Summary of 980918 Meeting W/Nei,Ucs & Other Util Groups in Rockville,Md Re Continuation of Discussions on Proposed Changes to NRC Enforcement Program.List of Attendees EnclML20154H484 |
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NUDOCS 9810140208 |
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Category:MEETING MINUTES & NOTES--CORRESPONDENCE
MONTHYEARML20217E4831999-09-23023 September 1999 Summary of 990812 Meeting with DOE Re NRC Involvement with West Valley Demonstration Project.Attendance List,Encl ML20207J8501999-03-14014 March 1999 Summary of 990216 Meeting with NRC & Licensee Re Amend of Rev 10 of Nuclear Criticality Safety Chapter in License Application ML20207K3831998-12-31031 December 1998 Summary of 981218 PRB Meeting Re 2.206 Petition Request from P Gunter to W Travers,Nrc Requesting That NRC Convene Public Hearing to Consider Revocation of Nine Mile Point,Unit 1 Operating License ML20202D3521998-12-0909 December 1998 Summary of 981123 Petition Review Board Meeting Re 2.206 Petition on Perry Unit 1,submitted on 981109 by Ucs.Meeting Attendees Listed ML20154R4171998-10-20020 October 1998 Summary of 981013 Meeting with Nei,Ucs & Other Util Groups & Public in Rockville,Md to Continue Discussions on Proposed Changes to NRC Enforcement Program ML20154H4841998-10-0606 October 1998 Summary of 980918 Meeting W/Nei,Ucs & Other Util Groups in Rockville,Md Re Continuation of Discussions on Proposed Changes to NRC Enforcement Program.List of Attendees Encl ML20236Q2721998-06-0404 June 1998 Meeting Minutes Re NEI & Council of Radiopharmaceuticals, Inc to Discuss Process Being Used to Revise 10CFR35, Medical Use of Byproduct Matl ML20238F1551998-05-0505 May 1998 Summary of 980429 Conference Call Between NRC & EPA Re Shipment of LLW from Pesses to Waste Control Specialist,Inc in Tx IA-98-204, Summary of 980429 Conference Call Between NRC & EPA Re Shipment of LLW from Pesses to Waste Control Specialist,Inc in Tx1998-05-0505 May 1998 Summary of 980429 Conference Call Between NRC & EPA Re Shipment of LLW from Pesses to Waste Control Specialist,Inc in Tx ML20199J2971998-01-22022 January 1998 Trip Rept of 980113-15 Visit to Western Pennsylvania to Tour General Licensees Facilities to Gain Understanding of Licensees in NRC Jurisdiction ML20199L8561997-10-23023 October 1997 Summary of 971023 Meeting W/Nuclear Energy Inst & EPRI Re Identification of Certain Code Required Insp Activities That Might Be of Questionable Value for Purpose of Containment Insp ML20211P4991997-10-0909 October 1997 Summary of 970917 Meeting W/Vynp in Rockville,Maryland Re ASME Code Case N560.List of Meeting Attendees,Meeting Agenda & Meeting Handouts Encl ML20216B4111997-09-0505 September 1997 Summary of 970903 Meeting W/Nei Re safety-conscious Work Environ.Attendance List Encl ML20138M6391997-02-21021 February 1997 Summary of 970220 Telcon Between J Winters,D Lindgren & G Isrealson of Westinghouse & C Li & D Jackson of NRC to Discuss Unresolved Open Items Related to Ssar Chapter 11 Detailed in 970131 NRC Ltr ML20136G8051997-02-13013 February 1997 Summary of 970213 Meeting on Docket 70003089,w/USEC in Rockville,Md Re Part 76 Rulemaking Status,Internal Guidance/ Procedures,Status of Privatization,Tsr Transition,Compliance Plan & Certificate Amend Requests Status ML20134J3821997-01-17017 January 1997 Summary of Senior Mgt Meeting on 970114-15 & 17 in Region IV to Discuss Plants of Greatest Concern to Agency & to Plan Coordinated Course of Action ML20136A8611996-11-27027 November 1996 Partially Withheld Summary Meeting W/Florida Power & Light Held on 961121 Re General Update on FPL Nuclear Plants ML20248F7041996-04-24024 April 1996 Summary of 960409 Meeting W/P Blanch Re Forthcoming Policy Statement on Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML20132A4731995-12-19019 December 1995 Partially Deleted Summary of Chairman Jackson 951109 Meeting W/Yy Hsu at NRC Re Matters of Mutual Interest ML20217P0111995-02-22022 