ML021610348
| ML021610348 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/2025 |
| From: | Camper L NRC/NMSS/DWMEP |
| To: | Dapas M NRC/NMSS/DWMEP |
| Shared Package | |
| ML0350390470 | List: |
| References | |
| Download: ML021610348 (1) | |
Text
NMSS Policy and Procedures Letter 1-76, Rev. 0 (Revised April 2002)
NMSS PROCEDURES FOR PROCESSING INSPECTION MANUAL CHAPTERS AND INSPECTION PROCEDURES PURPOSE This Policy and Procedures Letter (PP&L) establishes the NMSS procedure for processing new and revised inspection guidance for matters within Nuclear Material Safety and Safeguards (NMSS) purview. This PP&L also defines NMSSs relationship with NRR regarding the maintenance of the NRC Inspection Manual and pertains to all NMSS staff. This PP&L is intended to supplement the guidance found in NRC Inspection Manual Chapter 0040 (MC0040);
it is not intended to replace any instructions defined in MC 0040.
DEFINITIONS Point of Contact (POC). The POC is designated by the cognizant technical division having purview over the inspection activity governed by specific inspection guidance documents. They are responsible for working with the Rulemaking and Guidance Branch (RGB) Coordinator to ensure the timely periodic update and revision of inspection guidance as assigned by their management.
Document Issuing Form (DIF). The DIF is that form, issued by RGB, that submits the final revised document to NRR for incorporation into the NRC master inspection manual and eventual posting on the NRC web-site. In each case, the DIF will indicate the last date of review for the inspection guidance, even if no change was made to the document.
Inspection Manual Chapter (IMC). An IMC is a document containing written administrative or inspection program statements of policy. IMCs state the purpose, objectives (or policy),
definitions, responsibilities, authorities, and basic requirements for inspection programs.
Detailed instructional material may be put in an appendix. A manual chapter for an inspection program defines the program through a listing of inspection procedures, which is normally appended to the manual chapter.
Inspection Procedure (IP). IPs describe the activities to be performed by an inspector, including administrative requirements. IPs also identify the applicable program, state the objective of the inspection, list the inspection requirements, give inspection guidance, and estimate the resources needed.
Temporary Instruction (TI). A TI is a temporary inspection procedure focused on current safety issues or concerns. TIs are issued to supplement an inspection program and are generally in effect for 12 months, but not longer than 24 months. TIs are issued by a change notice and have the same force as an IP but are used for a once-only or initial inspection of a safety issue, or a one-time collection of information. If a TI will be in effect for more than 24 months, special justification is required. A TI is always issued by a change notice (not by memorandum). TI requirements are mandatory.
NMSS Policy and Procedures Letter 1-76, Rev. 0 (Revised April 2002)
Change Notice (CN). CNs list documents issued, revised, superseded, and deleted; indicate distribution; and give other information on the updating, maintenance, and new training requirements of the manual. Any special training required to perform an inspection procedure or TI is stated in the change notice in the Remarks section. The transmittal document that lists new, revised, and deleted manual documents, distributes the new and revised documents, and includes information on updating and maintaining the manual.
Technical Guidance. In implementing an inspection program, an NRC regional office may have a technical question that requires more guidance than is given by, or referenced in, an inspection procedure. If the requested guidance has nation-wide applicability, it is the responsibility of whoever issues the guidance to ensure that it is included in the manual.
Technical guidance documents are in Part 9900 of the NRC Inspection Manual. Technical guidance documents directly applicable to licensee activities covered by inspection program procedures are incorporated into the procedures during their next revision or periodic review.
The organizational unit responsible for the manual document is responsible for updating the inspection procedures.
RESPONSIBILITIES AND AUTHORITIES Rulemaking and Guidance Branch, Division of Industrial and Medical Nuclear Safety, NMSS (RGB)
Lead NMSS organization for processing all inspection-related guidance for NMSS. Coordinates with NRRs Division of Program Implementation and Management. RGB will designate a RGB Coordinator for each inspection guidance item.
RGB Coordinator Responsible for day-to-day management of processing new and revised NMSS inspection guidance. Coordinates with lead technical Division POC and Regional Branch Chiefs and assigned staff. Provides regions with advance notice, to the extent practicable, of anticipated reviews required. Directly initiates 3-year review process. Prepares and processes DIFs through RGB management.
Coordinates with NRR. Maintains the Inspection Procedure database in ACCESS. Keeps RGB management informed of status.
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NMSS Policy and Procedures Letter 1-76, Rev. 0 (Revised April 2002)
Inspection Program Branch, Division of Inspection Program Management, NRR (IPB)
Responsible for overall maintenance of NRCs Inspection Manual for reactor and materials programs.
Regions Provide expert staff review of inspection guidance document changes as requested. Coordinates with RGB Coordinator and cognizant RGB Section Chief.
Technical Divisions of NMSS (DWM, FCSS, IMNS, SFPO)
Responsible for working through RGB to ensure that licensing and inspection guidance governing licensees under their purview is technically accurate and complete. Also responsible for reviewing existing inspection guidance every three years to determine whether the guidance document needs to be updated or revised and working with RGB to maintain current and accurate inspection guidance. The technical division having oversight responsibility for the inspection activity of interest will designate a Point of Contact (POC) for each inspection guidance document under their purview.
PROCEDURE General Staff creating new or revising existing inspection-related documents will follow the guidance of Inspection Manual Chapter 0040, "Preparing, Revising, and Issuing Documents for the NRC Inspection Manual." The Rulemaking and Guidance Branch (RGB) of the Division of Industrial and Medical Nuclear Safety, NMSS will coordinate the review and revision of all inspection-related documents under NMSS purview. An RGB staff member will be designated as coordinator for specific reviews and revisions.
The RGB Coordinator will be responsible for initiating and coordinating the review of new and revised inspection-related documents by or for the responsible technical division, coordinating the issuance of requests for comment to organizations other than the responsible technical division, and working with the responsible technical division as needed or requested to resolve these comments.
The RGB Coordinator will also prepare the Document Issuing Form for all NMSS inspection guidance. IMCs and IPs under NMSS purview will be reviewed at least every three years and revised if necessary.
Staff reviewing and commenting on new or proposed revisions to NMSS inspection guidance should communicate using the most efficient means available. E-mail and faxes are acceptable. Staff may use conference calls as necessary to discuss significant issues, however, decisions made during these conference calls, as well as Page 3 of 6
NMSS Policy and Procedures Letter 1-76, Rev. 0 (Revised April 2002) conference call participants should be documented. Such documentation may be done via e-mail or conference call notes which are provided or kept by the RGB Coordinator.
Region and Division management may designate any individual as the person authorized to comment or concur on a specific inspection guidance document on behalf of the affected Region or Division. RGB will treat the comments and concurrence of this individual as that for the Region or Division which they represent.
Review Process 1.
If staff identify the need for new inspection guidance, such as a Manual Chapter or new inspection procedures, the affected technical division will inform RGB of this need and designate the technical point of contact (POC) who will author this new guidance. RGB, in cooperation with the affected Technical Division shall determine a tentative schedule for issuance of this new inspection guidance. The procedure for issuing new inspection guidance documents shall follow, in general, the steps outlined below.
2.
At least six months before the need for review of specific inspection guidance (2.5 years from the last revision date), the assigned RGB Coordinator will request, via e-mail, that the lead NMSS technical division identify a point of contact (POC) and initiate review.
3.
Initial procedures for developing revised or new inspection guidance are:
A.
For existing inspection guidance: Within 10 working days, the lead NMSS division will designate a POC for the inspection guidance. The POC will review the inspection guidance to determine whether an in-depth review is necessary.
