ML20214H796
| ML20214H796 | |
| Person / Time | |
|---|---|
| Issue date: | 05/20/1987 |
| From: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| To: | Starostecki R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8705270500 | |
| Download: ML20214H796 (1) | |
Text
D=3 MAY 2 01987 MEMORANDUM FOR:
R. Starostecki, Assistant Director for Inspection and Technical Assessment Nuclear Reactor Regulation FROM:
James Lieberman, Director Office of Enforcement
SUBJECT:
TRACKING OF LICENSEE-IDENTIFIED VIOLATIONS The memorandum from J. G. Partlow, IE to each of the five Deputy Regional Administrators dated June 4, 1986 discussed the need to include in inspection reports a description of violations that were not cited on the basis of the criteria in the Enforcement Policy for not issuing a Notice of Violation.
These violations satisfied specific criteria, which included licensee identi-fication, Severity Level IV or V, appropriate and timely corrective actions, and not a violation which could have been expected to have been prevented by corrective actions for a previous violation.
We have become aware that various methods are used by the regions to track those types of licensee-identified violations. Some regions use an open items tracking system and others are merely documenting the violations in the inspection report. Our concern is that without a quick reference method to retrieve these types of violations it is difficult to assure that repeti-tive violations are properly evaluated.
In addition, with the Commission approval of the use of enforcement discretion (SECY-86-332) for violations at plants after major events or during forced shutdown, there is an increased need to be able to track these significant licensee-identified violations for SALP and lessons learned purposes. The Comission specifically cautioned that care needs to be taken to ensure that documentation is adequately reviewed and conveyed for lessons learned to those that can benefit.
We recommend that instructions be provided to the regions to assure that licensee-identified violations, which fit the criteria in the Enforcement Policy ' r SECY-86-332 and are not cited in a Notice of Violation, are o
properly tracked and accounted for.
The goal should be to be able to identify quickly licensee-identified violations at plants in order to evaluate significant and/or repetitive violations.
OriginalSicredby James Lieberman James Lieberman, Director Office of Enforcement cc:
J. Taylor, DEDR0 J. Snierek, NRR J. Partlow, NRR DISTRIBUTION:
J. Goldberg, OGC D
HWong JL'i.berman 5/fg /87 5/n%/87 16 8705270500 870520 PDR MISC 0705270500 PDR