February 1995 Summary of 950222 Meeting with Doe,Umetco,State of Colorado, Congressman Mcinnis & Town of Naturita in Rockville, Maryland Re Disposal of Tailings from Naturita,Colorado U Mill Tailings Radiation Control Act 1978 Title I Site ML20058G3781993-11-18018 November 1993 Summary of 931108 Meeting W/Numarc & Interested Parties Re Facilitating Dialog Between Industry & NRC on App J Rulemaking.List of Attendees,Proposed Schedule & Requested Testing Data Encl ML20056G4611993-08-24024 August 1993 Trip Rept of 930821 Visit to Portsmouth Gaseous Diffusion Plant(Gdp) Re Observation of GDP Emergency Exercise ML20058J5171990-08-23023 August 1990 Summary of Meeting of Working Group 10 on Erosion/Corrosion Destruction of Piping & Components ML20058J4041990-06-29029 June 1990 Summary of Meeting for Working Group 6 on Severe Accidents ML20058J3601990-06-29029 June 1990 Summary of Meeting for Working Group 3 on Radiation Embrittlement of Housing & Support Structures & Annealing of Housing ML20058J3261990-06-29029 June 1990 Summary of 900625-0706 Meeting of Working Groups of US-USSR Joint Coordinating Committee on Civilian Nuclear Reactor Safety ML20058J3871990-06-29029 June 1990 Summary of Meeting for Working Group 4 on Fire Protection/ Prevention ML20127J2961990-04-0606 April 1990 Trip Rept of Commissioner Curtiss 900201 Site Visit.Facility Has Undergone Radical Change in Mgt Personnel & Experiencing Problems W/High Attrition of Licensed Operators ML20246B6901989-08-0101 August 1989 Summary of 890727 Meeting W/Util in Arlington,Tx Re Plant Security Enhancement Program & Personnel Changes ML20247A3961989-07-11011 July 1989 Summary of 890512 Meeting W/Util Re Operational Reliability of Several Components & Items Procured & Installed in Plant & Various Vendor Interface Weaknesses Identified During Insp 50-302/89-200.Handouts Encl ML20247K1011989-05-16016 May 1989 Summary of 890517 Meeting W/Inpo in Bethesda,Md Re Similarities & Differences Between INPO & NRC Performance Indicators IA-89-202, Agenda for 890412 Meeting W/Veterans Admin in Washington,Dc to Discuss Program Improvements.Related Info Encl1989-04-12012 April 1989 Agenda for 890412 Meeting W/Veterans Admin in Washington,Dc to Discuss Program Improvements.Related Info Encl ML20247D1371989-04-12012 April 1989 Agenda for 890412 Meeting W/Veterans Admin in Washington,Dc to Discuss Program Improvements.Related Info Encl ML20236E2301989-02-22022 February 1989 Summary of 890222 Meeting W/Nuclear Industry Representatives in Rockville,Md Re Effects of Revs to 10CFR20 on Nuclear Fuel Fabrication Facilities ML20155F7271988-09-0808 September 1988 Summary of 870903 Meeting in EPA Ofcs Re Results of DOE Request to Clarify Interagency Issues to Implementation of CERCLA Requirements for Cleaning Up Radwaste Sites IA-88-311, Agenda of Epa/Nrc Interface Council 880503 Meeting in Washington,Dc & Lists of Lead NRC Technical & Mgt Contacts & EPA Members1988-07-14014 July 1988 Agenda of Epa/Nrc Interface Council 880503 Meeting in Washington,Dc & Lists of Lead NRC Technical & Mgt Contacts & EPA Members ML20151D8611988-07-14014 July 1988 Agenda of Epa/Nrc Interface Council 880503 Meeting in Washington,Dc & Lists of Lead NRC Technical & Mgt Contacts & EPA Members ML20150C1951988-06-29029 June 1988 Summary of 880613 Meeting W/Numarc Re Status of NUMARC Activities & Organization Re Primary Interface W/Nrc on Generic Operational & Technical Regulation Issues ML20195H8131988-05-27027 May 1988 Summary of 880526 Meeting W/Doe in Rockville,Md Re Alternate Concentration Limits at Umtrap Sites ML20154G9541988-04-18018 April 1988 Summary of 880414 Meeting W/Hsbii Representatives to Discuss Upcoming NRC Enforcement Conference on I&H ML20149L4981988-02-12012 February 1988 Summary of 871207 Meeting W/Utils in Bethesda,Md Re Licensees Revised Proposal to Comply W/Nrc Requirement for Simulation Facilities Under 10CFR55.45(b).List of Attendees & Util Simulation Facility Group Guideline Encl