Once he/she has determined the review scope, the POC and RGB Coordinator will agree on a schedule for completion of the POCs proposed revision. The POC will inform the RGB Coordinator of any needed schedule changes. The POCs Branch Chief, or his/her designee, will approve the transmission of the draft document to RGB.
The POC will determine whether the inspection guidance of interest needs revision. There are two revision categories for existing inspection guidance:
1.
No revision needed. If the existing inspection guidance is still accurate and complete, the POC will inform the RGB coordinator that no revisions were identified. The RGB coordinator will then e-mail a request for regional concurrence to the Regional Branch Chiefs (with a copy to Regional Division Directors, the POC and the POCs supervisor).
2.
Revision needed. The POC identifies a need for revision. The POC will develop revised inspection guidance. The POC will send an electronic Page 4 of 6
NMSS Policy and Procedures Letter 1-76, Rev. 0 (Revised April 2002) redline/strikeout version (incorporating the formatting requirements of MC0040-05 through -08) to the RGB Coordinator in accordance with a schedule agreed on between the POC and the RGB Coordinator. The RGB Coordinator will then forward the revised inspection guidance in redline/strikeout form to the Regional Branch Chiefs and other interested HQ Divisions for comment via e-mail. The RGB Coordinator will copy the Regional Division Directors, the RGB Branch Chief, the cognizant RGB Section Chief, and the POC.
B.
For cases involving new inspection guidance: The POC will work with the Regions and other affected divisions and offices to draft new inspection guidance. Once the draft new inspection guidance has been reviewed by the affected Technical Branch Chief, he/she shall transmit the draft inspection guidance to the Chief RGB, for formal processing.
4.
There may be occasions when Technical Division work priorities are such that RGB assistance is needed in order to effectively accomplish program activities. Should that occur, Technical Division Directors may request that the RGB Coordinator assist the POC with the review and comment phase of this process. This applies to both existing and new inspection guidance. Those needing RGB assistance should notify the RGB Coordinator of this need as soon as possible for RGB resource planning purposes.
5.
The RGB Coordinator normally will request Regions, and other cognizant or affected divisions as necessary, to provide their comments on the new or revised inspection guidance to both the POC and RGB Coordinator within 30 days. Should an organization not provide comments within 30 days, RGB will assume that tacit concurrence has been given, unless specifically informed that comments are forthcoming.
6.
Reviewing organizations must provide their comments to the clearly identified POC and the RGB Coordinator by e-mail or fax. This is done to ensure that RGB can effectively track all the comments. Receiving organizations have discretion to determine the appropriate level of review required; however, unless otherwise notified, comments submitted will be assumed to represent the views of the reviewing organization.
7.
If necessary, the POC may hold a conference call with the Regions to resolve any comments or recommendations.
8.
Once the POC has resolved all comments, he/she will transmit an updated redline/strikeout of the inspection guidance document, along with a summary of comments received and a description of how they were resolved to the RGB Coordinator. Whenever possible, repeated review of the same document should be minimized; as such, if receiving organization comments do not conflict and are non-controversial, another review by reviewing organizations is not necessary. However, if the POC believes that additional Regional review is necessary, due to competing comments received or policy issues introduced, he/she will consult with the RGB Page 5 of 6
NMSS Policy and Procedures Letter 1-76, Rev. 0 (Revised April 2002)
Coordinator who will formally request review of the final document by the affected organizations.
9.
The affected Division Director, or his/her designee, will either concur on the final document or designate an appropriate individual to concur for them. Reviewing organizations are offered discretion to determine the appropriate review level for inspection documents needing a second review. Normally, the more complex or policy-related the revision, the higher the level of review. Concurrences may be provided by e-mail.
10.
Once all concurrences are obtained, the RGB Coordinator will compile a concurrence package containing a completed Document Issuing Form (DIF), the latest redline/strikeout version, and the comment resolution summary. This package will be forwarded to the cognizant RGB Section Chief and RGB Branch Chief for review and signature before forwarding to NRR.
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