ML20236P440
| ML20236P440 | |
| Person / Time | |
|---|---|
| Issue date: | 08/05/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8708120364 | |
| Download: ML20236P440 (92) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Title:
Briefing on Staff Response to Recommendations of the Materials Safety Review Group 1
Location:
Washington, D. C.
Date:
Wednesday, August 5, 1987 Pages:
1 - 59 Ann Riley & Associates Court Reporters 1625 i Street, N.W., Suite 921 Washington, D.C. 20006
(
(202) 293-3950 J
r:
t 4-1 D I SC LA I M ER 2
3 4
5 i
6 This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on S.
8/05/87 In the Commission's office at 1717 H Street, 9
'N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain
((
12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may i
21 authori=e.
22 23 24 25
l 4
1 l'
UNITED STATES OF AMERICA 4
2 NUCLEAR REGULATORY COMMISSION i
3 4
BRIEFING ON STAFF RESPONSE TO RECOMMENDATIONS OF THE 5
MATERIALS SAFETY REVIEW GROUP 6
7 PUBLIC MEETING 8
i i
9 i
10 Nuclear Regulatory Commission
{
11 Room 1130 12 1717 H Street, Northwest 13 Washington, D.C.
14 15 Wednesday, August 5, 1987 16 17 The Commission met in open session, pursuant to 18 notice, at 10:00 o' clock, a.m., the Honorable LANDO W.
- ZECH, 19 Chairman of the Commission, presiding.
20 21 COMMISSIONERS PRESENT:
22 LANDO W.
- ZECH, Chairman of the Commission 23 THOMAS M. ROBERTS, Member of the Commission 24 FREDERICK M. BERNTHAL, Member of the Commission 25 KENNETH CARR, Member of the Commission
t.,
2 1
STAFF AND PRESENTER SEATED AT THE COMMISSION TABLE:
2 3
S. CHILK 4
W.
PARLER 5
G. SJOBLOM 6
V. STELLO 7
-R.
BERNERO 8
R. CUNNINGHAM 9
10 11 "12 13 14 15 l'
16
-17 18 19 20 21 22 23 24 25
i 3
L 1
PROCEEDINGS 2
CHAIRMAN ZECH:
Good morning, ladies and gentlemen.
l 3
The purpose of the meeting this morning is for the 4
Commission to be briefed on the recommendations of the 5
Materials Safety Regulation Review Study Group.
These 6
recommendations stem from an independent review of safety within the Licensing and Inspection Program for Fuel Cycle and 7
8 Materials Facilities.
9 The Commission has a strong commitment for improved 10 safety.in our Materials Licensing Program across the board.
11 I believe the Commission is desirous of improving 12 operational safety and reducing the chances of accidents, not 13 only in the reactor area which we spend a great deal of our 14 time on, but also in the materials area.
15 The Staff recently submitted.a paper, SECY 87-189, 16 for approval to implement the recommendations of the report, 17 which is the subject of today's discussion.
Following this 18 meeting, I would urge my fellow Commissioners to review this 19 paper very carefully and to complete your own thinking on it 20 and to vote as soon as you possible can.
21 Do any of my fellow Commissioners have any opening 22 remarks to make this morning?
23
[No response.]
24 CHAIRMAN ZECH:
If not, Mr. Stello, will you begin, 25 please?
1
e of i
- 1 i-MR, STELLO:
Thank you, Mr. Chairman.
,'Tais is the third briefing in two days on NMSS 2'
3 activities.
I think the Commission has a fairly good i
4 understanding of the programs that'are now at NMSS'that-are 5
currently being reexamined, relooked at, and perhaps the most
.i significant of those are'those that will be presented to you 6
7 today.
l
'8 You will. recall that fcilowing the event at Sequoyah,'
9 we did a variety.of things in the Staff.
We had our own 10
' lessons learned.
l We commissioned a group to go back and take a 11 good look at the programs, make recommendations.
We had some L
12 problems with it and had to publish it for comment, which we 13 did, and as a result of that process, we~merely are here to 14 tell you what our views are after those responses are in and 15 recommend what we ought to do with each of the recommendations 16 from those' reports.
l'7 We have added one more dimension to the problem.
18 After the Synar hearings, which I'm sure all of you remember, a 19 report was written, and he had in it a variety of 20 recommendations, and we have decided it would be best to gather 21 all of those and make the comparisons, and depending on the 22 Commission's view, we would suggest that when the Commission is 23 finished dealing with the recommendations as a package, that it 24 would also deal with the issue of dealing with recommendations 25 from the Synar report.
Although there is not any official
p '-
5 1-document.comingLfrom Congress directing us to do anything, it's 2
a matter of record, and I think when we are finished, it would 1
3:
.be our11ntent.to draft up.aLresponse'and send it up as a matter 4
of courtesy.and.say, "Here's what we are doing in response to 5
those recommendations."
6.
COMMISSIONER BERNTHAL:
Well, I understand that the-7 conclusions of the Synar report and, in fact, the report itself 8
L were-substantially similar to our own report which came out six 9
' months.previously.
10-MR. ST2LLO:
That's correct.
It is.
And we will 11 make that point.
'12 We want to try to get through an' awful lot of
'13 information.
If there is any area where we need to slow 1down 14 or go into much detail, the commission might wish us to do, but 15 I.think it's important to get this -- these kinds of issues 16 behind us and move on.
17 Now we've done an awful lot of work.
Wa-have not 13 been sitting still, and I think you're going to get a fairly f3 distinct impression that we have not been waiting, but moving 19 5
20 where it's been' indicated that we ought to.
21 With that introduction, let me ask Mr. Bernero to introduce the other people at the table, and then let us get 22 23 started with the briefing.
a 24 CHAIRMAN ZECH:
Before you start, let me just say,
'25 you're absolutely correct.
We've had several briefings
l
,4 6
1 recently on NMSS-metters, and that's, of course, as the 2
Commission designed, because we do wanu to emphasize, as we've 3
said many times, an emphasis on NMSS matters.
This is just our 4
recognition of that focus that we're trying to put on this 5
area, and we expect the Staff and all of the NMSS people to 6
follow through on the Commission's emphasis on this area.
7 Also I would just make one quick note and then ask 8
you to begin.
You've got a lengthy briefing, as far as I can 9
tell, and so I appreciate the fact that you do have a lot to 10-cover.
It's very important material, and I would ask you to 11 move along and try to do your best to end us up on time.
12 Let's begin.
13 MR. BERNERO:
Mr. Chairman, I would just like to 14 point out that we have Dick Cunningham and Glenn Sjoblom here.
15 Dick is Director of our Fuel Cycle and Materials Safety 16 Division, and Glenn is the Deputy Director of that division.
17 Glenn is going to give the briefing.
He has been 18 closely involved with this work and with these parallel 19 initiatives.
20 I would just like to emphasize that in the briefing 1
21 he. will treat the comparison of lessons learned, the Study 1
22 Group recommendations, and the Synar report.
And there is, I 23 am pleased to say, a virtual consensus on the directions, and 24-our stratagic planning that exists now in this arena of 25 regulation reflects that consensus for improve regulation of
7 1-materials. safety.
I" 2
CHAIRMAN ZECH:
Good.
And let me just say, too, I 3
agree with Mr. Stello in that I do think it would be 4
' appropriate for us to respond to Mr. Synar at the appropriate
~5 time.
So let's put that on our action calendar.
6 MR. BERNERO:
Okay.
Let me turn it over to Glenn 7
now.
8 CHAIRMAN ZECH:
Thank you.
i 9
MR. SJOBLCM:
Mr. Stallo has essentially covered the 10 first slide here which identifies the purposes of the briefing, 11 except to say that we also, as a related major initiative, 12 would like to inform the Commission of the results of some 13 operational safety team assessments that were conducted at the 14 other major fuel facilities that NRC licenses as part of this 15 briefing.
16 If we could go to Slide 2, then, this indicates that 17 the Study Group was established in May of
'86, and its charter, 18 as you have been told, was to independently review both the i
19 licensing and the inspection activities related to fuel cycla 20 and materials safety in NRC and to provide recommendations to 21 the EDO.
22 The Study Group was formed by the named individuals 23 on page 2.
All of these have backgrounds in nuclear materials 24 and fuel cycle and/or reactor regulation and chemical safety, 25 and so they were the group that were selected.
In the process
8 l'
of doing their work, they' talked to both Headquarters staff 2
from NMSS as.well as the Office of Inspection and Enforcement, 3
the Regional Offices.
They also talked to regulatory groups in 4
two states, one an agreement, one a non-agreement state, as 5
well as to personnel from three of our licensens in these 6
categories,: two fuel facilities and one major mTterials 7
facility.
8 I believe this is the facility that the Chairman 9
visited,-in fact, earlier this year.
~
10 CHAIRMAN ZECH:
Yes, that's right.
11 MR. SJOBLOM:
Then the Study Group sent its' report in 12 last October, and in December, based on a question raised with 13-regard to the Federal. Advisory Committee Act, the OGC though*.
i 14 that to best resolve that, it would be desirable, and as a 15 result of that, the Commission directed that the Staff put the 16 recommendations in the Federal Register for a period of public 17 comment, and that was done in December, and then subsequently 18 the public comments, 49 letters worth, were summarized in an 19 earlier Commission paper in parallel with the Staff analysis of 20 those.
l 21 We then went into and have now completed our
.l 22 evaluation of those 22 recommendations and kind of an overview 23 of the recommendations to get you into an understanding of what 24 the major issues identified are, which is on page 5.
