ML20006E118
| ML20006E118 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1990 |
| From: | Cline W NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Sjoblom G Office of Nuclear Material Safety and Safeguards |
| References | |
| NUDOCS 9002220090 | |
| Download: ML20006E118 (6) | |
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.4-l(/ h, MEMORANDUM FOR: Glen L. Sjoblom. Deputy Director Division of Industrial & Medical Nuclear Safety Office of Nuclear Materials Safety and Safeguards
- FROM:
William E. Cline, Chief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards
SUBJECT:
REVISION TO MANUAL CHAPTER 2810 Based on our conversation following the 1989 NMSS Program Review, please find enclosed a draft revision of the subject Manual Chapter.
This draft revision
- reflects Region 11 experiences with the Navy License over the past two years.
The thrust of these changes is to reiterate the responsibilities of the home Region.
We have also attempted to define more clearly the responsibilities of the Project Manager.
As an aside, please be aware that our experience has been. that more FTE is expected in the management / oversight of this program than is allocated to it by Headquarters.
d
- G William E. Cline
Enclosure:
Manual Chapter 2810 bec: Document Control Desk RII RII LFranklin 1 pine 1/$/90 1/3l/90 ggggggg30voom
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I JAN 811990 CHAPTER 2810 MATERIALS INSPECTION PROGRAM FOR MULTISITE, MULTIREGIONAL BROAD LICENSEES 2810-01 PURPOSE To establish the inspection program for licensees with a single broad license.
These licensees conduct a variety of materials programs in several regions and have their own internal inspection programs.
Note that the frequency and quality of internal inspections conducted by licensees might influence the type and frequency of NRC inspections, but decisions about when and where to conduct NRC inspections remains with NRC, 2010-02 OBJECTIVES 02.01 To establish the program for NRC inspections of multisite, multiregional licensees.
02.02 To define the role of the regional offices that assist the primary regional office and the role of the regional office that has primary responsibility for inspecting a particular licensee.
2810-03 DEFINITIONS Multisite, multiregional broad license.
A broad license that authorizes a licensee to conduct its activities at facilities (sometimes known as permittees) located in other regions and that does not limit activities to one inspection category.
The region in which the licensee's headquarters or main facility is located shall be referred to as the home region and the main facility shall be referred to as the primary facility. The other regions will be designated as assisting regions.
2810-04 RESPONSIBILITIES 04.01 Home region. The home region shall assign a staff member as project manager to provide total oversight of the licensees program and keep regional management informed of all significant events.
The following are the responsibilities of the home region:
a.
Request at least one or more Jsist inspection; annually in each of the remaining regions where the licensee has facilities (or "permittees") unless all permittees in a given region have been recently inspected by NRC.
More inspections of pemittees may be requested of the assisting region depending on the number of user categories, extent of licensee or pennittee operations, and curie quantities involved in facilities at the permittee's sites in the assisting regions.
After coordination with the assisting region the home region will issue a written request which specifies:
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2 1.
the facilities to be inspected; 2.
the type of inspection to be conducted, e.g.,
independent, followup, or accompaniment; and 3.
any special instructions which may be required such as scope / breadth of inspection, significant issues to be reviewed, and inspection frequency information.
In selecting the facilities to be inspected primary consideration will be given to safety risk.
Other factors to be considered in making this selection include facility performance, enforcement history, and effectiveness of the broad licensee's program in identifying and correcting problems at a particular facility.
I The home regions written request for initial inspection should be i
issued prior to October 1 of each year in order to facilitate planning.
If the home er gion determines that a perfomance degradation has occurred Ster the initial request is made, then a supplemental request will be issued.
b.
Request assist inspections each following year, of facilities I
except that assist different from those inspected previously,ly should be followed up inspections of those pemittees done previous when significant violations were found to determine whether corrective action was appropriately implemented.
Inde>endent inspections by assisting Regions will not be performed wit 1out cause.
The home region will be consulted in all cases, i
c.
Place less emphasis on inspection of facilities where the licensed activitics have less potential for health and safety problems.
d.
Accompany the licensee's own internal inspector (s) as often as it appears necessary but at least once annually to a facility other than the primary facility to determine whether the licenee's inspector (s) are inspecting the facility in accord with NRC's regulatory requirements and the licensee's requirements.
The home region shall closely follow all the licensee's actions with particular attention to inspection and enforcement.
e.
Request each region performing assist inspections to collect and sumarize inspection findings as specified in 04.02.b and to forward them to the home region for followup, f.
Annually, the home region will conduct a appraisal of the licensee's program. Normally, this will include an inspection at the licensee's primtry facility, but may include inspection at support facilities or other licensee facilities / operations as may be necessary for thorough evaluation of licensee programs.
