The Honorable Sam Gejdenson -2 JUN 17 1987 must face as it related to issues not covered by regulations. These events are real, emotionally charged, and physically threatening issues. But there are also security principles involved. I am speaking of the matter of screening out individuals whose character or personality manifest traits that are dangerous to the site, its personnel, operations, or the neighboring community. The social problems of the community are reflected in the population of the sites. Because the nuclear sites, which tend to be the major focal point of the rural communities in question, are licensed by the NRC does not make them immune to the ills of the surrounding communities. It takes comprehensive and intelligent proceduralized program efforts to prescreen personnel through background investigation, fingerprint checks, toxicology tests, and polygraph and psychological examinations. The post employment effort requires the use of the same disciplines plus incident investigations, behavioral observation skills and employee assistance resources. Standards for such effective programs are absent in the regulated nuclear industry and the declination of NRC leadership in this area creates a void. The nature of the rural communities, which host many of the nuclear sites tends not to provide a background for coping with rapidly fluctuating social conditions. The professional expertise at the management level of the sites tends to be in the field of engineering and many of these managers have stated to me that they don't understand the issues and find the pressure to address such human behavior areas to be both distasteful and outside their area of interest. It is my position that such an attitude is at the core of this whole discussion. These conditions are even worse at those sites under construction and at certain licensed sites when they are in outage. In fact, I believe that those categories (construction and outage) are the main concern. Experience reflects that a small, but very disruptive segment of the large temporary forces, contains the primary risk. That risk, I believe, is paralleled with the long time permanent employee who undergoes some emotional trauma. Yet, the industry directs its limited efforts away from those categories. My explanation to the Committee was not intended to be critical of my management in Region IV. Instead, it was an effort to clarify, rationalize and justify the methods of operation of one NRC security inspector who has had to deal with these real situations in the absence of regulations. I do not mean to imply that I always timidly agree to a managerial decision, nor does my point of view or philosophical position always prevail. However, those views are heard and considered. But when the decision is made, I comply. Further, my statement was intended to be an expression of empathy for my regional managers. They must, in their decisionmaking, balance regulatory authority, concerning obviously threatening situations, in the absence of guidance. In summary, my statement was mostly a plea to the Nuclear Regulatory Commission to consider the world through the eyes of a professional, a security inspector, on the ground. The fact that we have such wide grounds for debate is, in my mind, the real issue and not the fact that we debate. These wide grounds exist, I believe, because of the absence of an aggressive, The Honorable Sam Gejdenson -3 JUN 17 1987 positive, comprehensive NRC regulation with guidance, on the subject of "human behavior reliability estimates" for those personnel entering upon the nuclear sites. In addition, the capability to effectively investigate those apparent violations of such a subject is also required. I would appreciate it if this communique would be made a supplement to the testimony provided before your subcommittee on June 11, 1987. CC: Rep. Denny Smith Chairman Lando W. Zech, Jr. Commissioner Frederick M. Bernthal Commissioner Kenneth M. Carr Victor Stello, Jr., EDO Robert D. Martin, RIV James A. F. Kelly Senior Security Inspector U.S. Nuclear Regulatory Commission EDWARD J. MARKEY, MASSACHUSETTS BRUCE F VENTO. MINNESOTA JERRY HUCKABY, LOUISIANA DALE E KILDEE. MICHIGAN TONY COELHO, CALIFORNIA JAIME B FUSTER PUERTO RICO MEL LEVINE, CALIFORNIA JAMES MCCLURE CLARKE, NORTH CAROLINA WAYNE OWENS. UTAN JOHN LEWIS. GEORGIA BEN NIGHTHORSE CAMPBELL, COLORADO PETER A DEFAZIO OREGON DON YOUNG, ALASKA MANUEL LILIAN, JR, NEW MEXICO DICK CHENEY, WYOMING CHARLES PASHAYAN, JR. CALIFORNIA DENNY SMITH, OREGON JAMES V HANSEN. UTAH BILL EMERSON, MISSOUR BARBARA F. VUCANOVICH, NEVADA BEN BLAZ, GUAM JOHN J. RHODES IN ARIZONA RICHARD H. BAKER, LOUISIANA Mr. James A.F. Kelly Senior Security Inspector U.S. Nuclear Regulatory Commission Dear Mr. Kelly: I appreciated receiving your letter of June 17, 1987, augmenting your recent testimony before the Subcommittee on General Oversight and Investigations. As you have requested, your letter will be included in the record of the hearing. As you indicate, your prepared testimony was the product of |