ML19329G204
| ML19329G204 | |
| Person / Time | |
|---|---|
| Issue date: | 01/18/1979 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19329G202 | List: |
| References | |
| SECY-79-424, NUDOCS 8007140130 | |
| Download: ML19329G204 (1) | |
Text
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..:3 UNITED STATES f ). p mtact
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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u t,s January 18, 1979 5
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!?.l CFFICE OF THE SECRETARY
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- [e5E 5E MEMORANDUM FOR:
Lee V. Gossick 3
Executive Director for Op ions
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FROM:
Samue*4 J. Chilk, Secretal y
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SUBJECT:
COST-BENEFIT, VALUE-IMSA4T A OTHER SIMILAR il ANALYTICAL METHODS IN REG.e"LATION The Comission recuests the staff to conduct a detailed review of Professor 5
Ste Baram's study, "Co'st-Benefit Analysis in Energy Decision-Making of the 5
note Nuclear Regulatory Comission." As part of'an earlier NRC review of the i
below recomendations in Professor Baram's study, the Commission decided to request staff to review,.with an eye toward making available for public coment, the "Value-Impact Guidelines" adopted by the Commission in i
January 1978.. The purpose of such a statement is to provide for public
=
review NRC's perspective in its cost' benefit approach (e.g., method for i
evaluating regulatory impacts,' discounting future costs, etc.) as well 4
as the manner and extent of public participation in the process.
s Accordingly, the Comissidn also requests the staff to JLrepare a draft E
Federal Reaister notice for Comission approval which would solicit 5
public comment on the "Value-Impact Guidelines" and to review any office
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. level guidelines which were prepared to impl'ement the Comission's i
guidelines to determine if they should alsoi.be made available for public
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coment as part of this process.
(SECY SUSPENSE:
March 15,1979) i cc:
Chairman Hendrie i
Comissioner Gilinsky 5
Comissi,oner Kennedy Comissi'oner.Bradford 5
Comissioner Ahearne
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Director, Policy Evaluation Acting General Counsel
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,f NOTE MPA and ELD comments on Baram Report were sent to Commission in March 1979. NRR i
l' comments were sent to each Comssioner in May 1979.
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Enclosure A (Item 3)
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Draft federal Register Notico U. S. NUCLEAR REGULATORY COMMISSION REVIEW OF COMMISSION'S VALUE-IMPACT GUIDELINES Significant proposed Commission regulatory actions (such as development of new, or modifications to existing, regulations)'are subjected to value-impact analysis.
Such analysis attempts to illuminate both the merits and the undersirable ramifications of these proposed actions.
The term value-impact appeared in a memo dated 4/15/76 from Chairman Anders to Mr.
' Gossick suggesting the need to improve upon NRC's evaluation of proposed regulations.
For the sake of convenience the reader may equate value-impact Swith benefit-cost or cost-effectiveness analysis.
However, the reader is warned that this view is not universally held by NRC staff.
A summary of the agency-wide Value-Impact Guidelines, which were adopted by the Commission in January,,1978 is provided below.
The Commission believes that it would n'ow be useful to review comprehensively the guidelines.
In keeping with the NRC's efforts. to increase public participation in the regulatory process, and in order to provide for public review of NRC's perspective on the benefit-cost portion of its regulatory analysis, the Commission is requesting public comments on the guidelines.
In addition to comments on the guidelines' cl.arity, perceived usefulness, and discus ~sion of analytical techniques, the Commission would appreciate receiving comments on whether the role of cost impacts could or should be broadened beyond that stated or implied by the Guidelines.
It is anticipated that the guidelines will-be modified after their review has been completed.
n
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Several NRC offices have developed their own office-specific implementing guidelir>es.
The public is welcome to comment on office-specific guidelines as well.
The agency-wide gil'Celines are available for review at any of the Commission's
'Public Document Rooms (PDRs) listed below.
Office-specific guidelines, pre-vious Commission comments, anc recent staff comments have also been placed in the PDRs.
