairly frequent basis. 17 MR. MILLER: I'd like to have this marked as 1104. 18 (Exhibit No. 1104 identified.) I9 MR. MILLER: Off the record. 20 (Discussion off the record.) ) \\ 21 MR. MILLER: Back on the record. 22 We have had marked for identification as Exhibit 1104, ,23 Mr. Kenneke', a cover page from the aforementioned, quote, (~) \\ 24 \\/ " Military Standard 882A," and two pages wnich are labeled ' Ame-F.emi n.ponen, Inc. 25 l pages 2 and 3, and I would like to ask you some questions l
20 mto 4 1 pertaining to the definitions which are on those pages of this 2 Particular exhibit. 3 BY MR. MILLER: \\-) 4 G First of all, calling your attention to the 5 Item No. 3.5, " Safety," which reads as follows: 6 " Freedom from those conditions that can cause death, 7 injury, occupational illness or damage to or loss of the 8 equipment or property." 9 I call your attention to the latter part of this definition 10 which defines safety not only in terms of people problems but 11 also damage to equipment, and I would ask you whether any 12 policy statement or document of any form that you can think (]) 13 of associated with the Nuclear Regulatory Commission uses 14 this definition of safety? 15 A No. I think we -- NRC and AEC before it have been 16 at pains to not take such things into account insofar as it l 17 means losses to the licensee in the operation of the facility. ) 18 But it does include, certainly, death, injury, occupational 19 illness. 20 G I call your attention to Item 3.6 -- 21 A Oh, let me clarify also. Certainly it would account () 22 for the fact that contamination off-site and loss of property 23 off-site would be part of our aspect insofar as that contami-
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24 nation would affect public health and safety. But in terms w ee.cs nepo,w,. inc. 25 of the facility losses, damage to equipment, there is a
i 21 mto 5 1 I direct concern of NRC or AEC's regulation that doesn' t in my
- ~s 2
view exist presently. 3 G To clarify that a little bit, if it's contamination .,D (\\s' 4 off-site of property, your ultimate safety concern is that 5 this contamination affects people, is that correct? 6 A Right. And therefore we would be concerned about 7 the loss of the property related to that. 8 G I call your attention next to 3.6 and the definition 9 of " System" as: "a composite, at any level of complexity, of 10 personnel, materials, tools, equipment, facility, and software. 11 The elements of this composite entity are used together in the 12 intended operational or support environment to perform a given 7-)s I3 (_ task cr achieve a specific production, support or mission Id requirement." 15 Now, this goes back to a previous question I think we had, 16 but I would ask you in the context of this definition of II " system," is there any NRC policy statement, documents, 18 program, whatever, which defines " system" in this terminology? A Not that I'm aware of. But it is not impossible. 20 G On the next page I call your attention to Item 17, 21 known as " System Safety." This Item 3.7 entitled " System (m kj 22 Safety" is defined as follows: "The optimum degree of safety 23 within the constraints of operational effectiveness, time, G i 24 and cost, attained through specific application of system Am FWWW Cmorters,1N. 25 safety management and engineering principles whereby hazards
22 mtO 6 1 are identified and risk minimized throughout all phases of the 2 system life cycle." 3 My question, Mr. Kenneke, is whether this terminology is, ss 4 to your perception, used in NRC's activities in any way? 5 A I think there's a school of thought that would more 6 or less subscribe to tt.is notion. It has to do with the 7 question of the degree to which you take economics into 8 account in your safety judgments. I think all would agree 9 that under some circumstances whatever is required to achieve 10 . safety will be required. II There are some who say that can be the only consideration 12 and others who say you can go beyond that, provided you take n 13 (; cconomics into account. I4 Does that -- that would be my answer to the thing.
- Yes, 15 there is a school of thought on this.
16 G You're familiar at least with the titis of II Roger Mattson -- M-a-t-t-s-o-n -- Roger Mattson's organiza-18 tion, the Division of Systems Safety, are you not? A Yes. 20 G Is it your understanding that their use of the 21 terms " systems safety" and " system safety" at defined here ry (_) 22 in Item 3.7 are alike? 23 A Yes, very similar. 2d G Calling your attention to Item 3.10, " System Safety Ace Federet Reponers, Inc. 25 Management. An element of management that establishes the
mto 7 23 1 system safety program requirements and ensures the planning, g -(_) 2 implementation and accomplishment of tasks and activities to l 3 achieve system safety consistent with the overall program nU 4 requirements." 5 I ask you, Mr. Kenneke, if system safety management within 6 this sort of definition exists at NRC? 7 A Well, insofar as we have an organizational structure 8 labeled that, yes, an element of management does exist. 9 G All right. Now, I'm going to ask you a number of 10 questions really in the same format, and the format will be 11 basically that I would like to know whether, within the 12' policies of NRC as you know them, certain things exist. So (]) 13 for example -- 14 A Could I back up a minute? Just a thought. 15 G Yes. 16 A The orientation of the military standard that you're 17 referencing it seems to me is aimed at the operator -- the 18 user. In our case, it would be like the licensee, and it's 19 a somewhat different orientation for the regulator than is 20 here, and to that degree I think that would affect these 21 -definitions. I) 22 I'm sorry to interrupt. 23 4 No problem. As I say, I'm going to give you a list (n) 24 of things.here and my basic question is going to be, are there Aco Federal Reporters. Inc. 25 NRC policies that speak to these particular points, and if L
24 mto 8 I they do, could you give them. That is basically what we're ~ 2 going to go into here, and the first item in that area is what 3 I will call ~a program of project management approach using a (,) 4 matrix concept of staffing and decisionmaking. And permit 5 me to define matrix as I am asking it in the question. A 6 matrix approach in management to me is one in which you have 7 a project or program manager who is provided staff as need be 8 from functional organizations. And the matrix tei.unology 9 comes from when you might have several projects down one 10 axis of the matrix and several functions along the other, and 11 that's where the terminology comes from. 12 I want to know whether, as a matter of NRC policy, that 13 program / project management and using the matrix concept, is I# that part of NRC's policy? 15 A. Yes. I think the NRR organization to a great degree I0 represents that. I7 I Some time in the past, in the early 70s, there was a 18 conscious decision to split the technical resources into' project management on the one hand and technical review 20 specialists on the other. And as a consequence, that's 21 specifically the two parameters. One is a case analysis on O'~) 22 the one hand, and the other is a specialties on the other. 23 0 Do you recall any, as I say, policy document or ,m-ya) %,,,,, i 24 organization document which describes to what extent program 25 . management and the matrix concept is to function here? L
25 mtn 9 l A Not in those specific terms. ) /^N. k-) 2 0 Is there a policy document or similar type instruc-3 tion which would describe the method of assignment of safety ,-) (_/ 4 tasks to the various offices? Again, let me phrase the 5 situation in which I ask this question: An issue or a problem 6 comes in to the Commissioners from the outside world. How 7 does it get to the various offices and what policy or procedure 8 covers that distribution? 9 A The normal route is through the executive director, 10 except insofar as the law permits the individual -- certain II individual office directors to report directly. Usually, it 12 would be in a written form and come by way of the executive {} 13 director. 14 g My question, however, is more, is there any kind of 15 a written policy within NRC that says how this is to be done, 16 to your knowledge? I7 A Well, the manual chapter and the delegation of 18 authorities would govern communications between staff and l9 Commission. 20 g Is there any policy or similar instruction in 21 existence at NRC that discusses how NRC treats the man in the O 22 Nuclear Reactors System? I'm thinking of this particularly (_j 23 from the standpoint of whether he's a positive influence on 9*9 amorwri,im. 24 safety, a negative influence on safety, or I guess in other A* 25 words, how he is to fit into the program. l.
