ML20198G127

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Responds to 970711 SRM & Informs That Staff Plans to Conduct Further Analyses & Meet W/Us Fema,Us FERC & Us Army COE Over Next Several Months & Will Provide Results of Analyses to Commission by 980101
ML20198G127
Person / Time
Issue date: 08/06/1997
From: Callan L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, The Chairman
NRC COMMISSION (OCM)
References
NUDOCS 9708130318
Download: ML20198G127 (11)


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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2066H001

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August 6, 1997 MEMORANDUM T0:

Chairman Jackson Commissioner Dicus Commissioner Diaz Comiscioner McGaffigan FROM:

L. Joseph Callan ExecutiveDirectrpor'Upertions

SUBJECT:

STAFF REQUIREMENTS - DAM SAFETY PROGRAM In response to the staff requirements memorandum (SRM) dated July 11, 1997, the staff has reevaluated several of Ms conclusions provided to the Commission in SECY-97-110. " Status Report on Implementation of Dam Safety Program," dated May 29, 1997.

In this reevaluation, the staff considered the recommendations made by the Commission, including:

(1) the need to devote one full-time equivalent (FTE) to the Nuclear Regulatory Commission dam safety program (DSP) in fiscal years CFY) 1997 and FY 1998, and the effectiveness of the staff's current approach to implementing the DSP: and 2) the use of alternative approaches for acccmplishing the goals and objectives of the program.

Because of the expedited schedule, this response focuses on the approaches that the staff will take in the next several months to implement recommendations made in the SRM, The staff plans to conduct further analyses and to meet with the U.S. Federal Emergency Management Agency (FEMA), the U.S. Federal Energy Regulatory Commission (FERC), and the U.S. Army Corp of Engineers (COE), over the next several months.

By January 1, 1998, the staff will provide the Commission with results of these further analyses and the meetings with other Federal agencies, as well as any additional recommendations for improving and streamlining the DSP.

1.

Need for One FTE and Effecttveness of the Proaram A"

The estimate of one FTE needed for FY 1997 and FY 1998 was based largely on

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actual staff resources expended in the Jast, As of July 1, 1997, the staff

]C' has expendeJ approximately 0.6 FTE on t1e dam safety arogram (DSP),

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t corresponding to an annual rate of approximately 0,8 7E for FY 1997. Thus, i

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it appears that less than one FTE will be expended in 1997 cn the DSP.

6 Discussions with the FERC staff have indicated that FERC expends approximately 140 FTEs on its DSP for approxinately 3000 dams under its jurisdiction. The o ny Q

staff notes that this ratio is similar to the NRC's proposed ratio of 1 FTE g) foa 19 dams, and that a program as large as FERC's results in an economy of scale that is not possible to achieve at the 1-FTE level, g

The NRC Dam Safety Officer has developed a program that uses staff resources in a very efficient manner.

The staff resources used on dam safety have t,een CQ in support of basic DSP management activities such as:

1) participation tb 3

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in the Interagency Committee on Dam Safety (ICODS): 2) preparation of input on the biennial dam safety report issued by FEMA: 3) overall management of the FERC Memorandum of Agreement for dam safety inspections: 4) support of inspections conducted by FERC: and 5) other overhead activities related to the DSP.

Consistent with the direction provided by the Commission, the staff has worked, and will continue to work, to streamline the program and to make it more effective. However, the staff considers that additional resource savings could possibly be achieved if some of the current staff activities are reduced or contracted to FERC.

With the help of FERC. dam inspections have now been completed for all NRC-licensed facilities that require them, and it is expected that tiie number of inspections and further staff participation in inspections can be reduced.

Some savings in staff resources could be obtained by not su) porting five inspections per year.

Reduced participation is possible 3ecause there are specific provisions, in most NRC licenses, that require routine inspections to be performed by licensees.

The staff considers that it may t,e possible to use these licensee inspections to replace or augment NRC-led inspections, now that the init;al inspections at all 19 dams have indicated no significant problems.

Further, contract funding could be reduced by using FERC to review the licensee reports, rather than conducting in-field inspections.