Copies of each of these documents or further information may be obtained by contacting John A. Sullivan, Office of Management and Program Analysis, U. S. Nuclear Regulatory Commission, Washington, D.C. 20555 (phone 301-492-7721).
" Written comments should be submitted to the Secretary of the Commission, U. S. Nuclear Regulatory Commission, Washington, D.C. 20555, ATTENTION:
Docketing and Services Branch.
Comments must be received by the 120th day after publication.
Copies of. comments received from the public may be examined at the Commission's Public Document Room at 1717 H Street, N..W., Washington, D.C.
Summary of the Nuclear Regulatory Comission's Agency-wide Value-Impact Guidelines (The following is extracted from the guidelines that have been in effect at the NRC)
Reculatory PersDeetive The policy of the Nuclear Regulatory Ccmmission is that value-impact
- analyses be conducted for any proposed regulatory actions that might impose a significant burden on the public (where the.erm public is defined in its broadest sense).
Such policy is not to be constr;ed to mean that cost considerations take precedence over considerations of health, safety, environinent,
~
- In order to provide uniformity and to avoid misunderstanding these analyses should be referred to is "value-impact" rather than " impact-value" or "value/
impact."
4
3 or national security. These factors remain paramount.
However, where there are alternative means of realizing equivalent benefits in regulatory matters, cost should be a prime consideration.
It is recognized that only rarely will all considerations in a regulatory matter be amenable. to quantification.
Regulatory decisions will in the final analysis remain a matter of judgment.
However, value-impact analyses, by focusing on the narrower issue of public benefit and burden, can help to make mcre informed judgment possible.
Elimination of unnecessary cests
' associated with a regulatory action provides resources to achieve de~ sired levels of other societal goals.
It is not intended that the value-impact analyses replace the normal pro /co, discussions usually contained in staff papers'. Such analyses should be complementary to the more inclusive pro / con discussion which may address more subjective items such as procedural and organizational' alternatives, or.public perception o~f the issues.
Value-impact analysis is appropriate for unique or generic licensing actions and other non-routine, non-recurring regulatory actions requiring Commission decision.* Value-impact analysis is also appropriate for proposals which are reviewed by the Regulatory ReqQirements Committee and during the pre-paration of Branch Technical Positions and new or revised regulatory guides.
Value-impact analyses-will not routinely be required for specific licensing actions, such as the issuance of facility, material and eroort-import licenses, license amendments, and enforcement actions.
~
See Appendix I for more extensive discussion inclu, ding examples of previous staff work for which value-impact analysis would have been appropri. ate.
4 Some NRC evaluations such as generic environmental impacts statements already contain elements in common with value-impact analyses.*
In instances where value-impact analyses have been integrated with such non-routine appraisals, a separate section (called a value-impact statement) which briefly summarizes the elements of the value-impact analyses should be included when the document is forwarded to the Commission-.
i All Commission papers classified as either " Commission Actions Items",
" Policy Session Items", or " Consent Calendar Items" should be accompanied by a value-impact sta'tement or an explanation of the reasons for not including a statement.
Such reasons might be that the action is non-regulatory (e.g., paper recommends that the Chairman sign a letter to a Congressman) or that che regulatory actions recommended is " routine" or recurring in nature (e.g.,
approval of an export license for low-enriched uranium).
In instanceswhere it has been concluded that the public would not be significantly affected, a declaration of negative findings is appropriate, i.e., " Analysis indicates inconsequential impact associated with recommendation." A brief statement of the elements evaluated should accompany a negative declaration.
In some instances the following statement may be appropriate, " Alternatives to the staff recommendation have may been precluded (or limited) by statute ~(or previous Commission action)."
These guidelines would not require additional documentation' to that staff now provide where the latter contain the. essential elements of value-impact evaluations listed on pp. 5 & 6.
Thus no new format would be necessary.for i
the analyses (unless required by office-specific guidelines.
However, when
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feasicle, value-impact statements should follow the format used in_the illustrative value-impact statement presented at the end of this summary section.
5 As a general rule, the depth or extensiveness of a value-impact analysis should depend on the magnitude of the expected costs and benefits associated with the proposed action, except where anticipated public interest alone would dictate a more complete statement.
