DeMinimis and BRC

[Robin_Siskel@notes.ymp.gov]

At the time BRC was being seriously debated, I was all for it.  What can be
more reasonable than specifying a level below which the risk is negligible
and therefor no additional efforts are needed to quantify, track, trend,
and expend resources on?  Initially I couldn't understand why the utility I
was working for failed to support regulatory implementation of BRC.  Not
only did they fail to support it, they were adamantly opposed to
instituting such regulations.  With a little digging, however, I discovered
that if BRC was implemented as proposed, it appeared that an unbelievable
amount of  documentation would be necessary to PROVE and technically
justify that items/areas met the requirements to be classified as below
regulatory concern.  It would actually cost the utility MORE to use BRC
than to continue under current requirements.  Never ceases to amaze me the
absurd situations we can get ourselves into.

(email:  Robin_Siskel@ymp.gov)
The above is strictly my own two cents.

Are them aliens giggling yet?