ML20203D495
| ML20203D495 | |
| Person / Time | |
|---|---|
| Issue date: | 07/24/1998 |
| From: | Diaz N NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20203D425 | List: |
| References | |
| SECY-98-132-C, NUDOCS 9902160225 | |
| Download: ML20203D495 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
COMMISSIONER DIAZ
SUBJECT:
SECY-98-132 - PLANS TO INCREASE PERFORMANCE-BASED APPROACHES IN REGULATORY ACTIVITIES (WITS
- 9700093) x Approved Xg, Disapproved Abstain Not Participating Request Discussion COMMENTS:
See attached comments.
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SIGNATU$t4
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Release Vote / x /
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DATE Withhold Vote /
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X Entered on "AS" Yes No
- gaiggggg gggu CORRESPONDENCE PDR INIkk$
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COMMISSIONER DI AZ' COMMENTS ON SECY-98-132 The proposed plan to increase performance-based approaches in regulatory activities as described in SECY-98-132 is the staff's first attempt to respond to a portion of the SRM for SECY-96-218.
i have come to the conclusion that we need to have better understanding of performance-based regulation and the proposed plan needs to be improved before it is ready for implementation.
Therefore, I disapptove the proposed plan in SECY-98-132. liowever, I encourage the staff to enhance this plan by incorporating experience from existing performance-based regulatory activities (e.g., Maintenance Rule, Appendix J to Part 50) and comments from the Commission and the ACRS, as well as from DSI-13 meeting participants.
I believe that our understanding of and our maturity in applying performance-based regulation need to be further developed. This could be accomplished by participating in pilot projects for performance-based regulation. I applaud the staff's plan to solicit stakeholder input in DSI-13 meetings. The identification of candidates for performance-based regulatory activities should be the responsibility of staff members in all program offices instead of relying largely on RES and AEOD staff as suggested in the paper. I also believe that the proposed plan could be enhanced by providing more guidelines for staff to identify candidate regulatory activities and by simplifying the screening and reviewing process for selecting performance-based regulatory activities.
Ilecause the performance-based regulation lacks the experience and maturity of the risk-informed regulatory applications, I do not support modification of Management Directive 6.3 at this time to require evaluation of performance-based ~ alternatives for all new rulemaking plans and regulatory analyses.
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