25 First of all, however, we felt that it was a very l
4
'l 9
1 useful thing.
In fact,' personally I feel that it's useful 2
periodically-for any program, a major program like this, to 3-have an independent review, whether there is an instigating 4
' event or not.
And.so we feel very pleased that we've gotten 5
this done.
6 The recommendations were similar and reinforced the 7
recommendations that the independent group, independent of 8
NMSS, had made earlier in a published report, NUREG-1198, and indeed, the House' Committee on Government Operations, when they 9
10 recently published their report, contained 18 recommendations
'11 in the back of that report, and those are similar as well.
12 To give-you an idea of what the major issues are, it 13 appeared,that most of the recommendations could be grouped into 14 some categories or issue areas.
Probably the most significant 15 one is on the quality and timeliness of licensing and 16 inspection reviews.
And there you see that the Study Group 17 made three, and the House committee made six related 18 recommendations.
. 19 The other issue area of chemical and other non-20 radio 3ogical hazards, as well as the appropriate agency 21 interfaces, was similar, they commented on, and then emergency 22 preparedness, the Study Group made an overall recommendation, 23 and the House committee report made several specific technical 24 recommendations.
And then there were some recommendations 25 related to the organization within NRC to deal with these i
10 1
matters, primarily there by the Study Group, and then there
)
2 were a number of individual recommendations.
i I
3 My intent is to spend most of the time on these major i
issue areas and then go through some of the individual 4
5 recommendations as time permits.
2 6
CHAIRMAN ZECH:
Fine.
7 MR. SJOBLOM:
The intent is to try to cover.them all.
8 CHAIRMAN ZECH:
Okay.
9 MR. SJOBLOM:
The next slide covers, then, this first 10 issue, and there it summarizes Nos.
5, 6,
and 7, and those are 11 the recommendation numbers out of the Study Group report.
And 12 they recommended broadening the scope of licensing and 13 inspections, and they recommended doing safety reviews onsite 14 for major facilities, so you could actually see the facilities 15
'when you're doing an evaluation and to improve the quality of 16 our inspections and license reviews.
17 The public was in favor of that.
The licensees were 18 a little bit objecting on the basis that it would be involving 19 more cost to some extent, and they were concerned a little bit 20 about that, but not greatly.
21 The House report made a number of similar 22 recommendations.
I think you can scan down through them.
The idea of doing team inspections was made mention of, and here is 23 24 where the recommendation came to invite other agencies to help 25 in these team assessments.
11 1
The Staff position basically is that we're in 2
agreement with all of these.
Our implementation is to 3
emphasize periodic and multidisciplinary onsite and multiagency i
4 assessments and improve training for inspectors and license i
5 reviewers and completing more standard review plans,
{
so we 6
better communicate with our licensees what we expect of them.
7 Now before I go to the next slide, I would like to give a preamble that in parallel, beginning last summer about a 8
9 year ago, the Staff began a series of these onsite 10 multidisciplinary safety assessments.
And so the next series 11 of slides is going to cover how we did that, what we found, and 12 what the lessons from that series of efforts are, because that 13 bears directly then on our implementation of these 14 recommendations, as well as some of the others that follow.
15 So I would like to digress, then.
Slide 7 identifies 16 what we would cover.
We will describe the makeup of the teams, 17 the facilities we went to, what we looked at, the findings, and 18 what actions we think are needed there, and then our future use 19 of team assessments and the coordination we plan with those and 20 with the licensing process.
21 So the next slide then shows the makeup of those 22 teams.
It included the Regional Offices, which were in charge 23 of these teams.
They had not only materials and fuel cycle 24 facility inspectors, but we also had a few from the reactor 25 groups with areas of particular expertise like fire protection,
12 1
maintenance schedules, and things like that.
We had a couple I
2 Reactor Resident Inspectors on some of these.
We had also 3
people from the Office of Inspection Enforcement and NMSS and 4
Headquarters.
5 Then we invited through the Regions representatives 6
from the Occupational Safety and Health Administration and 7
through them some of the OSHA states.
OSHA has a program similar to our agreement state program wherein, I think,.20 of 8
9 their -- 20 of the states have assumed OSHA responsibilities.
10 So we dealt with the states as well in this case.
11 We invited the EPA people through the Regions, and in 12 a couple cases, we even had FEMA on the teams.
We had 13-representatives from Oak Ridge in the area of chemical safety, 14 because they had particular expertise.
15 The next slide identifies the twelve major fuel 16 facilities that NRC licenses.
There are the two that produce 17 UF-6.
There are the seven that produce from UF-6 uranium fuel 18 for power reactors, and there are three that produce fuel for 19 Naval reactors, and all of these were assessed.
20 I might say that the total makeup of these teams was 21 perhaps about ten people and lasted about a week.
22 The areas that were looked at are identified on page 23 10.
First of all, management controls.
This is probably the 24 common element, of course, to all safety regulation, to make 25 sure that the management is involved in directing the policy p
i
13 l'
and in reviewing the results of the licensee's.own programs, 2
.and that's what that first one is about.
3 The traditional areas of criticality safety, radiation safety, and emergency preparedness wera also looked 4
5 at. -And then we had fire protection as a major item to look 6
at, as well as looking at trying to find chemical safety 7
hazards and what the facilities were doing about that.
8 And then the last there was related to instrumentation, maintenance, and related matters there.
9 10 Now'the findings, I'll run through very quickly.
11
.Probably the most significant area that there were findings in 12 was in the area of fire protection.
For these kind of 13 facilities, the hypothetical kind.of occurrence that could-14 result in the release of material, radioactive material, is the 15 fire.
They typically involve organic solvents used in chemical
'16 processes which are flammable, and so this, then, is intimately involved with the nuclear material, and that's the obvious 17 18-thing that all of our studies in the past have shown is one of 19 the more likely reasons for release, although the consequences 20 of the release are'not large, like potentially in the case of a 21 reactor.
This is the predominant reason.
I 22 There really aren't any detailed NRC regulations in 23 this area.
In the past, we have depended on the licensees' 24 conformance, for example, with the local building code 25 requirements for fire protection, and we have reviewed his
..............- - -. - - -- -- b
11 4 1
material ~in his license submittal, but we have not come out 2
with any regulations in this area.
3 COMMISSIONER BERNTHAL:
I hadn't really thought that 4
much about it before, but on your mentioning and discussing 5
fire protection as a major finding, it does occur to me, sort 6-of sifting back through previous visits, that that probably is 4
7 something that, shall we say, does not meet the standards that 8
we tend to require in our power plants.
9 I also did not get the sense that the Synar committee 10 report -- and I have not read it completely, to say the least -
11
- but that they focus so much on that as on chemical and non-12 radiological hazards.
13 MR. SJOBLOM:
That's true.
)
i 14 MR. BERNERO:
That's correct.
15 COMMISSIONER BERNTHAL:
Which is a fairly -- I mean,-
16 that's something that the Commission early focused on, in fact, 1
i 17 in the very first meeting we had on this subject.
But the fire i
18 protection thing, I have to say, would just appear to me to be 19 a very important element.
20 MR. SJOBLOM:
Yes.
As examples only of the typical 21 Kinds of deficiencies that the expert fire safety inspectors 22-from the Regions found were related to design of fire-fighting 23 systems such as the fire main in a couple cases could be
)
24 defeated by a single break in the line.
25 There was some lack of expertise in fir e protection
15 l'
and fire-safety engineering, some lack of equipment in some 2.
cases, a need for pre-fire planning.for how to fight a fire in
~
3 certain parts of the facility, because.it varies depending on 4
what's in there, and some. lack of program definition from the 5
top.
6 Now what we're doing there is, we're following up, 7
because all of these assessments have been reported.
There 8
have been reports issued to the licensees, and all of these
'9 deficiencies are being followed up by the Regions on a case-by-
'10 case basis.
11 But we also believe and are starting to think about 12 what kind of license requirements would be appropriate in this 13 case, and we need to think about that and determine -- work 14 with the licensees and work with the Regions a little bit and 15 then come up with'what seems to be appropriate there.
16 In the area of management controls, this, of course, 17 was a major reason for the Sequoyah accident.
Management needs 18 to be involved and making sure that every aspect of things-like 19 training procedures, equipment control and the like are 20 followed and that there are adequate audits of the performance 21 and-feedback and so forth.
22 CHAIRMAN ZECH:
Are you talking mainly here fuel 23 cycle facilities?
24 MR. SJOBLOM:
All of these team assessments were a 25 fuel facilities.
16 1
CHAIRMAN ZECH:
Right.
2 MR. SJOBLOM:
I'll cover a little bit more on where 1
3 we intend to go next with this idea.
4 CHAIRMAN ZECH:
Yes, but we are focusing on the fuel 5
cycle facilities.
That's what you're telling us about now.