In any event, though there may be extensive back-ground or supporting analysis, the value impact statement itself should be kept as brief as possible.
Elements of Value-Imoact Anaysis Value and impact analysis as commonly interpreted at the Nuclear Regulatory Commission is essentially a technique equivalent to benefit and cost analysis, or cost and effectiveness.* The term value-impact was introduced at NRC to dispel certain connotet'.ons associated with other terms.
Benefit-cost analysis, in particular, is sometimes misperceived as a process of reducing all factors to a common dollar form.**
In these guidelines impacts are negative consequences (e.g., environmental damage or increased economic costs) and values are positive or beneficial (e.g., reductions in radiation doses to the public.)
Ideally, elements of value and impact evaluations would include:
A statement of the objectives of the reccmmended action.
A description of the setting and oackground of the problem including analytical assumptions, and specification of the relationships between alternatives and the objective.***
See Appendix II which discusses benefit-cost and ' cost-effect6eness analyses.
When, in fact, factors expressed in physical units can be quite acceptable
'in some benefit-cost analyses.
- This element is sometimes called the scenerio or the model.
l
6 Description, identification, and definition of alternatives (which should include the status quo or current system).
Estimates of the incremental _ (or marginal, or differential) benefits (or
~
levels of effectiveness), and associated costs, (including side effects) of the various alternatives when comoared with the base case or status auo.
Identification of criteria for assessing or ranking of alternatives.
The heart of value-impact analysis is the. evaluation of alternatives and these should be described and defined in the statement.
Ideally, alternatives would be defined as different actions with the identical or similar consequences, benefits or costs. A po;sible exception is the base or reference case (e.g.,
the status quo, the option of taking no action, or continuing with current practices). The implications of taking no action should be evaluated even in those instances where the option would not completely satisfy the same 4
objectives as would the alternative recommended by NRC ' staff.
Both basic elements and special topics are addressed at length in the body of the guidelines.* Although pro-forma, sketchy treatment of alternatives should be avoided, it is unlikely that many value-impact analyses conducted at NRC will necessitate such lengthy discussion of each of the elements.
Nevertheless,
- the material may prove to be useful on a selective basis to NRC analysts, Appendix III contains examples of the possible scope and content of value-impact analyses and evaluations.
These guidelines are intended to provide general instr 0ctions.
Each NRC office should develop its own specific. guidelines.(e.g., emphasizing format) which are adapted to the particular issues analyzed by the office..
e e
4 7
i Ac Illustrative Value-Imoact Statement (Inerting of Containment)
A.
Objective It is predicted that inerting of containments of selected react. ors will reduce the probability of a hydrogen explosion immediately following a Loss-of-Coolant-Accident (LOCA)
B.
Background and Setting In some small containments (for a few boiling water reactors) the combustible gas control system would not he able to accommodate the large concentration of hydrogen associated with the metal-water reaction immediately following a LOCA.
Five reactors would be required to inert if staff recommendations are approved.
Major assumptions are:
1.
Agency policy is continue with the current technical approach, a passive containment concept.
2.
Reduced containment inspection will not result in failure to diagnose a reduction in containment integrity.
C.
Alternatives 1.
Retain Status Quo 2.
Inerting 3.
P. urging 4.
Recombiners D.
Value-Impact Evaluation l
Value and impact estimates are provided in the accompanying' table.
For example, the incremental value of alternatives 2 and 3 is that each would e
8 prevent a radioactive dose release of 595 rem in the event of a post-LOCA hydrogen explosion.
Note that the costs shown are per plant. Total plant costs estimated to be:
Alternative 2, $62,500 to $3,260,000; Alternative 3, 57,000,000 equipment cost plus $620,000 annual operating cost. Incremental costs associated with increased demand for and transportation cr,t of nitrogen, used in inerting, are estimated to be minimal.
E.
Criteria Select icwest cost alternative which reduces probability of a hydrogen explosion. See discussion in Text of guidelines - pp. 14 and 15 - regarding additional analysis which might be accomplished on the inertir.g issue.
