ML20196A714
| ML20196A714 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1999 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20196A689 | List: |
| References | |
| SECY-99-007-C, SECY-99-7-C, NUDOCS 9906220296 | |
| Download: ML20196A714 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary FROM:
COMMISSIONER DIAZ
SUBJECT:
SECY-99-007A - RECOMMENDATIONS FOR REACTOR OVERSIGHT PROCESS IMPROVEMENTS (FOLLOW-UP TO SECY-99-007)
Approved XX Disapproved Abstain i
Not Participating COMMENTS:
See attached comments.
j 1
SIMATURE" 3/3l /99 DATE Entered on "AS" Yes xx No 9906220296 990618 REh DENC PDR 99o6zzo29p
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COMMISSIONER D!AZ'S COMMENTS ON SECY-99-007A - RECOMMENDATIONS FOR REACTOR OVERSIGHT PROCESS IMPROVEMENTS (FOLLOW-UP TO SECY-99-007)
I continue to be impressed by the staffs aggressive, forthright, and self-ci tical effort to improve the NRC's regulation of nuclear power plants. The staff is clearly on the right path to make NRC oversight more transparent and focused on protecting public health and safety, while providing for due process and not imposing unnecessary burdens. It
-is also apparent that much remains to be done; in fact, as the programs have been refined, the " holes" that need to be filled have become more clearly defined. Rather than having misgivings over the work yet to be done, I am encouraged by the better definition of the scope of both the remaining effort and the policy decisions still to be made. This is a clear sign that we are nearing our goal.
In addition to my comments on SECY'-99-007, as the staff carries out the pilot program and develops and implements further refinements, we all should maintain a balanced perspective of the interplay between the technical, regulatory, and risk-informed bases for determining the significa 1ce of findings. Additionally:
o The staff should reformulate the success criteria of the pilot program to address the conflict between risk-informed methods and specific targets for reductions in inspection effort.
o From the points of view of some of our stakeholders, all activities that the NRC undertakes vis-a-vis its licensees. represent a form of enforcement of our regulations. However, in keeping with our agency's name, we view these activities as being regulatory, with Enforcement being a subset of regulation. To help provide for a common understanding of concepts and terminology as we change the way we do business, the staff should more clearly articulate the NRC's functions for regulating operating plants. Within the bounds of this regulatory function, the staff should specify the different, yet complementary, roles of Enforcement and the actions that are in the action matrix.
o in the next status report to the Commission, the staff should provide the results of its further research into criteria for evaluating findings associated with the containment barrier, fire protection, and shutdown operations.
o Finally, the process that is evolving appears to be sufficiently effective and robust to enable the NRC to fulfill its public health and safety mission. Therefore, in this light,' I do not believe that it is necessary to do further research into the determination of whether a combination of " green" items can represent a significant pattern.