Some funding would be retained to conduct one or two inspections at the NRC-licensed facilities. to confirm the accuracy of licensee reports, or respond to specific issues indentified at NRC-licensed sites. Overall, however, the staff could realize a resource savings of about 0.1 FTE.

In addition, preparation of NRC's input to the biennial dam safety report could possibly be contracted to FERC. resulting in resource savings of about 0.2 FTE. However, based on FEMA's negative criticism in the recent biennial report, this resource savings may be difficult to achieve if the staff needs to interact with FEMA to resolve any outstanding issues and criticisms raised by FEMA on the biennial report input.

The staff has considered the possibility of transferring dam safety responsibilities to another Federal agency, such as FERC or the COE.

However, as noted above, only minor savings can be achieved over the arrangements already in effect, since the staff is already using contr0ctors to support the NRC DSP where possible.

Other aspects of the NRC DSP such as the regulatory responsibility concerning the radiological consecuences associated with NRC dams, or its responsibility concerning all hazarcs related to aranium mill tailings dams, cannot be transferred. Therefore, although another Federal agency or a State might be able to assume concurrent oversight of the non-radiological hazards associated with these dams. NRC would still maintain regulatory oversight responsibilities that would overlap the former activities.

Furthermore. NRC is identified by statute (Section 7 of the National Dam Safety Program Act) as a member of ICODS.

Therefore. NRC participation in ICODS is required and includes attendance at regularly scheduied meetings and the preparation of a biennial report to FEMA.

In summary, the staff is effectively using its resources to implement the NRC DSP. Data on staff expenditures in FY 1996 have shown that the staff effort has been at approximately 0.8 FTE. This appears to be the level of effort expected in FY 1997. based on data available through July 1. 1997, and

I' The Commissioners 3

projections for the fourth quarter of FY 1997. This shows the staff's

- commitment to working in the most efficient manner in implementing the DSP, and results in a resource savings of 0.2 FTE over the projected budget.

The staff can also realize resource savings of about 0.3 FTE by reducing the number of dam safety inspections being conducted, and by using FERC to prepare NRC's input to the biennial report. Combi ing this resource savings of 0.3 FTE with the 0.2 FTE savings from actual versus budgeted expenditure, the total staff effort needed to support the NRC DSP is estimated to be about 0.5 FTE. This represents a 50 percent resource reduction in the projected budget estimate.

The FY 1999 Internal Program / Budget proposal includes one FTE per year for FY 1997-FY 2001 to support the NRC DSP.

If the proposed actions in this paper can be irr.plemented, it is estimated that approximately 0.5 FTE per year could be saved, as discussed above. The exact amount of savings will ba determined in the next several months following meetings with other Federal agencies, and the staff will also determine where these savings will be redirected.

The Chief Financial Officer has reviewed t..., paper and has no objections.

2.

Use of Alternative ADoroaches The staff considers that efforts have been made to minimize its resource expenditures in the DSP, commensurate with 3erforming its statutory obligations.

It recognizes the minimal rists associated with NRC dams and intends to carry out its responsibilities in a fiscally appropriate manner.

'To further minimize resource demands of the program, the staff will consider the possibility of using other approaches.

Several additional options that will be investigated include:

(1) Increased use of FERC to perform certain functions, such as preparation of emergency action plans (if they become necessary):

(2) Increased use of State inspections, if available; and (3) Reduced staff participation in interagency dam safety activities, relying on FERC, for example, to report to the NRC dam safety officer.

In addition, in the next several months, the staff intends to meet with other Federal agencies, including FEMA, FERC, and COE. to examine additional possibilities for streamlining the program and for increasing the use of these agencies.

By January 1. 1998, the staff will provide the Commission with the results of these meetings and with suggestions for further improving and streamlining NRC's DSP.

However, as discussed above, the staff believes it can achieve a resource reduction af only 0.5 FTE by taking the actions described.