I D
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CONTROL OF llYDROGEN FROM M-W REACTION IMMEDIATELY (2 min.) AFTER LOCA (FOR THE ESTIMATED 5 PLANTS THAT WILL STILL DE REQUIRED TO INERT Potential Cost of Developmental Alternative Radiation Dose ~
Implementing Work Comments Inerting 0
$12,500 to None Appeal Board Decision Against Inertid
$507,000 Vermont Yankee Purging 0
$1,400,000 capital cost Very Little Will have to purge immediately after
$120,000 annual operat-LOCA with maximum radiation in con-ing cost (Does not tainment. Must therefore have filteQ account for loss in pro-ing system capability of 150,00 cfm>
duction time associated Representsaradicalde'parturefrom(
with maintenance of these passive containment concept that is systems) presently required by NRC.
Recombiners 595 rem *
$200,000 per 100 cfm None for present Recombiner must operate immediately unit units. However, a after accident and must handle 150,C major effort cfm. This would require about 1,500 would be required currently available units or under-to develop a system taking a major developmental progran to handle 150,000 that may or may not succeed in pro-cfm.
ducincj 150,000 cfm units in a reasor able time period..'he calculated dos assumes loss of containment integril because of inability of currently
{
available units to handle large amounts of hydrogen rapidly. This the same release as if the plant ha, not been inerted.
Assumes'no fuel failure, however, transient occurred before LOCA and resulting iodine spike is at Technical Specification limit of 4 uCi/gm I-131 equivalent.
e
_ This concludes the summary of the Guidelines.
The Guidelines themselves, as well as relatad materials, can be reviewed at the locations listed below:
ROSTER'0F ALL LOCAL PUBLIC DOCUMENT ROOMS BY STATE ALABAMA CALIFORNIA 1.
Mrs. Maude S. Miller 1.
Mr. C. Combs Athens Public Library Kern County Library South and Forrest 1315 Truxtun Avenue Athens, Alabama 35611 Bakersfield, California 93301 (205) 232-1233 (805) 861-2130 2.
Mr. Wayne Love 2.
Mrs. Alice Rosenberger G. S. Houston Memorial Library Palo Verde Valley District Libra 0 212 W. Verdeshaw Street 125 West Chanslorway Dothan, Alabama 36301 Blythe, California 92255 (205) 792-3164 (714)922-5371 3.
Mrs. Joanne Wyatt 3.
Mr's. Eileen Danforth Clanton Public Library Mission Viejo Branch Library 100 First Street 24851 Chrisanta Drive Clanton, Alabama 35045 Mission Viejo, California 92676 4
(205) 755-1768 (714)830-7100 4.
Mrs. Peggy McCutchen 4.-
Mrs. Patricia Clark Scottsboro Public Library San Luis Obispo County Free
- 1002 South Broad Street Library Scottsboro, Alabama 35768 888 Morro Street San Luis Obispo, California 93400 (805) 543-6076 ARIZONA 5.
Mrs. Judy Klapprott Humboldt County Library 1.
Mrs. Mary Carlson 636 F Street Phoenix Public Library Eureka, California 95501 Science and Industry Section 12 East McDowell Road (707)445-7513 Phoenix, Arizona 85004 6.
Mrs. Dorothy Harvey (602) 262-6534 Business & Municipal Department Sacramento City-County Library 828 I Street ARKANSAS Sacramento" California 95814 1.
Mr. Vaughn (916) 449-5204 l
Arkansas Tech College Russellville, Arkansas 72801 l
(501) 968-0304
. CALIFORNIA, Cont'd.
CONNECTICUT, Cont'd.
[
7.
Mr. Andrew LaMance 2.
Mr. Stewart Porter, Director Stanislaus County Free Library Russell Library 1500 I Street 119 Broad Street Modesto, California 95345 Middletown, Connecticut 06457 (209) 526-6821 or 6823 (203) 347-2528 8.
Mr. William B. Rohan San Diego County Law Library DELAWARE c
1105 Front Street San Diego, California 92101 1.
Mrs. Yvonne Puffer Newark Free Library (714) 236-2231 750 East Delaware Avenue Newark, Delaware 19711 9.
