ML20199M071
| ML20199M071 | |
| Person / Time | |
|---|---|
| Issue date: | 11/19/1998 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20199M059 | List: |
| References | |
| SECY-98-256-C, NUDOCS 9901280243 | |
| Download: ML20199M071 (2) | |
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NOTATION VOTE RESPONSE SHEET TO:
John C. Hoyle, Secretary FROM:
CHAIRMAN JACKSON
SUBJECT:
SECY-98-256 - PROPOSED REVISION TO THE ENFORCEMENT POLICY TO ADDRESS SEVERITY LEVEL IV VIOLATIONS AT POWER REACTORS Approved xx Disapproved Abstain Not Participating COMMENTS:
See attached comments.
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Shir ey Ann Jackson l
SIGNATURE November 19, 1998 DATE Entered on "AS" Yes XX No l
9901290243 990122 PDR COtm8 NRCC CORRESPONDENCE PDR Q90/?$0'?
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l Chairman Jackson's Comments on SECY 98-256:
l approve of the staff recommendations in SECY 98-256, but I believe it is important that ne view these Enforcement Policy changes from a broad perspective (i.e., in terms of our overall enforcement goals), and that NRC management takes the utmost care in how these changes are communicated to the NRC staff and to licensees at the working level.
l The staff proposals, as presented here, describe viable methods of improving process efficiency while continuing to meet our objectives. However, our recent experience with the issuance of Enforcement Guidance Memorandum (EGM) 98-006 indicates that NRC management must be careful to manage the imolied messaae as well as the written guidance. EGM 98-006 attempted to make reasonable changes within existing policy to increase efficiency while retaining the essential NRC capability of tracking and assessing licensee performance (an integral objective of non-escalated enforcement). According to NRC management, EGM 98-006 was n_ot an attempt to de-emphasize the importance of compliance with NRC requirements, nor was it I
intended to be a message to NRC ir,spectors to eliminate the use of SL IV violations. Feedback l
from the field, however, indicates that, at least in some quarters, the latter, unintended message
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was received.
l This experience leads to the following point of caution, regarding the current proposals for change in SECY 98-256. While the proposals in themselves are reasonable and should produce a positive result, NRC management must be careful to manaae the messaoe of these changes. The NRC staff should that a basic objective of non-escalated enforcement-that is, to i
monitor SL IV violations as one way of tracking and understanding licensee performance trends-remains unchanged. In fact, by reducing the administrative burden on NRC and licensee staff, and by increasing the emphasis on credible, healthy licensee corrective action programs, these changes should improve, rather than reduce, our capabilities in this area.
l Additional comments on Commissioner Diaz' vote:
l t agree with the first three of Commissioner Diaz' proposed actions. Removing ambiguity in our non-escalated enforcement processes is consistent with our overall objectives in this area; therefore, providing additional definition to the terms "within a reasonable time" and " repetitive violation" will be useful to all parties concemed. These clarifications should be made in a way l
that is commensurate with the increased NRC emphasis on licensee corrective action programs.
In addition, the request for a report to the Commission, in 6 months, will help to ensure a proper results-oriented focus in implementing these changes.
Regarding Commissioner Diaz' fourth recommendation, I have no objection to having the staff re-evaluate this area as part of the 6-month report. However, as currently understood, the inspection report descriptions of SL IV violations (together with corresponding PIM entries) are of significant benefit in the NRC assessment process. In other words, they help to ensure that the NRC is able to track and understand licensee performance trends. Any staff re-evaluation of this area should ensure that this objective is understood, and this capability preserved.
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