ML20217Q578
| ML20217Q578 | |
| 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) |
| Shared Package | |
| ML20217Q571 | List: |
| References | |
| REF-WM-5 NUDOCS 9804130036 | |
| Download: ML20217Q578 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION e
WASHINGTON. D.C. 2056tMoo1
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August 6, 1997 MEMORANDUM TO:
Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan FROM:
L. Joseph Callan Executive Direct r per tions
SUBJECT:
STAFF REQUIREMENTS - DAM SAFETY PROGRAM In response to the staff requirements memorandum (SRM) dated July 11, 1997, the staff has reevaluated several of its 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 (FY) 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 accomplishing 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 Effectiveness of the Proaram The estimate of one FTE needed for FY 1997 and FY 1998 was based largely on actual staff resorces ex ended in the )ast. As of July 1, 1997, the staff has expended approximatel 0.6 FTE on t1e dam safety arogram (DSP).
corresponding to an annua rate of approximately 0.8 UE for FY 1997. Thus, it appears that less than one FTE will be expended in 1997 on the DSP.
Discussions with the FERC staff have indicated that FERC expends approximately 140 FTEs on its DSP for approximately 3000 dams under its jurisdictior.. The staff notes that this ratio is similar to the NRC's proposed ratio of 1 FTE for 19 dams, and that a program as large as FERC's results in an economy of l
scale that u not possible to achieve at 'he 1-FTE level.
l 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 been in support of basic DSP management activities such as:
- 1) participation CONTACT:
T. L Johnson. NMSS/DWM l
(301) 415-6658
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The Commissioners 2
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 inspecticns 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 M 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 the 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 Jecause there are specific provisions, in most NRC licenses, that require routine inspections to be performed by licensees.
The staff considers that it may 'e possible to use these licensee inspections to replace or J
augment NRC-led inspections, now that the initial 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 j
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 auove, only minor savings can be achieved over the arrangements l
already in effect. since the staff ir already 'asing contractors to support the NRC DSP. where possibie.
Other aspects of the NRC DSP. such as the reguiatory j
responsibility concerning the radiologial consecuences associated with NRC l
dams, or its responsibility concerning all hazarcs related to uranium mill tailings dams, cannot be transferred.
Therefore, although another Federal agency or a State might be able to assume concurrent oversight of the non-4 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 membe, of ICODS.
Therefore. NRC i
participation in ICODS is required and includes attendance at regularly j
scheduled 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
F..
l 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 I
NRC's input to the biennial report.
Cambir'ng 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 implemented it is estimated that approximately 0.5 FTE per year could i
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 i
'the staff will also determine where these savings will be redirected.
The Chief Financial Officer has reviewed tl gper and has no objections.
l 2.
Use of Alternative Acoroaches The staff considers'that efforts have been made to minimize its resource expenditures
'.n 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 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 NPC 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 ninimal.
r l '.
1
- l 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.
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