ML20206H396
| ML20206H396 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/1999 |
| From: | Joseph Holonich NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Reynolds S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9905110195 | |
| Download: ML20206H396 (4) | |
Text
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natu j $ UNITED STATES s* j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20565-0001 i
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f May 03, 1999 MEMORANDUM TO: Steven A. Reynolds, Deputy Director I Division of Reactor Safety, RGN-Ill l
FROM: Joseph J. Holonich, Deputy Director Division of Waste Management,
/
SUBJECT:
NRC DAM SAFETY ADVISORY GROUP (AITS R-99-1112)
On April 1,1999 Ross B. Landsman, Project Engineer with Decommissioning Branch, DNMS, submitted a memorandum to James E. Dyer, Regional Administrator (Rlll), which expressed a belief that the NRC Dam Safety Advisory Group (DSAG)" .. appears to be forgotten about." Mr.
Landsman requested that Mr. Dyer ask what NRC is doing for dam safety at the upcoming Senior Management Meeting.
Pursuant to Mr. Landsman's interrogative, Steven A. Reynolds, Deputy Director, Division of Reactor Safety (Rlli), forwarded Mr. Landsman's comments to the NRC Dam Safety Officer (DSO), Joseph J. Holonich, Deputy Director, Division of Waste Management. The
- memorandum from Mr. Reynolds requested that the DSO clarify the existing commitments ,
associated with the previous NRC actions, and if any commitments involve periodic dam inspections, to clarify the expectations regarding who will perform said inspections.
In response to the questions posed by Mr. Landsman and Mr. Reynolds, I can report that NRC's [ '
dam safety program is active, and that we are assisted in all inspections by experienced l
engineers from the Federal Energy Regulatory Commbsion (FERC). The FERC engineers [
follow guidelines consistent with their " Operating Manual for inspection of Projects and bgh Supervision of Licenses for Water Power Projects" docurnent. We currently inspect all dam l structures which are related to radiological health and safety on a two-to-three-year cycle, which is consistent with the Federal Guidelines for Dam Safety. All of the structures in our program have been classified as having " low-hazard potential."
Our mission with respect to dam safety is limited to inspecting those water retention structures which are related to radiological health and safety. A list of those dams in our mandate is attached. For reactor sites, our domain is limited to dams for ultimate heat sink ponds. Thus, dams for component cooling water and other such uses, which are not necessarily related to radiological health and safety, do not fall within our purview.
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CONTACT: Dan Rom, NMSS/DWM (301) 415-6704 $k. e 9905110195 990503 f(/ /u 7b PDR ORG NOMA //
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S. Reynolds To upgrade NRC's dam safety program to its current level of good standing, the program was revised in a 1997 SECY with OCM approval. The SECY and Staff Requirements Memorandum (SRM) documents, which were developed in this regard, are attached The DSAG was kept abreast of the progress of the SECY and SRM as the documents were drafted > nd submitted, in conjunction with the improvement of the program in 1998, a meeting was held with the Federal Emergency' Management Agency (FEMA), which oversees and coordinates interagency dam safety activities. FEMA expressed support of NRC's revised program at that time, and we have subsequently met quarterly with FEMA and the Interagency Committee on Dam Safety (ICODS), to maintain close contact with those charged with interagency oversight.
' in summary, I believe that NRC's dam safety activities are being given appropriate attention. !
. Mr. Landsman has expressed concem for Rlli dams which are beyond NRC program control as
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authorized by law. Such dams, which are not directly related to radiological health and safety, should be receiving inspections by others, including the States. If Mr. Landsman knows of any dams which are not currently being inspected, please let us know so we can forward the information to the appropriate agency.