Further resource savings may be minimal.

l

The Commissioners 4

The staff plans to implement the prcposed actions discussed above when it begins its contracting activities for FY 1998, unless directed otherwise by the Commission within two weeks of the date of tUs memorandum, cc: SECY OGC OCA OPA CF0 CIO DISTRIBUTION: NMSS 9700319/ED0 9700231 FILE CENTER-PUBLIC NMSS r/f URB r/f URB t/f DWM r/f DWM t/f CPoland CNWRA ACNW CCain EDO r/f-LJCallan-EJordan-HThompson-NMSS Dir Off r/f MFederline DGillen KDattilo MBridgers-DOCUMENT NAME:

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The Commissioners 4

The staff plans to implement the proposed actions discussed above when it begins its contracting activities for FY 1998, unless directed otherwise by the Commission within two weeks of the date of this memorandum.

DISTRIBUTION:

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The Commissioners 4

The staff plans to implement the proposed actions discussed above when it begins its contracting activities for FY 1998 unless directed otherwise by the Commission within two weeks of the date of this memorandum.

DISTRIBUTION:

Ticket N-9700319 WITS 9700231 FILE CENTER PUBLIC NMSS r/f URB r/f URB t/f DWM r/f DWM t/f CPoland CNWRA ACNW CCain EDO r/f LJCallan EJordan HThompson PTressler Dir Off r/f MFederline DGillen KDattilo it

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The Comissioners 3

projections for the fourth quarter of FY 1997.

This shows the staff's commitment to working in the most efficient manner in implementing the DSP.

.and results in a resource savings of 0.2 FTE over the projected budget.

The staff can also realize resource savings of about 0.3 FTE by reducing the number of dim safety inspections being conducted, and by using FERC to prepare NRC's input to the biennial report. Combining this resource savings of 0.3 FTE-with the 0.2 FTE savings from actual versus budgeted expenditure, the total staff effort needed to support the NRC DSP is estimated to be about 0.5 FTE.

This represents a 50 percent resource reduction in the projected budget estimate.

2.

Use of Alternative ADoroaches The staff considers that efforts have been made to minimize its resource expenditures in the DSP. commensurate with aerforming its statutory obligations, it recognizes the minimal risc.s associated with NRC dams and intends to carry out its responsibilities in a fiscally appropriate manner.

To further minimize resource demands of the program, the staff will consider the possibility of using other approaches.

Several options that will be investigated include:

(1) Increased use of FERC to perform certain functions, such as preparation of emergency action plans (if they become necessary) and preparation of input to the biennial dam safety report:

(2) Reduced staff participation in inspections and increased use of licensee and State inspections. if available; and (3) Reduced staff participation in interagency dam safety activities, relying on FERC, for example, to report to the NRC dam safety officer; In addition in the next several months, the staff intends to meet with other Federal agencies, including FEMA. FERC, and COE. to examine additional possibilities for streamlining the program and for increasing the use of these agencies.

By January 1. 1998, the staff will provide the Commission with the results of these meetings and with suggestions for further improving and streamlining NRC's DSP. However, as discussed above. the staff believes it can achieve a resource reduction of only 0.5 FTE by taking the actions described.

Further resource savings may be minimal.

The staff plans to implement the proposed actions discussed above when it begins its contracting activities for FY 1998, unless directed otherwise by the Commission within two weeks of the date of this memorandum.

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The Commissioners 3

projections for the fourth quarter of FY 1997. This shows the staff's n_

commitment to working in the most efficient manner in implementing the DSP.

and results in a resource savings of 0.2 FTE over tne projected budget.

The staf f can also realize resource savings of about 0.3 IE by reducing the number of dam safety inspections being conducted, and by using FERC to prepare i

l NRC's input to the biennial report.

Combining this resource savings of 0.3

-FTE with the 0.2 FTE savings from actual versus budgeted expenditure the total staff etfort needed to support the NRC DSP is estimated to be about 0.5 FTE. This represents a 50 percent rewurce reduction in the projected budget estimate.

2.

Use of Alternative Anoroaches The staff considers that efforts have been made to minimize its resource expenditures in the DSP. commensurate with )erforming its statutory obligations.