ML20148G1051988-01-21021 January 1988 Summary of 870923 Meeting W/Embassy of South Africa, Political Counsellor Re Status of South African Nuclear Exports & Overall Nuclear Cooperation Between Us & South Africa.Status of Pending Export Applications Also Reviewed IA-88-478, Trip Rept of Commissioner Carr & T Elsasser 871215 Site Visit to Util & 871216 Attendance at Region I Periodic Regional Resident Counterpart Meeting1988-01-0505 January 1988 Trip Rept of Commissioner Carr & T Elsasser 871215 Site Visit to Util & 871216 Attendance at Region I Periodic Regional Resident Counterpart Meeting ML20196A2161988-01-0505 January 1988 Trip Rept of Commissioner Carr & T Elsasser 871215 Site Visit to Util & 871216 Attendance at Region I Periodic Regional Resident Counterpart Meeting ML20154K2281987-12-0808 December 1987 Summary of 871208 Meeting Re Joint Umtra/Aml Plans for Cleanup of Title I Site at Spook,Wy ML20236T4991987-10-0707 October 1987 Summary of 871007 Meeting W/Doe in Silver Spring,Md Re Aquifer Restoration Costs at Selected U Mills.Agenda Encl ML20237J6231987-08-24024 August 1987 Revised Agenda for 870826 Meeting W/B&W Owners Group in Bethesda,Md to Discuss Thermal Hydraulic Testing for B&W Plants ML20237L0661987-07-0303 July 1987 Summary of 870618-19 Meeting W/Sandia,Bnl & Ukaea in Bethesda,Md Re Energy Transfer to Containment Atmosphere, Given That Core Melt from Severe Accident Breached Vessel ML20197H0391987-06-30030 June 1987 Summary of 870624 Meeting W/Utils in San Francisco,Ca Re Commission Activities Associated W/Licensing of High Level Waste Repository & Naruc Summer Meeting ML20154K3071987-06-0808 June 1987 Trip Rept of Chairman 870527-29 Visit to Canada Re Meeting W/Officials of Atomic Energy Control Board of Canada & Briefing by Ontario Hydro Mgt Concerning Organization of Ontario Hydro & Design of Canada Deuterium U Reactor Sys 1999-09-23
[Table view]Some use of "" in your query was not closed by a matching "". Category:MEETING SUMMARIES-INTERNAL (NON-TRANSCRIPT)
MONTHYEARML20217E4831999-09-23023 September 1999 Summary of 990812 Meeting with DOE Re NRC Involvement with West Valley Demonstration Project.Attendance List,Encl ML20207J8501999-03-14014 March 1999 Summary of 990216 Meeting with NRC & Licensee Re Amend of Rev 10 of Nuclear Criticality Safety Chapter in License Application ML20207K3831998-12-31031 December 1998 Summary of 981218 PRB Meeting Re 2.206 Petition Request from P Gunter to W Travers,Nrc Requesting That NRC Convene Public Hearing to Consider Revocation of Nine Mile Point,Unit 1 Operating License ML20202D3521998-12-0909 December 1998 Summary of 981123 Petition Review Board Meeting Re 2.206 Petition on Perry Unit 1,submitted on 981109 by Ucs.Meeting Attendees Listed ML20154R4171998-10-20020 October 1998 Summary of 981013 Meeting with Nei,Ucs & Other Util Groups & Public in Rockville,Md to Continue Discussions on Proposed Changes to NRC Enforcement Program ML20154H4841998-10-0606 October 1998 Summary of 980918 Meeting W/Nei,Ucs & Other Util Groups in Rockville,Md Re Continuation of Discussions on Proposed Changes to NRC Enforcement Program.List of Attendees Encl ML20236Q2721998-06-0404 June 1998 Meeting Minutes Re NEI & Council of Radiopharmaceuticals, Inc to Discuss Process Being Used to Revise 10CFR35, Medical Use of Byproduct Matl ML20238F1551998-05-0505 May 1998 Summary of 980429 Conference Call Between NRC & EPA Re Shipment of LLW from Pesses to Waste Control Specialist,Inc in Tx IA-98-204, Summary of 980429 Conference Call Between NRC & EPA Re Shipment of LLW from Pesses to Waste Control Specialist,Inc in Tx1998-05-0505 May 1998 Summary of 980429 Conference Call Between NRC & EPA Re Shipment of LLW from Pesses to Waste Control Specialist,Inc in Tx ML20199L8561997-10-23023 October 1997 Summary of 971023 Meeting W/Nuclear Energy Inst & EPRI Re Identification of Certain Code Required Insp Activities That Might Be of Questionable Value for Purpose of Containment Insp