ML20137J153
| ML20137J153 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/1997 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Rogers K, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20137J058 | List: |
| References | |
| COMSECY-96-063, COMSECY-96-63, DSI-14, DSI-4, FACA, SECY-96-063-C, SECY-96-63-C, NUDOCS 9704030232 | |
| Download: ML20137J153 (2) | |
Text
m p u'og oeoeeasc.e*aac.n av....ee
[, ' /
NUCLEAR REG TORY COMMISSION l RELEASED TO THE FDR WASHING TON, 0.C. 20555 e
,./
.inb3!3 date e i OFFICE OF THE February 3, 1997 COMMCSIONER MEMORANDUM T0:
Chairman Jackson Commissioner Rogers i
Commissioner Dicus Commissioner Diaz h[
4 FROM:
Edward McGaffigan. Jr.
i Commissioner g, g 0
SUBJECT:
COMSECY-96-063 - DSI 14 - PUBLIC COMMUNICATION INITIATIVES Having reviewed this paper and the stakeholders' comments. and bearing in mind overall resource constraints on the agency. I support Option la (continue 4
existing approach but focus on maximizing effectiveness and economy) with a
" longer course of implementation" that would avoid the need for additional resources to implement.
In reviewing this paper and the comments on it. I was struck by the bias toward allocating more resources to the public communications function.
In my view, other Direction Setting Issue papers make a far more compelling case for additional resources.
Public communication is important to carrying out NRC's mission and the agency currently devotes significant resources (although "the full level...is difficult to assess") to more than meeting, and usually far exceeding, the legal requirements in this area.
Most of the increases in j
efforts in this area, proposed under Options 2 and 3 would require substantial additional resources in return for uncertain and unpredictable benefits at a time when the NRC may be increasingly hard-pressed to fully meet its core public health and safety, common defense and security, and environmental responsibilities with the resources that it has avaiiable.
To some degree. I believe the agency still appears to be traumatized by the Below Regulatory Concern (BRC) policy affair of the early 1990s.
Speaking with the perspective of a former Congressional staffer. I do not believe that the Commission can or should become so risk-averse in its decision-making and rulemaking activities that it will seek never to be challenged, and perhaps overturned, in Congress or the courts.
When the Commission completes its final rulemaking on criteria for clean-up of decommissioned facilities (hopefully very shortly), we should expect challenges to our decisions despite the staff's use of enhanced ]articipatory rulemaking and years of effort by l
j the staff to communicate wit 1 every conceivable stakeholder about all facets of this issue.
The flip side of constant " enhanced Jublic participation" and an endless (and frequently fruitless) effort to furtier narrow often irreconcilable differences is indecision and delay in rulemaking and other decision-making. thereby preserving a status qu that is unsatisfactory to almost all stakeholders. and resulting regulatory requirements that are sometimes ineffective or unworkable.
i 9704030232 970401 PDR NRCSA I 9
14 PDR
\\.
2 This all said, I would favor constant efforts to improve the agency's public communications functions within existing resources.
Much of the agency's public communication disseminated by other than our communication professionals is incredibly dense and difficult to understand, witness the DSI papers themselves.
On a highly technical rulemaking, that may be necessary and unavoidable.
But we also need a vocabulary that can answer the simple questions "What is my risk?" and "How safe is the facility?", which one stakeholder, a Colorado regulator, said constituted eighty percent of his public communications work.
That will involve developing a comparative risk vocabular, that may benefit from the recently released report of the Presidential / Congressional Commission on Risk Assessment and Risk Management.
cc: