ML20196G328
| ML20196G328 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/1999 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20196G313 | List: |
| References | |
| SECY-99-100-C, NUDOCS 9907010127 | |
| Download: ML20196G328 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET
< TO: Annette Vietti-Cook, Secretary FROM: CHAIRMAN JACKSON
SUBJECT:
SECY-99-iOO - FRAMEWORK FOR RISK-INFORMED REGULATION IN THE OFFICE OF NUCLEAR MATERIAL.
SAFETY AND SAFEGUARDS '
w/ comment Approved x Disapproved Abstain
! Not Participating
- l COMMENTS:
SEE ATTACHED COMMENT l
l .
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l l b.~J S l 51GNATURE fnM7 DATE Entered on "AS" Yes x No 3 W Co ss 72 n**
CORRESPONDENCE PDR
@@b/0/3 7 <3P9 i
CHAIRMAN JACKSON'S COMMENTS ON SECY-99-100 The staff approach and framework for risk-informed regulation in NMSS has been well thought out as an overall structure, although the details of estab'is' sing and implementing specific risk-informed approaches are left to future implementation steps. The NMSS framework has been patterned after the reactor framework, while appropriately recognizing the need for different safety goals and risk-management strategies in the two programs. I approve of the staff proposed framework, including the joint ACRS/ACNW subcommittee to provide technical peer review. The staff has indicated that an unbudgeted 6 FTE would be reprogrammed from other, as yet, unidentified NMSS efforts in FY 2000. The Planning, Budgeting and Performance Management (PBPM) Process should be used for any reprogramming actions. However, if l high-priority activities will be impacted by the FTE reprogramming, I agree with Commissioner l Merrifield's request for staff to inform the Commission.
As staff proceeds with this effort, the staff should develop a material safety goal, analogous to the NRC reactor safety goal, to guide NRC and to define what " safety" means for the materials program. The staff should develop this goal through an enhanced participatory process including broad stakeholder participation. The staff also should consider whether critical groups j can be defined for classes of material use, consistent with recent Commission decisions in the License Termination Rule (Part 20) and the proposed rule on high-level waste disposal at Yucca l Mountain (Part 63) Defining these critical groups v/ !! be essential in estimating total detriment (or l collective risk) to the population. I would expect that full development and implementation of a material safety goal will have broad ramifications on the use and regulation of radioactive materials by providing a yardstick for measuring the effectiveness of materials regulation in a consistent and defensible manner.
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