ML20151S764
| ML20151S764 | |
| Person / Time | |
|---|---|
| Issue date: | 08/14/1998 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20151S738 | List: |
| References | |
| SECY-98-175-C, NUDOCS 9809090037 | |
| Download: ML20151S764 (2) | |
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l NOTATION VOTE '
RESPONSE SHEET !
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TO: John C. Hoyle, Segretary FROM: COMMISSIONER MCGAFFIGAN l
SUBJECT:
SECY-98-175 - PROPOSED GUIDELINES FOR APPENDIX C, "OTHER EVENTS OF INTEREST," TO THE ABNORMAL l OCCURRENCE REPORT TO CONGRESS Approved - Disapproved X' Abstain Not Participating COMMENTS: ;
See attached comments.
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.C l Commie <ioner McGafban's Comments on SECY-98-175:
I disapprove the staft's recommendation to pursue Option 1--delete Appendix C from the annual Abnormal Occurrence Report to Congress and instead propose retaining it for the following reasons.
Regarding Option 1-In the staff requirements memorandum on SECY-97-288, the Commission clearly stated its intent to retain a mechanism for reporting certain events to Congress that, while they do not meet the Abnormal Occurrence criteria, warrant inclusion for specific reasons such as the potential for public exposure, the frequency of such events, media coverage, Congressional and public interest, and increased attention by the NRC or Agreement States. Consistent with the SRM, such events may be included on a one-time basis. The Commission's position on the earlier paper is also consistent with earlier Commission direction on SECY-95-244 as discussed in the current paper. In addition, I disagree with the staff position that informal communications such as electronic mail between NRC staff and Congressional staff and dissemination of information through the NRC w& site ami public document room provide an adequate public record of events the Commission ir ouded that either individually or collectively warrant inclusion in the required annual report to Congress. Therefore, I disagree with the use of Option 1.
- Regarding Options 2 and 3, I do not agree that the threshold for inclusion of such events should be review by an Accident Review Group, incident Investigation Team or equivalent Agreement State investigation or response by the Federal Radiological Emergency Response Plan. These thresholds may be too high in certain cases. I would argue that in the case of events involving certain lost sources and devices, there have been several events that did not result in such formal review and response processes yet, collectively, they represent a problem area. In response to these events, the Commission directed the staff to enhance regulatory oversight of this program area to improve the national program and reduce the potential for additional unnecessary public exposures from certain sources and devices. It is exactly this type of event that I believe is the primary purpose of Appendix C. I do not believe that the criterion for capturing these types of events needs to be complex. For the most part, the staff should be able to identify events that at ,
least warrant consideration for Appendix C through routine event assessment and trending analyses. As stated in the SRM on SECY-97-288, for future AO reports, the staff should identify the events that were considered as candidates for inclusion as Appendix C items and briefly discuss the merits ofincluding them in the report.
- 1 suggest for the staff's consideration the following criteria for capturing Appendix C events.
" Appendix C may include, but not necessarily be limited to, events tha: do not meet the Abnormal Occurrence criteria but may be perceived by Congress or the public to be of health and safety significance, may have resulted in materials entering the public domain in an uncontrolled manner, may have received media coverage, or may have caused the NRC to increase its attention to or oversight of a program area."
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~ // 'g UNITED' STATES NUCLEAR REGULATORY COMMISSION l f ~ ,
WASHINGTON. D.C. 20555-0001
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y September 4, 1998 OFFICE oF THE SECRETARY I
MEMORANDUM TO: L. Joseph Callan Executiv i ctor r Operations ,
John C oy b
tary
- FROM:
SUBJECT:
STA REQUIREMENTS - SECY-98-175 - PROPOSED ,
GUIDELINES FOR APPENDIX C, "OTHER EVENTS OF !
INTEREST," TO THE ABNORMAL OCCURRENCE REPORT TO -
CONGRESS The Commission has disapproved the staff's recommendation to pursue Option 1 and the other j options presented in the subject paper. Instead, Appendix C should be retained using the
- criteria described below to identify events considered for inclusion in Appendix C. When forwarding draft Abnormal Occurrence reports to the Commission for review and approval, the staff should briefly discuss the merits of including each event in the report. The Commission will exercise its collegial process to determine which events are included in the final Abnormal Occurrence report.
The staff should use the following criteria when considering events for inclusion in Appendix C :
Appendix C may include, but not necessarily be limited to, events that do not meet the Abnormal Occurrence criteria but have been perceived by Congress or the public to be i of high health and safety significance, have received significant media coverage, or have i caused the NRC to increase its attention to or oversight of a program area, or a group of l similar events that have resulted in licensed materials entering the public domain in an uncontrolled manner.
l cc: Chaitman Jackson Commissioner Diaz Commissioner McGaffigan ;
OCA OlG '
- Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
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