mte 10 I A. Among the licensees, you mean? .g 2 G Yes, sir. 3 A I would -- my impression would be that in general O it's a consideration for which the staff would have said, we 5 don't take credit for it but we assume the operator will act 6 positively when necessary in an untoward situation. 7 In the normal situation, it's part of the quality assurance 8 program to do that, plus we have the operator trained to 9 operate a licensing program. Those three areas come to mind. 10 0 Is there any NRC policy or procedure which speaks 11 to the achievement of an effective organization in management I2 at the utilities? 13 A I believe the quality assurance program would speak to that. 15 And these are fotind in the standard review plan 0 16 and documents of that sort? I7 A Well, they're referenced by the standard review 18 plan. 19 G Have any top-level policy statements been issued 20 by the Commission in this area, to your knowledge, that is, 21 demanding certain performance of the utilities? 22 A In broad terms, I don't recall anything. Primarily 23 it's a staff function. In the past it has been staff 24 Aco Federal Reporte,s, Inc. ' 25 G Has any NRC policy ever been issued or instruction, i
mt2 11 27 I as the case may be, which deals with the use of either formal (/ 2 or informal safety boards or safety councils? Again, let me 3 m amplify that a little bit. The thrust of my question is to . tg 4 find out to what degree NRC nanagement encourages group 5 actions to resolve problems of a safety nature. I'm wondering 6 if they're -- 7 A. Non-NRC groups? 8 g Within NRC. And whether this use of group dynamics 9 is reflected in any policy document or instruction. 10 A. I'm not sure I understand the thrust of the question. The Commission often appoints task forces to resolve matters. 12 It expects that the staff will put together appropriate teams 13 to address various programs. Id I'm not sure I'm responding to the thrust of your question, 15 but that's the best I can think of at the moment. I0 MR. MILLER: Off the record. 17 (Discussion off the record.) IO-MR. MILLER: Back cn the record. BY MR. MILLER: 20 g Other than the so-called Ratchet Committee, are there 21 any standing boards or groups that you can think of which 22 could be thought of as an overall safety policy group or 23 safety review group? 2# A. Only ACRS comes to mind. t Am4ased neporwes,Inc. 25 g Is there any NRC policy or instruction which i
28 mto 12 i encourages the use of safety surveys or staff assistance 2 visits as distinguished from inspections or audits? And again, 3 let me clarify my question before I ask you to answer. 4 Inspections and audits I think are generally accepted as going 5 to an organization and evaluating their performance against 6 some preselected standard, and indeed, training the people in 7 a way against those standards. 8 The safety survey staff assistance visits, in my definition 9 of the term, is sort of a Whitehead approach, where you're out 10 there to help them, but there's no formal record made to the 11 people whom you are going to visit, and indeed, as the name -- 12 certainly, the staff assistance visit implies, it is just O 13 th t, with n ramificati n f enf rcement r adherence to 14 specific rule. 15 My question, then, is whether or not as a matter of policy 16 or instruction or procedure within NRC, are safety surveys 17 or staff assistance visits part of the method of operation? A. I don't believe so. 18 19 G Is there any NRC policy or procedure which defines 20 or encourages NRC people to participate in non-gov 2rnmental 21 Professional safety activities? 22 A. There is a fairly wide membership representation 23 by NRC staff members on committee and professional organiza-h 24 - tions. - Ace Fees,se neporte,,, Inc. 25 0-Is this a matter of formal policy or informal
29 mts 13 l I policy? O 2 A I would say it's a formal policy. There is -- it's 3~ a very heavy involvement with respect to standards program over O 4 the years. 5 g Are you aware of any literal -- anything written 6 which identifies which groups of people should participate in 7 or how this comes about? 8 A I can only reference the Office of Stanc,.- 9 Development. They can tell you in more detail as to precisely 10 how that policy operates. I'm sure it's with the full know-II ledge md support of the Commission. 12 g Similarly, is there any NRC policy, procedure, or O 13 v instruction, that deals with participation in inter-agency, Id that is, intergovernmental agency, safety activities, such 15 as the Federal Safety Council or equivalent to that? 16 A There ar3 a number of things that are done pretty 17 much on an ad hoc basis. For example, there is a close 18 work with the so-called Libassi group on occupational exposure, I9 on the radiation exposure standards. j 20 g That's a government group? 21 A Yes: O 22 And there was a report issued this past year. 23 NASAP is another one. But'this happens on a regular basis. 24 g Here again, are you aware of any specific policy ' Aco Federd Hopo,ters, Inc. 25 document or instruction that says, yes, we xc acing to do l e
mta 14 30 I these sorts of things? O 2 A No. I think it's more of an implicit ' assumption on 3 an ad hoc basis that that will be done. O 4 G Could you tell me, similar to these previous 5 questions, what policy, procedure and instruction deals with 6 the health 2nd safety of NRC's own employees? 7 A Yes. There's a -- I can't recall the title of it -- 8 where it occurs, but there is an appointed safety committee 9 of NRC representatives in each building, and they do have a e-2 10 program for that. 11 12 ~ 13 14 15 16 17 18 19 20 21 .() 22 23 '( ) 24 Ace Feder:s nepormes, Inc. 25 J
31 CR7828.03 WAIBEL rmg 1 -1 O Would it be asking too much if you could identify ('h k-) 2 and provide for the record any coverage or something that 3 describes that program, or could you tell me where I can find 4 it? 5 A Right down the hall here is a fellow named Bob 6 McKinney. I was personally on that to start, but I quickly ~ 7 found out that I could not do both jobs, and recommended Bob 8 to that, and he's been on it ever since. He's a member of the 9 ACRS staff. 10 G If you could be kind enough just to identify an 11 overall program document for that, we would appreciate it. 12 A You want me to ask Bob for that? ( 13 0 Yes. 14 A Okay. Sure. 15 0 Is there any policy, procedure, or instruction put 16 out by NRC which speaks specifically to accident incident 17 investigation as distinguished from, now, response to accidents? l 18 A What was the initial part? Is there any documented -- 19 G Policy," procedure, instruction. 20 A No. The closest thing I can recall was about 1-1/2 l 21 years or so ago when Dr. Harld Lewis made a suggestion to O (/ 22 Congressman Udall that there be something like an accident 23 review board set up. () 24 Mr. Udall passed that on to NRC and, after deliberating Ace-Federd Reporters, Inc. 25 for some period of.t'.me, the Commission said no, it didn't like e