Attachments:
- 1. List of dams
- 2. SECY-97-110 $
- 3. Staff Requirements Memorandum '
TICKET: DWM-99019 DISTRIBUTION: FILE CENTER PUBLIC NMSS r/f URLL r/f DWMr/f-t/f JDyer/ Rill RLandsman/ Rill JGavula' Rill ACNW w/oAtt.: CAbrams RWeller JGreeves DOCUMENT NAME: S:\DWM\URLL\DS,R\ TICK _ DAM.WPD OFC URLL dh pME DRom:bbh Jhnfch 4 DATE I/ S /99 hlJ/99 OFFICIAL RECORD COPY
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9 S. Reynolds To upgrade NRC's dam safety program to its current level of good standing, the program was
_. revised in a 1997 SECY with OCM approval. The SECY and Staff Requirements Memorandum (SRM) documents, which were developed in this regard, are attached. The DSAG was kept abreast of the progress of the SECY and SRM as the documents were drafted and submitted.
In conjunction with the improvement of the program in 1998, a meeting was held with the Federal Emergency Management Agency (FEMA), which oversees and coordinates interagency dam safety activities. FEMA expressed support of NRC's revised program at that time, and we have subsequently met quarterly with FEMA and the Interagency Committee on Dam Safety (ICODS), to maintain close contact with those charged with interagency oversight.
In summary, I believe that NRC's dam safety activities are being given appropriate attention.
Mr. Landsman has expressed concem for Rlli dams which are beyond NRC program control as authorized by law. Such dams, which are not directly related to radiological health and safety, should be receiving inspections by others, including the States. If Mr. Landsman knows of any dams which are not currently being inspected, please let us know so we can forward the information to the appropriate agency.
Attachments: l
- 1. List of dams l
- 2. SECY-97-110
- 3. Staff Requirements Memorandum I
p, -
l CATEGORYlDAMS-USNRC Name and Location NRC Region Number of Dams Type of Facility l Uranium Mills & In-Situs l
l Lucky Me (WY) IV 1 Mill Tailings l Crow Butte (NE) IV 3 Evaporation Ponds ,
l l White Mesa (NM) IV 4 Evaporation, Tailings l Power Resources, Inc (WY) IV 1 Purge Fluid Storage Shirley Basin (WY) IV 1 Mill Tailings Power Reactors North Anna (VA) ll 1 Service Water Pond Summer (SC) ll 3 Service Water Pond Catawba (SC) 11 1 Standby Service Reservoir Comanche Peak (TX) IV 1 Safe Shutdown Water l
Farley (AL) 11 1 Cooling Water Storage Shearon Harris (NC) 11 1 Auxiliary Reservoir McGuire (NC) 11 1 Standby Service Reservoir April 28,1999
! Attachment 1
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, i POLIC[ ISSUE {
($ cyp, tation Vote) 4 May 29, 1997 gi sECY-97-11o f: I d-FOR: The Commissioners A
FRON: L. Joseph Callan ,i Executive Director for Operations l b :
SUBJECT:
STATUS REPORTiON IMPLEMENTATION OF DAM SAFETY PROGRAM h i PURPOSE: 3
.o i To provide the Comission with an update of the U.S. Nuclear Regulatory Commission's efforts on implementing the Agency's Dam Safety Program (DSP).
P i BACKGROUND: Ji y di m In a memorandum dated October 4h1979. President Carten. asked that each Federal agency involved with dani's adopt and implement the " Federal Guidelines on Dam Safety" (FGDS). as applic'able. The memorandum diso requested Department and Agency heads to submit a report to the Federal Emergency Management Agency (FEMA) by January 31, 1980. Consistent with the memorandum.
NRC undertook efforts to implement the FGDS. However.dbecause NRC did not have a formal Dam Safety ProgramiPlan (DSPP). FEMA wasferitical of the NRC dam safety efforts. To address thish. concern, the staff prepared SECY-91-193. " Dam Safety Program Plan." SECY-91-193 outlined the various steps the NRC staff ;
had taken since October 1979 andiprovided an NRC DSPP for Comission approval.
Resources needed for the DSP were estimated to be approximately 1.0 full-time equivalent (FTE) per year and f200.000 in contractor 50pport. By memorandum dated July 30, 1991, FEMA on August 16, 1991. the ACommission a> proved copy >of tie approved DSPP s inthe DSPP1.{aand Attachment a copy wa SECY-91-193alsonotedthatNRCfjurisdictionoverdams'atNRC-regulated facilities was limited to dams that were: 1) integral!totheoperationofthe facility and radiologically safety related, or 2) assodiated with mill !
tailings impoundments. This excluded from NRC consideration those dams that may be on-site _ dams associated With, or attendant to a(licensed facility but not related to radiological safety. This cate90rization was based on an i b "
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CONTACT: T. L. Johnson. NMSS NOTE: To BE MADE PUBLICLY AVAILABLE WHEN ..
