ML19338E145
| ML19338E145 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/2019 |
| From: | Derstine T, Michael Layton NRC/NMSS/DMSST |
| To: | |
| A McMurtray, NRC/NNSS | |
| References | |
| Download: ML19338E145 (5) | |
Text
Joint NRC/Agreement State Phase Three Materials Inspection Program Working Group Charter PURPOSE To recommend and implement Phase Three of the modern risk-informed approaches to the materials inspection program, in a way that will not diminish the protection of public health and safety or security of licensed material.
To enhance the inspection program and incorporate new - or evaluate existing - risk and performance insights into the program.
To explore additional options to leverage the collective inspection/oversight efforts of the National Materials Program.
To incorporate strategies to address low safety-significant issues in the inspection program, processes, and procedures.
BACKGROUND On April 13, 2016, the Commission issued an SRM to SECY-16-0009, Recommendations Resulting from the Integrated Prioritization and Re-Baselining of Agency Activities. In the SRM to SECY-15-0015, Project AIM 2020 Report and Recommendations, the Commission directed the NRC staff to perform a prioritization of all work activities across the agency and a one-time re-baselining of these work activities. We have initiated a phased approach to address the re-baselining of the materials inspection activities.
To more efficiently and effectively address the Commission direction in the SRM to SECY-16-0009 for Item 110, the NRC staff divided the WGs efforts into two phases:
- 1) to specifically address the items listed in the Commission paper; and 2) to conduct a more comprehensive evaluation of the entire materials inspection program.
Phase One of the project was completed with the issuance of a revision to Inspection Manual Chapter (IMC) 2800, Materials Inspection Program, dated September 12, 2017 (ADAMS Accession No. ML17186A204).
The second phase of this project included another revision of IMC 2800, Materials Inspection Program, incorporating lessons learned and recommendations from Phase One and other audits and reports focused on the NRCs materials inspection program. Phase Two included reviewing and ultimately rescinding IMC 1220, Processing of NRC Form 241, Report of Proposed Activities in Non-Agreement States, Areas of Exclusive Federal Jurisdiction, and Offshore Waters and Inspection of Agreement State Licensees Operating Under 10 CFR 150.20, by incorporating the guidance into existing licensing and inspection guidance. Phase Two also included updating how inspections are documented.
The third phase of this project will include evaluating the various Materials Program inspection priorities (i.e., inspection frequencies), changing the Materials Inspection Procedures (IPs) to update the IPs and make them more risk-informed and performance-based, revising the Incident Response IMCs and IPs, addressing dispositioning inspection findings of low safety
significance, evaluating use of modern Information Technology to support inspectors in the field (e.g., providing inspectors with tablets that could be used for inspection activities and inspection reports), and exploring potential future changes to the materials licensing and enforcement programs.
MEMBERSHIP The Joint NRC/Agreement State WG operates under NRC Management Directive 5.3, Agreement State Participation in Working Groups, dated June 22, 2016. The lead organization for the WG is the Office of Nuclear Material Safety and Safeguards (NMSS). One WG will be formed, and a Project Manager (PM) will oversee all the WG task completions. The PM for this WG is Anthony McMurtray. Current membership for the WG can be found on the NMSS public website (https://scp.nrc.gov/workinggroup.html). Membership information is updated quarterly.
The following representatives will participate in the WG:
Organization Working Group Members NMSS Lizette Roldan-Otero, Co-Chair Leira Cuadrado (Co-Chair:
effective 4/2020)
Organization of Agreement States (OAS) Augustinus Ong (NH), Co-Chair NRC Region I Office/Division of Nuclear Materials Safety Tara Weidner Jan Nguyen (backup)
NRC Region III Office/Division of Nuclear Materials Safety Ryan Craffey NRC Region IV Office/Division of Nuclear Materials Safety James Thompson OAS Amy Ford (TN)
Brian Goretzki (AZ)
Steve Mack (AR)
The following individuals will serve as advisors to the working group:
Aaron McCraw, NRC Region III Office Betsy Ullrich, NRC Region I Office Duncan White, NMSS The WG may invite additional representatives from other NRC offices, namely the Office of the General Counsel, the Office of Enforcement, the Office of International Programs, the Office of Nuclear Security and Incident Response, or additional subject matter experts from NMSS or the Regions, to participate in certain team activities when requiring special expertise.
OBJECTIVES The WG will focus on the listed priorities in the attached project plan. The WG will establish its work plan and meeting schedule to meet the project objectives. The WG will periodically brief and solicit feedback from NMSS management and the DNMS Directors on the progress of the WG.
