ML20151V774
| ML20151V774 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1998 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20151V707 | List: |
| References | |
| SECY-98-089-C, SECY-98-89-C, NUDOCS 9809150073 | |
| Download: ML20151V774 (3) | |
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NOTATION VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER MCGAFFIGAN
SUBJECT:
SECY-98-089 - PUBLIC COMMUNICATIONS INITIATIVE (DSI-14)
Approved X Disapproved X Abstain Not Participating Request Discussion COMMENTS:
See attached comments.
(w-SIGNATURE FU (,
Release Vote / x /
\\x l'1,
M8 DATy V
Withhold Vote /
/
Entered on "AS" Yes x No
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u CORRESPONDENCE PDR ftW 9/5 Ad 73
9 Commissioner McGaffigan's Comments on SECY-98-89 l generally agree with the Executive Council's recommendations. I have two fundamental reasons for not wanting to undertake the larger program proposed by the Communications Coordinating Committee. One reason has to do with budget, and the other with the nature of what is needed to improve our communications.
As to the budget, from the beginning of our review of our public communications, I have
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argued that we should pursue improvements that can be had within the confines of our j
shrinking budget. The agency currently devotes significant resources to more than meeting, and usually far exceeding, the legal requirements for communicating with both citizens and regulated parties (compare the FAA's relative closedness (see Matthew Wald's March 16, 1997, article in the New York Times]). With large licensing backlogs, long review times, and declining dollars and FTE, we cannot spend even more on communications, or take steps that would slow our decisions down even more. It is obvious that in a deregulated environment, timely decisions will be even more important than in the past, and a failure to make a timely decision on a given issue will mean that that issue will be settled by the agency's defaulting on its responsibility to decide what is required for public health and safety, it is perhaps less obvious that, whether the power market is deregulated or not, our slowness can harm many parties. For example, just recently the Energy Facility Siting Councilin the Oregon Office of Energy wrote Chairman Jackson describing the safety and dollar consequences of the NRC's not making more timely decisions about the decommissioning of the Trojan Nuclear Plant (see the June 15,1998, letter from Patrick Edvalson to the Chairman). Similar concerns were raised at a July 10 public meeting on Maine Yankee's appeal under the backfit rule. Indeed, it is a consistent theme on many of our licensing actions. Credibility is not solely a function of listening to all comers. It is also a function of timely, technically sound, stable, and consistent decisions.
As to the nature of what is needed to improve our communications, I agree with Commissioner Diaz that we can make progress without a new and elaborate program.
Indeed, more elaborate programs do not necessarily succeed. DOE's is more elaborate than ours, but a consistent theme throughout the Department's work on extemal regulation of its nuclear facilities is that its self-regulation of those facilities has little credibility with the public.
I continue to think as I did a year ago when we were discussing DSI-14 that the Office of Public Affairs is one of the most important resources we have for improving our public communications on significant issues, but there are good writers and communicators elsewhere in the agency too, and they should be sought out, and their example studied. I continue to beeve that we must be able to tell citizens clearly what risks our licensees pose to them, how safe their facilities are, and how those risks might be judged (I wish the CCC's report had had more to say about risk communication).
One of the most important resources for improving our reception of citizens' communications to us is a door open to serious consideration of all views. Public meetings in which extraordinarily patient NRC staff too often have to suffer through uncivil behavior will not take us very far. We need more meetings that require preparation, focus, and responsiveness on j
the part of all participants. UCS wrote the Commission recently (June 16,1998) to express i
its appreciation for the Commission's having given it a ' fair opportunity to present (its] view
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l regarding the restart of Millstone Unit 3.' The letter spells out the elements of a " fair l
opportunityF The Commission considers all views, it does not simply passively endure the
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i presentations but asks questions based on its reading of the public's submissions in order to understand the issues raised by the public; and it considers the public's views in reaching its decision.
We can expect challenges to our views no matter how good a communications program we have, but better writing, more serious discussion with critics, and more timely decisions can make our decisions more informed and our various audiences more confident that we are rational and responsible.
In two areas, I would not make the changes proposed by the EC, to the extent I understand them. I question whether Management Directive 6.3 needs to be revised, as recommended in ll.A.1 and ll.D.3. Rulemaking plans already adequately deal with public involvement, l
including enhanced public involvement where appropriate. My fundamental concem with the rulemaking process is its slowness. To the extent this revision would require the staff to dot even more i's and cross even more t's than the current process requires, it strikes me as overkill. I am also skeptical about the annual stakeholders' meetings proposed in ll.D.4. It is not clear to me what such meetings would accomplish beyond the meetings we already have, and I am reluctant to sign off on something about whose organization and funding we are so uncertain.
One last concem: According to the SECY paper, the Deputy EDO for Regulatory Effectiveness will next coordinate development of a more specific implementation plan, to be provided in six months. I would urge that the staff not overdo the development of this plan.
At a time of budget instability, the plan will need to be short and flexible enough to accommodate changes. Otherwise, it may be overtaken by events soon after it is submitted.
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._m p uouq'o UNITED STATES g
'8 NUCLEAR REGULATORY COMMISSION o
WASHING TON. D.C. 20555-0001 g
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Septemb r 10, 1998 s.
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v OFFICE OF THE SECRETARY MEMORANDUM TO:
L. Joscph Callan Executive Director for Operations Wdlia'm M. Beecher Dire r,
ce f Public Affairs f
D FROM:
Jo o' le, ecretary
SUBJECT:
S AFF REQdREMENTS - SECY-98-089 - PUBLIC COMMUNICATIONS INITIATIVE (DSI-14)
The Commission has approved expansion of the role of the Deputy EDO fcr Regulatory Effectiveness to include public communications ana interaction and approved the Executive Council's recommendations, with two exceptions: The Commission would not revise Management Directive 6.3 as recommended in ll.A.1 and ll.D.3 of the Council's recommendations, and would not hold annual stakeholders' meetings as proposed in ll.D.4. In developing a more specific implementation plan, in coordination with OPA, the staff should keep it short and flexible enough to accommodate changes. It should include general principles for effective communications with the public which are simple, such as being able to tell citizens what risks licMsees pose to them, how safe the facilities are, and how those risks might be judged, and a series of milestones which can be easily implemented.
(EDO/OPA)
(SECY Suspense:
2/19/98) cc:
Chairman Jackson Commissioner Diaz Commissioner McGaffigan
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