ML20084B223
| ML20084B223 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/18/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| 2NRC-4-043, 2NRC-4-43, NUDOCS 8404260117 | |
| Download: ML20084B223 (2) | |
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2NRC-4-043 (412) 787 - 5141 Telecopy Nuclear Construction Division April 18, 1984 Robinson Plaza, Building 2 Suite 210 Pittsburgh, PA 15205 Secretary of the Commission United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Docketing and Service Branch
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Comments on General S t at eme nt of Policy and Procedure for Enforcement Actions Gentlemen:
In Federal Register Vol 49, No. 47 dated March 8,1984, the Commis-s ion provided its revised General Statement of Policy and provided fo r comment s on these revisions.
The Commission is part icularly interes ted in comments on the issue of " material false s t at eme nt s."
S peci fic ally, the Commission asks:
(1) Has the Commission's emphasis on material false statement s had a positive ef fect on the quality of communications with the NRC or has it had a chilling ef fect on such communications?
(2) Should the definition of material false statement be changed to apply only to written statements, submitted under oath?
(3) Should " materiality" be contingent upon the safety significance of the underlying information?
(4) Should " materiality" be de pe nde nt upon actually influencing an agency reviewer as opposed to having the capability of influ-encing a reasonable agency reviewer?
BV-2's comments are as follows:
(1) The overall quality of communications with the NRC has improved as a result of the Commis sion's pos it ion on mate ri al false statement. The recent emphasis on material false s t atement has cont rib ut ed to more tho rough inves t iga t ions fo r res pons es to NRC concerns.
Howev e r, the recrnt em phas is might have a t endenc y to "ch il l" commun ic a t io ns since the pos sibility of misinterpretation always exists.
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United States Nuclear Regulatory Commission Sec retary of the Commis sion Page 2 (2) The definition of material false statement should be changed to apply only to written statements submit ted unde r oath.
In verbal res po ns e s, there exists a greater chance fo r mis int e r-or inac curac i es to be made both by the s pe ake r and pr et at ion the listener as compared to written responses.
(3) The safety significance of the information should be taken into account whe n material false s t at eme nt is cons ide red.
If a response to the NRC has no direct relation to the prot ect ion of the public he al t h and safety, it should not fall into the material false statement prac t ic e s.
(4) This question cannot be addressed adequately seeing as there is no criteria to de t ermine if the "ma t e ri ali ty" ac t ually influenced the reviewer.
DUQUESNE LIGHT COMPANY By E(/J. Woolever Vice President JS/wjs cc:
Mr. R. DeYoung, Director Of fice of Inspection and Enforcement (3)
NRC Document Control Desk Mr. G. Walton, NRC Resident Ins pe ct o r Mr. M. Lacitra, Project Manager