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$k Office of the General Cour/sel (0GC) analysis tha NRC regulatory authority would be confined to either dams with radiologic)al hazards, or mill tailings i
dam: where there was statutory authority. That analysis also stated that if i no other Federal or State agency were regulating;the non-radiological hazards of a dam associated with an NRC-regulated facility, an argument could be made for NRC authority over thehnon-radiological safety aspects to avoid the creationofaregulatoryg4p. (There is expressistatutory authority to address non-radiological hazards with respect toduranium mill tailings impoundments.) Originalljiin NUREG-0965. "NRC Iriventory of Dams." the staff identified 65 dams associa1ed with NRC licensees , However. further analyses indicatedthatnotallofhhese dams were radiol ically safety-related (or thatotherswerealreadyregulatedbyanotherFedralagencyviewedashaving more responsibility than NRC for implementing the FGDS). and that only 34 could be regulated under NRC authority. Recent closures of several uranium mill tailings impoundmentsthave further reduced that number to 19 dams now under NRC jurisdiction. ih t 9 R~
Since July 1991, the staff'has undertaken a number of activities to work toward full implementationfof the DSPP. On August 28. 1991, the NRC Dam Safety Officer met with FEMA personnel, including' the Chairman of the i Interagency Committee on Qam Safety (ICODS). The purpose of the meeting was to obtain from FEMA feedback on the DSPP. FEMA made no adverse coments on it. Having obtained input (from FEMA, the staff then moved to implement the DSPP. .. l
% 8 Consistent with the plan, ,the ttaff and the Federal Energy Regulatory Commission (FERC) developed a Memorandum of Understanding (HDU). The MOU provided for assistance from the FERC Office of Hydropower Licensing in inspecting those dams undet NRC jurisdiction. Under this H00. FERC has conducted inspections at 18 of the 19 NRC dams. $esults from these inspections have not identified any significant problems with the dams. The staff, with assistance from FERC. currently plans to complete the inspection of the one remaining dam by,the end of Fiscal Year (FY) 1997. However.
because of budget reductiorls, the staff has been, unable to achieve some of the other actions identified in the DSPP such as therdevelopment of a standard
. review plan (SRP). In accordance with recommenda'.tions presented in the FGDS.
thestaffalsoperformeda%detailedreviewanddeterminedthatnoneoftheNRC dams posed a high or signi'ficant downstream hazard, since failure would not result in loss of life or 'significant property damage. Thus, consistent with theFGDS.thestaffconclqdedthattherewasnoneedfortheEmergencyAction Plans (EAPs) anticipated 1,ri, the DSPP.
A recent FEMA report. "Nat'ional Dam Safety Program - 1994 and 1995." was critical of the NRC progra'm. The report provides several recommendations for NRC to implement including increased use of FERC development of EAPs (notwithstanding the earli:er NRC staff conclusion). and expanded involvement (increased level of effort) in the DSP. A co)y of the report is provided as Attachment 2. Based on the FEMA report and t1e recent passage of the National Dam Safety Program Act (NDSPA). ]assed as Section 215 of the Water Resources Development Act (WRDA) of 1996 (Public Law 104-303), the staff decided that a reevaluation of the DSP was a warranted. y
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R b The Comissioners i 3 9 p K To further clarify FEMA's neerns. staff met with\ FEMA on January 10. 1997.
At this meeting staff dis jssed the recent FEMA gational Dam Safety Program ,
recommendations and NRC plabs: for implementation qf these recomendations. I NRC staff identified plans! o finish the first ro d of inspections (for dams i included in the NRC invent ) by the end of FY971 nd to discuss follow-up inspection frequency after $he currently-schedule , inspections are completed.