ML20211P4991997-10-0909 October 1997 Summary of 970917 Meeting W/Vynp in Rockville,Maryland Re ASME Code Case N560.List of Meeting Attendees,Meeting Agenda & Meeting Handouts Encl ML20216B4111997-09-0505 September 1997 Summary of 970903 Meeting W/Nei Re safety-conscious Work Environ.Attendance List Encl ML20138M6391997-02-21021 February 1997 Summary of 970220 Telcon Between J Winters,D Lindgren & G Isrealson of Westinghouse & C Li & D Jackson of NRC to Discuss Unresolved Open Items Related to Ssar Chapter 11 Detailed in 970131 NRC Ltr ML20136G8051997-02-13013 February 1997 Summary of 970213 Meeting on Docket 70003089,w/USEC in Rockville,Md Re Part 76 Rulemaking Status,Internal Guidance/ Procedures,Status of Privatization,Tsr Transition,Compliance Plan & Certificate Amend Requests Status ML20134J3821997-01-17017 January 1997 Summary of Senior Mgt Meeting on 970114-15 & 17 in Region IV to Discuss Plants of Greatest Concern to Agency & to Plan Coordinated Course of Action ML20136A8611996-11-27027 November 1996 Partially Withheld Summary Meeting W/Florida Power & Light Held on 961121 Re General Update on FPL Nuclear Plants ML20248F7041996-04-24024 April 1996 Summary of 960409 Meeting W/P Blanch Re Forthcoming Policy Statement on Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML20132A4731995-12-19019 December 1995 Partially Deleted Summary of Chairman Jackson 951109 Meeting W/Yy Hsu at NRC Re Matters of Mutual Interest ML20217P0111995-02-22022 February 1995 Summary of 950222 Meeting with Doe,Umetco,State of Colorado, Congressman Mcinnis & Town of Naturita in Rockville, Maryland Re Disposal of Tailings from Naturita,Colorado U Mill Tailings Radiation Control Act 1978 Title I Site ML20058G3781993-11-18018 November 1993 Summary of 931108 Meeting W/Numarc & Interested Parties Re Facilitating Dialog Between Industry & NRC on App J Rulemaking.List of Attendees,Proposed Schedule & Requested Testing Data Encl ML20058J5171990-08-23023 August 1990 Summary of Meeting of Working Group 10 on Erosion/Corrosion Destruction of Piping & Components ML20058J3261990-06-29029 June 1990 Summary of 900625-0706 Meeting of Working Groups of US-USSR Joint Coordinating Committee on Civilian Nuclear Reactor Safety ML20058J3601990-06-29029 June 1990 Summary of Meeting for Working Group 3 on Radiation Embrittlement of Housing & Support Structures & Annealing of Housing ML20058J3871990-06-29029 June 1990 Summary of Meeting for Working Group 4 on Fire Protection/ Prevention ML20058J4041990-06-29029 June 1990 Summary of Meeting for Working Group 6 on Severe Accidents ML20246B6901989-08-0101 August 1989 Summary of 890727 Meeting W/Util in Arlington,Tx Re Plant Security Enhancement Program & Personnel Changes ML20247A3961989-07-11011 July 1989 Summary of 890512 Meeting W/Util Re Operational Reliability of Several Components & Items Procured & Installed in Plant & Various Vendor Interface Weaknesses Identified During Insp 50-302/89-200.Handouts Encl ML20247K1011989-05-16016 May 1989 Summary of 890517 Meeting W/Inpo in Bethesda,Md Re Similarities & Differences Between INPO & NRC Performance Indicators ML20236E2301989-02-22022 February 1989 Summary of 890222 Meeting W/Nuclear Industry Representatives in Rockville,Md Re Effects of Revs to 10CFR20 on Nuclear Fuel Fabrication Facilities ML20155F7271988-09-0808 September 1988 Summary of 870903 Meeting in EPA Ofcs Re Results of DOE Request to Clarify Interagency Issues to Implementation of CERCLA Requirements for Cleaning Up Radwaste Sites ML20150C1951988-06-29029 June 1988 Summary of 880613 Meeting W/Numarc Re Status of NUMARC Activities & Organization Re Primary Interface W/Nrc on Generic Operational & Technical Regulation Issues ML20195H8131988-05-27027 May 1988 Summary of 880526 Meeting W/Doe in Rockville,Md Re Alternate Concentration Limits at Umtrap Sites ML20154G9541988-04-18018 April 1988 Summary of 880414 Meeting W/Hsbii Representatives to Discuss Upcoming NRC Enforcement Conference