ML23151A374
| ML23151A374 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/1984 |
| From: | NRC/SECY |
| To: | |
| References | |
| PR-002, 49FR08583 | |
| Download: ML23151A374 (1) | |
Text
DOCUMENT DATE:
TITLE:
CASE
REFERENCE:
KEYWORD:
ADAMS Template: SECY-067 03/08/1984 PR-002 - 49FR08583 - REVISED GENERAL STATEMENT OF POLICY AND PROCEDURE FOR ENFORCEMENT ACTIONS PR-002 49FR08583 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete
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C HERNE SINCE 19 16 CHERNE CONTRACTING CORPORATION POST OFFICE BOX 975 MINNEAPOLIS, MINNESOTA 55440;~\\f, December 31, 1985 Secretary of the Commission uff,,,"~-)* G.:i"st"i<0\\c; U.S. Nuclear Regulatory CommissionDOCKLl~R~~CH Washington, DC 20555 Attention:
Docketing and Service Bran~h TELEPHONE 612-944-265 0 TWX 910 - 576 -2 788
Reference:
Proposed revisions to enforcement policy (49 FR 8583) as stated by Vol. 50, No. 224 o-f;~:the Federal Register.
+'"".
Gentlemen:
The proposed changes to the enforcement policy as stated does not recognize the relationship and responsibilities between contracting parties to resolve and correct deficiencies.
Interpretation of contractual requirements including corrective action to correct deficiencies is initially the respon-sibility of the contracting parties. This relationship has, and continues to, provide for the early detection and effective correction of deficiencies.
I recommend that the NRC change their enforcement policy to recognize this important relationship by emphasizing the following:
- 1.
Require all NRC inspections of a vendor to be performed in the presence of a licensee who has contracted with the vendor.
- 2.
Require all inspection findings to be directed to the licensee who has contracted with the vendor for resolution and response.
I believe that an Inspection and Enforcement policy based on the foregoing items will ensure the efficient and effective correction of deficiencies and minimize the confusion and regulatory burden to the non-NRC licensed vendors.
If I may be of further assistance please contact me.
Sincerely, CHERNE CONT~RPORATION
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QA Manager GAR :mj cc: / QAC~41
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COR PORATE OF"F"ICE-9855 78TH STR EET - MINNEAPOLIS, MINNESOTA 55344
U.S. NUCLEAR DOC'<ETI ;~GUIATOPY cOMMtSS o*rirE ) ~ SE.. Vl(e SFCTlON :JON
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