ML20195H328
| ML20195H328 | |
| Person / Time | |
|---|---|
| Issue date: | 05/25/1999 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Vietticook A NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20195H255 | List: |
| References | |
| REF-10CFR9.7 SECY-99-087-C, SECY-99-87-C, NUDOCS 9906160328 | |
| Download: ML20195H328 (2) | |
Text
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NOTATION VOTE RESPONSE SHEET TO:
Annette Vietti-Cook, Secretary l
FROM:
COMMISSIONER MCGAFFIGAN
SUBJECT:
SECY-99-087 - PROPOSED STRATEGY TO REVISE THE ENFORCEMENT POLICY TO ADDRESS THE PROCESS FOR ASSESSING SIGNIFICANCE AND ASSIGNING SEVERITY LEVELS OF NONCOMPLIANCES (INCLUDING l
REGULATORY SIGNIFICANCE AND RISK)
- m$
- T.}
Approved Y
Disapproved 4 Abstain l
Not Participating i
COMMENTS:
See attached comments.
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DATE I
Entered on "AS" Yes No __
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Commissioner McGaffigan's Comments on SECY-99-087 i
l I approve in part, and disapprove in part, the staff's recommendations in SECY-99-087.
1.
I approve Recommendation 1.
2.
I approve Recommendation 2. I have long had concerns with the term
" regulatory signJicance."
- 3. -
I approve Recommendation 3, except the use of aggregation under the potential safety consequences criterion.
4.
I approve Recommendation 4, except for the aggregation of less significant violations into one of higher significance and the use of repetitive violations to increase the severity of a given violation. I concur with my fellow Commissioners that these matters can be handled by the current assessment process and, in the future, in the new assessment process for reactor licensees. I concur in Commissioner Dicus' comment with regard to materials licensees. Finally, I concur in Commissioner Diaz's comment that the staff should approach the Commission in any instance where there appears to be an extraordinary situation. Such an approach is' consistent with the discretion language within the
' Enforcement Policy, as well as the fact that the document is a statement of NRC policy and not an NRC regulat!on.
5.
I approve Recommendation 5, consistent with my positioi. on Recommendation 4.
6.
l ~ disapprove Recommendation 6, consistent with my position on Recommendation 4.
7.
I approve Recommendation 7.
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