ML20147B193

Submits Reasons Why Escalated Enforcement Not Warranted. Severity Level IV Enforcement Recommended

ML20147B193
Person / Time
Site:	Salem
Issue date:	02/03/1992
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Public Service Enterprise Group
Shared Package
ML20147B009	List: ML20147B004 ML20147B028 ML20147B068 ML20147B094 ML20147B102 ML20147B117 ML20147B137 ML20147B149 ML20147B160 ML20147B169 ML20147B187 ML20147B193 ML20147B205 ML20147B219 ML20147B238 ML20147B247 ML20147B256 ML20147B262 ML20147B267 ML20147B274 ML20147B282 ML20147B287 ML20147B340 ML20147B347 ML20147B354
References
FOIA-96-351 NUDOCS 9701300059
Download: ML20147B193 (2)

Text

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FEB 0 31992 i

l MEMORANDUM FOR: Salem AIT Enforcement Panel Caucus i

1 FROM: A. Randolph Blough, Chief Projects Branch No. 2 l

I'm sorry I wasn't able to attend the enforcement conference. Despite my absence today, I l have spent over 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> on the AIT and associated issues, so I hope you'll consider my views. For the following reasons, I do not believe ewalated enforcement is warranted:

(1) The AIT identified over a dozen significant contributory causes for the Salem 2 event.

Most contributing causes are not traceable to current regulatory requirements but are l

nonetheless important to safety. Escalated enforcement will focus intense attention on only one or two of the contributing causes, distorting the perspective provided by the AIT itself.

(2) From a nuclear safety standpoint the event and underlying problems are Severity, Level IV, even though the event had high visibility and severe financial consequences to the utility.

(3) The utility has been extraordinarily introspective, and cooperative with NRC, in evaluating this event. We send the wrong feedback to utility management by pursuing escalated enforcement when it is clearly within our discretion to do otherwise.

(4) Since the enforceable issues are basically RO and SRO performance issues, the ROISRO community will view NRC as being tough on operator performance issues but weak on management issues.

(5) Escalated enforcement will give the public an overinflated view of the nuclear safety signincance of this event. Because of NRC requirements imposed during licensing and 10CFR 50 APP R upgrading, as well as licensee fire protection measures beyond regulatory requirements, the event was not safety significant.

I recommend instead, routine Severity Level IV enforcement, forwarded by a letter that appropriately relates our concerns about the violations, expresses our disappointment about all the contributing factors that led to the event, and recognizes the licensee's thorough event evaluation.

I think the Salem AIT findings warrant aggressive regulatory action, but enforcement is the wrong tool for this case. Our action should focus on ensuring:

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9701300059 970124 PDR FOIA O'NEILL96-351 PDR

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~2 (1) comprehensive licensee action for all contributing causes; (2) aggressive pursuit of potential generic issues, and (3) thoughtful assessment of regulatory issues and identification of potential NRC l regulatory improvements.

=-$ 11 A. Randolph Blokgh, Chief Projects Branch No. 2 l

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