ML20140D108
| ML20140D108 | |
| Person / Time | |
|---|---|
| Issue date: | 03/27/1997 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20140D095 | List: |
| References | |
| SECY-97-052-C, SECY-97-52-C, NUDOCS 9704220212 | |
| Download: ML20140D108 (3) | |
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NOTATION VOTE l RESPONSE SHEET TO: John C. Hoyle i Secretary of the Commission 1
j FROM: COMMISSIONER DICUS 1-
SUBJECT:
SECY-97-052 - COMMITTEE TO REVIEW GENERIC l REQUIREMENTS (CRGR) - SCOPE OF REVIEW AND i PERIO7IC REVIEW OF ACTIVITIES l
Approved x w/c - ent Disapproved Abstain Not Participating Request Discussion COMMENTS: See attached comments 1
Lhv 0 e ew Q U dIGNATURE .1 Release Vote / X_/
W nneh 22 /9 f?
DITE I i
Withhold Vote / / l Entered on "AS" Yes [ No
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9704220212 970418 PDR COMMS NRCC CORRESPONDENCE PDR
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, Cmr. Dicus Comments to SECY-97-052 i.
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- 1. I approve staff's recommendation with regard to extending the trial period related to 4
NMSS activities, for one additional year. !
- 2. I approve of the staff's recommendation to initiate a two-year trial program related to CRGR review of selected inspection guidance. ,
3.
f I approve of the staff's recommendation to use the proposed process for criteria for periodic reporting and evaluation of CRGR activities, subiect to the followina: -
1 l- It seems to me that the AEOD Annual Report will inevitably reflect that CRGR has
, povided berefit to the Agency in some qualitative manner. However, I don't think that '
- that type of evaluation will serve the Commission well. The rnetrics I believe the l Commission intended in its SRM on DSI-1g would allow the Commission to assess the benefits to the Agency (safety vs. resources and/or cost) of CRGR activity in a particular area, versus not having CRGR activity in that area.
! Staff should come back to the Commission with some definable criteria that considers j tabulated data compiled on an annual basis, such as:
J a) Of the number of documents reviewed by CRGR whose issuance was proposed-j by the staff, how many were returned to staff due to fundamental technical or !
! procedural flaws, or were flawed with respect to established policy.
- b) Of the documents that were reviewed by the CRGR, how many were returned to staff for enhancements, and what were the number of total staff hours expended 4
to address CRGR concerns as compared to the significance of the requested changes or improvements.
c) How many reviews required two or more iterations by staff before being " cleared" by CRGR. How many of the extra iterations resulted from concerns not expressed during the original CRGR meeting on the subject, or due to new viewpoints resulting from a change in CRGR membership since the original CRGR meeting on the subject. What were the number of total staff hours expended to address these additional concems as compared to the significance of the requested changes or improvements.
In my view, and contrary to the staff's assertion, the staff's submittal of a " framework for periodic reporting of CRGR activities, and evaluation of the Committee's contribution to the NRC regulatory mission ..."is not the same as, or consistent with " producing a set of criteria, for Commission consideration," as stated in the SRM to DSI-19.
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- Furthermore, whatever criteria are chosen, I do not believe it is appropriate for CRGR to l l formulate either the "value-addsd" evaluations that get reflected in the AEOD Annual l R1 port or determine the value it p rovides to the Agency, without first having received i and considered input from those program offices that have had issues before the CRGR I for review.
- 4. The SRM to SECY-96-032," Charter of the Committee to Review Generic Requirements (CRGR)-(Proposed Revision 6)" dated March 22,1996, states in part, that
" Exemptions from regulations should not be favored." l
- As a result of the Commission issuing its SRM to SECY-96-249 regarding exemptions, 3 dated January 29,1997, the above statement in the SRM to SECY-96-032 should be j superseded by the positions stated in SRM to SECY-96-249.
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