32 r 2 1 the idea of a separate board, but would ask ACRS to look into 2 it. 3 As I understand it, that's what led to the ACRS Subcommittee' (, 4 on Licensee Event Reports -- LERs. 5 G Do I understand you -- that was one of the Lewis 6 Committee report recommendations? l 7 A. It was a personal recommendation -- a letter to 8 Congressman Udall. I don't know what the exact origin of it 9 was. I believe -- I don't recall the timing of it with 10 respect to the Lewis Committee's operation. 11 G It was from Dr. Lewis personally? 12 A It was. There was some debate within my office on (.- () 13 the subject as to how we felt about it. 14 G Were any position papers develooed on this to your 15 recollection? 16 A. Yes. I am sure there were memos on the subject. 17 G I wonder if you could provide those for the record, 18 please. 19 A. Sure. 20 G tir. Kenneke, I am reasonably familiar with the LER 21 system, but I would ask you, regarding that system or any V 22 other, if you could identify any pclicy, procedure, or 23 instruction which not only speaks to recording and tacking O V 24 safety deficiencies as they are reported, but more particularly, Ac..r.d.r: n porters, inc. 25 what happens to recommendations resulting therefrom and the e I
33 rmg 3 1 action taken either positively, negatively, or neutrally with (~) \\ /- 2 respect to those recommendations? 3 A Other than ad hoc materials, there are the abnormal O O 4 occurrence report systems, which is case by case, plus 5 quarterly reports that go to Congress and public notification 6 made of those as to what the event was and how it is being 7 treated, as well as follow-up, if necessary. 8 G Does that follow-up include a formal closing out of 9 the recommendation in the sense of it has been agreed to or 10 hasn't been agreed to, there has been alternative action? 11 Is there a follow-up system? 12 A Yes, it is supposed to operate with a clear endpoint D) 13 at which it is closed down. g 14 G Once aguin, is there a particular document that 15 describes how this action is to be taken? 16 A The documents describing the abnormal occurrence 17 system, I'm sure, were in a series of staf f papers back through 18 '75, '76, and maybe even '77, and since then it has operated 19 in which the criteria were developed and so on, and I am 20 assuming that along in there it became clear that appropriate 21 close-out had to take place. r~ k_) 22 Precisely where that would occur would be in that stream 23 of paper somewhere, but it is my understanding that everyone () 24 understands that there is to be a close-out of that. Ace Feder-J Coporters, Inc. 25 0 .Is there-any particular office or person we could go
34 ggg 4 1 to pin this down further, because I am interested in identifying 2 a specific instruction on this particular point, if one exists? 3 A The coordinator on a staff level is a fellow named I 4 Jack Crooks in the Office of Management and Program Analysis. 5 0 C-r-o-o-k-s? 6 A Right. 7 G Is there any NRC policy that speaks to development 8 of what I will call a nuclear safety awareness program 9 throughout the entire staff of NRC? 10 A I am not sure what you mean by that. 11 g Let me explain by reference to sr.ne work that was 12 done by NASA. And I think an example might frame this for you. () 13 At one point in the NASA space program the NASA managers 14 realized that they had to go out to all elements of their 15 program, from the designer to regulators, if you will, the 16 workmen at the plant and say, look, this is a very important 17 business you are in and everything you do is important. It 18 is a safety awareness and motivation awareness type program. 19 And my question is whether NRC has ever put forth any policy 20 or program, instruction, procedure, whatever, to try to develop 21 this sort of safety awareness, first of all, within the NRC? 22 A .I am not aware of any at the Commission level that 23 the Commission has signed off on,,but I would assume that the j ) 24 staff in the normal course of its business had carried on l Ace Feder) Repo,ters, Inc. l 25 activities. of this sort. I am reasonably confident that they
f 35 rmg 5 1 have. (D \\~/ 2 G Are you aware of any such program under the aegis 3 of NRC.which has been named, as the utilities or other agencies / 4 outside of NRC? 5 A The next series of questions here are going to bear 6 upon some of the statutory background and history of NRC since 7 the Act of 1974. And again, don't hesitate to tell me if you 8 don't have an opinion on this. 9 Beginning k. '.1 the efforts attended to the Act of '74 until 10 now, have any studies been conducted either internally or by 11 outside groups concerning the organization of NRC? 12 A The only study that I can recall was one that had ,m 13 to do with the arrangement of the offices reporting to the w-) 14 executive director for operations, merged within that, because 15 of the difficulties people have in distinguishing between MPA -- 16 what is now MPA -- and OPE. The functions of OPE were 17 considered. 18 The result was that OPE remained intact and there was a 19 number 'of functions under EDO which were regrouped -- recombined - ' 20 and the office of MPA was formed. That is the only one I can 21 recall that had to do with reorganization. (~ (, ), 22 I can recall in the AEC days, under the Director of 23 Regulation, there was a major reorganization, I would say, on ,,() 24 the average every 2 or 2-1/2 years. There has been nothing RnFMed Rwonus, \\m, 25 like that, nothing comparable under NRC. j i
36 i rmg 6 1 G Has there been -- were these reorganizations you 2 just mentioned generated by studies internal to NRC or AEC? 3 A Yes, I would say generally internal. O 4 G Have there been any studies of a management 5 organization nature conducted in, say, the last five years 6 by any outside agency that you know of? 7 A Not that I am aware of. ~ 8 G Do you think you would be in a position to know if 9 they had taken place? 10 A I would. 11 G To what extent, prior to TMI-2, had any consideration 12 been given to a staff safety office for either NRC or AEC O i3 in eddition to the eefety eeeks beine eeeienea obvious 1r eo 14 virtually all organization segments? 15 A Try that on me again. Paraphrase it so I understand. 16 0 Let me go back to your own experience where you had 17 a position as, I believe, a deputy radiation safety officer. 18 That presumably would carry with it the implication of a 19 safety officer of some sort, or might be in some agencies at 20 least. 21 A The title was bigger than the job. l 22 G Okay. But I think you are familiar with industries l 23 certainly that have a safety office of some kind in addition lO 24 ee eefeev beine gresumeb1v the resgone1b111er of everybodv.- l Ace Federst Reporters, Inc. l 25 A. Yes. /
37 1 G My question then -- and I will repeat it exactly -- 2 to what extent prior to TMI-2 had any consideration been given k/ 3 to a staff safety office for NRC or AEC in addition to the O 4 safety tasks being assigned obviously to virtually all 5 organization segments? 6 A Well, Chuck, I guess I still don't understand the 7 point. Let me try something and see if I can come close to 8 what you are looking for. 9 The recent formation of this office to look at operating 10 experience separate from the present line offices, is the only 11 example -- if I understand -- that comes to mind of what you 12 might be describing here where the Commission decidedly came () 13 down in favor of an independent, separate office and not a 14 committee, not leaving the function with a given line office 15 and attempted to get an independent review of the data. 16 G To what extent were any studies made p: ior to TMI-2 17 to establish an accident investigation function independent le of the principal offices of NRC? And among those principal 19 offices would include I&E. 20 So my question is in the same vein as the previous one, 21 that has there been any attempt or study, that you know of, -n ') 22 to your knowledge, which. considered setting up a separate (_ 23 accident investigation function? () 24 A Yes. The recommendation by Lewis of an accident I Ace Federd Reporters, Inc, 25 review board. I use that term, but it may not have been exactly
38 rmg 8 1 his term. As I recall, the example was used of the National 2 Highway Transportation Safety Board as an analogy. There were 3 views pro and con, and the end result was, as I say, no, we O- \\- 4 didn't need a new group, but we will ask ACRS to look at it. 5 G Do you have any idea why the accident investigation 6 function is currently in I&E7 7 A It has been traditional. I don't think there has 8 been anything conscious other than the consideration of the 9 accident review board to leave it there. 10 But it's always been traditional. They are closer to the 11 scene, I guess, is the concept. 12 G Have you ever encountered any officers at the () 13 utilities or the major contractors with the duties similar to 14 yours? That is, if you went to MET-ED or some of the other 15 utilities, could you find an opposite I amber there? n 16 A Policy evaluation? 17 G Yes, sir. 18 A I doubt it. I haven't tried, but I doubt it. 19 G How about at major contractors like B&W? 20 A Well, let me put it this way. As OPE is primarily 21 used, it is unlikely, but that is possible as OPE conceptually e-(_)g 22 to be should have been used, I doubt that seriously. 23 G I guess I am only now getting back to some of my i )' 24 questions about t broader bas ed things emanating from the AwFWw3 R4smes, lm. 25 statute. f
39 i 012-1 Do you consider nuclear power safety as a Federal j 2 responsibility? Let me rephrase that. 3 Does your policy office assume that nuclear power safety 4 is a Federal responsbility? 5 A Yes. 6 Q Does it follow then that NRC is the central 7 federal agency for this type effort? 8 A Yes. 9 Q What is your understanding of the current respective 10 roles of NRC and the Department of Energy, particularly ERDA 11 regarding nuclear power? i 12 A The only exception to power plant safety that I O ia cea **1ax or or to reector ereer is eue muc1eer rec 111eie-14 under DOE's own control. They are now exceptions to regulatior. 15 In other words, DOE operates and is a sub-regulating industry. 16 Commercial power plant industry is regulated by the Government. 17 Q Do -- again all these questions are from your 18 perspective as head of the Policy Office. 19 Do you feel that DOE has any role in the developing of 2' improved methodologies, either technically or in the management 21 area, as to how this nation should approach nuclear power 22 plants? l 23 A On the one hand I feel that they probably ought to .O 24 se am exception to seing regu1ated, on the eeuer hand, they l Ace-Feder:) Reporters, Inc. l 25 have definitely the benefits within -- nominally the DOE l l l
40 cle-2 umbrella -- of operating experience that could be useful. j ~ 2 On the other hand, again it's quite difficult experience 3 in different reactors, different purposes and they are under a /~N kl different contstraint. It's not primarily our producing. 4 5 Certainly, in individual areas or other areas of fuel 6 cycle, DOE has been a source of information and assistance to 7 NRC. There has been a lot of cooperation. There is a 8 standing DOE /NRC coordination group that goes on that exchanges 9 information, and I don't recall specifically, but I would assume 10 that the subject of nuclear safety is discussed within that. 11 Q I am interested particularly in the area of safety 12 management. In other words () 13 A I can't give you a specific on that. Let me think 14 of who the -- within NRR by the name of Pete Riehm -- 15 R-i-e-h-m -- comes to mind. You might confer with him. 16 Q You were with the AEC at the time of its conversion, 17 or at least the formation of NRC? 18 A Right. 19 Q What was your understanding of Congress' intent of 20 establishing three of the major offices by statute? I am 21 referring, of course, to NRR, NMSS, and ACRS. What is your 22 personal view on Congress' intention doing this -- setting it 23 up this way? ( 24 A In. naming the three offices? ' Ace Federal Repo,ters, Inc. 25 Q Yes. I
41 c10-3 A I think -- I have to say I'm bootstrapping here. i (O/ 2 My recollection of it is that you are simply trying to describe 3 some general structure to NRC that would give emphasis to O k/ safety as separate from what I was calling safeguards earlier, 4 5 namely, nuclear materials aspects, and also to identify that 6 there ought to be some kind of R&D function, even if that were 7 to be different, so that when NRC formed its structure it 8 would account for those general goals. 9 On the other hand, perhaps it made NRC too rigid, too 10 unwilling to consider or reconsider that structure to get the 11 job done better. 12 Q Well, let me ask this question then: In what manner, () 13 if at all, did this legislative charter result in any 14 organizational problems, including, I might add, for example, any relationships between the executive director's office, 15 16 the principal's office, as is spelled out in the statute, 17 and the Commission? 18 A I think that's a very crucial problem. The way it 19 specifies now, the EDO is nothing but a nominal head in my view 20 of those line. offices. The law specifically permitted line 21 officers to report directly to the Commission, and indeed have. 22 They only recently amended the law to say they were going to 23 keep the EDO informed. But that still doesn't give them very (. 24 much authority over them.
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25 Thelend' product of that has been an EDO who was not in a 4 4
42 clo-4 position, by experience at least, and by position certainly, ( 2 to make those offices conform to some single process. 3 So, I think the result has been some operation from a 4 different philosophical perspective. And not only that, but 5 ur continued physical isolation from one another in different 6 buildings has -- where as it might have been a better situation 7 before, it's now so ingrained into the organization that indeed 8 we are like many agencies within one. 9 I feel very strongly about that, that this business of 10 letting ourself continue to be physically isolated like they 11 are after five years is just unconscionable and it has a lot to 12 do with safety. () 13 It's a difficult thing to say how that is true. It's just 14 solid feel, and I think many people would agree. I feel strong 15 about it. 16 Q You just:took away one of my other questions. 17 A I think the Commissioners -- that responsibility 18 rests squarely with them to change that. 19 Q We touched on this earlier and maybe your previous 20 answer already covered it, but do you think it's the Federal 21 statutes that suggest that NRC should interpret safety only I 22 with respect to people as distinguished from say conservation 23 of economic and material resources? I m (_) 24 A' -Try me again, Chuck. Ace-Federal Reporters, Inc, '25
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- Do you believe it goes back to federal statutes that i
43 I )le-S j NRC should treat safety with respect only to the health and 2 protection of the people from injury as distinct from the 3 conversation of material resources? ( ') 4 A Let me try to work around to your question. I have 5 to modify it a little bit. If you mean do we take economics 6 into account in our safety judgments, does that reflect on the 7 law, yes, I would say the origins are there. The law is not 8 very clear that we are permitted to take economics into account, 9 One has to interpret it, in fact. However, in my own view it 10 is unavoidable that we do, because safety is not an absolute 11 quantity. One can reach zero risk, and that implies some kind 12 of trade-off at some point. But certainly I would subscribe () 13 to the school that says up to a certain point you will achieve 14 a certain minimum safety level regardless of cost, or not do it. 15 And beyond that we can require still more. And I say there is 16 at least an inkling within the law if one chooses to interpret 17 it that way. However, the staff has been fairly equally 18 divided on this thing and the Commission has never firmly 19 decided which way they will go, as a result, that's been left 20 confused. 21 The closest they came to it was when they were considering ( 22 the so-called draft licensa reform bill about a year or two ago, 23 and it was raised, I believe, by the Chairman, and it came out 24 in the form of a proposed preamble that said something to the Ace-Federd Reporters, Inc. 25 effect that health and safety was paramount, but-somehow we trould I I I
44 lo10-6 consider economics. It was a very wishy-washy thing. But j A) (_ nevertheless, it was an attempt to address that matter. 2 Q Whatever happened to that proposal? 3 O \\~/ A That died on the vine, like all of the other licensing 4 reform proposals. 5 0 Who was the author, or where might I get a copy of 6 the draft of that preamble? 7 A The Office of General Counsel can put you in touch 8 with that. But there were memorandum just this week, in fact, 9 sent out -- or last week -- sont out by the Office of General lo Counsel on the general subject of economics and safety 11 regulations, and OPE was asked for its comments by them -- by 12 33 Commissioner Ahearne. We sent him a memorandum on Friday () 14 afternoon. .End t-3 15 16 17 18 l-i 19 20 21 22 23 24 l Acefederal Reporters, Inc. 25 'a= c \\ i
45 j l i Cr. 7828 1 Q Here again, based particularly on what you just L 1s t-2 said, my next question may be a little redundant, but I would 3 like to phrase it anyhow and start out by saying I have ,f'T \\ 4 personal knowledge of some Federal Statutes which essentially 5 define an objective of the Agency to be the highest degree of 6 safety possible, consistent with a viable - whatever type of 7 system they are talking about. 8 Do I detect on your previous comments that no such 9 philosophy had been applied to NRC? 10 A The philosophy is murky in terms of a formal 11 policy. I'd say that what you stated is the predominant view 12 of members of NRC. (m (,) 13 Q Are you aware of any statute that allows you to 14 take that broad a picture? 15 A Yes. You have to read the Atomic Energy Act and 16 the references to the general welfare fairly broadly. That's 17 exactly what the General Counsel's Office has done now.-- 18 supplied an analysis of that. l9 Q Looking back upon your experience in AEC, compared 20 with NRC, do you think the Act of '74 had either a positive 21 or negative effect on nuclear power safety and, if so, which (' O) 22 one? 23 A It probably is mixed. Certainly, in light of (~T k-) 24 Three Mile, one now has grave doubts about whether or not it Ace-Federd Reporters, Inc. 25 was positive. Surely, when you now have five commissioners I
46 l who have nothing to do but focus on regulations, one would have 310-2 j ( expected that a lot more of them. 2 In the old AEC a regulation was only a partial aspect of 3 that. The Commission traditionally in the last five years 4 has been extremely slow to reach a policy judgment, to identify 5 6 policy needs. Partly is the fact that now that authority for decision making rests with the five of them, whereas under 7 the old AEC it would be split, general managers / director of 8 9 regulation. There was a great deal of delegation, I think, 10 to the director of regulation. And that includes both Harold 11 Price on the one hand and Manning Muntzing, and they were 12 strong decisionmakers, and there was a liaison. There was a ( )) 13 liaison with the Commission, but not in terms of policy making. 14 Policy making was effectively made at that level and radified 15 by the Commission, when necessary to get back. 16 So, I have sensed that decisien making now is much more 17 rocky when it comes to five to decide. There is no strong 18 support somewhere -- on one person's mind to make up that 19 did exist in practice in the AEC. I think that has a lot to 20 do with the situation, so it is difficult to say.
- Surely, 21 there are some good things, but it is difficult now in light of
() 22 Three Mile Island to focus on it. 23 Q Let me define a certain phraseology here -- s (I' terpo' sing) Chuck, while I am at it, let me s) 24 A n Am FWwd Reorwes, lm. 25 just unload a little. Certainly, with regard to reactor safety
47 l I I think that's especially true that basically that policy 010-3 j -- the policies of reactor safety have been left largely to 2 staff discretion by sheer momentum of expertise and numbers. 3 O That policy has flowed from what the staff's view is. \\' 4 5 Q I want to ask you about something I am going to term a National Nuclear Power Plant Accident Prevention Program 6 7 Plan. Let me define that by saying -- and this may be somewhat idealistic, but an Accident Prevention Program Plan is something 8 9 which an appropriate group or groups get together and say 10 for a fixed period of time -- one year, five year, ten years -- 11 we intend to approach nuclear safety in such and such a manner. 12 My question is: Has any such effort ever been done on () IJ a national basis to your knowledge? 14 A Not that I am aware of. 15 Q Do you think it would be a good idea? 16 A I have to see it in detail, but in general I would 17 favor'such a plan. 18 Q Concerning the NRC organization as it existed 19 at the time of Three Mile Island, what path did the line func-20 ti.:a follow? And I'll define line function as being in my 21 sense of the question a safety decision making function. To 22 repeat, what path does this follow throughout NRC7 And you 23 might answer it by saying a problem occurs at this case at a 24 low level in the organization. How is the decision made - Ace Federal Reporters, Inc. 25 regarding that problem? 1 4
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well, I have to speak from a point of view of some-( )~ one involved with licensing review. Furthermore, I should 2 have noted earlier in my response to your system safety thing 3 /~ \\_)T that I was concerned with a siting organization, what is 4 n w the Division of Site Environmental Analysis. I'd say that 5 safety decisions are basically made at the working level. 6 The license reviewer makes the decision by the fact that he's 7 ultimately handed a document to review, does the initial 8 9 reading, with no specific guidance other than as presently 10 exists, the standard review plan; formulates some questions to 11 ask the applicant. 12 While there is some editing of that or modification or () 13 oversite management of that process at the management levels 14 throughout or going out, I would say the basic decisions are 15 made at that level because that sets in motion a certain 16 direction, a certain sense of a set of thoughts. Not only that, 17 but these thoughts are coming from a series of specialists -- 18 30 or 40 perhaps on a given case -- and none of them will work 19 unnecessarily in conjunction with one another towards some 20 kind of common way of looking at it. l 21 The standard reviewer plan in part was effected because of p(_) 22 an awareness that we had to have certain kinds of guideln i 23 to guide the reviews: What was the purpose of review? What i l () 24 were they to take into account? So, it wasn't entirely seat of Ace Feders Reporters, Inc. 25 the pants each time, but the end result still has been I think, s _
49 l c10-5 the project manager normally was to integrate but in fact by j sheer momentum, by the time he got all these inputs and s_/ 2 various pieces of paper, whether it was the questions or so-3 called staff positions or the pieces of the final safety 4 evaluation report, the die was cast by these pieces. So, it 5 became sort of a patched together product. 6 7 So, I w uld say the safety decisions primarily are made at the bottom, where certain things came to the top. Tough 8 decisions could be made at the branch chief level or even 9 10 assistant director level. 11 The only specific things that sort of rose to the surface 12 that would show that process would be some of the so-called () 13 dissenter views that were raised. In 1976, the Pollard -- P-o-1-1-a-r-d -- matter -- which has now taken the form of a 14 15 document that has just come out for public comment -- 16 professional differences of opinion. 17 So, I guess my answer to your question is safety decisions 18 in my view are pretty much made at the bottom on a case by 19 case basis and very difficult for it to be managed at the 20 top. 21 Q Is it true then from what you said that the program (~%,--) 22 manager or project. manager, if he is called in, is more of a 23 coordinator than he is a decision maker? O X_) 24 A I would say that's true. Ace Federd Caporters, Inc. 25 Q 'And I would also assume that, going on up the line. l i
I 50 A And the end result, of course, is a lack of )lo-6 i (~/ integration of the safety review. In my view, there is no one ~\\ s_ 2 3 now who looks and tries to put those pieces together. I 4 mentioned the systematic evaluation program that was in part 5 developed as a response to that kind of concern. Let's go back 6 and let's not look at these things in piecemeal, but look at it 7 more as a team in the approach to safety. 8 Q And may I also assume from what you testified 9 earlier that once this stuff goes up to the office director's 10 level and above it has the capability of going directly from 11 the office director to the commissioners, as opposed to in a 12 true line sense through the EDO; is that correct? () 13 A Well, if you are talking about a license review 14 that's under the ex parte rules and that result would be 15 reports going out on public record before the licensing board 16 which the Commission would adjudicate. So, it's separate 17 from it in that respect unless it's a generic matter, which 18 at least that would clarify the Commission could participate 19 in. 20 0 Let me go back. Let's assume for the record a 21 subject comes up for decision and there's a controversy and 22 it eventually gets to the office director, say the head of NRR. 23 It is of such a nature that he feels that there should be a 24 higher decision level made than where he is. It's my under-c Am Feder:3 Reporters, Inc. I 25 . standing, or at least I gather from your previous testimony, l I
51 that it really could go directly from there to the Commission, ols-7 O \\/ 2 as opposed to necessarily going through, except for information 3 purposes, to the EDO; is that correct? "T 4 A I think that's right. And now, whether or not you 5 have it go through the EDO or be informed or not, he is 6 simply not in a position of authority or experience to alter 7 that. I think Lee Gossick has said quite clear that he has 8 never tried to impose his thoughts on the others in that 9 respect. He is entitled to know what is going on. That's his 10 only position. 11 Q Let me just ask you a question similar to that 12 you just provided, but think of it now in a staff or () 13 advisory function. Let's take a problem now that is coming 14 up the line, so to speak. My question is what other sources 15 of staff or advisory information to this decision process 16 carrying it right from the lower section right on up to the 17 very top? 18 A Well, the way NRR is organized, you have the project j 19 -- talking about a case review, the project comes in and it's 20 farmed out to a series of branches, and within those branches 21 one or more -- usually more -- and disciplines. You may have 22 something like 40 technical specialists working within 20 or 23 30 sections within 15 branches under four different ads in p sj 24 two different divisions, each of which following a chain and l Ace-Federal Reporters, Inc. l 25 floating to the top and sending over to the Division of 1
I 52 Project Management the composite of their individual views c10-8 1 () coordinated to the degree it's covered by the standard review 2 3 plan. ( 4 So, they interact and advise in that respect. The project That 5 manager then puts that together for sending out. 6 represents the staff reviews. The staff review at the stage of the STR involves a standard stop with the ACRS. 7 8 Q Let me interrupt you. Meaning the ACRS is an 9 advisory group at this point in time? 10 A Right. So at that point ACRS, while nominally receiving the case at the time the staff does, it is my 11 12 impression that they really take no action on it until the () 13 Staff Safety Evaluation Report is done. And that could be at 14 least a year, if not two years from the beginning. They don't 15 provide advice early in the process; they provide it late. 16 Then the staff waits for the so-called ACRS letter that 17 basically they concur with various suggestions. And while 18 that process goes on, the staff supplements its safety 19 evaluation and issues it, and at that point they are prepared 20 to go to hearing, if that's called for. 21 In the course of both of those steps, the staff may use O \\- 22 consultants, and ACRS may use consultants. 23 O All right. Let me phrase the question just a little s-) 24 differently. ( ! Aco-Federd Reporters, Inc. 25 Let's put you in the position of being a commissioner, not l I
53 110-9 necessarily the chairman, and you want advice on a safety 3 issue. How many different places can you and do you go to? 2 A Three places, in general. The specific office 3 within the staff that would appear to have the basic expertise 4 and knowledge, and maybe several places within the staff, 5 depending on the problem; two, relevant sources from outside 6 the Commission that I may be aware of to give me an independent 7 idea of what to do, and to the Commission level staff office, 8 such as OPE. 9 10 Q How about ACRS? 11 A Yes. From time to time the Commission has referred 12 things on a formal basis to ACRS, but normally I am not aware O 13 that commissioners as such confer with ACRS other than through 14 the normal channels. I am sure they know each other individu-15 ally. Maybe that goes on. 16 The present chairman was a former member of ACRS and knows 17 many of the members. I am sure he talks with some of them, 18 but not as a group. 19 Q Is there anyone that comes to your mind who might 20 be thought of as most responsible for decisions related to 21 safety within NRC -- any or one person, within any one office? 22 A No. As I was trying to say before, I think the 23 basic decisions about safety are cast more or less into stone 24 at the basic working level. They are done piecemeal.
- Now, Ace Federd Reporters, Inc.
25 the two most influential people I would say are the Director of I
s 54 NRR and the Director of I&E, which in their respective roles, 31c-10 g I would say the Director of NRR in fact has the predominant 2 3 voice, if I have to point to the most influential safety decision maker within NRC. ~ 4 5 O Similarly, who is the most responsible for the advice relative to safety if you can pick one or two out of 6 the others? 7 A Advice to the Con: mission? 8 9 Q Yes. Or really looking at NRC as a total, who is 10 really the chief advisor of these things? 11 A I would say the two officers I just mentioned, 12 in the order I mentioned, along with ACRS from time to time. O is o "o r ' eue vou u1a -- tee =e e x v u airece v-14 Do you think there's a chief safety officer of NRC? 15 A Reactor safety? I would say Harold Denton is that 16 person, with Vick Stello a close second, by nature of their 17 office. 18 Q Mr. Kenneke, I would like to close this with 19 really just one question which is a broad based question. Do 20 you have any observations you would care to make regarding the 21 safety engineering or safety management practices at NRC beyond 22 those you have already testified to and particularly as its 23 been influenced by TMI:,2?' 24 AL Well, I think we have to seriously question the
- Aco Federal Reporters, Inc.