1 1
6 COMMISSIONER BERNTHAL:
I would guess that even -- or 7
maybe especially the fire protection matter does also trace 8
back ultimately to chemical hazards and the special fire hazard 9
that they offer.
I sort of haven't thought hard about it 10 before, but upon doing so here en the spur of the moment, it 11 seems to me that's where a lot of your fire hazard would lie, 12 and if we don't do a careful analysis from a chemical 13 engineering standpoint of the fire hazards, maybe the fire 14 hazards for chemicals, bring your fire expert or chemical 15 engineer, which ever you wish, we're going to miss the boat on 16 some of these things.
17 MR. SJOBLOM:
And each of those licensees has to have 18 the capability to do that on an ongoing basis as they modify 19 the facilities and so forth.
20 COMMISSIONER BERNTHAL:
That's right.
And frequently 21 there will be modifications in the chemical processes, and if 22 you don't have' knowledgeable people looking at them, they can 23 pose significant fire hazards.
24 MR. SJOBLOM:
So in the area, then, of management 25 controls, here again we felt that while we have some
17 1
requirements already in the licenses that define management 12 controls, they need to be broadened to cover some more areas 3
than they do now.
4 Currently they cover criticality safety and radiological protection, and we need to broaden that somewhat.
5 61 So that's another area that we're going to be working on.
7
.Then the next major item that we found was chemical 8
and other hazards identification and mitigation, some of the typical findings there, and I'd like to say that no individual 9
10 place had all of these deficiencies, but these are some of the i
11 typical ones that we found -- the need to segregate
(
12 incompatible chemicals.
If you had an oxidizing chemical and 13 something which would, say, react with that, you could produce 14 a lot of heat, perhaps pressure in a system.
15 Just scan down through there.
There were some in the l
16 environmental area, like no. dikes around chemical storage 17 tanks.
Those were typical kinds of things that EPA looked at.
18 In the OSHA area, one of the OSHA requirements is 19 that for all hazardous chemicals, the plant worker shall be 20 provided with what are called materials safety data sheets, 21 which' provide information on the' hazardous nature of the 22 material and what the appropriate ways to treat those are and 23 how to safely handled those materials.
And in some cases, 24 those were missing.
25 And then in a couple cases, we found unneeded numbers
18 1
of toxic chemicals in the laboratories in the facilities.
2:
Now'NRC hasn't been really responsible for chemical
.3 safety per se, but wa-felt that we ought to exercise some what 4
we call leadership here to facilitate, making sure that'the 5
whole job gets done,.that all aspects are covered to the extent 6
we.can.
And that's the reason we invited these other agencies
.7 to participate with us in these assessments.
8 CHAIRMAN ZECH:
I think that's very good, and I would i
9.
like to commend you for that.
I agree with you.100 percent.
q 10.
We shouldn't bicker about, you know, who's responsible for 11 what.
Certainly we have to stay.within the law.
We-have 12
.certain regulations that we all follow.
But leadership is important in this area, and these facilities that we have some 13 14 responsibility for, I hope all of you in NMSS will feel.a keen 15 responsibility for it and will help and as'sist.those other 11 6 agencies, other federal agencies, state agencies, local 17 agencies, in any kind of emergency or any kind of serious 18 event, because I think it's important that we just say, "Well, 19-this is not just our job; it's just a chemical accident,"
20 certainly, but if we have any responsibility at all for a 21 facility, then I expect us to take a leadership role and 22 certainly work with the others and do what we think is proper 23 to coordinate, but take charge unless somebody else is there.
24 If somebody else is there, then that's fine.
If it's their 25.
responsibility and they have the role, that's perfectly fine
19 1
with me.
'But until that happens, I want to make sure that we, 2'
as public servants'of this country, really do what we think is 3
right, coordinate with everybody, turning it over when it's 4
appropriate to'the responsible agency, if there-is a 5
responsible agency.
6'
'But if there's any. question about it, my only point is, I hope that you, all of you~in NMSS,~will feel a keen 7
8.
responsibility to help out and to work together and to not 9
worry about the details, if there is a doubt.
When there isn't 10 any doubt, that's fine.
But there are doubts in some of'these 11 areas, as we know.
12 MR. SJOBLOM:
Yes.
There is no bright line.
I 13 CHAIRMAN ZECH:
So I appreciate your emphasizing the s
14 leadership aspect.
I think that's very important.
15 MR. PARLER:
Mr. Chairman, th'a point that you just-16 raised was also discussed at the first Commission meeting on 17 this subject, that has already been alluded to by a member of 18 the Commission this morning.
At that meeting or after that 19 meeting, OGC was asked to provide a legal analysis or a legal 20 memorandum that would provide the legal framework, so that what 2'l you have just described could be accomplished.
22 That has been done.
I just mention that for the 23 record.
That was done back in September of --
24-CHAIRMAN ZECH:
I appreciate that very much, because 25 that's very important, and we do have to have a legal basis for
-_-__-________________a
~
20 I
what we're doing, and it was important that we have the Office 2
of General Cot'.sel prepare such a document, because we don't 1
3 want to do anything illegal.
4 That document, as I recall, does show that we should be mindful certainly of our legal responsibilities, but it also
{
5 I
6 doesn't prec3ude us from coordinating with other agencies and
{
7 doing what we think we should to get coordination and 8
responsible agencies to act.
9 So anyway, leadership in this area I think is 10 extremely important, and I appreciate the General Counsel for 11 bringing that to our attention, because it does give us a 12 foundation for good judgment and common sense, and that's what 13 we're talking about, the protection of the public.
14 COMMISSIONER BERNTRAL:
I wouldn't want to say that 15 the House Government Operations Committee gave us a hunting 16 license, but I think that the language in the Synar report 17 makes fairly clear that one of the options that OGC identified 18 in its memorandum, namely that at a fuel cycle facility where 19 toxic chemicals and other hazards exist, we would be within our 20 apparent legal rights to extend our regulatory authority to 21 those associated materials.
22 The sense from the Government Operations report was 23 that we not only can, but should, do that, and I think that's 24 what I hear you saying, Mr. Chairman.
25 MR. PARLER:
That certainly would be the case where
21 11 the hazards that.the Commissioner just described' flow from the licensed material that we do have control over, as was the 2
~3 case, at least as this non-technical persen understands it, in 4
.the sequoyah facility.
So I agree with you, sir.
5 MR. BERNERO:
Actually the logic for exercising that 6-leadership (nr that control is touched cnt in the paper, for-7-
example page 9 of' Enclosure 2, where the hazard is broken down into four categories, three of which can clearly be tied to our 8
9-existing. regulatory authority.
10-MR. SJOBLOM:
We will: cover ~that in more detail.
11 CHAIRMAN ZECH:
Commissioner Bernthal brings out an 12 important point, and I think -- I tried to cover it by saying, 13
{
exercise common sense and good judgment really, and that's what 14 I think the Government Operations Committee is also asking us
-15 to do, and I say we should take advantage of that, clearly 16 within the law, but be mindful that we are public servants, and
~17 that gives us a lot of responsibility in this regard, and we.
18 should be mindful of that fact as we exercise leadership and 19 coordinate with other activities.
20 But we should feel responsible until that 21 responsibility is clearly given to someone else.
22 COMMISSIONER CARR:
Mr. Chairman, it seems to me that 23 what you're trying to say is, if we see something wrong, we 24 ought to make sure it gets followed up on, no matter who is 25 responsible.
22 l
1 CHAIRMAN ZECH:
That's exactly right.
Thank you.
2 That's it.
3 COMMISSIONER BERNTHAL:
Yes.
There are two important points to be made in addition, maybe, as long as we're on the 4
5 subject.
6 One is that I also read OGC's primary concern as being in the area of preemption of state authority.
The Atomic 7
8 Energy Act gives us rather specific preemption authorities, and 9
I would say the line you have to tread is to make sure that 10 you're not catching in the net and preempting state authorities 11 in associated areas, although I don't -- I think with common 12 sense that's not likely to happen.
13 The other point that I would hope Staff is extremely 7
14 sensitive to is the limitations of our own expertise, and I 15 understand that you're trying to remedy that to the extent that 16 we are able, but this agency is going to be expert in many 17 chemical areas, probably a lot other areas as well, and 18 therefore --
19 MR. SJOBLOM:
I might say that the chemical safety 20 area is a whole other field of regulation.
21 COMMISSIONER BERNTHAL:
Precisely.
22 MR. SJOBLOM:
And it does require a specialized 23 talent to properly do.
While people in NRC cortainly have the inherent knowledge and capability, we don't have the process of 24 25 looking and we don't have the expertise to ferret out and find l
a
~
23 1
these things directly.
So we do need.to involve the other i
2 agencies.
3 What I would hopenthat we do, and I think that from 4
what.I hear about your efforts out in the Staff now in the wake
=;
'5 of this incident, what I would hope that we.will do is seek 6
anough people at least that they know a duck when they see one 71 waddling down the road.
1 8
MR. SJOBLOM:
Yes.
.9 COMMISSIONER BERNTHAL:' And that they know when.to 10 ask for assistance from other agencies, and, in fact, it seems 4
11 to.me that theLbroader question should be asked ---and you 12 might want to follow up, Mr. Chairman, in the wake of this
[
13 meeting ---as to whether there is any sort of formal 14.
understanding between agencies, whether there should be a 15 memorandum of understanding --
16 MR. SJOBLOM:
We're getting ahead of our -- if we 17 could go to Slide 14.
