ML20235A840
| ML20235A840 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/1987 |
| From: | Bradburne J NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Bernthal, Roberts, Zech NRC COMMISSION (OCM) |
| Shared Package | |
| ML20235A045 | List: |
| References | |
| FOIA-87-737 NUDOCS 8801130088 | |
| Download: ML20235A840 (19) | |
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UNITED STATES 5 #"
NUCLEAR REGULATORY COMMISSION 5 .I wAssiNorow,0. c. 20sss s 1 3 . Sa f.
%,***** / October 2, 1987 7y ,.Q MEMORANDUM FOR: Chairman Zech Commissioner Roberts Commissioner Bernthal Commissioner Carr Commissioner Rogers
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FROM: John Bradburne, Direc r Congressional Affairs GA
SUBJECT:
SHARP SUBCOMMITTEE .EET$ ON EMERGENCY DATA SYSTEM, SAFEGUARDS AND APPA AC IAN COMPACT BILLS On Thursday, October 1, the Subcommittee n Energy and Power held hearings on H.R.1570, which establishes an emergency response data system for nuclear reactors; H.R. 2683, the NRC's legislative proposals for improving safeguards and reporting defects; and H.R. 3025, the " Appalachian States Low-Level Radioactive Waste Compact Consent Act." The Subcommittee later marked up and reported the NRC's legislative proposals and the Appalachian compact without amendment. The emergency response data system bill will be marked up next week.
The hearing was chaired by Rep. Philip Sharp (D-IN). Rep. Jerry Huckaby (D-LA) testified on behalf of his original data system concept, one that would be turned on only during emergencies at nuclear plants, rather than the continuous monitoring system reported by the Interior Comittee. The Comission also favored the original system, but offered to require the system to be turned on during an " unusual event." The Comission urged approval of its legislative proposals and endorsed the Appalachian Compact.
Dr. Terry Lash, Director of the Illinois Department of Nuclear Safety, said that the Department has been continuously monitoring operations at comercial nuclear plants in Illinois for the past 21 years. He endorsed contir.ucus monitoring and felt that other states should be able to develop their own systems as long as those systems are compatible with the system required by the NRC.
Mr. Ron Harris, representing Duke Power company and ANEC, opposed H.R.1570 because it appeared to move towards centralized control of reactor operations by the NRC. He added that continuous monitoring would weaken the operators' authority and responsibility and could shift nuclear power regulation from the NRC to the states. He suggested that as an alternative, utilities could store plant operating data for a few days, then " dump" the data to the data system in the event of an accident requiring monitoring.
Copies of written statements are available at CA.
1 CONTACT: Frederick Combs x-41443 d '
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S. NUCLEAR REG LATORY COMMISSION TESTI NY ON H R. 268 , H R 1570, H R. 3025 SHORTSTATEMENTOFdHAIRMANZEdH l
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MR. CHAIRMAN, MEMBERS OF THE SUBCOMMITTEE, 1 AM PLEASED TO l
APPEAR BEFORE YOU TODAY TO DISCUSS H.R. 2683--WHICH CONSISTS i 1
0F FOUR LEGISLATIVE PROPOSALS THAT THE NUCLEAR REGULATORY COMMISSicN (NRC) SUBMITTED TO CONGRESS THIS YEAR, j H.R. 1570--THE " NUCLEAR POWER EMERGENCY RESPONSE DATA SYSTEM ACT OF 1987", AND H,R. 3025--THE " APPALACHIAN LOW-LEVEL
[ RADI0 ACTIVE WASTE DISPOSAL COMPACT CONSENT ACT." THE ,
I COMMISSION IS MOST APPRECIATIVE OF THE COMMITTEE'S INTEREST IN THESE LEGISLATIVE PROPOSALS. WITH YOUR PERMISSION, I WILL I SUBMIT MY COMPLETE STATEMENT FOR THE RECORD AND SUMMARIZE IT BRIEFLY. LET ME BEG,'N WITH A DISCUSSION OF H.R. 2683, THE NRC'S LEGISLATIVE PROPOSALS.