It recognizes the minimal riscs associated with NRC dams and intends to carry out its responsibilities in a fiscally appropriate manner.

To further minimize resource demands of the program. the staff will consider the possibility of using other approaches.

Several options that will be investigated include:

(1) Increased use of FERC to perform certain functions, such as preparation of emergency action plans (if they become necessary) and preparation of input to the biennial dam safety report:

(2) Reduced staff participation in inspections and increased use of-licensee and State inspections, if available: and (3) Reduced staff participation in interagency dam safety activities, relying on FERC. for example, to report to the NRC dam safety officer:

In addition, in the next several months, the staff intends to meet with other Federal agencies, including FEMA. FERC. and COE, to examine additional possibilities for streamlining the program and for increasing the use of these agencies.

By_ January 1. 1998, the staff will provide the Commission with the results of these meetings and with suggestions for further improving and streamlining NRC's DSP.

However, as discussed above, the staff believes it can achieve a resource reduction of only 0.5 FTE by taking the actions described.

Further resource savings may be minimal.

The staff plans to implement the proposed actions discussed above when it begins its contracting activities for FY 1998 unless directed othenvise by the Commission within two weeks of the date of this memorandum.

DOCUMENT NAME:

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The Commissioners 4

The staff plans to implement the proposed actions discussed above when it begins its contracting activities for FY 1998. unless directed otherwise by the Commission within two weeks of the date of this memorandum, DISTRIBUTION:

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The Commissioners 3

projections for the fourth quarter of FY 1997.

This shows the staff's t

commitment to working in the most efficient manner in implementing the DSP.

l and results in a resource savings of 0.2 FTE over the projected budget.

The staff can also realize resource savings of about 0.3 FTE by reducing the number of dam safety inspections being conducted, and by using FERC to prepare NRC's input to the biennial report.

Combining this resource savings of 0.3 FTE with the 0.2 FTE savings fron, actual versus budgeted expenditure. the total staff effort needed to support the NRC DSP is estimated to be aliout 0.5 FTE.

This represents a 50 percent resource reduction in the projected budget estimate.

2.

Use of Alternative Anoroaches The staff considers that efforts have been made to minimize its resource expenditures in the DSP commensurate with 3erforming its statutory obligations.

It recognizes the minimal rists associated with NRC dams and intends to carry out its responsibilities in a fiscally-appropriate manner.

To further minimize resource demands of the program, the staff will consider the possibility of using other approaches.

Several options that will be investigated include:

(1) Increased use of FERC to perform certain. functions. such as preparation of emergency action plans (if they become necessary) and preparation of input to the biennial dam safety report:

(2) Reduced staff participation in inspections and increased use of licensee and State inspections, if available: and (3) Reduced staff participation in interagency dam safety activities, relying on FERC. for example, to report to the NRC dam safety officer:

In addition, in the next several months, the staff intends to meet with other Federal agencies, including FEMA. FERC. and COE. to examine additional possibilities for streamlining the program and for increasing the use of these agencies.

By January 1. 1998, the staff will provide the Commission with the results of these meetings and with suggestions for further improving and streamlining NRC's DSP..However, as discusseo above. the staff believes it can achieve a resource reduction of only 0.5 FTE by taking the actions described.

Further resource savings may be minimal.

The staff plans to implement the proposed actions discussed above when it begins its contracting activities for FY 1998. unless directed otherwise by the Commission within two weeks of the date of this memorandum.

