ML19284B052
| ML19284B052 | |
| Person / Time | |
|---|---|
| Issue date: | 09/10/1980 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19284B050 | List: |
| References | |
| FOIA-80-533, REF-SSINS-6020 NUDOCS 8011070118 | |
| Download: ML19284B052 (2) | |
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, bU Septenter 10, 1080 o
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- B6" OFFICE OF THE DTh'c 0-sECaETrav O T-@um/
~q,R t1EMORANDUM FOR:
William J. Dirc
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W Ph' FROM:
amuel J. Chilk creta 3,@ \\
SUBJECT:
STAFF REQUIREMENTS - DISCUS ON & VOTE ON NFORCEMEt POLICY (See SECY-80-139A), 10.
A.M., THURSDAY, SEPTEMBER 4, 1980, COMMISSIONERS
FR P r M,
D. C. OFFICE (OPEN TO PUBLIC ATTENDANCE)
The Comisskon* discussed the staff's proposed General Statement of Enforcement Policy, and the proposal that the proposed policy be used as interim guidance until the final statement of policy is approved.
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The Cormission requested:
1.
that the language on page 9 concerning failure to make required reports be broadened in order to answer concerns on failure to report events and on material false statements; 2.
that the first paragraph on page 16 be changed to indicate the need for prior Comission approval for all civil penalties above the amounts specified; 3.
that the policy clarify the severity level assigned to failure to m'ake required Part 21 reports; 4.
that the parenthetical statement be removed from the first full paragraph on page 11. The last sentence of that paragraph should be rephrased to indicate the concern the NRC places on operator involvement in violations; 5.
that the policy address the concern about increasing, a:, well as decreasing the base civil penalties shown in Table 2; 6.
that the policy clarify that willfulness is a basis for increasing civil penalties; 7.
that the policy specify the basis for application of " good faith" in mitigating civil penalties; 8.
that provision be made for licensee responses to bulletins to be submitted under oath or affirmation; 9.
that sub:ect to the changes listed in items 1-8, the policy statement be issued ar, a staff proposal for a 90 day public cocinent period.
(IE,) (SECY Suspense: 9/19/80)
- Comissioner Hendrie was not in attendance.
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I The Comission:
10.
requested that the staff examine the various means of ccmunicating with licensees. This examination will address:
a) the formality of NRC ccmunications with licensees; and b) possibilities for consolidating the various methods used by NRC offices to communicate with licensees.
(MPA/IE/NRR/NMSS) (SECY Suspense: 10/31/80)
- 11. by a vote of 3-0 approved the publication of the policy statement, as revised above, for issuance by the Comission;
- 12. by a vote of 2-1 (Chairman Ahearne dissenting), adopted the proposed policy statement as interim guidance to the staff.
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