18 MR. STELLO:
Yes.
We were going to cover that in 19' detail, and maybe we ought to get to the bottom line, because 20 you're raising'it now.
21 MR. SJOBLOM:
Let me try to-go to the bottom line on 22 Slide 14.
It is our plan, and we have been meeting with both 23 OSHA and EPA, and we do, for example, in the case of OSHA, have 24 since the early '70s a working relationship wherein if OSHA is 25 at a licensed facility, and they see something in our area,
24 1
they. report it to us for action.
If we, when we're-inspecting _
2 our facilities, see what our inspectors think is an industrial 3.
safety issue, then they'are directed to inform the OSHA 4
Regionalf0ffice.
5 We have been meeting with OSHA.
In fact, this 6
arrangement was.recently in 1985 reworked a little bit, and we 7
have been, subsequent to these recommendations -- in fact, as 8
late as this week -- talking with them again to try to see what 5F additional improvements we might make in our relationship.
So-
~ 10
'that's a --
11 COMMISSIONER BERNTHAL:
It sounds'like it didn't work
.12 very well somewhere.
Now whether'it was because we didn't have 13 the people that could even say, "We've got a problem here," or 14 whether it was because we simply didn't have the kind of 15 communication and understanding and the clear lead agency
~
16 authority, and that would really be the point that I would 17 wonder about.
18 Do we have a clear understanding with EPA, OSHA,-and 19 other agencies that might be involved for a given facility that 20 mixed hazards and mixed responsibilities?
21 MR. SJOBLOM:
We have the lead on radiation safety.
22 I'
There's no question about that.
23 COMMISSIONER BERNTHAL:
But facility.
Do we have a 24 clear lead agency for a given facility?
25 MR. SJOBLOM:
Well, our licenses license the i
4 25 1
1 radioactive material to be handled.
It's not like a reactor.
2 COMMISSIONER BERNTHAL:
I would think, for example, 3
that the NRC would be understood and recognized by these other 4
agencies to be the lead agency for Sequoyah.
l 5
MR. STELLO:
Let me get to the bottom line.
The last 6
sentence on that slide says just what you're getting at:
Are 7
we sure that we've got this clear enough?
Do we need better 8
definitions, better memoranda of understanding?
And that's l
9 what we're working for.
10 COMMISSIONER BERNTHAL:
Well, I would broach the term 11
" lead responsible agency" or something like that.
12 MR. STELLO:
That will be clear when you document it 13 as to who has what and its purpose.
That's where we're l
14 heading, and that's where we're going to go.
15 CHAIRMAN ZECH:
Well, let's take the leadership.
16 Let's us take the initiative to get it done.
17 MR. STELLO:
Yes, yes.
18 CHAIRMAN ZECH:
Okay, that's fine.
Very good.
19 COMMISSIONER BERNTHAL:
Are we going to skip the
'20 other stuff now?
21 MR. BERNERO:
No, we're going to go back.
22 MR. SJOBLOM:
Let me go back.
Back on page 12, a 23 couple more things that we're going to do in that area is, 24 we're going to try to give our inspectors enough flavor for 25 chemical safety fundamentals and fire protection fundamentals
26 1
that they'll be able to better refer problems to the agency 2
that has the ability to force compliance with their rules.
In 3
other words, there are OSHA rules that cover both fire safety 4
and chemical safety.
5 But if we have better ability to see these items, as 6
our people are in the facilities, we'll be able to make a more 7
appropriate referral and be able better to follow up to make 8
sure that those things get corrected.
9 The next item here, then, if we are finished with the 10 chemical safety discussion, is an item which we're calling 11 safety-related instrumentation and maintenance.
We found quite 12 a variation in the-maintenance programs, for example, and in 13 the testing of the few automatic control systems -- in other 14 words, systems that were needed for safety.
15 We're not talking here about reactor plants where i
16 there are numerous automatic shutdown systems.
There are a few 17 key controls like the heating control system for UF-6 18 cylinders, is one of those, and the testing and maintenance to 19 make sure that system doesn't overheat the cylinders is an 20 important thing.
21 There are a few others like that, and we concluded 22 that those key items need to be identified for each of the 23 facilities and culled out in the license, so that they get the 24 appropriate high quality attention that they deserve.
25 Another area that was a key area, on page 13, was in
c.--
-A.
g 27 1
- the area of emergency preparedness, and here we have an ongoing i
2 rulemaking.
The proposed rule was published April 20 of this
.3 year.
The.public comment period has just ended.
And this will 4.
serve.to help us upgrade the emergency preparedness.
5 of course, there is an order that went out.several 6
years ago, and there are emergency plans in all of these-7 facilities.
The existing emergency plans were thoroughly 8
evaluated by these teams, and the Regions are now following up 9
on the' individual deficiencies that were found.
And now the 10 next ctaps here are to work on the implementation of-this 11 rulemaking.
In other words, we're getting -- analyzing the 12 comments from the public review, and there will be an issue 13 back with the commission -- I think it's scheduled to be done 14 next March, wherein that rule will then become final, and than 15 we would go ahead and make sure that all the licensees to which it's applicable would be implementing it and follow up with 16 17 more inspections on those.
18.
The last item here related to the team assessments is 19 the future use of these things.
We felt that they would be 20-useful for the larger facilities that we license, and there are 21 about 30 of those.
About half of them are fuel facilities, and
\\
(
22 the other half are major materials licenses.
l 23 We have done assessments now at three of these other 24 major materials license, and that's kind of an ongoing thing 25 and probably through next year we'll be conducting more of
28 1
these. 'That's what's in the program and the plan and provided 2
for in the budget proposal.
3 We believe this approach, because we're using 4
experts, does find real safety. problems or does find what would 5
turn into safety problems and can have a preventive effect.
6 That's what we're after.
7 It also provides a useful coordination mechanism-8 among the agencies, as well as between-the-licensing and the 9
inspection staffs.
So what we're intending, then, the bottom 10 line on this future use of the assessments, is to do these 11 every several years, about a year before these licenses come up 12 for renewal, so that we would identify problems that the 13 licensee would then have to factor into his license renewal 14 submittal, and so that that's the time, the orderly time when 15 the improvements that would be suggested by the assessments 16 could best be factored into the licensees' programs.
17 I think we've covered No. 14, page 14 here.
18 Insofar as the Study Group's recommendations on 19 emergency preparedness --
20 COMMISSIONER BERNTHAL:
Let me -- excuse me -- let me 21 ask one more question about this coordination business.
22 Has the reception generally been pretty good?
For 23 example, we're, I hope, taking the lead, as the chairman i
24 suggests, in going to other agencies.
25 MR. SJOBLOM:
That's the way we've done it.
29 1
COMMISSIONER BERNTHAL:
And asking for their 2
assistance, really is what we're doing.
'3 Is there any evidence at all that on occasion they X
4 may have facilities that have radiological hazards that they're 5
not just entirely heavyweight in dealing with, where they may 6
also have our expertise, or is there no evidence of that sort 7
of thing?
8
,MR. SJOBLOM:
No, no.
9 MR. STELLO:
By law, how could there be?
10 MR. SJOBLOM:
We regulate all the radioactive 11 facilities, or the states do.
12 COMMISSIONER BERNTHAL:
Well, I'm thinking really --
13 I guess they would not be facilities.
14 MR. STELLO:
They'd have to discover a violation, you 15 know, that somebody's got illicit byproduct material or 16 something like that.
17 COMMISSIONER BERNTHAL:
We don't regulate all 18 radioactivity, though.
19 MR. SJOBLOM:
Atomic Energy Act material.
20 COMMISSIONER BERNTHAL:
That in particular I'm 21 thinking of.
But generally, then, expertise, and obviously EPA 22 is one example where, quote, " expertise" --
23 MR. SJOBLOM:
We found -- now I had indicated that in t
24 some of these places, OSHA had been there in the recent past, 25 and in others they had not, and they came with us, and some of
t 30 l'
them, they did not come.
2 COMMISSIONER BERNTHAL:
Yes.
OSHA is another 3
example.
They don't regulate the radioactivity, but they 4
regulate the workplace.
5 MR. SJOBLOM:
That's right.
The industrial --
6 COMMISSIONER BERNTHAL:
Do you get the sense that 7
this is going to flow both ways?
8 I think it will flow to the benefit of the American 9
people if it does.
10-MR. SJOBLOM:
We have had some -- in accordance with 11 the arrangement that I mentioned earlier, we have had some 12 calls from OSHA people.
For example, one I remember _over at 13 Children's Hospital, there was an inspector there looking at an 14 industrial area and heard some rumor that there was something 15 wrong with the X-ray machine.
New they happened to refer it to 16 the wrong agency, NRC, but we quickly then called FDA.
17 COMMISSIONER BERNTHAL:
Good.
That's really what I'm 18 asking.
19 MR. SJOBLOM:
There are some.
Now I don't claim that 20 it's extensive, but there is some.
21 COMMISSIONER BERNTHAL:
Good.
