ML20132C870
| ML20132C870 | |
| Person / Time | |
|---|---|
| Issue date: | 12/04/1984 |
| From: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| Shared Package | |
| ML20132C621 | List: |
| References | |
| FOIA-85-427 NUDOCS 8504080379 | |
| Download: ML20132C870 (3) | |
Text
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MEMORANDUM FOR: Clemens J. Heltemes, Jr., Director Office for Analysis and Evaluation of Operational Data FROM: John G. Davis, Director Office c,f Nuclear Material Safety and Safeguards
SUBJECT:
STUDY OF THE NEED FOR AN INDEPENDENT AGENCY T0 INVESTIGATE INCIDENTS AT NUCLEAR POWER PLANTS We have reviewed the draft report forsarded by your memorandum of November 16, 1984 t
Section 2.5, "Non-NPP Licensed Facility Events," does not accurately reflect the full range of NMSS events analysis efforts. The discussion (particularly page 42, paragraph 2) leads the reader to the incorrect
- conclusion that in the whole of NMSS, which is responsible for virtually all non-reactor licensed activity as well as reactor safeguards, the only event evaluation and analysis done is for physical security issues, ed All fuel cycle, materials, and waste management licensce events are also systematically analy
- :ed and evaluated, and safety information is promptly disseminated to licensees. The implication in paragraph 2 on page 43 that cnly AE00 reviews and evaluates non-reactor events, and that NMS$ ceuld help (but does not) is incorrect.
Sntion 2.5 should be rewritten to accura'tely depict the full range of licensee event evaluation in NMSS.
hecific coments and revisions are provided as follows:
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o The Section 2.5 title, "Non-NPP Licensed Facility Events," does not W'
accurately label the contents of the section. Many of the safeguards events referenced in this section occur at nuclear power plants.
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o On page 40, after the second sentence in the second paragraph, insert p.5 the following sentence: "It also includes the disposal of nuclear
_ materials produced as wastes of these uses."
o On page 40, in the last paragraph, the statement is made that strategic special nuclear material is regulated under 10 CFR 73.60. This citation p*-
_ should be changed to "10 CFR Parts 70 and 73."
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Clecens J. Heltemes, Jr. D:.0 4M
_ _ ,, Io On page 41, the first paragraph, concerning materials incidents, is inaccurate and should be rewritten as provided in enclosure 1.
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o On page.41, the phrase " attempted theft" should be added to' the CI'" first sentence of the last paragraph after the word "when."
o The first paragraph on page 42 is inaccurate. There is a well-Further, defined set of procedures to dett.rmine event severity.
all threats are reviewed by the Information Assessment Team which c .i includes representatives f rom all relevant !!RC program offices as well as the regional offices.
It should be
'o The second paragraph on page 42 is misleading.
revised as provided in enclosure 1.
"o On page 43, the second sentence of the second paragraph is misleading and should be stricken. !! should be replaced by a F
discussion which indicates that NMSS independently reviews, analyzes and evaluates licensee operational data.
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hn G. Davis, Director
./ Office of fluclear Material Safety and Safeguards
Enclosure:
As stated O
r Page 41, Revision to Paragraph 1 Revise to read as follows:
" Responsibility for managing materials incidents that fall below the threshold envisioned by NRC Manual Chapter 0502 and coordinating at the Headquarters level rests with the Office of Nuclear Material Safety and Safeguards (NMSS) . NMSS provides policy guidance and technical support After the initial related to the incident and coordinates NRC actions.
report of the incident, NMSS becomes the point of contact for informationNMSS flow at Headquarters and processes further information within the NRC.
also maintains the records of the NRC actions and provides periodic updates for other offices and the Executive Director for Operations (EDO). The Office CC" ' of Inspection and Enforcement (IE) is responsibl'e for transmitting to NMSS initial reports of incidents received from the Regional Offices or through the NRC Operations Center. IE also coordinates enforcement action by Regional Offices and issues orders, when appropriate. Regional Offices are responsible for evaluating compliance with NRC regulations and for instituting enforcement actions if necessary. These and other levels of responsibility are described in " Modified Interim Plan for NRC Response to Materials Contamination Incidents," a memorandum to Office Directors and Regional Administrators from J. G. Davis dated October 18, 1984."
Pace 42, Revision to Paragraph 2 Fevise to read as follows:
"i:::SS staf f members in all three divisions, Safeguards, Fuel Cycle and Material Safety, and Waste "anagemer.t, review licensee operational event data in accordance with prescribed procedures in order to ider.tify problems, significant trends and patterns. Safety information
,g, is prcaptly disseminated to licensees.
"Most of the safeguards events occur at nuclear power plants, primarily because there are many more nuclear power plants than other types of facilities subject to safeguards. MMSS also maintains a Safeguards Summary Event List (SSEL) that provides summaries of nuclear materials or facilities events. The total number of safeguards events recorded These are for the period of January 1980 to December 1983 was 420.
sub-divided into nine categories:"
Enclosure 1