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SCHEDULE Beginning January 2020, the WG will initiate its tasks/charges based on the attached project plan. Phase Three is estimated to be completed by July 2021.
LEVEL OF EFFORT Members of the WG should expect to provide a substantial commitment to this project until its objectives are completed.
Staff should charge all work associated with Phase 3 to Cost Activity Code (CAC) A34011, NB-NMU-NUC MAT USERS-OVERSIGHT-INSPECTION and Enterprise Product Identification (EPID), V-2019-IMC-0007 - Risk-Informed Decision Making for the Materials Inspection Program.
In consideration of the planned schedule and approach for this WG, the materials program Full-Time Equivalents (FTE) estimate is 0.25 FTE.
MEETINGS The WG will meet, as needed, to meet its objectives. The WG will use a combination of in-person meetings and remote participation (e.g., conferences calls, e-mail, SharePoint, GoToMeeting) tools to facilitate interaction within and among the team in pursuit of the completion of the objectives.
/RA Kevin Williams for/ 12/20/2019 Michael C. Layton, Director, NRC/NMSS/MSST Date
/RA/ 12/11/ 2019 Terry Derstine, Chair, OAS Date 3
ML19338E145 *Via email OFFICE NMSS/MSST RIII/DNMS OAS NAME AMcMurtray ACM LRoldan-Otero* AOng*
DATE 12/4/19 12/9/19 12/4/19 OFFICE NMSS/MSST OAS NMSS/MSST NAME DAlley DWA TDerstine KWiliams for:
MLayton DATE 12/9/19 12/11/19 12/20/19 Phase 3 Project Plan Priority Items Review data collected during IMC 2800 Phase 2 activities to support an evaluation for potential changes to inspection frequencies/priorities.
Draft new guidance in IMC 2800 for dispositioning items of low safety significance (i.e.,
establish guidance on ensuring that potential risk or potential safety gain is commensurate with level of effort).
Review and revise the Materials Inspection Procedures to modernize the IPs and incorporate additional risk and performance insights.
- Prioritize the IPs based on potential safety gain, impact to the program (i.e., number of affected licenses/inspections), and time since last revision.
- The highest priority IPs should be revised first, and then medium and lower priority IPs based on available resources.
- Consider listing a range of hours (level of effort) for performing the various types of inspections in the Materials IPs.
Review and revise the Incident Response IMCs and IPs (e.g., IMC 1301, IP 87103, IP 87250) to modernize the IMCs and IPs and incorporate additional risk and performance insights.
- Establish reasonable, risk-based timelines for conducting to materials events.
- Establish criteria for when remote follow-up to materials events is appropriate.
- Alternatively, or incidentally, determine what if any guidance could be incorporated into IMC 2800.
Develop recommendations for outreach to internal (i.e., NRC inspectors) and external (e.g.,
Agreement State personnel) stakeholders on the changes being implemented as a result of the Phase 3 activities. Implement these outreach recommendations.
Develop recommendations/ideas regarding the materials licensing and enforcement programs for MSST and DNMS management to consider in establishing a shared vision for the future of the overall materials program.
Other Items to Consider Enhance communications and overall inspection effort for multi-regional licenses to gain efficiencies.
- Establish a collaborative environment in which regions can proactively complete field office inspections within their geographic boundaries on behalf of other regions.
- Propose enhancements to WBL for long-term solution.
- Consider developing standing lists of facilities in other regions as short-term solution.
Explore additional ideas to strengthen and leverage the collect inspection/oversight efforts of the National Materials Programs
- How can we collectively better communicate inspection scope and findings?
- Can we rely on or honor/recognize each others enforcement actions?
Explore providing inspectors with upgraded Information Technology to support in the field inspections (e.g., provide inspectors with tablets that could be used for inspection activities and inspection reports) and initiate these upgrades.
Review list of existing Temporary Instructions and determine which can be incorporated into other existing guidance and which can be unsettled/rescinded.
Establish conceptual hierarchy/philosophy on how inspectors should spend their time/effort and the basis for findings (e.g., observations, demonstrations, and interviews take precedence over procedures, records, and processes). Performance vs. compliance.
Define programmatic as it relates to licensee performance and provide additional guidance criteria on when to pull the thread and/or when to increase oversight (i.e., reduce inspection interval). Ensure coordination with the Office of Enforcement (OE) on the definition of programmatic.
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