22 MR. SJOBLOM:
In the emergency preparedness area on 23 page 15, this was one of the issue areas, and the Study Group 24 simply recommended that we hurry up and get this rule finished.
25 The House report had several detailed recommendations
31
'l'
-- in other words, Nos. 12 through 16 there, and I would simply 2
say that the content of this proposed rule is largely 3
consistent with the detailed House recommendations.
4 MR. STELLO:
But I think fairness dictates that --
i 5
when I read the Synar report, I got the impression that he was 15 looking for emergency planning set up exactly the way we have it in reactors, where we go through that entire process.
7 I
8 don't say that that's what it says, but one could infer that 9
that was the intent of what was there or at least leaning in
- 10 that direction.
11 We are not planning to go that far obviously, as 12 you're aware, but the elements that he.had in there, we're 13 going to be covering.
But you could conclude that is was going 14 further and more in the direction of the way we do it with 15 reactors.
That's not our plan.
16 CHAIRMAN ZECH:
You've got to give us your rationale 17 for that kind of --
18 MR. STELLO:
Well, it's in the rule.
19 CHAIRMAN ZECH:
Yes, it's in the rule, I guess, but I 20 mean, what you're telling us right now -- are you telling us 21 something different now?
22 MR. STELLO:
No, no, no.
It's all in the paper, and it's all in the rule, and that's the way we propose to go.
23 I
24 just, in fairness, when you're reading the comments in the 25 Synar report, it clearly moves more in the direction of doing
Q 32 1
things in the way in which we do it for reactors, and we're not 2
doing it that way.
3 MR. PARLER:
Mr. Chairman, the rule that is being discussed is the emergency planning rule for fuel cycle 4
5 facilities; is that correct?
6 CHAIRMAN ZECH:
Yes.
7 MR. STELLO:
That's correct.
8 MR. PARLER:
To the extent that Mr. Synar's 9
recommendations raise questions about emergency planning for 10 non-radioactive, but yet potentially hazardous chemical 11 matters, there is another law that should be mentioned, and 12 that is Title III of the Superfund Amendments and 13 Reauthorization Act of 1986.
It has a section -- Emergency 14 Planning and Community Right-to-Know Act of 1986.
This does 15 require others, another agener, to make sure that there is 16 emergency planning and response capability.
17 So that's something in addition to what we have, and s
18 it occurs to me that could well be an area, in view of what Mr.
19 Stello and others have said about our expertise in the 20 emergency planning area, where other agencies might look to us 21 for our advice.
22 So there is this other law, which incidentally we 23 alluded to in our other proposed emergency planning rule, which 24 attracted quite a bit of attention.
25 CHAIRMAN ZECH:
All right.
1
+
33-t.
l' MR. SJOBLOM:
That's incorporated in the proposed
- 2 rule,.if you recall.
y 3
CHAIRMAN ZECH:- Yes, that's fine.
4 MR. BERNERO:: EPA has the responsibility under the 5
act referred to, and we'have an interface with EPA even now on 6
reactor emergency planning.
It's an even more closely meshed 7
or complex on in_the: emergency planningHof chemical and 8
radiological facilities.
9 I just had a conversation with AEOD this morning on 10 that point because of the lessons learned from the Zion 11 exercise and carryover for.how we might exercise this interface 12 with LPA.-
(~
13 CHAIRMAN ZECH:
Yes.
Well, the important point here, 14 too, I think, as General Counsel mentioned, is we do have 15
-expertise in this area, and we should offer our experience, 16 expertise, to the other agencies and encourage them to take a 17 good hard look, and perhaps that will be helpful to them.
I 18 think that's important, too.
19 MR. SJOBLOM:
In fact, there's a meeting currently 20 scheduled in a couple weeks called the EPA /NRC Interface
. 21 Council at which one of the items on the draft agenda covers 22 that.
23 CHAIRMAN ZECH:
Okay, good.
24 COMMISSIONER BERNTHAL:
Just one comment.
I'm sure 25 this isn't going to happen, particularly with Mr. Bernero's 2
34
{
l 1
background, but because the law that the General Counsel just 2
referred to -- and I would presume references EPA and its 3
emergency planning responsibility, not us -- and becauce we 4
tend _to focus our emergency planning on power plants and 5
, emergency planning there, I would trust, though, that we're not going to sort of go off now and decide on our own -- I think 6
7 you've-just told us-that -- how we're going to regulate for the 8
chemical hazard element of this plant for which we happen to be 9
the lead agency, because we ought to conform to the spirit of 10 that law that wce just passed.
11 MR. BERNERO:
Absolutely.
In fact, that law requires l
12 EPA to set threshold quantities for that, and we have to look 13 at that, because I'm sure we'll get excited about a lot less of 14 a chemical than they will.
15 CHAIRMAN ZECH:
All right.
Let's proceed.
16 MR. SJOBLOM:
All right.
If we can go ahead then to 17 page 16, this begins the series on the individual 18 recommendations that primarily relate to the non-fuel facility 19 or the materials facilities.
They simply wanted us to expedite 20 our actions on control of radioactive sources that are under 21 general license.
22 I would point out that there is a very recent I
23 Commission paper that was sent for information, SECY 37-167, 24 that describes the results of a study that NMSS has been doing 25 of the effectiveness of the general licensee program, and it
4, 35 1
does indicate that, as we later this summer and this year, we will probably be reinitiating a rulemaking to help clarify the 2
3 general licensee recommendations and regulations that are on 4
the books, and so I'd like to move-on on that one.
That's an 5
ongoing effort.
6 Another area that is important is in the area of 7
radiography safety.
This is the category of licensee that gets 8
a great deal of attention and has a considerable number of 9
overexposure._ There was general support that this needed to 10 be continued to be looked at.
11 The specific recommendation had to do with requiring 12 NRC or state certification of radiographer.
Now this is an 13 issue the Commission looked at fairly recently, and there was a 14 SECY Commission paper on this, and the Commission just a couple 15 years ago, after weighing the pros and cons of that one, 16 decided that NRC would not enter into that program.
NRC would 17 not initiate that.
18 But recently an industry group, the American Society 19 for Non-Destructive Testing, has come to NRC, asking NRC 20 technical help for an initiative of there own whereby they 21 would try to set up a program for third-party certification of 22 radiographer.
This could help make sure that every 23 radiographer is adequately trained for this operation.
24 Now we are participating in that, and we think that's 25 a good initiative there.
~*
36 1
We have some other items that we are also pursuing, improving our inspection of radiography to make sure that the I
2 3
procedures are followed.
4 COMMISSIONER CARR:
Well, that's commendable.
I'm 5
concerned about the area where those people can move around 6
from state to state and employer to employer without anybody 7
tracking whether they're qualified or not or have been fired 8
for malperformance.
Somehow we've got to set up a system to 9
solve that, and I would suggest that if it looks like that 10 American Society for Non-Destructive Testing doesn't improve 11 things,1ee ought to take an other look at that at the 12 Commission level.
13 MR. CUNNINGHAM:
Yes, I think that's correct.
That is one of the issues, and I think if this industry radiography 14 15 certification works out, as we hope it will, that would go along way towards addressing that problem.
i 16 l
O 17 I think some of the industry initiative might stem 18 from that very problem itself, and if it doesn't, why, of-19 course, then we have to relook at it.
Ns_
)
20 CHAIRMAN ZECH:
I agree.
I think we ought to keep f
8 21 that as kind of an open item and not just close it out 22 completely.
It seems to me that it's not the most -- not the 23 strongest thing that you've told us here this morning.
I think 24 we ought to keep looking at that one.
25 MR. BERNERO:
It's an open item.
'O 37 1-MR.'SJOBLOM:
I.might also point out that there is a 2
proposed rulemaking being developed which would improve the 3-
' performance of equipment to make it more failsafe, and that's 4.
also an ongoing effort.
5.
CHAIRMAN ZECH:
Fine.
6 MR.'SJOBLOM:
Page 18, then, simply covers the 7;
agreement state program, encouraging more agreement states, and 8
they even went so far as to recommend that agreement state 9
status be made mandatory.
We don't feel that's appropriate.
10 That's been looked at before.
So we're not supporting that 11 part of it.
12 Then another one relating te using a suitable mixture.
13 of performance-based regulation and precariptive type 14 regulation.
We certainly agree with_that, and we think we've 15, been doing that.
In the case of licensees such as 16 radiographer, we believe we need prescriptive requirements.
17 In the case of larger facilities such as fuel facilities where 18 they have a more engineering capability on their staffs, that's 19 the area where we are using more performance type standards, as O
20 well as some prescriptive standards.
So we believe we're doing 21 that.
22 Page 20, then, encourage more broad licenses, the idea here that they recommended is that major industrial
'23 24 companies which have many facilities throughout the country 25 should have a broad license to their corporate management from 1
9 38 1
NRC, and then they should be responsible as a corporate entity 2
for the safety at all of the facilities.
I 3
Now we're doing that for the Navy material program 4
and the Air Force material program, and that seems to be 5
working quite well.
We do not have it with any industry groups 6
at this point.
I have some doubts, and so we'rs doing that, we 7
believe, to the extent it's appropriate at this time.
