ML19332A773
| ML19332A773 | |
| Person / Time | |
|---|---|
| Issue date: | 03/28/1980 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19332A770 | List: |
| References | |
| REF-10CFR9.7 SECY-80-139A, NUDOCS 8009180284 | |
| Download: ML19332A773 (1) | |
Text
.+#
'o, UNITED STATES Dornell m
i )3'"
NUCLEAR REGULATORY COMMISSION Rehm
$I E W ASHIN GTON. D.C.20555 Minogue y, 4 nm%f!
Shapar
' '+2 M/
March 28,11980 Denton l
Haller OFFI:';E OF THE NM35 SECRETAM Moseley MEMORANDUM FOR:
William J. Dircks,. Acting Arndt FROM:
Samuel J. Chilk, Secretad
}
s STAFFREQUIREMENTS-DISCpSLI )N OF SECY-80-139 - NRC
SUBJECT:
ENFORCEMENT PROGRAM, '2:05 P.b., WEDNESDAY, MARCH 19, 19BO,'C0".MISSIONERS' CONFERENCE ROOM, D. C. OFFICE The Comission discussed ~a proposed revised NRC enforcement policy, but reached no final conclusions. It was agreed that detailed individual Comissioner comments would be provided directly to the staff and that a further Commission meeting on this subject would be necessaryf Tha Comis. don also requested that the ED0' insure the following:
1 clarification.regarding the circumstances under which technical discretion. in_ applying the enforcement policy, referenced in the footnote on phge 4 of the General Statement of Enforcement Authority.
ought to be utilized by the staff; and the factors on which such staff
~
judgments wil'1 be basec; 2.
infomation regarding the practice of other agencies with respect
.to imposition of civil, penalties on the individual licensed operator as well as the corporate licensee; 3.
information o'n the practice of ot'her agencies in distinguishing
~
certain' classes of licensees, such as non-profit organizations, from other licensees in the level of civil penalties imposed for similar infractions of regulations; 4.
further consideration of the following items:
the question of the proper role of criminal penalties in a.
the enforcement program; b.
the role of Bulletins,-licensee comitments and other informal documents in the enforcement program;,
c.
inclusion of violations of environmental requirements in the highest levels of the violation severity categories for j
civil penalties; d.
differentiation within the civil penalty structure cf willful or negligent violations; de-emphasizing the consequences of a violation as the e.
basis for detemining the extent of the civil penalty to be' imposed so that a licensee whose facility was not c.perating at the time a violation was comitted would not be penalized less than another licensee committing the.same violation during the time his facility is operating.
(SECY Suspense for all items: Two Weeks after receipt of Commissioner coments).
,0 m y0 D ~3'Y a
6 cc:
g Comissioners Comission Staff Offices AJ 6009180284