Nuclear Regulatory Comission, Region V (302) 731-7550 Office of Inspection and
[
Enforcement Suite 202,1990 N. California P' *d.
FLORIDA Walnut Creek, California 94596 1.
Ms. Sally Litton i
(415)~ 486-3141 Jacksonville Public Library 122 North Ocean Street Jacksonville, Florida 32204 COLORADO (904)633-3926 1.
Miss Ester From Greeley Public Library 2.
Mrs. R. Scott City Complex Building Indian River Comunity Greeley, Colorado 80631 College Library 3209 Virginia Avenue (303) 353-6123 X-271 Ft. Pierce, Florida 33450 2.
Mrs. Elizabeth Morrissett (305)464-2000 Acquisitions Department Auraria Library, University of 3.
Mrs. Rene' Daily Colorado at Denver Environmencal and Urban Affairs Lawrence and lith Library Denver, Colorado 80204 Florida International University; Mia, 5, Florida 33199
-(303) 629-2623 (305) 552-2414 CONNECTICUT 4.
Mrs. Bonsa'l Crystal River Public Library
-1.
Mrs. Liskov 668 N. W. First Waterford Public Library Crystal River, Florida 32639 Rope. Ferry Road Rout 156 (904) 795-3716 Waterford, Connecticut 06385 (203)442-8551
6.
Mrs. Penny O'Roarke 1.
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Savanna Township Public Library 326 Third Street 1.
Mr. Ed Anderson Savanna, Illinois 61074 Illinois Valley Comunity College Rural Route #1 (815) 273-3714 Oglesby, Illinois 16348 (815) 224-6011 INDIANA 2.
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Mrs. Marie Hoschied Moline Public Library 2.
Mr. Don C. Johnson 504 - 17th Street Madison-Jefferson County Moline, Illinois 61265 Public Library e
420 West Main Street 1
Madison, Indiana 47250 t (309) 762-6883 4.
Jo Ann Ellingson (813)265-2745 Zion-Benton Public Library 2600 Emmaus Avenue Zion, Illinois 60099 IOWA (312) 872-4680 1.
Miss Kay Burke Reference Service 5
Mrs. M. Evans Cedar Rapids Public Library Vespasian Warner Public Library 428 Third Avenue, S.E.
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. Cedar Rapids, Iowa 52401 120 West Johnson Street Clinton, Illinois 61727 (217)935-5174
Mr. Jack Scott 1.
Mrs. Elizabeth Hart Coffey County Courthouse Charles County Library Burlington, Kansas 66839 Garrett and Charles Streets LaPlata, Maryland 20646 (316) 364-2191 (301)934-9001 LOUISIANA 2.
Mrs. Marie Barrett Calvert County Library 1.
Business and Science Division Prince Frederick, Maryland 20678 New Orleans Public Library 219 Loyola Avenue (301)535-0291 New Orleans, Louisiana 70140 3.
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Mr. Mark Titus 4.
Mr. Jimmie Hoover Plymouth Public Library Government Documents Department North Street Louisiana State University Plymouth, Massachusetts 02360 Baton Rouge, Louisiana 70803 l
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The Carnegie Library MAINE Avenue A Turner Falls, Massachusetts 0132 1.
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2.
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6.
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i 3700 South Custer Rod (402) 274-4023 8
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Monroe, Michigan 48io 5
3.
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215 South 1,5th Street l
Omaha, Nebraska 68102 g
.=.
(402) 444-4800 or 4834 0
s NEW JERSEY NEW YORK,' Cont'd.
1.
Arthur Flandre 4.
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Ms. Marsha Russell 2.
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. OHIG, Cont'd.
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(513) 732-2128 (704) 374-2725 3.
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416 N. Main Street Berlin Heights, Ohio 44814 P.O. Box 158 Mocksville, Nroth Carolina 27028 (419) 58S-2250 (704) 634-2023 OREGON 4,
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Mr. H. B. Allen 109 W. Moore Street City Hall, Records Office Southport, North Carolina 28461 Arlington, Oregon 97812 (919) 457-6237 (503) 454-2743 5.