1 THE FIRST SECTION OF H.R. 26E l
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THE FIRST SECTION OF H.R. 2683 WOULD AMEND SECTION 147 0F THE ATOMIC ENERGY ACT TO PROVIDE THAT THE COMMISSION IS AUTHORIZED TO PROTECT FROM PUBLIC DISCLOSURE SENSITIVE GENERIC SAFEGUARDS INFORMATION WHEN DISCLOSURE COULD COMPROMISE OR NEGATE' SITE-SPECIFIC SECURITY MEASURES REQUIRED BY THE COMMISSION TO PROTECT NUCLEAR MATERIALS AND FACILITIES AGAINST THEFT, DIVERSION OR SABOTAGE.
l AS A RESULT OF ITS EXPERIENCE IN IMPLEMENTING SECTION 147, THE COMMISSION IS AWARE OF AN AMBIGUITY IN THAT SECTION.
I RELATING TO THE COMMISSION'S AUTHORITY TO PROTECT FROM PUBLIC DISCLOSURE GENERIC INFORMATION THAT WOULD BE LIKELY TO ENDANGER SPECIFIC SAFEGUARDS MEASURES IMPLEMENTED BY NRC LICENSEES. q i
2 THIS LEGISLATION, IF ENACTED, 1
THIS LEGISLATION, IF ENACTED, WOULD NOT SIGNIFICANTLY INCREASE THE SCOPE OF INFORMATION WHICH THE COMMISSION MAY WITHHOLD FROM THE PUBLIC. YET, BY EXPLICITLY AUTHORIZING THE WITHHOLDING OF A SMALL CLASS OF SENSITIVE SAFEGUARDS INFORMATION, CONGRESS COULD HELP PREVENT ANY POSSIBILITY THAT l
1 AN ALTERNATIVE INTERPRETATION OF SECTION 147 COULD RE3 ULT IN l
THE DISCLOSURE OF INFORMATION THAT COULD BE OF ASSISTANCE TO A SABOTEUR. )
i SECTION 2 0F H.R. 2683 WOULD AUTHORIZE THE COMMISSION TO PROMULGATE REGULATIONS WHICH WOULD PROHIBIT A PERSON WHO HAS NOT OBTAlHED PRIOR AUTHORIZATION TO CARRY, TRANSPORT, OR OTHERWISE INTRODUCE OR CAUSE TO BE INTRODUCED ANY DANGEROUS WEAPON, EXPLOS!YE, OR OTHER DANGEROUS INSTRUMENT INTO ANY FACILITY, INSTALLATION, OR REAL PROPERTY REGULATED BY THE COMMISSION.
3 THIS PROVISION IS NEEDED
THIS PROVISION IS NEEDED BECAUSE THERE HAVE BEEN AN INCREASING NUMBER OF REPORTED INCIDENTS WHERE PERSONS WITHOUT AUTHORIZATION HAVE BROUGHT FIREARMS INTO PROTECTED AREAS OF NRC REGULATED SITES. WHILE THE COMMISSION CURRENTLY CAN AND DOES IMPOSE SANCTIONS AGAINST LICENSEES FOR PERMITTING UNAUTHORIZED WEAPONS OR OTHER DANGEROUS INSTRUMENTS TO ENTER THE SITE, THERE IS NO FEDERAL LAW PERMITTING THE IMPOSITION OF CRIMINAL SANCTIONS AGAINST THE PERSON RESPONSIBLE FOR BRINGING THE WEAPON OR OTHER DANGEROUS INSTRUMENT TO THE SITE.
THE THIRD SECTION OF H.R. 2683 WOULD AMEND SECTION 236 0F THE ATOMIC ENERGY ACT TO MAKE IT A CRIME TO SABOTAGE OR ATTEMPT l
TO SABOTAGE A NUCLEAR PRODUCTION OR UTILIZATION FACILITY l
DURING ITS CONSTRUCTION WHERE THE ACTION, IF IT WENT UNDETECTED, COULD AFFECT PUBLIC HEALTH AND SAFETY. CURRENTLY, SECTION 236 COVERS ACTS OF SABOTAGE TO A UTILIZATION FACILITY ONLY AFTER I IT HAS RECEIVED ITS OPERATING LICENSE FROM THE COMMISSION.