FEMA agreed that EAPs woul not be necessary if NRC confirmed that none of the NRC dams was classified as@Ni high- or significant4 hazard dam.
FEMA and NRC also discussed methods for ' determining responsibility for dams at certain sites not subject to NRC juitisdiction and not included in the NRC inventory.
In addition, other recomeqdations were discussedj including expanded use of the FERC. NRC staff plans ,to follow up on these recommendations.
DISCUSSION:
The NDSPA formalizes the direction President Carter provided in 1979 to ;
encourage implementation of^the FGDS. A copy of Section 215 of the WRDA is in Attachment 3. In general, the NDSPA does not impose any express new manaates for dam regulation on Fedecal agencies and does not supersede existing authorities of Federal agencies. Some questions rsmain open concerning FEMC s authoritytoimposenewobygations. Even if it has the authority to impo e I new obligations, these newipbligations would not supersede existing i authorities. However. it is premature to address'such questions until FEMA issues implementing regulations. Therefore, the staff has concluded that no I new actions are required aththis time in implement'ing the NRC DSP. lj t d WithrespecttotheFEMAcrfi"ticismoftheNRCproiram,asdiscussedabove,the j staff considers that it hasDadequately im)lemented the FGDS. Based on the ;
staff analysis of downstream hazards et t1e 19 dams.now under NRC l jurisdiction. the staff concluded that there were yo dams that could be considered a high hazard. High-hazard dams are those dams that if breached, could result in substantiapproperty damage or loss of life. Because only high-hazard dams are required to have EAPs. the staff. therefore, does not i plan to develop EAPs. In addition, when FERC. under NRC direction. completes I the inspection of the one remaining dam. it will have inspected all the dams ;
over which NRC has regulatory authority. This effort will allow the staff to l initially determine if all the NRC dams meet the FGDS under the current DSP. .
The staff plans to continue' i year. to help ensure continu,to use FERC ed compliance to routinely with FGDS. inspect some It is anticipated that dams each; this effort will cost approx'imately 50.000 dollarsiper year for between three to five inspections. In addition. the staff plansito continue to support ICODS at an annual cost of 10.000 dollars. ?
If the Comission decides tq pursue any new work.
anSRPorpreparationofEAVS.additionalresource[suchasthedevelopmentof s would be needed. The staff is currently ravising its SRP for the revie4 of reclamation designs at milltailingsimpoundments.l/ourcesforcompleting!thisad this SRP. The estimated re,9A chapter covering dam safety could be added to be approximate ? 0.4 FTE (or about 100.000 dollars if a contractor were used).
If the Comission were to hcidethatEAPsshouldbecomletedforallNRC dams. this effort would taks an additional 2.0 FTE ' spread over approximately two fiscal years. It shoul be noted that NRC r 1 tions currently do not a j k O
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tp b require NRC licensees to pqepare EAPs for dams. If the Comission decided to i have licensees prepare EAPsgand licensees chose not to, the staff would have enforcement capability reg ding licensee EAP preparation only on uranium mill licensees. under Section 8 of the Atomic EneroyfAct of 1954. as amended. l Successful implementation 3rogram would require the promulgation of a rule requiring the development EAPsof by licens)ees.'an EAP This rulemaking effort rces beyond those previously identified. However, would the staff need does notadditional plan to resou$ndertake either of thsse two activitie l directed by the Comissiond Rather. the staff finds the current DSP !
sufficient for ensuring compliance with the FGDS and the WRDA. ]
0 ,
J RESOURCES: M !
h i In FY 1996. NMSS expended approximately 0.8 FTE on the DSP. In FY 1997 and J FY 1998. NMSS had budgeteds0.2 FTE and 10.000 dollars. The staff has I reprogrammed resources in FJ 1997 and FY 1998 to support the DSP at !
approximately 1.0 FTE and 60.000 dollars. Activities that will be undertaken ;
usingthe1.0FTEbudgeted:linclude: 1) continueddinteraction with FEMA on dam i safety issues, and preparation of input to the biJannual dam safety report: 2) i i
coordination conducted participation;l by FERC: 3) genera contract management)f the FERC contract:in, 4) and follow continued participation in;ind support to ICODS: ind 5) overall management and i implementation of the agency's DSP. The 60.000 dollars of contractor su l will be for the continued use of FERc to inspect 3 to 5 dams each year pport and I the 10.000-dollar membership fee for ICODS. I !
