ML20042F524
| ML20042F524 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1990 |
| From: | Remick NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9005090026 | |
| Download: ML20042F524 (2) | |
Text
-__
/
l A F F I R M A T 1 0 N S D_I E...............,
RELEASED TO THE PDR' RESPONSE SHE 3 S7V/4o qt- :
cath i
............. nitia t T0:
SAMUEL J. CHILK, SECRETARY OF THE COMISSION i
FRON:
C0MISSIONER REMICK
SUBJECT:
SECY-90-094 - PUBLIC COMENTS RECEIVED CONCERNING THE ENFORCEMENT POLICY REVISION INVOLVING MAINTENANCE-RELATED ROOT CAUSE A
g,/c0W APPROVED DISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION COMENTS:
l i
I E
(/f/4IGNATURE RELEASE VOTE
/M /
.7/).7/72)
DATE WITHHOLD VOTE
/
/
ENTERED ON "AS" YES NO
[fA
{
SO 6 900323 i
90-094 PDC
j' l
,. ?.
- i Comments on BECY-90-094 I approve the Staff's recommendation'that the Enforcement Policy civil penalty escalation factor for maintenance-related root cause be deleted. As I stated in my comments related to SECY '325, REVISED POLICY STATEMENT AND ENFORCEMENT CRITERIA RELATED TO THE MAINTENANCE OF NUCLEAR POWER PLANTS, I continue to have serious reservations regarding.the ability of the' staff to corelusively determine that maintenance, and not training or human error for example, is a root cause of a regulatory violation in actual enforcement application. Even if a licensee has implemented a maintenance program consistent with the scope.
and activities defined by the revised Policy Statement on the Maintenance.of Nuclear Power Plants, components and equipment may fall. The extent to which the cause is maintenance programs j
related or training or human error related may not be clear.
j In addition, special treatment of maintenance violations in this way could draw licensee's attention and resources away from other operational areas which might have equal or even greater safety importance relative to maintenance.
1
+
9 5
w-ev 4
9 P
v~~
7
_.