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'JATE RECEIVED: - 07/15/97 ORIGINAL DUE DT: 08/04/97 CONTROL Not 9700319 DIVISION DATE: 07/30/97 DOC DT: -07/11/97 FROM:

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COMP DT: y /7 /y John C. Hoyle SECY-TO:

L.. Joseph-Callan FOR SIGNATURE OF :

SECY NO:

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SRM to Callan from SECY re: SECY 97-110 - STATUS Paperiello REPORT ON IMPLEMENTATION OF DAM SAFETY PROGRAM Knapp Linehan Dattilo voland SPECIAL INSTRUCTIONS OR REMARKS:

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UMTED STATES C75:

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NUCLE AR REGULATORY COMMISSION Jordan g

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July 11, 1997 Blaha j

Collins,-NRR I

stengrany Thadani, RES Johnson, NMSS MEMORANDUM TO:

L. Joseph Callan

'xecutive Director for perations

&iLsex -W FROM:

John C. Hoyle, Secr tary

SUBJECT:

STAFF REQUIREMENTS - SECY 97-110 - STATUS REPORT ON IMPLEMENTATION OF DAM SAFETY PROGPJd4 The Commission, recognizing its statutory obligation to implement the requirements of the National Dam Safety Program Act, has approved the staff's plans to continue implementing NRC's current dam safety program.

Nevertheless, the Commission believes that the staff should apply resources judiciously to the program, apply the minimum resources necessary to comply with NRC's responsibilities, and explore mechanisms to reduce resource commitments, if possible.

Specifically, the staff should reconsider whether devoting one full FTE to the program in FY 1997 and FY 1998 is necessary to complete the most significant commitments made in the dam safety program.

In addition, the staff should reevaluate whether our current approach is the most effective and efficient for accomplishing the goals and objectives of the dam safety program or whether there are more cost effective alternative approaches, such as the transfer of oversight responsibility for the 19 dams under NRC jurisdiction to an agency that has a larger, well-established dam safety program.

(BBG)NMSS (SECY Suspense:

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8/4/97 9700231 pwA a l t oi

-l SECY NOTE:

THIS SRM, SECY-97-110, AND THE COMMISSION VOTING RECORD CONTAINING THE VOTE SHEETS OF ALL COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS SRM.

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cc

Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigr.n OGC CIO CFO OCA-OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)

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-July 11, 1997 OFFICE OF THE SECRETARY COMMISSION VOTING RECORD DECISION ITEM:

SECY-97-110 TITLE:

STATUS REPORT ON IMPLEMENTATION OF DAM SAFETY PROGRAM i

The Commission (with Chairman Jackson and Commissioners Dicus and McGaffigan agreeing) approved the subject paper as recorded-in the. Staff Requirements Memorandum (SRM) of July 11, 1997.

. Commissioner Diaz disapproved this paper.

This Record contains a summary of voting on this matter together with the individual vote sheets, views and comments of the Commissioners, and the SRM of July 11, 1997.

l.. 'TrL s h E. - Q :.r k M John C. Hoyle-Y Secretary of the Commission Attachments:
1. Voting Summary
2. Commissioner' Vote Sheets
3. Final SRM cc:

Chairman Jackson-Commissioner Dicus Commissioner Dia:

Commissioner McGaffigan OGC EDO PDR DCS l

M70777000P

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VOTING

SUMMARY

- SECY-97-110 RECORDED VOTES NOT APRVD DISAPRVD ABSTAIN PARTICIP COMMENTS DATE CHRM. JACKSON X

X 6/6/97 COMR. DICUS X

X 6/23/97 COMR. DIAZ X

X 6/10/97 COMR. McGAFFIGAN X X

7/3/97 COMMENT RESOLUTION In their vote sheets, Chairman Jackson and Commissioners Dicus and McGaffigan approved the staff's recommendation and provided some additional comments.

Commissioner Dia: disapproved the staff's recommendation.

Subsequently, the comments of the majority of the Commission were incorporated into the guidance to staff as reflected in the SRM issued on July 11, 1997.

2.

NOTATION VOTE RESPONSE SHEET t

TO:

John C. Hoyle, Secretary FROM:

CHAIRMAN JACKSON

SUBJECT:

SECY-97-110 - STATUS REPORT ON IMPLEMENTATION OF DAM SAFETY PROGRAM Approved d

Disapproved Abstain Not Participating Request Discussion COMMENTS:

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Entered on "AS" Yes

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No 41^iQ (jug p

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COMMENTS OF CitAIRMAN JACKSO!1 O!! SECY-97-110 I approve the continuation of the current Dam Safety Program as described in SECY 97-110.