4 THIS PROPOSED LEGISLATION
5 THIS PROPOSED LEGISLATION NARROWLY DEFINES THE TYPE OF SABOTAGE WHICH WOULD CONSTITUTE A FEDERAL OFFENSE. THE SAB0TAGE OR ATTEMPTED SABOTAGE MUST BE SERIOUS ENOUGH TO HAVE A POSSIBLE EFFECT ON PUBLIC HEALTH AND SAFETY IF NOT DISCOVERED PRIOR TO OPERATION.
WE BELIEVE THAT ENACTMENT OF H.R. 2683 IS WARRANTED TO PROVIDE GREATER PROTECTION FOR THE PUBLIC HEALTH AND SAFETY BY ENACTING CRIMINAL SANCTIONS TO DETER SUCH SABOTAGE.
THE FOURTH SECTION OF H.R. 2683 PERTAINS TO THE COMMISSION'S 1
ABILITY TO RECEIVE PROPER NOTICE OF DEFECTS OR REGULATORY VIOLATIONS AT NUCLEAR POWER PLANTS AND OTHER REGULATED I
ACTIVITIES, WHERE SUCH DEFECTS OR VIOLATIONS COULD CREATE SUBSTANTIAL SAFETY HAZARDS.
I 5 BASED ON MORE THAN A DECADE
BASED ON MORE THAN A DECADE OF EXPERIENCE IN IMPLEMENTING THIS STATUTORY PROVISION, WE BELIEVE THAT SOME CHANGES IN of Dw GHtwt It M %sutud her SECTION 206 ARE g WARRANTED. FIRST, WE BELIEVE THAT THE SECTION SHOULD BE REVISED TO PROVIDE THAT THE FIRM, AS WELL AS INDIVIDUAL DIRECTORS AND RESPONSIBLE OFFICERS SHOULD BE RESPONSIBLE FOR NOTIFYING THE COMMISSION. THIS ASSIGNMENT OF RESPONSIBILITY WOULD BE MORE IN ACCORD WITH THE GENERAL APPROACH TO REGULATION UNDER THE ATOMIC ENERGY ACT, WHICH IMPOSES RESPONSIBILITY ON THE LICENSEE, RATHER THAN '
INDIVIDUAL CORPORATE OFFICERS FOR COMPLIANCE WITH REGULATORY REQUIREMENTS.
6 UNDER OUR PROPOSAL THE CURRENT
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-7 UNDER OUR PROPOSAL THE CURRENT PROVISION THAT A CIVIL PENALTY l MAY BE LEVIED AGAINST INDIVIDUAL DIRECTORS AND RESPONSIBLE i
0FFICERS FOR A KNOWING AND CONSCIOUS FAILURE TO NOTIFY THE COMMISSION WOULD BE RETAINED. HOWEVER, THE PROPOSED LEGISLATION WOULD SUBJECT A FIRM TO SANCTIONS FOR ANY FAILURE TO NOTIFY,
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REGARDLESS OF ITS INTENT OR DEGREE OF NEGL:GENCE IN FAILING 1
l TO COMPLY WITH THE COMMISSION'S REGULATIONS. THIS WOULD l l
ENSURE THAT THE FAILURE TO REPORT VIOLATIONS OR DEFECTS,
( REGARDLESS OF THE REASONS FOR THE REPORTING FAILURE, WOULD BE SUBJECT TO POSSIBLE civil SANCTIONS.
H.R. 2683 WOULD ALSO CLARIFY THE COMMISSION'S AUTHORITY TO PROMULGATE REGULATIONS, ISSUE ORDERS, AND CONDUCT INSPECTIONS AND INVESTIGATIONS UNDER SECTION 206. THESE PROVIS10NS'WOULD v '
CODIFY EXISTING PRACTICE AND REMOVE ANY QUESTIONS REGARDING THE COMMISSION'S AUTHORITY TO TAKE NECESSARY ACTIONS TO IMPLEMENT SECTION 206.