8 Another item is to improve -- on page 21, improve 9
staff training.
This, I think, is an obvious thing, that 10 training is an ongoing need, both for the materials licensing 11 as well as the inspection program, and we do have some efforts 12 underway to identify additional training courses for inspectors, both in the materials and fuels areas, and we're 7
13 14 exploring now an increased involvement of the NRC Technical 15
~ Training Center staff to help us in that regard.
i 16 COMMISSIONER CARR:
I think that's good, because I
{
l 17 don't think there's any doubt but that our reactor inspectors t
18 are better trained than these people are and that they have a 19 training program set up.
20 I was only concerned about the little comment there 21 that said your training will be put in consistent with budget
)
22 constraints, which means to me you've left yourself an out, 23 that that may not happen.
24 How does the budget look for setting up the training i
25 program?
39 1
MR. SJOBLOM:
We have, in fact, in the budget 2
proposal -- perhaps at the time these slides were made up, it 3
wasn't completely agreed to -- but we do have some agreement 4
that TTC will add a dedicated person.
5 MR. BERNERO:
Yes.
6 MR. SJOBLOM:
And we also have a little bit in our 7
own budget for that.
So I think that that's not really an 8
issue.
9 COMMISSIONER CARR:
There will be some courses then?
10 MR. BERNERO:
Oh, yes.
We have an extensive interaction need with AEOD on the structure of the staffing, 11 12 and, of course, it has to be consistent with their resources, 13 too.
14 CHAIRMAN ZECH:
How about training by the facilities 15 by themselves and the various activities themselves?
16 MR. SJOBLOM:
That's one of the areas that we look 17 at, is their training programs.
18 CHAIRMAN ZECH:
How are there training programs?
19 MR. SJOBICM:
We found that they did have -- in the field facility assessments, they all did have training 20 21 programs, both fundamental for all the staff as well as 22 training.
23 There was a need for a little bit more formality and 24 making sure that every person got all the training needed.
If 25 you recall, this is one of the items at sequoyah itself where j
o.
40 1
staff weren't appropriately trained on one particular aspect of 2.
a procedure.
3 CHAIRMAN ZECH:
Well, we've gone a long way on the 4
reactor side with the accreditation program and all that.
I 5
doubt if they've done that in this program.
6 I would ask you'to take a good hard look at training, 7
not only from our standpoint, but from the facility l
8 responsibility standpoint.
I could imagine it requires a lot E
9 more formality, a lot more discipline, a lot more review, a lot 10 more up-to-data methods, technology and so forth.
11 I think this is a good area to look into real hard 12 and lay'it on the facilities.
That's a responsibility they j
13 have.
If we license them, you know, we ought to be very 14 satisfied with training.
15 I know you've had that as a look-see before, but I 16 would say this is a very important area, and it's their 17 responsibility to train their people.
Let's look at this one 18 real hard.
19 MR. SJOBLOM:
The next slide there simply suggests a 20 recommendation related to Part 20, which is under development 21 within the agency.
I'd like to not dwell on that.
22 COMMISSIONER CARR:
I'd like to dwell on it long 23 enough to find out when it's going to come up to the 24 Commission.
25 MR. STELLO:
I can't answer that right now.
We've
c 9
41 1
had one meeting last week where the first task that was given 2
them was to put together people in the agency who have views on this matter, get together and resolve all the technical issues 3
4 that came up out of the comment period.
5 I guess you recall, the comments on this rule are 6
.probably more than we've had on any other rule.
7 MR. PARLER:
No, wait a minute.
8
' COMMISSIONER ROBERTS:
What?
11,000?
9 MR. PARLER:
That's what somebody told me on the 10 emergency planning.
11 COMMISSIONER CARR:
This was about 800, I believe it 12 was, about 800.
(
13 MR. PARLER:
I just thought I would mention that in 14 view of the short deadline we're under from you, sir.
15 (Laughter.)
16 CHAIRMAN ZECH:
All right, fine.
I know you're doing 17 a good, thorough job 18 MR. STELLO:
The General Counsel is doing such 19 excellent work, you'll have that done over the weekend.
i 20
[ Laughter.]
21 COMMISSIONER CARR:
You'll probably have it done 22 before we have this Part 20 done.
23 MR. STELLO:
That I can almost assure you.
I think, 24 if I remember, Dick -- you were there -- I tasked you to come 25 back to me by November 1st with all issues resolved.
And if
42 1
they do that and everything is in good shape, then I hope to be 2
able to squeeze the schedule that I have in front of me, which
)
3 I'd rather not give you because it's too long.
{
4 COMMISSIONER BERNTHAL:
Well, Commissioner Carr's 5
point is well-taken.
I think it's time to move along on that j
6 and get it finished.
}
7 MR. STELLO:
I just had a meeting to encourage the 8
Staff to do that.
9 COMMISSIONER BERNTHAL:
Okay.
i 10 MR. STELLO:
We've made some progress, and I hope i
11 we're going to make some more.
12 COMMISSIONER BERNTHAL:
And I'll bet you smiled and 13 were just as soft-spoken as you're being right now.
14 MR. STELLO:
Absolutely, yes.
15 (Laughter.]
16 CHAIRMAN ZECH:
All right.
Let's move along.
17 MR. SJOBLOM:
On page 23, there were some 18 organizational changes suggested, one of which was indeed the
{
i 19 organizational change that the Commission directed, was the 20 combination of the inspection and enforcement staff with the 21 NMSS staff, and that's been accomplished.
22 There was another recommendation relating to the 23 Regional materials licensing and inspection staff to put them 24 all together, and a couple of our Regions do that.
A couple 25 have them together at the branch level.
And this
l I
43 l'
recommendation suggested they be.together at the section level.
1 1
2 We thought that either one worked, depending on the commitment 3.
of the management to-do so, and we didn't feel it appropriate 4
to make that a' mandatory thing.
5 COMMISSIONER CARR:
It would make it a-lot easier in 6'
your training.
It looks to me like a lot of issues in this 7
thing kind of took us on for not having the licensers and the 8-regulators in agreement on certain issues, and it looks like 9
that would kind of solve that problem as well.
10 MR. SJOBICM:
Training would help; yes, sir.
The 11 training should -- what we're approaching is that the training 12 should be required for both license reviewers and inspectors.-
13 COMMISSIONER CARR:
Well, I guess I'm in agreement i
14 with you.
We ought to watch carefully those guys who have 15 consolidated, and if that works well, we' ought to encourage the 16 other Regions to do it, perhaps.
17 MR. SJOBIOM:
That's basically our position, that we 18 ought to encourage them to look at that.
But we aren't, you 19 know, really at the point of making that a mandatory thing.
20 Another suggestion was to require rulemaking in this 1
21 area to be done by NMSS as opposed to Research.
The Commission 22 decided that one, and we're working hard to work with Research 23 on our rulemakings that relate to our responsibilities.
So we 24 don't feel it's' appropriate to do that one.
So at this point, 25 we've been responsive to those recommendations.
44 1
Then there's a couple recommendations on improving..
-)
2-standard review plans and regulatory guides.
Some of the 3
public thought that was a good idea,_and some didn't.
The 4
Staff basically'is in agreement, has been working to do that.
-5 Another one on page 24 is related to communication,.
]
6 which is very important, and suggests that there be joint 7
discussions between licensing staff, inspectors,'and licensees-8 before major amendments.
The basic thrust is to get.the inspector involved with the licensing staff when~you're-9 10 considering amendments to the major' licensees, and we certainly 11 agree with that.
We've been doing that to some extent.
We'll-12.
continue to emphasize.that.
13 MR. PARLER:
May I ask a question, please?
14 CHAIRMAN ZECH:
Sure.
15 MR. PARLER:
This is after the amendment is applied 16 for?
17 MR. SJOBLOM:
Yes.
18 MR. PARLER:
But before the license is issued.
19 MR. SJOBLOM:
Before the license is amended, but 20 after it's applied for, so we understand one another.
21 MR. PARLER:
So they understand each other and --
22 MR. SJOBLOM:
Yes.
23 MR. PARLER:
-- would permit everybody concerned to 24.
do that job better, not to have closed meetings to keep 25 information about risk to the public from the public, right?
45 1
MR. SJOBLOM:
No.
No, sir.
It's to promote 2
communications and so the licensee knows what NRC expects and 3
so we understand what they're committing to.
4 CHAIRMAN ZECH:
Okay, fine.
Thank you.
5 MR. STZLLO:
Thure's no reason that those meetings 6
are private, however.
We will be following our usual 7
procedures for meetings, and I assume most of those are 8
meetings that are advertised and posted, and members of the 9
public are free to attend.
They are not private meetings.
10 CHAIRMAN ZECH:
All right.
Go ahead.
11 MR. SJOBLOM:
The next one, the suggestion was 12 allowing more latitude for inspectors not to cite minor 13 violations.
There we really -- we agree that the latitude
(
14 should be there, but the inspectors themselves should cite 15 violations.
The latitude should come later by management in 16 terms of the appropriate degree of enforcement, and that's 17 consistent with the agency's enforcement policy.
4 18 Page 26, then, suggest establishing a regulation
)
19 interpretations file, and the public was in favor of that.