on I&H ML20149L4981988-02-12012 February 1988 Summary of 871207 Meeting W/Utils in Bethesda,Md Re Licensees Revised Proposal to Comply W/Nrc Requirement for Simulation Facilities Under 10CFR55.45(b).List of Attendees & Util Simulation Facility Group Guideline Encl ML20148G1051988-01-21021 January 1988 Summary of 870923 Meeting W/Embassy of South Africa, Political Counsellor Re Status of South African Nuclear Exports & Overall Nuclear Cooperation Between Us & South Africa.Status of Pending Export Applications Also Reviewed ML20154K2281987-12-0808 December 1987 Summary of 871208 Meeting Re Joint Umtra/Aml Plans for Cleanup of Title I Site at Spook,Wy ML20236T4991987-10-0707 October 1987 Summary of 871007 Meeting W/Doe in Silver Spring,Md Re Aquifer Restoration Costs at Selected U Mills.Agenda Encl ML20237L0661987-07-0303 July 1987 Summary of 870618-19 Meeting W/Sandia,Bnl & Ukaea in Bethesda,Md Re Energy Transfer to Containment Atmosphere, Given That Core Melt from Severe Accident Breached Vessel ML20197H0391987-06-30030 June 1987 Summary of 870624 Meeting W/Utils in San Francisco,Ca Re Commission Activities Associated W/Licensing of High Level Waste Repository & Naruc Summer Meeting ML20215F9291987-02-13013 February 1987 Summary of Meeting W/Nasa on 870212 Re Use of Standing Panels of National Research Council ML20207Q2461987-01-0909 January 1987 Summary of 870108 Meeting W/R Dahl of Central Valley Water Reclamation Facility & DOE Re U Mill Tailings Remedial Action Site in Salt Lake City,Ut.Meeting Scheduled in Albuquerque,Nm on 870114 to Discuss DOE Certification ML20147E9341986-12-0505 December 1986 Partially Withheld Summary of Investigation Referral Board Meeting 1 on 861202 Re Decision or Recommendation on Referrals ML20211K7631986-11-26026 November 1986 Summary of 861126 Meeting Between Chairman Zech & WO Doub of Southern States Energy Board Re Board Initiatives Concerning Tva.Viewgraphs Encl ML20215G6351986-09-25025 September 1986 Handwritten Summary of 860925 Meeting W/Util Re Engineering Expertise on Shift.Viewgraphs Encl ML20206U4651986-07-0707 July 1986 Summary of Telcon Interview W/Allegers Re Technical Review Team Disposition of Allegations AC-22 & AC-23 Concerning Category 2 of Civil/Structure Sser ML20202D2421986-07-0202 July 1986 Summary of 860610 Meeting W/Util in Bethesda,Md Re Licensee Analyses on Performance of Structural Steel Supports for Cable Trays (Electrays) in Unit 1 Mechanical Pipe Chase & Unit 2 Auxiliary Feedwater Pump Room After Fire ML20211D0351986-06-0202 June 1986 Summary of 860403 Meeting W/Util & State of Nj in Bethesda,Md Re 850924 Request to Cancel Replacement of Large Containment Purge & Vent Valves.Attendees List & Supporting Documentation Encl ML20206E7301986-03-0505 March 1986 Summary of 860305 Meeting W/Inpo Re Coordination of Policy Development in Fitness for Duty Approaches ML20141K0141986-01-0202 January 1986 Summary of 851111 Meeting W/F Webster (J Benjamin & Assoc) in Mountain View,Ca Re Statistical Sampling Approaches in App D of Applicant Program ML20137V1181985-11-25025 November 1985 Summary of 851112-13 Meetings W/Util at Plant Site Re Status of SEP Evaluations & Observation of Mods Made in Response to SEP Issues.Reviews in Progress on SEP Topics III-1,III-2, III-4.A,III-5.A,III-6,III-7.B & VI-4 1999-09-23
[Table view]Some use of "" in your query was not closed by a matching "". |
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Y PUBLIC MEETING
SUMMARY
On September 18,1998, members of the Nuclear Energy Institute (NEI), the Union of Concerned Scientists (UCS), and other utility groups and the public met with the Director, Office of Enforcement, and NRC staff in the NRC's Rockville office to continue discussions on proposed changes to the NRC's enforcement program. A previous public meeting on possible changes in the enforcement program was conducted on September 3,1998. The list of attendees from the September 18,1998 meeting is attached.