e 7 THE PROPOSED LEGISLATION
- I THE PROPOSED LEGISLATION WOULD ALSO CLARIFY THAT A FIRM, WHETHER IT BE A LICENSEE OR A fl0ft-LICENSEE, MAY BE SUBJECT TO ;
A CIVIL PENALTY FOR VIOLATING COMMISSION REGULATIONS OR ORDERS ISSUED TO IMPLEMENT AND ENFORCE SECTION 206, AS WELL i
AS FOR V10LAT10flS OF SECTION 206 ITSELF. THE CURRENT STATUTE IS AMBIGUOUS REGARDING THE COMMISSION'S AUTHORITY TO IMPOSE SANCTIONS AGAINST NON-LICENSEES, SUCH AS REACTOR YEf4 DORS. i i
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( SECTION 4 WOULD ALSO MAKE OTHER AMENDMEl4TS TO SECTION 206 AND l
WOULD SUBJECT THE DEPARTMENT OF ENERGY TO THE REQUIREMENTS OF SECTION 206 TO THE EXTENT THAT THE DEPARTMENT'S ACTIVITIES, FACILITIES OR MATERIALS, ARE LICENSED BY THE COMMISSION. THE l COMMISS10f4 BELIEVES THE DEPARTMENT OF ENERGY, TO THE EXTENT i l
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IT IS SUBJECT TO flRC LICENSING, SHOULD BE SUBJECT TO THE SAME 1
REGULATORY REQUIREMENTS AS OUR OTHER LICEllSEES.
8 WE BELIEVE THAT THE AD0PTION s
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_9 WE BELIEVE THAT THE ADOPTION OF THESE AMENDMENTS WOULD l
1 CLARIFY THE SCOPE OF SECTION 206 AND THEREBY ENSURE THAT THE COMMISSION HAS SUFFICIENT AUTHORITY TO IMPLEMENT EFFECTIVELY )
THE NOTIFICATION REQUIREMENTS MANDATED BY CONGRESS.
H.R. 1570, AS REPORTED BY THE COMMITTEE ON INTERIOR AND l l
INSULAR AFCAIRS, WOULD REQUIRE THE CREATION OF AN EMERGENCY 4
RESPONSE DATA SYSTEM (ERDS). THIS SYSTEM WOULD PROVIDE FOR
[ DIRECT ELECTRONIC TRANSMISSION OF SELECTED PARAMETERS FROM NUCLEAR POWER REACTORS TO THE COMMISSION.
THE COMMISSION SUPPORTS ENACTMENT OF LEGISLATION FOR A SYSTEM SIMILAR TO THAT WHICH WOULD BE REQUIRED BY H R. 1570 AS ORIGINALLY PROPOSED BECAUSE SUCH LEGISLATION WOULD
, SUBSTANTIALLY ENHANCE OUR INCIDENT RESPONSE CAPABILITY.
9 THE EFFECTIVENESS OF THE l
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THE EFFECTIVENESS OF THE NRC IN PERFORMING JTS ROLE IS l
DEPENDENT ON'THE QUALITY AND TIMELINESS OF THE EVENT INFORMATION THE-AGENCY RECE!VES.
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CURRENTLY, THE DATA IS TRANSMITTED TO THE NRC FROM THE LICENSEE BY STANDARD YOICE TELEPHONE COMMUNICATIONS. TWO-PRIMARY PHONE LINKS ARE USED. ONE IS DEDICATED FOR REACTOR-DATAJ THE OTHER IS PRIMARILY FOR RADIOLOGICAL AND i .
METEOROLOGICAL DATA. OUR EXPERIENCE WITH VOICE-ONLY EMERGENCY COMMUNICATIONS--STARTING WITH TMI AND REINFORCED NUMEROUS TIMES SINCE THEN--!S THAT IT CAN BE TOO SLOW AND CAN BE PRONE TO ERROR. INFORMATION MAY BE MISCOMMUNICATED, I FREQUENTLY CREATING FALSE ISSUES WHICH CAN DIVERT ATTENTION FROM THE REAL PROBLEMS. EVEN WORSE, INCORRECT DATA CAN CAUSE NRC TO RESPOND TO THE LICENSEE OR OFFSITE OFFICIALS WITH INACCURATE OR OUTDATED ADVICE.
10 NRC'S THINKING OF.HOW TO
- 11 NRC'S THINKING OF HOW TO ENHANCE ITS INCIDENT RESPONSE CAPABILITY HAS EVOLVED OVER SEVERAL YEARS. THE NRC HAS CONSIDERED VARIOUS OPTIONS RANGING FROM EXTENSIVE CONTINUOUS.
