ML20199M076
| ML20199M076 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1998 |
| From: | Dicus G NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20199M059 | List: |
| References | |
| SECY-98-256-C, NUDOCS 9901280245 | |
| Download: ML20199M076 (2) | |
Text
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NOT AT5ON VOTE 1
RESPONSE SHEET TO:
John C. Hoyle Secretary of the Commission FROM:
COMMISSIONER DICUS
SUBJECT:
SECY-98-256 - PROPOSED REVISION TO THE ENFORCEMENT POLICY TO ADDRESS SEVERITY LEVEL IV VIOLATIONS AT POWER REACTORS Approved X Disapprove-' _
Abstain Not Participating Request Discussion COMMENTS:
See attached.
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Commiscioner Dicus' Comments on SECY 98-256 I approve the proposed changes to the enforcement policy as proposed by the staff, subject to the following comment:
I agree with the Chairman's comment regarding the need for NRC management to take the utmost care in how these changes are communicated to the staH at the working level. However, it is equally, if not more important, to ensure that alllevels of NRC management that would ensure the enforcement policy changes are implemented consistently, fully understand and support the intent of the proposed policy changes.
I do not agree with the first two actions proposed by Commissioner Diaz. While I generally support the movement towards tightening the definition of terms that are loosely defined, I don't believe that is necessarily the appropriate thing to do in all cases. I also believe enforcement is one of those areas for which staff should be given some flexibility in determining what is considered to be "within a reasonable time" or "a repetitive violation." It is unlikely that one strict definition for either of these terms will fit all examples or situations. It is important that we provide staff with the necessary flexibility to effectively implement the enforcement policy.
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