M t I This reprograming, along with the availability of resources for FY 1999 through FY 2001. is being addressed as part of the FY 1999 Internal Program / Budget Review Proces's. If the Commission irects the staff to pursue
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new work associated with the DSP, as presented in he " Discussion" section :
above (i.e., development of'an SRP or preparation , f EAPs for all NRC dams), j additional resources would be required. j.
p l RECOMMENDATIONS: /G
.6
- Subject to Comission approY[al. the staff plans tdfcontinue with the current DSP. but with increased restbrces to support necessary staff efforts and expanded use of FERC for folllow-up inspections to {nsure compliance with FGDS.
COORDINATION:
I't The Office of the General Co'unsel has reviewed thiK paar and has no legal objection. The Office of the Chief Financial Officer las no objection to the i resource estimates contained:in this paper. The Office of the Chief Information Officer has alsb} reviewed this paper and concurs.
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! L. J allan ExecutiheDirector for Ope, rations Attachments: N d
- 1. Approved DSPP r E[
- 2. FEMA Report l j
- 3. WRDA Section 215 p , a y JL w ~.
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- Action: Paperiello, NMSS
,Q# .% UNITED STATES Cys: Callan Jordan
- 'n NUCLEAR REGULATORY COMMISSION
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' * * . . , +# July 11, 1997 Col 1 ins, NRR scenerany Thadani, RES Johnson, NMSS MEMORANDUM TO: L. Joseph Callan xecutive Director for perations FROM:
dwW John C. Hoyle, Secr tary
SUBJECT:
STAFF REQUIREMENTS - SECY 97-110 - STATUS REPORT ON 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 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.
(B9G)NHSS (SECY Suspense: ^/~'.'^")
8/4/97 9700231 pW4 qltoja" ;
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SECY NOTE: THIS SRM, SECY-97-110, AND THE COMMISSION VOTING i
RECORD CONTAINING THE VOTE SHEETS OF ALL COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS SRM.
f Attachment 3
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cc: Chairman-Jackson'
' Commissioner Dicus Comntissioner .Diaz
.. Commissioner McGaffigan-
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\o****) July 11, 1997 l OFFICE OF THE SECRETARY COMMISSION VOTING RECORD l DECISION ITEM: SECY-97-110 i
TITLE: STATUS REPORT ON IMPLEMENTATION OF DAM SAFETY PROGRAM The Commission (with Chairman Jackson and Commissioners Dicus and McGaffigan agreeing) approved the subject paper as recorded in i l
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.
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John C. Hoyle T Secretary of the Commission Attachments:
- 1. Voting Summary j
- 2. Commissioner Vote Sheets
- 3. Final SRM 1
cc: Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan OGC ;
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e VOTING
SUMMARY
- SECY-97-110 i
RECORDED VOTES 1
NOT DATE {
APRVD DISAPRVD ABSTAIN PARTICIP COMMENTS l 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 l
Q)MMENT RESOLUTION l In their vote she'ats, Chairman Jackson and Commissioners Dicus and McGaf figan :sppresed the staf f's recommendation and provided some additional ccrments. Commissioner Diaz disapproved the staff's recommrendation. Subsequently, the comments of the l mnjerity of the . ommission were incorporated into the guidance to I staff as reflected in the SRM issued on July 11, 1997.
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NOTATION VOTE RESPONSE SHEET f
TO: John C. Hoyle, Secretary FROM: CHAIRMAN JACKSON
SUBJECT:
SECY-97-110 - STATUS REPORT ON IMPrmmmTATION OF DAM SAFETY PROGRAM ,
Approved d Disapproved Abstain Not Participating Request Discussion COMMENTS: ,
Y(4 ,L r-S I G N A % () ,
Rolease Vote / f/- _
~7!3!77 DATE' Withhold Vote / /
Entered on "AS" Yes Y No f/Oit 7 Oo V &ff
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COMMENTS OF CHAIRMAN JACKSON ON SECY-97-110
.I approve.the continuation ofHowever,-I the_ current Dam Safety Program as would like to raise two described in SECY-97-110.
points that the' staff should consider in moving forward. First, the' staff' requests one full FTE for FY 97 and FY 98 for the Dam Safety 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 l 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 ,
j
. 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 ~.