Mrs. Charlotte Ellis 2.
Mr. Zimmer Franklin County Library Columbia County Courthouse 1026 Justice Street Law Library Circuit Courtroom Louisburg, North Carolina 27549 St. Helens, Oregon 97501 (919)496-4942 (503) 397-4322 OHIO PENNSYLVANIA 1.
Mrs. Betty Waltman 1.
Osterhout Free Library Perry Public Library Reference Department 3753 Main Street 71' South Franklin Street Perry, Ohio 44081 Wilkes-Barre, Pennsylvania 1870)
(216) 259-3300 (717) 823-0156
9 PENNSYLVANIA, Cont'd.
RHODE ISLAND, Cont'd.
2.
Mr. John Geschwindt 2.
Thomas Reynolds' Government Publications.
- University of Rhode Island Section University Library State Library of Pennsylvania Government Publications Office Education Building Kingston. Rhode Island 02881 t, m onwealth and Walnut Street Harrisburg, Pennsylvania 17126 (401) 792-2606 (717) 787-3752 SOUTH' CAROLINA 3.
Mrs. Gordon Bauerle Pottstown Public Library 1.
Joe E. Garcia 500 High Street York County Library Pottstown, Pennsylvania 19464 325 South Dakland Avenue Rock Hill, South Carolina 29730 (215) 326-6975 (803) 327-3630 4.
Mr. F. E. Virostek 1
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Reference Department j
663 Franklin Avenue Richland County Public Library Aliquippa, Pennsylvania 15001 1400 Sumter Street Columbia, South Carolina 29201 (412) 375-7174 (803) 799-9084 PUERTO RICO 3.
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Mrs. Allene Reep (809) 878-3173 Hartsville Memorial Library Home and Fifth Avenue j
2.
Mrs. Amalia Ruiz De Porras Hartsville, South Carolina 2955e Etien Totti Public Library College of Engineers, Architects, (803) 332-5115 and Surveyors Urb Roosevelt Development 5.
Mr. David Eden Hato Rey, Puerto Rico 00918 Cherokee County Library 300 E. Rutledge Avenue (809) 767-7522 Gaffney, South-Carolina 29340 (803) 489-4381
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RHODE ISLAND 6.
Mr. T. E. Richardson 1.
Mrs. ' Ann Crawford County Office Building Cross Mill Public Library Room 105 Old Post Road P.O. Box.443 Charlestown, Rhode Island 02813 Barnwell, South Carolina 29812' ATTN:
Fred Bodiford (401) 364-6211 (803) 259-3464
t 2 SOUTH CAROLINA, Cent'd.'
TEXAS 7.
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Mrs. Tim Whitworth Anderson County Library Somervell County Public Library 202 East Greenville Street On The Square Anderson, South Carolina 29621 P.O. Box 1417 Glen Rose, Texas 76043 (803) 225-1429 (817)897-4582 TENNESSEE 2.
Newton Public Library P.O. Box 657 1.
Miss Kendall J. Cram, Director Newton, Texas 77034 Tennessee State Library and Archives (713) 379-8300 403 Seventh Avenue, North hashville, Tennessee 37219 3.
Matagorda County Courthouse
.Matagorda County Law Library
'(615) 741-2764 P.O. Box 487 Bay City, Texas 77414 2.
Ms. Dorothy Dismuke Oak Ridge Public Library (713) 245-2801 Civic Center Oak Ridge, Tennessee 37830 4.
Mrs. Kroesche Sealy Public Library
^
(615)483-6386 201 Atchison Street Sealy, Texas 77474 3.
Mrs. Patricia Rugg Lawson McGhee Public Library (713) 885-6341 500 W. Church Street Knoxville, Tennessee 37902 VERMONT (615)523-0781 1.
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Mr. T. Cal Hendrix Kingsport Public Library 1.
Ms. Sandra Peterson l
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. i WISCONSIN VIRGINIA, Cont'd.
1.