During the meeting, discussions continued on the appropriate level of detail to support Severity Level IV issues. Both NEl and UCS maintained that inspection report write-ups should be brief.
NEl proposed a simple " logging" approach. _ NRC took the position that a certain amount of detail was necessary because the inspection report serves as an input for the assessment process (Plant issues Matrix (PIM)).
NEl also made a presentation that addressed the (1) guiding principles for industry's enforcement proposal, and (2) industry's enforcement proposal. NEl's proposal proposed that escalated enforcement action would be based on actual consequences, potential consequences, and other defined categories, that as a matter of policy would be considered important. NEl indicated that they were still continuing to refine their proposal (especially the third factor for escalated enforcement, i.e., " defined categories"). NEl indicated that they would attempt to submit their recommendations later in October.
Meeting handouts distributed by NEl are attached.
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NEl ENFORCEMENT CHANGES SEPTEMBER 18,1998 NAME TITLE ORGANIZATION PHONE E-MAIL AltC C istArcK SATOIR I u s Assr De aama Fea P4% off af' CAF W- 2nr1 111 A S $ 9 o r .c.,ou '
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I. GUIDING PRINCIPLES FOR INDUSTRY ENFORCEMENT PROPOSAL !
A. Enforcement Should Be One Part Of An Integrated Oversight Process i l
l The purpose of the NRC's enforcement program should be to encourage remediation of
- individual discrepancies or non-compliances and to prevent their recurrence.
l It should not be used as a forum for wide ranging, subjective evaluations of plant or j management performance. The NRC's comprehensive performance assessment process is designed to more effectively provide an overall evaluation of safe plant performance.
l
, The enforcement program can rely on licensee corrective action programs for non-safety significant violations. The assessment process will evaluate the effectiveness of corrective action programs based upon the licensee's overall performance. If the licensee's
- performance is good (i.e., performance indicators are predominantly in the " Green Zone"),
l the corrective action program is presumed to be effective. And, even with some minor l l imperfections in the corrective action program, if there is no impact on performance l
indicators, such imperfections are not likely to be important from a safety perspective.
i l If the quantity and severity level of enforcement actions are determined to be data l l appropriately included in the comprehensive assessment process, it will be critical for the l NRC to refocus its enforcement process on objective, safety significant violations. Without l l a properly focused enforcement process, enforcement data fed into the assessment process I
- could be misleading. In addition, if enforcement data are included in the assessment I process, the assessment process should respond to that data in a manner proportionate l with their safety significance, i B. Enforcement Should Reflect The Move To Risk-Informed. Performance-l Based Regulation -
Both NRC and industry agree that enforcement action for each and every discrepancy or non-compliance-i.e., an enforcement approach based on a strict liability concept-will not i l advance safety. Such an approach is inefficient and diverts resources from more safety-significant matters. By rafocusing enforcement action on safety significant issues through a risk informed, performance based approach, additionallicensee and NRC inspection resources will be more effectively applied.
! There are several ways to incorporate a risk informed and performance. based approach into the enforcement process. One is to define the lowest level at which a violation has a realistic likelihood of affecting safety, e.g., below Severity Level III. As a matter of policy, l any violation with a safety significance below Severity LevelIII should not be processed through the enforcement process, but rather, the matter should be closed based on the licensee's internal actions to resolve it and to prevent recurrence -
! Another way to incorporate risk information into enforcement is to define severity levels
- based upon risk information. Individual enforcement actions should be considered for
^
. escalated treatment only for three well defined categories of violations: (1) those with 4
actual safety consequences; (2) those with only potential safety consequences, but where the potential is realistic and the consequences potentially severe based on objective, risk-7 _ .