TRANSMISSION OF A LARGE QUANTITY OF PARAMETERS FROM ALL FACILITIES, TO THE CURRENT SYSTEM IN WHICH WE RELY ON i
TELEPHONE COMMUNICATIONS. THE COMMISSION HAS DETERMINED THAT AN EMERGENCY RESPONSE DATA SYSTEM WILL PROVIDE THE DATA IN AN ACCURATE, RELIABLE, AND TIMELY MANNER. WE HAVE SUCCESSFULLY 1
CONDUCTED TESTS OF AN ERDS CONCEPT WITH DUKE POWER COMPANY AT l
THE MCGUIRE FACILITY AND WITH COMMONWEALTH EDISON AT THE LASALLE AND ZION FACILITIES. BOTH TESTS CONFIRMED THE ADVANTAGES OF HAVING DIRECT ELECTRONIC TRANSMISSION OF A SELECTED SET OF PARAMETERS.
11 BASED ON THESE SUCCESSFUL ,
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BASED ON THESE SUCCESSFUL TESTS OF THE CONCEPT, THE NRC INITI ATED AN ERDS REQUIREMENTS ANALYSIS. THE ANALYSIS CONSISTED OF VISITS TO THE LICENSEES TO DETERMINE THE DESIGN OF THE SITE DATA SYSTEMS AND THE AVAILABILITY OF THE DATA REQUESTED BY THE NRC. BASED ON THE INFORMATION OBTAINED, THE l
COMMISSION BELIEVES AN ERDS CONCEPT CAN BE IMPLEMENTED WITH RELATIVELY LITTLE DIFFICULTY AT ESSENTIALLY ALL SITES.
[ IN VIEW 0F THE LARGE POTENTIAL BENEFIT TO THE NRC INCIDENT l
RESPONSE CAPABILITY FROM THE ERDS AND THE RESULTS OF THE SURVEY INDICATING THE RELATIVE EASE OF IMPLEMENTATION, THE NRC CURRENTLY PLANS TO BEGIN IMPLEMENTATION OF THE SYSTEM ON A VOLUNTARY BASIS. WHILE WE EXPECT THE MAJORITY OF LICENSEES WILL SEE THE BENEFITS OF THE SYSTEM AND WILL PARTICIPATE, THERE IS NO GUARANTEE. H.R. 1570 WOULD MAKE IMPLEMENTATION i
0F A SYSTEM MANDATORY FOR ALL LICENSEES.
12 H.R.1570, WOULD REQUIRE
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H.R. 1570, WOULD REQUIRE COMPLETE IMPLEMENTATION.WITHIN 3 YEARS OF PASSAGE. THE CURRENT NRC IMPLEMENTATION PLAN IS PHASED OVER A LONGER PERIOD TO ACCOMMODATE CURRENT LICENSEES' SCHEDULES FOR EQUIPMENT UPGRADES.
H.R. 1570 WOULD REQUIRE THE EMERGENCY RESPONSE DATA SYSTEM TO l BE ACTIVATED UPON IMPLEMENTATION AND, THEREAFTER, TO TRANSMIT DATA TO THE NRC CONTINUOUSLY EXCEPT DURING SYSTEM MAINTENANCE
( . OUTAGES. THIS GOES WELL BEYOND THE NRC'S CONCEPT OF A DATA SYSTEM DESIGNED SOLELY TO ENABLE THE NRC TO CARRY OUT ITS !
EMERGENCY RESPONSE ROLE. THE NRC HAD ENYlSIONED A SYSTEM ,
1 ACTIVATED BY THE PLANT OPERATOR UPON RECOGNIZING AN ALERT, I i
SITE AREA, OR GENERAL EMERGENCY CONDITION. OUR ESTIMATE IS THAT IMPLEMENTATION COSTS FOR A SYSTEM THAT CONTINUALLY TRANSMITS DATA MIGHT BE FIVE TIMES THAT OF THE SYSTEM ENVISIONED BY THE NRC AND BECAUSE OF ITS COMPLEXITY MIGHT TAKE AN ADDITIONAL YEAR TO INSTALL.