The second point relates to NRC's overall involvement in the Dam Safety Program. It appears.to me that NRC has a relatively small role to play in this program at the national level. The FEMA bi-l annual l progress report (pp. 22-23) shows that NRC is responsible l l
for only 19 " low hazard" dams out of approximately 36,000The dams in staff the country, including about 3,500 "high hazard" dams.
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 staff should consider the viability of alternative methods for accomplishing these objectives.
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NOTATION V0TE 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 l Approved XX Disapproved Abstain Not Participating Request Discussion ;
COMMENTS:
SEE ATTACHED i
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g gE Release Vote /_X 7 m E3 /95>
p DATE Withhold Vote / /
Entered on "AS" Tis / No
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- # i l COMMENTS OF COMMISSIONER DICUS ON SECY-97_-110 Because of NRC's present responsibility to oversee the 19 dams identified in staff's analysis and because of the critical FEMA assessment of NRC's progress in l
implementing' the Federal Guidelines, I approve the stars 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 approval is based on the l
expectation that during this time staff will complete the most significant commitments L
made in the DSP; namely,1) the completion of the dam safety inspections, 2) the l evaluation of NRC's criteria and teichnical guidance against the Federal Guidelines and l
- 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 l encouraged by stars 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 l
support discontinuing or reducing the level of effort for NRC's existing dam safety program at this time. ,
l '
1 l 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 economy of scale could be realized from this approach. An inter-agency agreement should be '
I considered as a possible means for the transfer of oversight.
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NOTATION VOTE RESPONSE SHEET 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 FEMA that our implementation has demonstrated a lack of commitment to dam safety, nor that more should be done. The 19 dams considered by FEMA 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 to 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 sconomies 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 ap' reduce inspection frequency to the minimum. [
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' QGNATttSE Rolease Vote /__X _/ _
(o- 10 -97 DATE '
Withhold Vote / /
Entered on "AS" Yes No
'Q ~pe o 27 - jp
r NOTATION 3.
VOTE ,
RESPONSE SHEET TO: John C. Hoyle, Secretary FROM: COMMISSIONER MCGAFFIGAN .
l
SUBJECT:
SECY-97-110 - STATUS REPORT ON IMPL W ATION OF DAM SAFETY PROGRAM Approved X w/Coment Disapproved Abstain l Not Participating Request Discussion COMMENTS:
SEE ATTACHED W =I Shirley Ann Jackson SIGNATURE Release Vote / X/ June 6, 1997 DATE Withhold vote / /
Entered on "AS" Yes No l
i Wu/r/0027 -i79
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y . 1 COMMISSIONER McGAFFIGAN'S VOTE ON SECY-97-110-STATUS REPORT ON L IMPLEMENTATION OF DAM SAFETY PROGRAM i approve the staff's 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 resour::es expended on the DSP should be limited to satisfying only the mandatory requirements of the NDSPA.
In general, like Commissioner Diaz 1 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 initial inspection 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 i
area, and explore mechanisms to further reduce our resource commitments on these matters. )
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,8'Q CtcN UNITED STATES
- h. O' k NUCLEAR REGULATORY COMMISSION g WASHINGTON, D.C. 20555 0001 3
July 11, 1997 l % . .... #
.s e CR ETA RY l
MEMORANDUM TO: L. Joseph Callan xecutive Director for perations
\l M -Loridf FROM: ohn C. Hoyle, Secr tary
SUBJECT:
STAFF REQUIREMENTS - SECY 97-110 - STATUS REPORT ON' 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 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.
(EDO) (SECY Suspense: 8/11/97) 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 Consnissioner McGaffigan OGC CIO
'CFO OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
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