. l
. informed criteria; and (3) certain defined violations of other requirements such as 10 1 1
C.F.R. 50.5,50.7, and 50.9 (with safety significance still used as a guide). '
O. Enforcement Policy Criteria Should Be Oblective And Easily Annlied Development of objective, easily applied criteria will assure consistency and predictability I
of enforcement action. Neither civil penalties nor escalation of enforcement should be
! based on " regulatory significance," " regulatory concern" or other undefined terms. '
)
i l Enforcement should not provide an opportunity for the NRC to micromanage acensee 1 l
corrective actions based upon subjective judgments of what action is sufficiently prompt and comprehensive. Choosing and implementing corrective actions should be within the l discretion of the licensee. The standard for sufficiency of corrective actions is one of l reasonableness at the time, given the safety significance of the violation involved.
t D. Imnact of Distinctions Between Licensee-Identified And NRC-Identified Violations Should be Limited The enforcement analysis should be reoriented away from who found the violation to ensuring that the licensee remediates the problem and takes action to prevent recurrence.
The revised Enforcement Policy should, however, permit NRC to use discretion to adjust downward, or not issue, a civil penalty if a licensee identifies violations, including during an extended shutdown or as a result of a voluntary initiative. .
E. Enforcement Should Not Be Used To Imnose New Reauirements Enforcement should be premised upon clear and consistently applied requirements.
Enforcement should not be used as a vehicle to drive new NRC positions or to supplant the requirements of the Administrative Procedure Act or of the backfit rule.
F. The Enforcement Process Should Allow Meaningful Checks And Balances The enforcement process should provide an opportunity for a meaningful review of factual, backfit, and legal positions.
2
. II l@USTRY ENFORCEMENT PROPOSAL A. Enforcement Process Would Annly e
The revised enforcement process shcald apply only to those violations that meet a defined level of safety significance-e.g., Severity Level categories I, II, and III as redefined. (See Tables A, B and C.)
Determination of a violation should be based upon clear requirements oflaw. Specific 1
matters that would not be considered violations would include (1) random equipment failures; (2) vague or ambiguous regulatory positions; (3) procedure step violations that are not linked to a specific requirement other than Criterion V or Tech Spec 6.8.1 (i.e.,
the step was not necessary to meet the regulatory requirement, or was added to provide a regulatory margin of safety or additional guidance); and (4) individualisolated random errors in a program that contains multiple barriers (i.e., a reasonable expectation of compliance should be applied to programs which establish multiple barriers).
Enforcement action would be considered for Severity Levels I, II or III regardless of
- performance assessment category.
A violation's severity level would be assigned based upon safety signi6cance as defined l
by actual consequences, potential consequences or other categories determined, as a ,
I matter of policy, to be important.
Table A focuses on an actual offsite release, or an onsite release or exposure.
Table B addresses issues with only the potential for consequences. Table B incorporates risk information through categories of high risk significant, risk significant and non risk significant systems, structures and components as defined by
' AEOD. Table B does notincorporate a quantitative risk value. The revised policy would permit the licensee, in the course of an information exchange on potential enforcement action, to provide the NRC with quantitative risk analyses (including consideration of reasonable operator actions) to more precisely quantify the actual plant specific incremental risk created by the event or circumstance. These plant specific risk insights would be used as part of the NRC's exercise of discretion to increase or decrease the severity level of a violation.
Table C addresses those categories determined, as a matter of policy, to be important.
They would be well defined and would include many of the examples covered in the current supplements (e.g., licensed personnel attentiveness,50.59 violations for failure to apply for required NRC approval and "de facto" 50.59 violations; willful / deliberate violations; violations of 50.7; violations of 50.9; violations of reporting requirements; violations of emergency planning requirements; violations of security requirements; and violations of fitness for duty requirements.)
7 The revised Enforcement Policy would permit NRC discretion to adjust or not issue civil
~
penalties under certain limited conditions: 1) licensee identification of a violation, including during an extended shutdown or as a result of a voluntary initiative; (2) 3
. . . . _. _ ~ . . . . - . - . . . ~ . . . . .-..~...-.~..- -.. .._- . . -. -.-. . ..
mitigating circumstances in 50.7 cases; and (3) the licensee has been enforcement free for two years and its performance is in the " green zone."
