ML20236U393

Comments Supporting Rev to 10CFR2 Re Statement of Policy on Enforcement.Urges Commission to Expeditiously Issue Revised Policy on Matl False Statements

ML20236U393
Person / Time
Site:	Yankee Rowe
Issue date:	11/25/1987
From:	Denise Edwards YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-52FR36215, RULE-PR-2 52FR36215-00009, 52FR36215-9, FYC-87-025, FYC-87-25, GLA-87-175, NUDOCS 8712030003
Download: ML20236U393 (1)

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Attention: Docketdr.g and Servic'e Bha.1ch / i t t ,

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Subject:

RevisN't Enforcement Policy $htemer.t (52FR36215)

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Dear Sir:

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Yankee Atomic Electr/.c Company aN reciates the oppor'tunity to reply to the subject NRC revised da;ement of , policy on enforcement, bsukee Atomic

( Electric Company Mar, and operates a nuclear power plant in Rova, Massachusetts. Our Nuclear Services Division also provides engineering and licensing services for other nuclear power plants in the Northeast, including n* Vermont Yankee, & ine Yankee, and Seabrook.

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. s i We endorse the changes made to the Enforcement Policy of 10CFR, Part 2.

We note that iteportant recommendations made to the Commission by the independent Ad Hoc Adv.W ry Committee for review of the Enforcement Policy have been incorporatedgin t~t.a revised policy statemnht. We are pleased to see changes, such as allowadce,'or 100% mitigation of a ?everity Level I violation and provision for expanded'rtiseretion by NRC in 'Assuing ' violations and/or civil penalties. Such provisions allow overt recostition and encouragement of good performance by licensee 1.

s s It its, report to the Commission, the Ad Hoc Advisory Committee also 1

emphssized that the tdaterial falce statement issue concerns the regulated community more than any other aspect of the Enforcement Policy. We agree with the Committee's concluhion and have similarly stated our views in previous comment letters. We believe that the Commisrion has recognized the need to eliminate such concerns, and, as a result, proposed appropriate changes to the material false statement policy in March of this year. However, the absence yet,to date of a final revised policy has contributed nothing to achieving the cesults intended by such a revision - namely, to limit use of the term

" material false statement" to egregious enforcement actions. We urge the Commission to expeditiously issue the revised policy on material false statements. Such'en action is essential to maintaining an efficient and unimpeded flow of information between the NRC and licensees.

8712000003 871125 S PDR PR Very truly yours.

V-29 52FR36215 PDR J)S / O

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Md/ w w ,",' GCM.m2 d Donald W. Edwards Director of Industry Affairs I