The appraisal will involve review of the licensee's inspection programs, licensing (pemitting program), response to events, notifications to NRC, and misadministrations.
The licensee's inspection program will be reviewed for compatibility with the NRC inspection program.
3 Particular emphasis will be given to identification of safety issues, prompt followup on incidents / events, proper characterization and reporting of findings, corrective actions, and enforcement.
The appraisal should also focus on licenses or permits issued by the licensee.
The NRC inspector or license reviewer should review selected permits or licenses for compatibility and consistency with the NRC licensing program.
The annual appraisal should typically be at least a week's duration.
It is desirable that the appraisal be conducted by two or more inspectors / license reviewers.
At the completion of the appraisal an exit meeting will be held with licensee management.
Regional management should plan to attend the exit meeting (Branch Chief or Section Chief as a minimum).
Following the appraisal, a report will be prepared by the home region.
This report will include the findings of the appraisal plus results of any in-office reviews of licensee reports, permits, or licenses, and any other issues / findings surfaced by the home or assisting region.
The report should be structured along the guidelines in MC 610 and should normally be issued within 30 days of the date that the appraisal was completed.
g.
Obtain an up-to-date list of all facilities (or permittees) from the licensee on an annual basis.
h.
Evaluate written reports from the radioisotopes comittee (or safety comittee) at the licensee's primary facility (and from licensee's facilities /permittees located in other regions if there is more than one comittee or subcomittee).
1.
If, following an inspection, escalated enforcement action is contemplated, the home region shall invite the licensee to an enforcement conference.
There should be no undue delay in sending the licensee the report of an inspection and Notice of Violation, if needed.
This should be done promptly by the home region following an inspection by the assisting region.
Non-escalated letters should be forwarded to the licensee on a routine basis from the home region.
j.
The home region will have the lead role on all allegations received concerning a broad licensee.
The home region will make the determination on whether an allegation will be inspected by the NRC or referred to the licensee for action. An inspection report will be written when an allegation is inspected by NRC.
k.
The home region will be consulted concerning all issues involving licensee wrongdoing.
The home region shall have the responsibility for evaluating the wrongdoing issues and making a determination regarding an 01 referral.
The home region will keep the assisting region advised concerning 01 referrals and the status of 01 1
j investigative work, j
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4 04.02 Assistino Region:
The following are the responsibilities of the assisting region:
a.
Conduct inspections according to the request from the home region.
In some cases, the home region may request to accompany the inspector from the assisting region.
If the assisting region believes it necessary to conduct more inspections than requested, the region shall request pennission from the home region.
Prior to conducting assist inspections, a copy of the license or permit and any available inspection history will be obtained from the home region, b.
Depending on the inspection findings, the following shall be provided to the home region:
1.
For clear inspections or those that involve Severity Level V violations, provide a copy of the field notes and the NRC Form 591.
The home region will forward the NRC Form 591 to the licensee.
2.
For inspections where Severity Level IV violations (or a combination of Severity Level IVs and Ys) are identified, provide a copy of the field notes and send a draft NOV to the home region by 5520.
The draf t NOV should be transmitted to the home region within 18 days of the end of the inspection.
3.
For inspections which are candidates for escalated enforcement, notify the home region of the inspection findings as soon as possible, provide a copy of the field notes and send a draft NOV to the home region by 5520. The draft NOV should be transmitted within seven days of the end of the inspection.
Discussions between the home and assisting regions will then occur and a final decision concerning whether to proceed with escalated enforcement will be made.
At that point the assisting region should prepare an inspection report on an expedited basis and send it to the home region for issuance, c.
Discuss any violations found at the exit interview and attempt to have the licensee comit to correct the violations; otherwise, there may be a significant delay before the primary facility is informed.
If an apparent serious health and safety problefa exists, telephone the home region for implementation of imediate action, such as an order to shut down or cease operations, d.
Observe the licensee's inspector (s) at a facility doing an observation may be enough to get an idea if the inspector (ys of inspection if the home region requests it.
One or two da l
s)are inspecting against the license and NRC regulations.
During such
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5 observations, the NRC inspector should not become involved with the inspection, but rather should report any apparent irregularities to the home region.
This function will normally be performed by the home region project manager.
2810-05 INSPECTION REQUIREMENTS The methodology for conducting inspectior,s shall be the same as set out in the i
inspection procedures of MC 2800. The same program codes shall be used.
2810-06 BVDGETING The budget for each additional regional office includes FTE's for routine inspections and, separately, FTE's for assist inspections.
Any region conducting an assist inspection should credit the time spent to the resources budgeted to itself for assist inspections.
To avoid duplication, the home region should not take credit for assist inspections conducted at its request by other regions.
However, the home region should credit any inspection it
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conducts of the licensee's primary facility, or other licensee facilities in the home region, as a routine inspection.