l 25 present arrangement'of five commissioners who have divided t s
55 010-11 1 responsibilities for decision making with an EDO who has only 0 2 nominal direction over a set of staff officers which are quite 3 large and important, and I would say thatusafety decisions are a 4 function of all of those things together. And I think what we 5 have ended up with now is a nonintegrated approach to reactor 6 safety and, indeed, to maybe all of our functions, by the 7 nature of that situation the chickens have come home to roost, 8 and I think it b time for people to reexamine that and something 9 must be fixed. And I believe that it's in that area between 10 the office director, EDO Commission, that chain on one hand, II and now because of my feeling that the basic safety decisions 12 are made as the collection of these individual judgments at 13 the working level, I think we need to reexamine this cross-I4 road we took, a certain path seven or eight years ago when we 15 split into a technical review and project management, and we 16 need to find some way'to reintegrate those functions and main-37 tain the advantages somehow of specialization, but come back to 18 something that's a much more integrated point of view. I9 The third area that I would emphasize is the ability to 20 separate the trivial from the important. I think by its nature 21 our bureaucracy tends to like routine and to put things down 22 in writing and follow that. The standard review plan was an 3 effort to do that, so that things would be controllable. -24 Somehow ultimately the plan became the thing that became the control 1er and as'a result I think we spent a great deal of ~ l
56 010-12 time and have maybe this year we are going to have some things j differently, but we have in the past spent a great deal of s_/ 2 time doing repetitious analyses of things that fundamentally 3 ) probably don't mean a heck of a lot to safety, and as a result 4 we have spent less time on things that were really important -- 5 the things that don't even show on the standard review plan. 6 Unique aspects of safety reviews have been pushed aside. 7 The problem would then result in safety issues 8 because we have accumulated a whole bunch -- a longer laundry 9 list of interesting things to work on, but which don't -- 10 11 90 percent of the time don't contribute a hell of a lot to 12 safety -- and an inability to focus on those. And I think that the Commission has had some -- with some outside boosts -- () 13 14 has had some effect in the last year or two to focus and narrow down that the list of unresolved safety issues, I'd say probably 15 16 more due to the Congress passing Section 210 of the Act. That 17 helps that along. But we do need across-the-board a system 18 that separates out from a risk reduction -- a probable risk 19 reduction, which is cost approach. Those things that are going 20 to have the most influence on safety from those that do not, 21 so we will stop wasting our resources and things that might be . r) nice but are expensive in terras of what they gave for public (j 22 23 safety. () 24 I'd say those three things. Ace-Federal Reporters, Inc. 25 The fourth item I'come back to was the business about the 4
57 )l0-13 Accident Review Board. That was the most novel suggestion to m al ng. In my view, the Commission failed to take 2 advantage of an opportunity that came along and gone along 3 m with a general suggestion of an independent review board. 4 They got hung up on the specifics of it. And they could still 5 do something like that. I don't think ACRS is independent 3 enough of the process to order that kind of view that Harold 7 Lew s, I think, had in mind, and certainly not the Commission. 8 d-A And we take, for example, the very setting up of what 9 l'0 you are now part of, and bow difficult it was for the Commission to do that and swallow the idea that you would be 11 independent from its direction. And even now you have to 12 j3 supp y a rep rt. I think that is a suggestion that has some O merit and it need not take a '.ot of resources, but it is 14 15 something that I think you needed to get distance from a 16 difficult situation. Who are we to sit here and judge whether 17 or not we have done a good job? Inevitably, no matter what 18 you say, it would be questioned. The credibility of the 19 judgment would be questioned. So, I think the Commission made 20 a wrong return. It's too bad they didn't set something up at the suggestion of Harold Lewis.' And now I think we have 21 fxd 22 lived to regret it and it would have been set up and ready to i 23 go in the case of Three Mile Island and we might have had a 24 1oe:faseer eceton.. O ! Ace Federal Reporters, Inc. f 25 So,'I shot my piece, I think -- the key things. l i
58 01c-14 MR. MILLER: Off the record. (~h V (Discussion off the record.) 2 MR. MILLER: Back on the record. 3 .I ) \\/ THE WITNESS: A fifth item I would add is something 4 5 I mentioned earlier, and that is the subject of the physical 6 isolation of the various entities that make up NRC. I believe it is reenforcing the inevitable tendency to learn to live on 7 8 y ur own and therefore reenforcing the philosophies that may 9 affect and be inconsistent with one another, and it is not in 10 the best interest of the public safety. 11 I think the interest of public safety requires someone to 12 take a leadership, and I think it should be someone from the () 13 head of the NRC to get Congress to act to take whatever steps ja are necessary to get us in one place as quickly as possible, 15 however the organization looks. 16 All those pieces ought to be physically together, simply 17 because the people share views that they would otherwise not 18 share, simply by the nature of their daily trip to the 19 cafeteria, the library, and so forth. All those informal lines 20 of communication that would normally exist to share philosophy, 21 determine problems and point out needed policy changes and so () 22 forth. All those kinds of things. Not just the sheer 23 expenditure of manpower required to travel back and forth to ( 24 visit with the Commission. That's kind of trivial, in my view. Aos-Fockral Reporters, Inc. 25 It's these daily contacts that one establishes with people in i L
59 010-15 i these organizations that's been lost and, being lost and () perhaps irrevocably so, is something that needs to be changed. 2 3 I would say these would be the five things thac I would -s 4 recommend. 5 MR. MILLER: I thank you, Mr. Kenneke. 6 In conclusion, let me say this is, as you may be aware, an 7 ongoing investigation, and although I have now completed the 8 questions I have for you today, it is possible that you might 9 be brought back for further depositions or interviews. We 10 will, however, make every effort to avoic aaving to do so. 11 I will now recess this deposition rather than terminate 12 it, and thank you very much. I think your points have been a ( ) 13 considerable help to us. 14 (Whereupon, at 2:40 p.m. the deposition was 15 recessed.) i !nd 4-A 16 17 18 l 19 20 21 () 22 23 s_J 24 l Ace-Federal Reporte,s, Inc. ~ 25 l I