Ilowever, I would like to raise two

First, points that the staff should consider in moving forward.

the staff requests one full FTE for FY 97 and FY 98 for the Dam Satety Program.

The staff states that the one FTE per year will be used to (1) continue interaction with FEMA and prepare input for FEMA's bi-annual report; (2) participate in FERC inspections of NRC dams; (3) manage the FERC contract; (4) continue to participate in the interagency Committee on Dam Safety; and (5) manage the program.

In a period of tight and shrinking resources, it appears to me that one FTE per year for these activities is excessive.

The staff should reconsider whether one full FTE per year is required to accomplish the above listed tasks.

Tho second point relates to URC's overall invo'

.ent in the Dam It appears to me that NRC haL a relatively small Safety Program.

role to play in this program at the national level. The FEMA bi-annual progress report (pp. 22-23) shows that NRC is responsible for only 19 " low hazard" dams out of approximately 36,000 dams in cams.

The staff the country, including about 3,500 "high hazarde should re evaluate whether our current approach is the most effective and efficient method for accomplishing the goals and objectives of the Dam Safety Program.

The sta.f should consider the viability of alternative methods for accomplishing these objectives.

e r

NOTATION VOTE RESPONSE SHEET T0:

John C. Hoyle Secretary of the Comission FROM:

COMMISSIONER DICUS

SUBJECT:

SECY 97 110 STATUS REPORT ON IMPLEMENTATION OF DAM SAFETY PROGRAM Approved XX Disapproved Abstain Not Participating Request Discussion COMMENTS:

SEE ATTACHED tt S,m g gE Release Vote /J_7 w

23

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p DATE Withhold Vote

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Entered on "AS" T6s I No w

COMMENTS OF COMMISSIONER DICUS ON SECY 97110 Because of NRC's present responsibility to oversee the 19 dams identified in staffs analysis and because of the critical FEMA assessment of NRC's progress in implementing the Federal Guidelines, I approve the staffs plans to continue implementing the current Dam Safety Program (DSP) and to increase the level of staff effort during FY 1997 and FY 1998 to 1 FTE and $60,000. My approvalis based on the expectation that during this time staff will complete the most significant commitments made in the DSP; namely,1) the completion of the dam safety inspections,2) the evaluation of NRC's criteria and technical guidance against the Federal Guidelines and

3) the completion of the dam classification. Completing these activities should result in a positive assessment of NRC's progress in FEMA's subsequent reports.

I am encouraged by staffs recent progress in the increased number of dam inspections and in the resolution of the emergency plan issue. In light of this recent progress, I do not support discontinuing or reducing the level of effort for NRO's existing dam safety program at this time.

Although I presently support the continuation of NRC's dam safety program, I agree with Chairman Jackson's and Commissioner Diaz's comments that staff should evaluate the feasibility of an alternate approach to the oversight of the 19 dams. Specifically, I believe that the staff should be directed to evaluate the feasibility of transferring the oversight of these 19 dams to an agency that is currently overseeing a large number of dams and that has a well established dam safety program. Benefits from econchiy of scale could be realized from this approach. An inter agency agreement should be considered as a possible_means for the transfer of oversight.

L.

NOTATION VOTE RESPONSE SBEET TO:

John C. Hoyle, Secretary FROM:

COMMISSIONER DIAZ

SUBJECT:

SECY-97-110 - STATUS REPORT ON IMPLEMENTATION OF DAM SAFETY PROGRAM Approved Disapproved Abstain

'/

Not Participating Request Discussion COMMENTS:

I do not agree with FDiA that our implementation has demonstrated a lack of commitment to dam safety, nor that more should be done.

The 19 dams considered by FDIA as being under NRC responsibility are generally small holding ponds with small associated risks. The staffs current level of effort cannot be justified by virtue of the risk these dams represent.

I would like the staff ta investigate alternatives to the current program that would be significantly less resource intensive.

One possibility might be to seek a cooperative agreement with an agency that is responsible for many dams so that we can benefit from the economies of scale.

