ML20211F231
| ML20211F231 | |
| Person / Time | |
|---|---|
| Issue date: | 08/05/1999 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20211F207 | List: |
| References | |
| SECY-99-178-C, NUDOCS 9908300277 | |
| Download: ML20211F231 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary FROM:
COMMISSIONER MCGAFFIGAN
SUBJECT:
SECY-99-178 - TREATMENT OF VOLUNTARY INITIATIVES IN REGULATORY ANALYSES Approved I Disapproved Abstain Not Participating COMMENTS:
See attached comments.
hr SIGN TURE V" (Ju J, I'f M DATE U
Entered on"AS" Yes Y No E M S 8 M s M882' CORRESPONDENCE PDR 41b$300 l
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p; CGT,w'- ' -,eM4;seri's CGT,m,e,de on SECY-99-178 1
I approve the staff's plans to require a best estimate calculation of costs and benefits which gives measured credit to voluntary industry initiatives. This is a long overdue change, the necosehy for which became apparent during the Commission's consideration of the revised proposed shutdown rule (SECY-97-168). As I noted in my vote on that paper, "to the extent the
~ approved regulatory analysis methodology forces the agency to ignore reality by, for example, precluding reliance on, or credit for, voluntary actions, the methodology disserves the staff and the Commission."
The new methodology which the staff proposes will result, when necessary, in a "best or more realistic estimate of the costs and benefits of the regulation under consideration, and a full range of results that capture the uncertainty inherent in the baseline condition." This will make transparent, and subject to debate in the rulemaking process, the staff's judgment on credit to be given to voluntary practicos.
I join in Commissioner Merrifield's admonition to the staff regarding the discussion on page 3 of
' SECY-99-178 involving the potential for industry ' backsliding" as a result of deregulation and economic competition. This diammaion may well reveal a reluctance on the staff's part to fairty enusit voluntary industry initiatives.
I concur in the comments by Commissioner Diaz regarding the development of interim guidance for determining the appropriate " measured credit" for industry voluntary programs. It is my understanding that the staff has begun work on a revision to NUREG/BR-0058 and that it can be finalized within a reasonable period of time.
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