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- units to starto o % NUCLEAR REGULATORY COMMISSION & ; negion iv o ". - of 3 611 Ryan Plaza draive. suite 1000 *, .....” antington. Texas 760-11 JUM 17 887 The Honorable Sam Gejdenson, Chairman ..] so

Subcommitte on General Oversight
and Investigations
Committee on Interior and Insular Affairs
United States House of Representatives
Washington, D.C. 20515

Dear Chairman Gejdenson:

Subject: Testimony Before the Subcommittee on General Oversight and
Investigations, Committee on Interior and Insular Affairs,
U.S. House of Representatives, on June 11, 1987

The printed statement, issued by the Subcommittee at the hearing as drafted by the Committee staff with input from me, was the negotiated product of a 2-day, 20-hour interview session conducted by the Subcommittee staff. After reviewing the final product, I am not satisfied that the principles that I wished to convey were highlighted. The background for the Committee staff's questioning was a collection of reports and documents drawn from a variety of outside agencies and internal units of the NRC. I had two options. The first was to work through the series of points, that were pressed by the congressional staff, and attempt to explain the circumstances and educate the staff about the inspection processes and its limitations. My second option was to be subpoenaed, and thus be required to respond to random questioning by congressmen during the hearing. Given the nature of some of the situations and actions that I was called upon to explain and defend, and compounded by what I believe to be the absence of logical policy in matters apparently so clear in the minds of the public, the task was very difficult. I elected to contain the unpredictability of the line of questioning by reducing the volume of the material at issue and addressing it during the lengthy interview process. In retrospect, I still believe that the course that I took was correct and that my professional behavior was a credit to the region. However, the scenario approach did not highlight the principles of an effective program.

My statement reflects the facts, as I remembered them, concerning several examples of my inspection findings as contrasted with external materials possessed by the staff. The perspective offered by me is that of one who is on the ground and who admittedly is not privy to all of the relevant decisionmaking processes that follow such findings. However, informed or not, I must attempt to complete the inspection process within that clouded environment. The main theme of the scenarios that I presented was one intended to provide insight into the difficulties that a security inspector

JUM 17 387

The Honorable Sam Gejdenson –2–

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,

JUN The Honorable Sam Gejdenson -3- 17 oa.

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.

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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 extensive discussion with the Subcommittee staff. It is my understanding that your testimony reflected the facts as you know them. As was explained to you in the interviews prior to your testimony, if there is anything else you care to add, please feel

free to provide it to the Subcommit and it will be £ncluded
in the record.

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