ML20132F746
| ML20132F746 | |
| Person / Time | |
|---|---|
| Issue date: | 02/21/1985 |
| From: | Browning R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Purcell W ENERGY, DEPT. OF |
| References | |
| REF-WM-1 NUDOCS 8507190028 | |
| Download: ML20132F746 (4) | |
Text
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o NMSS r/f CF 406.1.2/KP/84/11/28 REBrowning CCunninghG MJBell . JBunting FEB 2 I 1985 LBarrett MRKnapp William J. Purcell HJMiller Associate Director SCoplan Office of Geologic Repositories
- agoyi, Office of Civilian Radioactive JLinehan Waste Management JKennedy /
RCook U. S. Department of Energy Washington, DC 20585 Tvema PPreschole
Dear Mr. Purcell:
JGiarrat KParr r/f Q Please refer to J. W. Bennett's letter to me dated September 19, 1984, V which transmitted the signed 00E/NRC Project-Specific Procedural Agreement for geologic' repository site investigation and characterization programs. The Agreement was complete with the exception of Appendix 7 concerning the NRC on-site representatives. Enclosed is a proposed appendix which is acceptable to the NRC. If you have any questions we will be happy to discuss them with you. Sincerely, f]-
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// Robert E. Browning, Director
- f. *p Division of Waste Management Office of Nuclear Material Safety I
n and Safeguards i u L
Enclosure:
Appendix 7 to the Project-Specific Procedural Agreement C 1 Rccord fib W'J Prtct _ /_ _.. _
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- SEE PREVIOUS CONCURRENCE
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NAME $KParr:rs iScoplan $JKennedy $JLinehan HJMiller $JBunting DATE :01/ /85
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- MQ//85 8507190028 850221 PDR WASTE 1
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I' ( 1 APPENDIX 7 AGREEMENT CONCERNING THE NRC ON-SITE REPRESENTATIVE (OR) FOR THE REPOSITORY PROJECTS DURING SITE INVESTIGATION AND CHARACTERIZATION The purpose and objective of the on-site representative (OR), as identified in item 1. of the Procedural Agreement *, is to serve as a point of prompt informational exchange and consultation and to preliminarily identify concerns O '"v'9 "' '"a ' a '' '""a ' " "- This appendix is intended to supplement the base agreement and to detail the guidelines which will govern interaction between the NRC OR, including any NRC personnel assigned to the OR, and 00E project personnel, including any DOE contractor personnel (prime and sub) involved in the project. Any interactions between the OR and 00E, its contractors, or subcontractors identified in this appendix will not constitute " meetings" within the intent of item 2. of the Procedural Agreement and therefore will not require the preparation of written reports and will not be subject to State / Tribal and public notification and participation or schedular requirements of item 2. of the Procedural Agreement. The interactions of the OR with 00E and its contractors and subcontractors are not intended to interfere with or replace other channels of NRC/00E communications and procedures for information release identified in sections 2., 3.A., and 3.8. of the the base agreement and sections 2., 3. and 7. of the Procedural Agreement. O ine roiio iao Poiats are aareed to: 1. The OR can attend any meetings o,n-site or off-site dealing with technical questions er issues relateo to work required as part of site characterization and site investigation (e.g., any items to be covered in Site Characterization Plans under the Nuclear War.. Policy Act) following notification of the cognizant 00E project represe..tative responsible for the meeting. Such notification shall be by memorandum, telephone or personal contact and will be given at least 24 hours in advance where DOE has provided adequate prior notification to the OR. The meetings may involve solely 00E or solely DOE's contractors (prime or sub) or any combination of 00E with their contractors. The OR may be precluded from attending only those meetings or portions of meetings which concern budgets, personnel actions or contract performance not dealing with technical / peer reviews and QA audits of contractor's work. "" Procedural Agreement between the U.S. Nuclear Regulatory Commission and the U.S. Department of Energy Identifying Guiding Principles for Interface During Site Investigation and Site Characterization" (48 FR 38701, 8/25/83) herein referred to as the Procedural Agreement.
y 2 2. The OR may communicate orally (in person or by phone) with project participants (persons) employed by 00E, DOE's prime contractors or the prime's subcontractors, on-site or off-siti. The OR will avoid discussions with personnel when it would appear to disrupt their normal duties and will schedule a discussion period at a mutually convenient time. The OR will keep 00E or cognizant DOE prime contractor supervisory personnel informed of near term (approximately 1 week) areas for intended review and the project participants who may be contacted. It is the option of 00E or the person contacted by the OR as to whether or not the presence of a supervisor or third party is to be present. Concerns which arise as a p result of the above interactions and which may affect NRC's ability to Ifcense the 00E to receive and possess source, special nuclear and by v product material at a geologic repository operations area will be reported to the tiRC Division of Waste Management and to the cognizant 00E project personnel by the OR as soon as practical. 3. 00E field office (s), 00E prime contractors and their subcontractors will provide the OR access to records which would be potential licensing decision by the Commission. generally relevant to a Upon request by the OR, the 00E or the 00E contractor or subcontractor shall provide copies of any records of raw data provided that the quality assurance checks specified in section 3.a of the Procedural Agreement have been perfurmed. Records which document the analysis, evaluation, or reduction of raw data or contain information deduced by reason will be made available to the OR, by the entity having the responsibility to produce the record, for copying after the quality assurance checks have been taken to assure the quality of the logic and analysis. Records at any stage of completion shall be O available for review but not to copy or to receive a copy for retention until quality assurance checks have been made. v 4. Drafts of 00E documents required'by the Nuclear Waste Policy Act of 1982, such as the EA, and SCP, which have not yet been approved by 00E, will not be provided by 008 ; contractors to the OR without 00E approval. Documents of this type will e made available by 00E, and not the 00E contractor. 5. The OR does not have the authority to direct 00E, their contractors ci' subcontractors to perform any work. Any formal identification of questions or issues for investigation by 00E that could result in significant contractor or subcontractor work must be formally presented to DOE through the NRC Olvision of Waste Management in writing. 6. The OR will attend on site meetings upon request by the 00E field office or primo contractor on site whenever possible. The OR will provide any records which would normally be available under 10 CFR Part 2.790 of the Commission's regulations to project participants upon request to copy. If convenient, copies of such records will be provided by the OR.
h ( ( i i 3 7. The OR shall be afforded access to the site, research facilities, and other contractor and subcontractor areas to observe testing or other data gathering activities, in progress, as part of site characterization and site investigation. Such access shall be immediate upon display of an appropriate access identification badge, or, if badging is not possible for national security reasons, upon prior notification to DOE or cognizant contractor supervisory personnel (by memorandum, telephone or personal contact). When an access identification badge is available to DOE or DOE's contractors and subcontractors on a routine basis, it shall be made available to the OR upon completion of the required security clearances and appropriate radiological and personnel safety training. DOE will ensure that any training required is provided to the OR. l 8. The OR and DOE will make arrangements which will allow for at least weekly 1 information exchanges to discuss pending DOE plans and program status, and ] any problem areas requiring attention of either or both parties. 9. DOE will assure that all of its contractors (prime and sub) involved in the repository projects observe applicable provisions of this appendix. This appendix will be distributed by DOE to all project specific prime l contractors and subcontractors. o 4 1 l i 1 l - - - - - - -}}