ML20207C276
| ML20207C276 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/1999 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20207C256 | List: |
| References | |
| SECY-99-063-C, SECY-99-63-C, NUDOCS 9906020238 | |
| Download: ML20207C276 (2) | |
Text
.
N OT ATIO N VOTE RESPONSE SHEET l
TO:
Annette Vietti-Cook Secretary of the Commission 1
FROM:
COMMISSIONER DICUS
SUBJECT:
SECY-99-063 - THE USE BY INDUSTRY OF VOLUNTARY INITIATIVES IN THE REGULATORY PROCESS Approved X
Disapproved Abstain Not Participating Request Discussion COMMENTS:
See attached comments Me ot ca.o SIG%9E l
Y l$/9?i DATE
- Entered on "AS" Yes No 9906020238 990527 PDR COMMS NRCC l
CORRESPONDENCE PDR 4
\\()90% opyg u
Cmr. Dicus' Comments on SECY-99-063 The staff should move forward with the development of the process to use industry voluntary initiatives in the regulatory process as outlined.
I agree that voluntary industry initiatives should not be used in lieu of a regulatory action where a question of adequate protection of public health and safety exists. I agree industry initiatives i
may be used an appropriate substitute for NRC regulatory action where the regulatory action to be taken is needed to meet existing requirements, for cases where a suiastantial increase in overall protection can be achieved with costs of implementation justifying the increased protection, and to address industry concems, with or without regulatory concem. I agree that the process should not preclude the use of risk-informed, performance-based approaches.
I have the following specific comments. For industry initiatives initiated to address an industry
)
concem, the staff should receive a commitment if the issue is also of regulatory concem. The i
staff should determine to what extent the process will apply to non-power reactors, decommissioning reactors, and materials and other licensees. The process should ensure that 1
clear lines of responsibility, deliverables and schedules are identified for each industry initiative, I
and include the detailed issues as outlined in SECY-97-303. The staff should ensure a process i
exists for enforcement of commitments to industry initiatives that are implemented in lieu of regulatory requirements.
I