13 H.R.1570 THUS WOULD REQUIRE 1
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- 14 H.R. 1570 THUS WOULD REQUIRE INSTALLATION OF AN EMERGENCY RESPONSE DATA SYSTEM THAT IS MORE COMPLEX THAN WE CONTEMPLATED AND WOULD BE CONSIDERABLY MORE EXPENSIVE TO OPERATE. WHEN !
i COMPARED TO :..d SYSTEM RECOMMENDED BY THE NRC, IT WOULD NOT APPRECIABLY INCREASE THE NRC'S CAPABILITY TO PERFORM ITS PROPER ROLE IN AN EMERGENCY.. AN ANALYSIS OF THE COSTS OF YARIOUS ALTERNATIVE APPROACHES IS Ai! ACHED TO OUR PREPARED TESTIMONY.
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l WE BELIEVE THE OBJECTIVE OF TRANSMITTING TO THE NRC PERTINENT PLANT DATA, WELL IN ADVANCE OF THE DEVELOPMENT OF POTENTIALLY SERIOUS PLANT COND!TIONS, COULD BE ACHIEVED WITHOUT CONTINUOUSLY MONITORING PLANT CONDITIONS.
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14 gACCOMMODATETHECONGRESSIONAL l
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TO ACCOMMODATE THE CONGRESSIONAL CONCERN THAT NRC HAVE l
PRE-EMERGENCY DATA AVAILABLE, WE WOULD RECOMMEND THAT THE I I
SYSTEM BE ACTIVATED AT THE " UNUSUAL EVENT" CLAS$!FICATION LEVEL. THIS CLASSIFICATION OCCURS AT A SUFFICIENTLY LOW l
THRESHOLD AHD OUR EXPERIENCE SHONS THAT DATA TRANSMISSION WOULD BEGIN, IN ALL CASES, WELL BEFORE ANY SERIOUS PLANT EMERGENCY CONDITIONS DEVELOP.
WE STRONGLY SUPPORT LEGISLATION WHICH WOULD REQUIRE EXPEDITIOUS IMPLEMENTATION OF AN EMERGENCY RESPONSE DATA OR SIMILAR SYSTEM. THIS WOULD GREATLY ENHANCE OUR INCIDENT RESPONSE CAPABILITY. OF THE POSSIBLE APPROACHES, WE PREFER 1
THE MODIFIED APPROACH DESCRIBED ABOVE BECAUSE WE BELIEVE CONTINUOUS TRANSMISSION OF DATA IS UNNECESSARILY COSTLY AND MORE DIFFICULT TO IMPLEMENT.
15 IF LEGISLATION IS ENACTED,
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IF LEGISLATION IS ENACTED, WE WILL WORK CLOSELY WITH STATES 3
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SUPPORTS THEM IN ATTAINING OUR COMMON COMMITMENT TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC.
H.R. 3025, THE APPALACHIAN LOW-LEVEL RADIOACTIVE WASTE DISPOSAL COMPACT, IS BEFORE CONGRESS S0 THAT THE STATES OF PENNSYLVANIA, MARYLAND, DELAWARE AND WEST VIRGINIA, MAY OBTAIN CONGRESSIONAL CONSENT AS REQUIRED BY THE CONSTITUTION TO ENTER INTO AN INTERSTATE COMPACT REGARDING THE DISPOSAL OF LOW-LEVEL RADIOACTIVE WASTE.-
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WE HAVE REVIEWED THE COMPACT AND THE PROPOSED CONSENT ,
LANGUAGE AND SUPPORT ENACTMENT OF H.R. 3025 AND COMMEND THE.
STATES FOR ARRIVING AT A SATISFACTORY SOLUTION T0 THE DIFFICULT TASK OF FULFILLING THEIR RESPONSIBILITIES TO PROVIDE FOR LOW-LEVEL WASTE DISPOSAL CAPACITY.
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MR. CHAIRMAN, THAT COMPLETES MY REMARKS.
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CHAIRMAN'S VIEWS ON H.R. 1570/ERDS AT THE UDALL HEARING On-Site Information As far a federal pre-emption is concerned, I view this in a sense as a step toward standardization. If we have the same information at NRC Headquarters as we haTre in the regions ina as we have at the licensee sites in g emergency, we can make better decisions. It is important in my view that we operate from the same information. In this sense I do think that a l uniform type system is important.
I think that the fundamental system should be standardized.
On the other hand, I agree with a grandfathering clause.
I Off-Site Information The states have responsibilities for the off-site decisions -- evacuations and so forth. My view is that we still should be operating from the same data, but I personally would not object if states want to have ad_ditional offsite instruments or evaluations off-s1te of what might be happening.
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