The NRC is to bear the " burden of proof' to demonstrate the basis for enforcement action. The NRC should describe clearly the basis of a violation, including the nexus to
. the regulation or other requirement violated, providing the basis for further .
deliberation and application of discretion.
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l- 4 l
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l
- l B. Enforcement Process Would Not Anulv l
l Current Severity Level IVs, NCVs, and minor violations would be characterized as non.
safety significant infractions (NSSIs).
1 l
- NSSIs would not be processed through the enforcement process. The lack of safety L significance of NSSIs provides an adequate basis for the agency to conclude, as a matter l of policy, that they should not be subjected to the enforcement process.
Once identified, NSSIs similar to those currently documented in an inspection report would be captured in, for example, an attachment to the inspection report.
Documentation in the attachment would be in the form of a list rather than a narrative description, e.g., " inspector log".
NSSIs would be closed out based on the licensee's action to enter them into its corrective action ("CA") program.
- The NRC's enforcement policy should reflect that the licensee's corrective action is not to be subjected to NRC evaluation for promptness and comprehensiveness in order to j close out a NSSI. The licensee is permitted to address NSSI corrective actions l according to its priority and schedule, as determined by the corrective action program.
- The NRC can obtain insight into the licensee's corrective action program through '
regular and other inspections and evaluation of performance assessment indicators.
Identified problems initially would be addressed by an increase in inspection scope.
- Should the NRC determine through the inspection or assessment process that the corrective action program is lacking in a significant way, greater NRC inspection or other regulatory tools could be applied. Should a more intensive inspection identify additional NSSIs or even repeated NSSIs, they would continue to be addressed through the corrective action program. If safety significant issues are identified, (SL I, II, III),
enforcement action would be considered.
l
. No enforcemant action would be taken even if NSSIs are repetitive. Repetitive instances of a non safety significant infraction do not necessarily represent a breakdown of the corrective action program. However, repetitive NSSIs and other indicators may prompt further inspections and/or action in the context of the performance assessment process.
- The current practice of aggregating Severity LevelIV violations to impose an increased severity level based upon " programmatic" issues would be discontinued. NSSIs would not be evaluated-at least in the enforcement context-for " regulatory concerns" or
" regulatory significance."
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l 5
.__m.. ..__.m . , _m_.m. . . - _ ._s.--. . . . - - . - . - -
- s PROPOSED ENFORCEMENT PROCESS
/
/ NOV N N j Actual 4N CP /
'N V /
, Consequences d TABLE A ,%N (Aqu.t) mort
. Asokjn M Severity Level l AquetCP
-> @m met)
\>
Enforcement Action ---
TABLEB considershon of quantitative "
^
risk date) ( - s 4 / NOV 'N f
No Other deined
/ No CP No Press
\ -
s l categories, e.g.. . NReisese '
50.5,50.7,50.9 V' safegtwds, FFD, mg Non Safety TABLE C C ---+ regulation other Yes---->
}
7 2 t
- l No Yes .
I E y .
Note:
I No Enforcement No OJ w. a Action ax into .
g .
Action k:ensee CAP
- Date reimted to event enay be included in essessment process U
ucensee enters t into CAP '
i i
C Table A l 1
ACTUAL CONSEQUENCES I Offsite Release I I.
I Onsite Releases or Exposures I/II/III (Criteria to be developed)
S 6
9 d
J
< ~..~. . . . . . . . . . . . _ . . . . - , _ _ . . _ _ , , _ , , , . , , _ , . _ . , ,
Table .B POTENTIAL CONSEQUENCES
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CONDITION HIGH RISK RISK NON RISK SIGNI'1 i CANT SIGNIFICANT SIGNIFICANT SSC SSC ,
SSC Both trains not functional II
One tr^in not functional m a III
. multi-train systen .
' System functional but not operable NSSI NSSI NSSI System degraded from design basis
, NSSI NSSI NSSI or licensing basis but functional -
NOTES:
- If a system is actually e- 11ed upon, raise one severity level.
f: If reasonable compensatory capability exists, or if compensatory action was taken, lower one severity level.
. . . . . . . _ . .. _ _ _