Mrs. Jane Radloff 2.
Mr. Gregory Johnson Lacrosse Public Library Alderman Library 800 Main Street Manuscripts Department Lacrosse, Wisconsin. 54601 University of Virginia (608) 784-8623 i
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Mr. Arthur M. Fish 3.
Mr. Edward Kube Document Department, Library Board of Supervisors University of Wisconsin -
2 Louisa County Courthouse Stevens Point P.O. Box 27 Stevens Point, Wisconsin 54481 Louisa, Virginia 23093 ATTN:
Ms. Manrique (715) 346-0123 (703) 967-0401 3.
Mrs. Frances Wendtland Mead Public Library 710 North Eighth Street WASHINGTON Sheboygan, Wisconsin 53081 1.
Miss D. E. Roberts (414)459-3420 Richland Public Library Swift and Northgate Streets 4.
Miss Sue Grosshuech Richland, Washington 99342 Kewaunee Public Library 822 Juneau Street (509) 943-9118 Kewaunee, Wisconsin 54216 2.
Mrs. D. Stendal (414) 388-3331 Sedro Wooley Library 802 Ball Avenue 5.
Mr. John Jax Sedro Wooley, Washington 98294 University of Wisconsin Stout Library (206)855-1166 Menomonie, Wisconsin 54751 3.
Ms. Selma Nielsen (715) 232-2363 W. H. Abel Memorial Library 125 Main Street, South.
Montesano, Washington 98563 (206) 249-4211 D
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Mrs. Caroll Highfill Converse County Library Douglas, Wyoming S2633 (307) 358-3644
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Mrs. Margaret Baker Carbon County Public Library Courthouse Rawlins, Wyoming 82301 (307) 324-4756 Dated at
, this day of
, 1979.
FOR THE NUCLEAR REGULATORY COMMISSION.
Samuel J. Cnilk Secretary of the Commission 4
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ENCLOSURE C DRAFT LTR TO CONGRESS O
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Dear Mr. Chairman:
Enclosed for the information of the Subcommittee on Energy and the' Envimnment is a notice requesting public comments.on the Commission's Value-Impact Guidelines.
(Significant proposed Commission regulatory actions - such as development of new regulations - are' subjected to value-impact analysis.)
Also enclosed is an associated public announcement which will be issued s ho rtly. '
1 Carlton,Kammerer. Director i
. Office of Congressional Affairs
Enclosures:
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- 1. ' Notice for Federal Recister 2.
Public Announcement O
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Enclosure C 4
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PUBLIC ANNOUNCEMENT [ Draft]
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NRC REVIDS VALUE-IMPACT GUID3LIUES FCn. EVALUATING REGULATORY ACTIONS
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'Ihe Nuclear Regulatory Comission is seeking public coment on agency guidelines for value-impact analyses conducted'by the NRC staff for significant proNsed regulatory actions.
In January 1978, the Comission adopted the value-impact guidelines as a technique for assessing th'e. merits and undesirable effects of regulatory a tions, such as developirq or modifying regulations and regulatory guides.
Under the NRC guidelines, impact,are censidered negative
. consequences, such as envirorrnental damage or increased economic costs, and values are positive or beneficial, such as reductions in radiation doses to the public.-
In conducting this review, the Comission will consider, among other things, whether the role of cost impacts could or should be broadened beyond that stated or implied by the guidelines.
An executive su::nnry of f.he value-impact guidelines has been published in the Federal Register of June Copies of the guidelines and other related Comission papers are available for review and inspection at the NRC's Public Document Room,1717 H Street, N.W., Washington, D.C., and at local public document rooms located near the site of nuclear power plants in operation or under construction.
Further information and copies of the guidelines also may be obtained by contacting John A. Sullivan, Office of Management and Program Analysis, Nuclear Regulatory Co=Tission, Washington, D.C.
20555(301/492-7721).