10/22/79 EMPLOYMENT HISTORY Albert P. Kenneke February, 1979 Acting Director, Office of Policy Evaluation (OPE), " ""'" ""'" "' ' **' " '"" '' ~ " C') Present Street, N.W., Washington, D.C. 20555. May, 1976 Assistant Director for Technical Review, GS-16, OPE, l to NRC, Washington, D.C. Present May, 1975 Senior Policy Analyst, GS-15. OPE, NRC, Washington, D.C. to May, 1976 March, 1972 Technical Coordinator for Site Safety and Environmental to Analysis, GS-15, Office of' Nuclear Reactor Regulation, May, 1975 NRC (and its predecessor, the regulatory arm of the U.S. Atomic Energy Comission (AEC), Bethesda, Maryland. December, 1969 Site Analyst, GS-14, Site Safety Division, AEC, Bethesda, t'N to Maryland. d March, 1972 August, 1962 Health Physicist, GS-13/14, AEC, Germantown and Bethesda, to Maryland. December, 1969 June, 1966 Electronics Engineer, RCA, New Jersey; Health Physicist, to University'of Michigan; Deputy Radiation Safety Officer, August, 1962 Sloan Kettering Institute, Memorial Cancer Center, New York. EDUCATION Completed all course requirements toward Ph.D. in Environmental Health, University of Michigan, 1960. ,. Q -Master of Public Health, University of Michigan,1959. M.SJ Radiation Biology, University of Rochester (New York), 1957. B.S. Physics, St.' Joseph's College (Pennsylvania), 1956. X8p l 102, WA I B t L l /o / 2*/79
4 U. S. NUCLEAR REGLtATORY CCPtilSSION f NRC MANUAL ~/ . il Volume: 0000 General Administratic,r. NRC-0.118-01 ' i PE Part : 0100 Organization CHAPTER NRC-0118 ORGANIZATION AND FUNCTIONS i O. 0 0FFICE OF POLICY EVALUATION 0118-01 'fdPERVISION 0118-03 DELEGATION OF AUTHORITY TO THE
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DIRECTOR Undre the supervision of a Director who reports to the Comission. The Director is authorized.tod directed to; 0118-02 FUNCTIONS 031 take such action as is necessary to carry out the functions assigned by this Provides overall planning and management chapter or other official directives or of activities involved in the performance comunications, subject to the limitations i of an independent review of positions prescribed therein. developed by the NRC staff which require policy determinations by the Comission. 032 recomend to the Comission, follow-Conducts analyses and projects which are irg independent evaluation of program policy, either self-generated or requestdd by the objectives, alternative policies and jositionsl I ~ Cecr.iission. Specifically the Office: and their impact upon the objectives of the C NRC. 021 provides an independent evaluation for the Comission of program policy objec-033 conduct special projects, either ~ Y tives, incorporating an assessment of such self-generated or at the request of the favors as goverrenental policy and objec-Comission, in areas with long-range policy tives, and their economic, technica!. and implications. societal impact. 0118-04 REDELEGATION OF AUTHORITY BY THE 022 provides independent technical DIRECTCR evaluation of selected cases presented to , f { #" W the Comission for adjudication. The Director may, except where expressly pro-; hibited, redelegate to others authority dele ' 023 as requested by the Comission, co-gated by this or other official directives or.. < - a -. S" ' ' comunications, subject to the limitation ordinates input for agency-wide studies and stated below and such other s integrates infonnation into overall p1anning ..Q O p. s< 5i' 4-c; . ;1 are deemed necessary. or evaluation for Comission use. ih+M..,N QT f
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1 i ,y)......... u.. ,.,.....,...............a 5 ORGANIZATION AND FUNCTIONS NRC Appendix 0118 0FFICE OF POLICY EVALUATION O. , :A PART I y. ! ', +.,, ; ~ ~ ~. ORGANIZATION CHART W..> ,, e 71 OFFICE OF THE DIRECTOR ~ AS$1STANT DIRECTOR ASSISTANT DIRECTOR ASSISTANT DIRECTOR FOR FOR FOR .. ~,.,,, POLICY REVIEW TECHNICAL REVIEW SPECIAL PP.0JECTS
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MIL-STD-882A 28 June 1977 /:. =~ SUPERSEDING MIL-STD-882 15 July 1969 a ....5 2 .:L -e< =^ iEl 5 3 5 MILITARY STANDARD EE r s;. SYSTEM SAFETY PROGRAM REQUIREMENTS "i.. . ih E E e ii:- " U.g. s ew . ' ~ ~. ',, 11 ,4 1 "I hl ..i:l IE ~ .c T j .r.- m5 2 s-J - l l,o 4 .s..... \\ CO u M 0 r t- - FSC MISC 1C n i: c, .t- .. A (o 2 79 ',O i:7e%W"g. , =. \\ .+s,.., 5 M-)$f.hY.h.[ [ ......r==..=.......'......... .. :.-::.:5~=1M '~i25%;- :" = ~" ~ ~ ^ ~=::r:- u: -- v=...v.=..-.
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[ 4 J MIL-STD-882A L..- e 28 Ju m 1977 f.:". E t:===== y.y (,, ; tu.n; program requirements and tasks shall be cross-referenced in the system safety $jji.y. I program plan or other contract documentation to svoid duplicatien of effort by ,p the managing activity and the contractor. l ""] V J.""":: 1.3.6 conflictine reout rements. The managing activity shall specify in the E""2" statement of work that when conflicting requirements or deficiencies are ,,, 3. _ f "-- f identified within system safety program requirements, the contractor shall '.1 ' '4.. ; :: = 3.,,._, .'O submit notification, with supporting rationale and proposed alternatives, to; y.. _,1p;wy. :. *, l ',i.N'h;ja['.;. 7[ i ( the managing activity for resolution. .a M n .:,,m.g .= 2. REFERENCED DOCUMENTS Q[.'[ .U. a h....(. --~~- n. + Referenced documents are not included in this document. Referenced"d3cuments
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' !.u. required to supplement this military standard shall be specified in system . J. j 2,*.". I...=.;.: ..a specifications and contractual documents. , Qgg l_.. .e, - e 3. DEFINITIONS .c 3 _...d .a The following definitions apply to t[ bis standard. f..=...=.. 31 centracter. A private sector enterprise or the organizational element of -C.~.T _ DcD (as used in this standard) engaged to provide services or products within .f. j.;, agreed limits specified by the managing activity.
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- "E.E 3.2 Manarine netivitv. The DoD organizational element of DoD that will plan, organize, direct, contract, and centrol tasks and associated functions appro-M,":fa..M SiinE"I priate to the Tre cycle phase of the system.
~ q'ig;,',;...- : =::: " ::= c. 3.3 Mishan. An unplanned event orfseries of.ev'ents that result-in deathi T 1
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.5_I_~. injury, occupational illness, or damage to or loss of equipment or property.~ ^' ~? ' M 1 % ~~~"~ '( } ' L,,f"??:.. f' n:= o 3.4 Risk. An expression of possible loss in terms of hazard severity and i.# rtd.'W t......w ~~[- Q . hazard probability. - ^ ~ % 0 W:n t.. E ;.::.:q j :. @ji ?.M.w t" !/2 7 !.:M 3.4.1 Hazard. An existing or potential condition that can result in a mishap, . fe .v"~ (e.'g., the presence of fuel in an undesired location is a hazard whereas the -G fuel itself is not). -
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_ l yfyi,g ["~"; 3.4.3 Harard severity. A qualitative assessment of the worst potential..- consequence, defined by the degree of injury, occupational illness, property ,3 ;;---- damage, or equipment damage that could ultimately occur. s.*giggf/.ji, ;,s.,fd.g.p*y,,.,""7 - ~ ~ ~:/,:%:M iP,$hr, W{Q t;, '-4 Freedom from those conditions that can cause death, inj 4. occupational illness, or damage to or loss of equipment or property'.'*'EP.; te ;. 3.5 safety. ... wa:p.,. r* M'&r,.'W. ;e. r*eM W m '4 ' s ~ 8 "-" ~ / '* L " A W T1g.4 f.p., ---~=>
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v.m/ e ,.. ~ o + A composite, at any level of compierity, of personnel, materials,;;.g;grg9,g . c.o o p" "s e 3.6 System. tools, equipment, facilities, and software. The elements of this composite *.~?.s.wp . N O.f=rp perform a given task or achieve a specific production, support,'or missionW6 entity are used together in the intended operational or support environment' toTIl [ p~~== requirement..
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