Another possibility would be to have licensees self assess the dams for which they are responsible and submit the results of those assessments to NRC for review. At a minimum, the staff should discontinue its participation in the quarterly National Dam Safety Program meetings gid reduce inspection frequency to the minimum.

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'gGNATUhE Release Vote

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(o-10 -97 DATE Withhold Vote

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Entered on *AS" Yes No

'W 00C 9 ]

NOTATI ON VOTE RESPONSE SHEET TO:

John C.

Hoyle, Secretary FRON:

COMMISSIONER MCGAFFIGAN

SUBJECT:

SECY-97-110 - STATUS REPORT ON IMPmnntTATION OF DAM SAFETY PROGRAM Approved x w/coment Disapproved Abstain Not Participating Request Discussion _

COMMENTS:

SEE ATTACHED L

=/

Shirley Ann Jackson SIGNATURE Release Vote

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X/

June 6, 1997 DATE Withhold Vote

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Entered on "AS" Yes No Q9,07 ; 7 00 2;j -.

COMMISSIONER McGAFFIGAN'S VOTE ON SECY 97110-STATUS REPORT ON IMPLEMENTATION OF DAM SAFETY PROGRAM i approve the staffs plans to continue the Dam Safety Program, but the staff should strive to economize the resource commitment to this program, given the low hazard rating for the 19 dams within NRC's regulatory authority. I recognize that the NRC has a statutory obligation to implement the requirements of the National Dam Safety Program Act (NDSPA) for these dams, but the level of resources expended on the DSP should be limited to satisfying only the mandatory requirements of the NDSPA.

In general, like Commissioner Diaz l found much of FEMA's criticism of the NRC Dam Safety Program to be unfounded and lacking in its supporting analysis. Since the staff, in coordination with FERC, has completed the initialinspection and hazard assessment of all 19 dams within NRC's regulatory authority and has determined that all 19 dams have a low hazard rating, I believe that we should not devote additional resources to develop emergency action plans (EAPs) or update the SRP. In light of ongoing budget reductions, I urge the staff to continue to apply resources judiciously to the DSP, apply the minimal resources necessary to comply with our statutory responsibilities in this area, and explore mechanisms to further reduce our resource commitments on these matters.

n

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UNITED STATES 8*

NUCLE AR REGULATORY COMMISSION

-h WASHINGTON.0 C 70llko00t

%,,S.,,,,

July 11. 1997 M CatfAMV MEMORANDUM TO:

L. Joseph Callan ecutive Director for-perations dM-W

TROM, ohn C. Hoyle, Secr tary

SUBJECT:

STAFF REQUIREMENTS - SECY 97-110 - STATUS REPORT CN IMPLEMENTATION OF DAM SAFETY PROGRAM

-The Commission, recognizing its statutory obligation to implement the requirements of the National Dam Safety Program'Act, has approved the staff's plans to continue impicmenting NRC's current dam safety program.

Nevertheless, the Commission believes that the-staff should apply resources judiciously to-the program, apply the minimum resources necessary to comply with NRC's responsibilities, and explore mechanisms to reduce resource commitments, if possible.

Specifically, the staff should reconsider whether devoting one full FTE to the program in FY 1997 and FY 1998 is necessary to complete the most significant commitments made in the dam safety program.

In addition, the_ staff should reevaluate whether our current approach is the most effective and efficient for accomplishing the goals and objectives of the dam safety program or whether there are more cost effective alternative approaches, such as the transfer of oversight responsibility for the 19 dams under NRC jurisdiction to an agency that has a larger, well-4 established dam safety progre.m.

(EDO)

(SECY Suspense:

8/11/97)

SECY NOTE:

THIS SRM, SECY-97-110, AND THE COMMISSION VOTING RECORD CONTAINING THE VOTE SHEETS OF ALL COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS-FROM THE DATE OF THIS SRM.

--ifJi~)I700l)

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2-cc Chaiman Jackson Conunissioner Dicus commissioner Diaz Consnissioner McGaf figan OGC CIO CFO OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)-

PDR-DCS

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