20 Again, it's directed towards improving communication and 21 understanding of what the NRC expects.
I 22.
We agree with that.
The official interpretations j
23 that have been made are published in Part 8, and we're looking 24-into a somewhat broader system.
There are some internal 25 tabulations that various people have collected over the years 4
1 of more informal kinds of things, and we're looking to see 1
2 whether some better system can be made there.
3 Again,-No. 22 relates to improved communications, in i
this~ case between Headquarters and the Regions primarily, and 4
5 between NRC and the licensees.
6' In the first case, we do have a series of different 7
levels of meetings in the Regions and at Headquarters 8
throughout the year.
We have a lot of phone calls.
We get the 9
PNs; we get calls based on occurrences.
We send out to the 10 Regions for comment, proposed changes of inspection 11-requirements or licensing guidance, so there's an ongoing 12 effort there.
13
}
Insofar as improving communications between NRC and 14 licensees, here we're exploring an innovative technique, what 15 we're calling a workshop or seminar, where we invita into a 16 public forum a group of licensees to examine the various roles 17 and what NRC expects.
The Chairman, I think, visited one that i
18 we had with the broad licensees up in Region I a couple months i
19 ago.
That one worked very well, and I think Dick Cunningham as 20 well.
21 CHAIRMAN ZECH:
Yes, we were both there.
22 MR. SJOBLOM:
What we're planning to do is to use 23 more of these to explore the possibility of doing this with 24
'more categories of licensees.
We obviously can't invite 9000 25 NRC licensees to the same meeting.
So we're doing this later
)
47 l'
'this year in the case of radiography licensees.
We're going to 2
have -- we're trying to plan one for fuel cycle facility licensees and so forth-to try to improve our communications.
3
~4 CHAIRMAF ZECH:
I think that's a good way of doing 5
just that.
It really -- those are important meetings.
I think' 6:
you can. overdo anything, of course, but I'think those things 7
are extremely important, and I had the sense that the people 8
who were there-were getting something out of it.
So I 9
encourage that kind of communication.
I think it's valuable.
i 10 MR. CUNNINGHAM:
Yes, and I think that as an example, 11 Mr. Chairman, the annual meeting for the Society of Non-12 Destructive Testing, which is the radiographer, scheduled in 13 october, we're giving a radiography workshop at that meeting, and we're just following through on the series.
i 14 j
.I 15 CHAIRMAN ZECH:
Good.
i 16 MR. SJOBLOM:
That brings us, then, to the last page 17 and the summary.
The public comment on the Study Group report 18
'is complete, and the {itaff recommendations have been submitted 19 te the commission.
The recommendations, again, were similar to 20 those, and they reinforced those of our lessons learned group.
3 21 The multidisciplinary team assessments that were 22 conducted in parallel with this are effective, we believe, in identifying actions needed to enhance safety at these 23 24 facilities, and they also provide an improved basis for us to R2 5 -
deal with many of the other recommendations, such as
- ?
48 1
communications between the inspectors and the licensing groups, 2
between agencies and the like.
3, We believe that the Staff actions that are planned or 4.
underway will implement these recommendations adequately and 5
work towards improvement of public health and safety in the I
6-fuels and materials program.
The effort and the resources to 7
do that_are in the budget that is before the Commission, and we
.8 would like to ask, then, to reiterate the recommendations of
~
9 the paper,'that the Commission act on our recommendations.
10 CHAIRMAN ZECH:
All right, fine.
Does that finish 11 the briefing this morning?.
12 MR.-BERNERO:
Yes, sir.
i 13 CHAIRMAN ZECH:- All right.
Questions from my fellow 14 Commissioners?
Commissioner Roberts?
15 COMMISSIONER ROBERTS:
No.
16 CHAIRMAN ZECH:
Commissioner Bernthal?
17 COMMISSIONER BERNTHAL:
I really want to spend 18 another minute or two on this question of our own personnel and 19 what deficiencies may exist in expertise.
That was, I guess, 20 one of the very first things that came up in the first meeting 21 that the Commission had in the' wake of the sequoyah event, and 22 you've addressed that to some extent here.
23 Could you outline for me in a little more detail, 24 though, what we are doing by way of what your plans are for 25 bringing on additional expertise in the chemical and chemical i
- *2 49 1
engineering areas?
2~
There may be other hazard areas that you might want
'3 to name, perhaps specific to firc.tatection, for example.
I 4
just stole on of-your Ph.D. chemical engineers for my own staff 5
recently, and I suspect that may represent at least 10 percent' 6
of the agency's resources in that area, maybe 25 percent; is 7
that true?.
8 MR. BERNERO:
No, not true.
9 MR. SJOBLOM:
Well, being a chemical engineer, I can 10 tell you that they are very valuable people.
I 11 (Laughter.)
12 MR. BERNERO:
And being an objective chemical 13
{
engineer, I'll tell you there are a lot of them in the agency.
-14 COMMISSIONER BERNTHAL:
Are there?
Good.
15 MR. BERNERO:
It's a longstanding tradition to hire 4
16 chemical engineers.
17 MR. CUNNINGHAM:
Yes.
We have a fair number of 18 chemical engineers, nuclear engineers, on our staff.
We are 19 trying -- we're in the process of hiring an individual --
20 COMMISSIONER BERNTHAL:
Just a moment.
I don't doubt 21 that you have a lot of nuclear engineers, but I want to focus 22 on chemical engineers.
23 MR. CUNNINGHAM:
Chemical engineers, too.
And some 24 have dual degrees.
25 COMMISSIONER BERNTHAL:
Okay.
~
[
50
'l MR. CUNNINGHAM:
We are in the process now of
'2 recruiting an individual with specific training in chemical 3
safety, which is a specialty area.
I 4
COMMISSIONER BERNTHAL:
Good.
\\
l 5
MR. CUNNINGHAM:
On fire protection, we haven't made l
6 up our mind.whether it should be used -- we should get better 7
service our of a consultant or to hire somebody on the Staff.
8 You mentioned that you took a fire safety expert on 9
your staff.
10 COMMISSIONER BERNTHAL:
No.
A chemical engineer.
l l
11 MR. CUNNINGHAM:
Oh, a chemical engineer.
12 I might note that we had the only fire safety expert 13 that we hired in the agency a number of years ago, and then 14 came the Browns Ferry fire, and we lost him promptly to NRR.
15 But we are looking at this again to see whether it would be 16 better to hire somebody full-time or to use a consultant on 17 this.
We just don't know.
It depends on the workload.
18 COMMISSIONER BERNTHAL:
Okay.
Are there also plans -
19
- believe me, I've taught both, and I understand the 20 differences -- are there plans to bring on some chemists as 21 well as chemical engineers for assistance?
22 MR. SJOBLOM:
A chemical safety expert may well be a
'23 chemist.
24 COMMISSIONER BERNTHAL:
That's a very good example, 25 and I would suspect that that's precisely what we need, that
1 1
51' 11
' kind of person.
2 MR. SJOBLOM:
Whether his training -- his degree.is 3
chemistry or chemical engineering --
4 COMMISSIONER BERNTHAL:
It sounds good either way, l
5 but --
6 MR. SJOBLOM:
It depends on his experience.
For 7
example,.the way we have written the position description, it 8
would require that person to have had experience inspecting 9
chemical safety at chemical plants.
That would give us the 10 requisite capability.
11 COMMISSIONER BERNTHAL:
Well, there clearly are --
12 there may even be three areas, perhaps four if you count fire 13 expertise, but enough said.
14 MR. CUNNINGHAM:
We do have some chemists on the 15-Staff, although I don't recall just how many, certainly not as 16 many as we have chemical engineers.
17 MR. BERNERO:
But the essential thrust is to get the 18 chemical safety expertise and the fire expertise in that 19
. context.
20 COMMISSIONER BERNTHAL:
Right.
Good.
21 MR. BERNERO:
And there's kind of a blur there.
22 COMMISSIONER BERNTHAL:
Good, good.
23 One other element that's related:
What are we also
'24 doing, then, to take the expertise that we have and make sure 25.
that not only do we take care of the question of training of
52-1-
plant personnel, licensee personnel,.but that we make'sure that 2
our own people'are. adequately. schooled and that there's 3
adequate-cross-communication, exchange of ideas and knowledge 4
for our own people throughout our Regions?
Are we doing'some 5
' things there?
6 MR. SJOBLOM:
As I mentioned, there is an existing 7
manual-chapter that identifies required training courses for-
.8 inspectors.and licensed reviewers.
Our intent _is, and we have 9-working right now, increased training requirements that are 10 going to be identified.
We want to have a fire safety-11 fundamentals course given to those people and a chemical safety 12 fundamentals course, so they can recognize the key things.
13 COMMISSIONER BERNTHAL:
Good.
- 14 MR. SJOBLOM
Not that they'll become the world's 15 greatest experts.
16 COMMISSIONER BERNTHAL:
That's right; that's right.
.17 MR. SJOBLOM:
But so that they can recognize it, if 18 they bump into it.
19 COMMISSIONER BERNTHAL:
Very good.
20 MR. CUNNINGHAM:
And we are also looking into the 21 types of cources OSHA gives their people.
)
I 22 COMMISSIONER BERNTHAL:
Good idea.