Enclosure D I
4 Written coments on the guidelines should be sub:itted to the Secretary of the Conmission,. Nuclear Regulatory Conmis'sion, W1:hington, D.C. 20555, Attention:
Do'cketing and Service Branch, by H
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ENCLOSURE E VALUE-IMPACT RELATED MATERIALS TO BE PLACED IN PDRs t
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U.S.* Nuclear Regulatory C'ommission's Value-Imoact Guidelines and Related Materials Item Title 1.
Memorandum of April 15, 1976, from W. Anders to L. V. Gossick,
" Impact-Value Assessments.",
2.
Memorandum of January 23, 1978, from S. J. Chilk, Secretary, to L. V. Gossick, Executive Director for Operations, "SECY-77-388A -
Value-Impact Guidelines" (Commissioner Action Item).
3.
NRC Agency-wide Value-Impact Guidelines (see the Guidelines for Table of Contents).
4.
" Responses to Comments on the Secretary's Memorandum (ar;l Enclosure) of 8/5/77 to the Executive Director for Operations" 5.
Memorandum of 5/1/79 from M. G. Malsch, Chief Regulations Counsel, Office' of Executive Leg'al Director, to N. M. Haller, Director, Office of Management and Program Analysis (MPA).
6.
Memorandum of 3/7/79 from J. R. Shea, Dire'ctor, Office of State Programs, to N. Haller, MPA.
7.
Memorandum of 3/7/79 from Dudley Thompson, Executive Officer for Operations Support, Office of Inspection and Enforcement, to N.
Haller,'MPA.
8.
Memorandum of 3/8/79, from J. M. Felton, Director, Division of Rules and Records, Office of Administration, to N. Haller, MPA.
9.
Memorand.' of 3/6/79, from L. W. Barry, Controller, to N.
Haller, h A (w/o Enclosures).
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10.
Memorandum of 3/20/79 from R. S. Brown, Jr., Assistant to the i
Director and Chief, Program Support Branch, Office of Nuclear Material Safety and Safeguards (NMSS),to N. Haller, MPA.
11.
Memorandum of 3/12/79 from R. F. Burnett,' Director, Division of Safeguards, NMSS,to R. E. Cunningham, Director, Division of Fuel i
Cycle and Material Safety, NMSS.,
12.
Memorandum of 3/1/79 from E. Perchonok, Chief, Technical Planning and Information Branch, to L. J. Evans, Jr., Chief, Regulatory
- Improvements Branch, NMSS l
13.
Comments by individual ' t.a NMSS l
- Note: Where Offices forwarded comments of individuals their names have been removed because individuals Enclosure E j
were not initially told that com;ents would be placed in WLCEiaiB01@0'O P6blic Document Rooms.
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Comments (on NMSS Policy and Procedure Letter 1-9 see item 22, below) by individual from NMSS.
15.
Comments by individual from NMSS.
16.
Memorandum of 3/7/79 from K. Dragonette, low-level Waste Branch, to E. Tourigny, Operations and Planning Branch, NMSS (Enclosures are in separate items).
17.
Memorandum of '4/26/79 from D. F. Bunch, Director, Program Support Staff, Office of. Nuclear Reactor Regulation, to N. Haller, MPA..
Memorandum of 3/14/79 from R. B. Minogue, Director, Office 1"
of Standards Development, to H. Haller, MPA.
19.
Comments by individual from NMSS.
20.
Comments by individual from NMSS.'
21.
Comments (on NMSS Policy and Procedure Letter 1-9, see item 22)
, by individual from NMSS.
i 22.
NMSS Policy and Procedure Letter 1-9 (October 13,1978) 23.
Memorandum of April 13, 1977 from R. Minogue, Director, Office
- of Standards Development (SD) to SD staff (document, "50 Staff Guidance for Preparation of Value/ Impact Statements," attached).
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24.
Memorandum of January 31, 1978 from E. Case, Acting Director, Office of Nuclear Reactor Regulation (NRR) to NRR Divisicn Directors - R. Boyd, H. Denton, R. Mattson, and V. Stello, Jr.
( Instructions for the Preparation of Value-Impact Analyses, NRR Office Letter No. 16").
25.
. Memorandum of February 16, 1979 from N. Haller to All Office Directors ( w/o' enclosures ).
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