23 MR. CUNNINGHAM:
To see if that would be a useful 24 type of thing for our people to be exposed to.
25 COMMISSIONER BERNTHAL:
That's a very good idea.
53 1
MR. CUNNINGHAM:
I might also add, the team 2
assessments themselves are a good training ground for people, 3
because there's a lot.of cross-fertilization in those teams, so 4
.that if you're a, radiation specialist, you can see what the 5
chemical engineer looks at, what the fire protection person 6
looks at.
So'that is a side benefit of those team inspections 7
also.
8 COMMISSIONER BERNTHAL:
Very good.
9 One last point, I just want to refer back to the 10 point that Commissioner carr raised on the certification of 11 radiographer.
12 We withdrew an advahce notice of proposed rulemaking 13
.I don't know how you withdraw an advance notice, but in any 14 case we didn't do a rule -- back in 1985.
Do you have a sense 15 that things are really going better and that this is an area 16 that's well in hand?
17 I have to say, I share the concern and discomfort 18 that Commissioner Carr mentioned earlier in this area.
19 MR. SJOBLOM:
You can never be comfortable about 20 radiography safety.
We have to be on it all the time for the 21 next decade, because of the inherent high activity that the 22 radiography sources have and the possibility of an 23 overexposure.
24 COMMISSIONER BERNTHAL:
That's right.
25 MR. SJOBLOM:
If they don't follow procedures 100
54 1
percent of the time.
So, no, we can never be comfortable, and l
2 the program is never finished.
3 We are looking at improvements to the equipment in a I
4 performance type standard that Research is doing.
We've got I
5 more inspections done now at field sites as of a couple years
)
6 ago.
We require the Regions to do 25 percent or more of their inspections in radiography in the field where people actually 7
8 are exposed to the weather and the conditions that these people 9
work under, and they might get a little lax.
So we try to 10 catch them in unannounced field inspections.
That keeps them a i
11~
lot more honest.
12 But I must say, it's the kind of a situation, kind of 13 a licenses situation, where you can never be fully comfortable.
.14 We have had just this summer, in the case of U.S.
Testing, a 15 case where a large radiography company, a nationwide 16' organization, had a' breakdown in the training and certification 17 of its people.
And we went back and we took action there, 18 enforcement action, and required them to, in effect, recertify 19 all their people, retrain them all, and put in place a program 20 where they assigned a responsibility to a Radiation Safety 21 officer at every one of their places, who was held personally 22 accountable for those certification and training programs, to 23 make sure that every radiographer was appropriately trained.
24 COMMISSIONER BERNTHAL:
Is the attitude out there 25 improving?
It seems to me an attitude check is also a very
?g 55 1
important element of our inspections.
2 MR. CUNNINGHAM:
Well, it's a hard one to answer now, i
i 3'
but I think that the industry initiative leading toward 4
certification may have resulted from the stronger enforcement 5
action that we're taking.
They see some problems there.
6 I might also add that one of the -- usually the 7
problem in safety with radiographer where there are I
I 8
overexposure are usually associated with equipment failure, 9
equipment failure in addition to not complying with procedures 30 or foll'owing the rules.
So a very important step that we are 11 working on, Research has some'rulemaking in process leading 12 toward improved equipment performance.
13 COMMISSIONER BERNTHAL:
I want to make'a comment in a 14 somewhat related area that we just discussed about a waek ago, 15 and I don't.know whether you noticed in the newspapers, but 16 literally one day after we were briefed here on the medical 17 uses of radioisotopes and raised the question of, you know, 18 these things are kind of small and portable, and they pack a-19 pretty powerful dose of whatever bit is, cesium or something 20 that's in them, these portable X-ray machines, they lost one.
21 MR. STELLO:
It was stolen.
It was stolen out of a 22 car.
23 COMMISSIONER CARR:
I was just happy that I knew what 24 it was.
25 CHAIRMAN ZECH:
All right.
Anything else?
'I
56.
1 COMMISSIONER BERNTHAL:
That's all.
I'm finished.
2 Thanks.
3.,
CHAIRMAN ZECH:
Commissioner Carr?
4' COMMISSIONER CARR:
I assume you're going to prepare 5
a response to the Synar report for,the Chairman's signature to 6
the committee.or something.
7 CHAIRMAN ZECH:
Yes, that's what I'd like.
Do you 8
h<1ve a problem with that?
9 MR..STELLO:
Yes.
10 CHAIRMAN ZECH:
Well, what is it?
11 MR. STELLO:
You need to tell us if you agree with 12 what we're doing.
13 CHAIRMAN-ZECH:
Well, certainly we want to see what 14 you say, and we'll --
15 MR. STELLO:
I think we can prepara it, but --
16 CHAIRMAN ZECH:
I read everything I sign.
Don't 17 worry about that.
I try to.
18 COMMISSIONER CARR:
Well, I thought that was stated 19 in your paper, that you wanted to send a response.
20 MR. STELLO:
Yes, and the response is here.
21 COMMISSIONER CARR:
And so all I'm saying is, when 22 you send that response up, how about making sure Research 23 agrees, but it looks like some of the emergency preparedness 24 rule things in there weren't quite up-to-date.
25 MR. STELLO:
Yes.
i
_ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ = _ _ _ _ - _ _ - _ _ _ _ - _ _ _ _ _
57 1
CHAIRMAN ZECH:
Well, certainly we want to agree on 2.
the response.
The Commissioners will be involved in it.
But I 1
J think it's appropriate to give Mr. Synar a response when we are-3 l
l 4
concluded with our actions.
5 MR. STELLO:
Oh, I agree with you completely.
I said 6
at the outset that we want to get'that, but I think we need to 7
be sure that we get the first step --
8 CHAIRMAN ZECH:
We're n,ot asking you to do it 9
tomorrow.
We're just saying when we've concluded.
10 MR. STELLO:
Sometimes you do that.
11 CHAIRMAN ZECH:
Sometimes I do that, but I didn't 12 this time.
13
[ Laughter.)
14 COMMISSIONER BERNTHAL:
But have we responded in any
'15 way to the receipt of his report?
Maybe at least there ought 16 to be some sort of preliminary acknowledgement in response.
I 17 didn't realize we hadn't said anything.
18 MR. SJOB10M:
Let me say this.
The report was made 19
.public.
It was not provided to NRC by a letter from the 20 committee.
21 We feel, however, that we should respond in some way, 22 whether they send it and ask formally for our comments or not.
23 COMMISSIONER BERNTHAL:
Yes, I agree.
Absolutely.
24 Sure.
25 MR. SJOB1CM:
The Staff response is as an attachment
58 1
to the commission paper, and if the commission agrees with 2
those responses, then-it's easy to draft'up a cover letter of 3
some-kind, if that's what you want us to do.
4' MR. STELLO:
Why don't you draft something up, and 5
then maybe we can accomplish both?
6 CHAIRMAN ZECH:
I think that sounds reasonable.
7 COMMISSIONER CARR:
We'll probably have to make it 8.
public, too.
9 CHAIRMAN ZECH:
I don't see any reason why not.
10 MR. PARLER:
I don't think there's any doubt at all
-11 that a response is expected and is probably required under some 12 legislation that the Congress has.
I've forgotten the name of
.13.
the act.
14 MR. BERNERO:
I'd just like to emphasize that the 15 response to the Synar committee report is.so closely meshed 16 with the; recommendations --
17 CHAIRMAN ZECH:
Yes, we understand that.
That ought 18 to be part of.the letter, too, and tell them the other things 19 we've done when we respond to them.
Sure.
20 All right, Commissioner Carr, anything else?
21 COMMISSIONER CARR:
No.
22 CHAIRMAN ZECH:
Let me just say, I'd like to thank
-23' you for a very fine presentation, and I think the Commission 24 certainly appreciates the efforts that NMSS has put into all 25 these areas, and certainly we also appreciate the effort of the a
59 1
Materials Safety Regulation and Review Study Group and what 2
they did for us, and I hope you'll pass along our respects to 3
them 4
MR. BERNERO:
We will indeed.
5 CEAIRMAN ZECH:
And I think they've done a 6
commendable job and a service to us.
7 The Commission is committed to making improvements in 8
the NMSS area and materials safety, and this is why we've 9
emphasized it these last few days.
10 I'd like the Staff to follow through and come back to 11 us when, Mr. Stallo, you feel you should on any of these 12 matters.
We do want to follow through and give emphasis to 13 materials licensing safety, 14 i
I would urge my fellow Commissioners, when they have 15 a chance, to review this SECY 87-189 and to make their 16 decisions as soon as they possibly can.
17 If there are no additional remarks from my fellow 18 Commissioners, we'll thank you again, and we'll stand 19 adjourned.
20 Thank you.
21
[Whereupon, at 11:30 o' clock, a.m., the Commission
(
22 meeting was adjourned.]
23 24 25 i
)
n 1
2 REPORTER'S CERTIFICATE 3
1 4'
This is to certify that the attached events of a 5
meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7
TITLE OF MEETING:
Briefing on Staff Response to Recommendations of l
the Materials Safety Review Group 8
PLACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING:
10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken
(.
13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the l
16 foregoing events.
17 i
18
..,l,
l
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