ML20151T324
| ML20151T324 | |
| Person / Time | |
|---|---|
| Issue date: | 04/13/1988 |
| From: | Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| NUDOCS 8804280648 | |
| Download: ML20151T324 (4) | |
Text
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MEMORANDUM FOR:
Robert D. Martin APR 131988 y.
Regional Administrator, RIV
.FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
MATERIALS LICENSING AND INSPECTION PROGRAM INITIATIVES Thank you for your memorandum dated March 3,1988, which suggested several initiatives to improve the material licensing and inspection program.
For most of the initiatives, we agree that Region IV could initiate pilot programs and report conclusions in early 1989.
Because you indicated in your outline that further development of the initiatives is necessary, we suggest that you coordinate with the NMSS staff in finalizing your implementat'lon plans.
The NMSS staff has some reservations with Region IV implementing tne initiatives dealing with renewal notices, applicants with questionable enforcement histories, and site visits by non-inspectors, even on a trial basis.
Specific comments on these intiatives are enclosed.
I suggest that our staffs discuss these initiatives further before Region IV takes any further action on them.
Please call me if John Hickey and Jack Metzger (you have further questions on these matters.
49-23424) will be the NMSS staff contacts.
M Aobert & Bemoto Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
Enclosure:
Comments on Initiatives i
cc: Regional Administrators E. Jordan, AE0D J. Lieberman, OE l
DISTRIBUTION: NMSS88-131 CJenkins JMetzger DACool RFonner hV CEstep VLMiller JHickey RBurnett IM0B r/f GSjoblom RECunningham MKnapp IMNS Central NMSS R/F NMSS Office R/F JFunches Editor: EKraus F 6/d See Previous Concurrence
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DATE:03/22/88
- 03/23/88:03/24/88:03/23/88: 03/ /88 :04/06 /88: 04/r3/88 :04//) /88 0FFICIAL RECORD COPY eeO.2g y a* "1 k')0h#
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7 MEMORANDUM FOR:
Robert D. Martin Regional Administrator, RIY FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
MATERIALS LICENSING AND INSPECTION PROGRAM INITIATIVES Thank you for your memorandum dated March 3,1988, which suggested several initiatives to improve the material licensing and inspection program.
For most of the initiatives, we agree that Region IV could initiate pilot programs and report conclusions in early 1989.
Because you indicated in your outline that further development of the initiatives is necessary, we suggest that you coordinate with the hMSS staff in finalizing your impimentation plans.
The NMSS staff has some reservations with Region IV implementing the first two initiatives, dealing with renewal notices and applicants with questionable enforcement histories, even on a trial basis.
The concern is that these initiatives would introduce significant inconsistencies between Region IV and the other Regions. Specific contrents on the first two intiatives are enclosed.
I suggest that our staffs discuss these initiatives further before Region IV takes any further action on them.
Please call me if and Jack Metzger (you have further questions on these matters. John Hickey 49-23424) will be the NMSS staff contacts.
Hugh L. Thompson, Jr., Director Office of huclear Material Safety and Safeguards
Enclosure:
Comments on Initiatives cc: Regional Administrators E. Jordan, AE00 J. Lieberman, OE l
DISTRIBUTION: fiMSS88-131 CJenkins JMetzger DACool RFonner i
CEstep VLMiller JHickey R8urnett IM0B r/f GSjoblom RECunningham MKnapp INNS Central NMSS R/F NMSS Office R/F JFunches t
Editor: EXraus PMDA See Previous Concurrence
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- 03/ /88:03/ /88 :03/ /88 l
DATE:03/ /88
- 03/ 23 8
0FFICIAL RECORD COPY l
MEMORANDUM FOR:
Robert D. Martin Regional Administrator, RIV FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
MATERIALS LICENSING AND INSPECTION PROGRAM INITIATIVES Thank you for your memorandum dated March 3,1988, which suggested several initiatives to improve the material licensing and inspection program.
For most of the initiatives, we agree that Region IV could initiate pilot programs and report conclusions in early 1989.
Because you indicated in your outline that further development of the initiatives is necessary, we suggest that you coordinate with the NMSS staff in finalizing your implementation plans.
The NMSS staff has some reservations with Region IV implementing the first two initiatives, dealing with renewal notices and poor enforcement histories, even on a trial basis.
The concern is that these initiatives would introduce significant inconsistencies between Region IV and the other Regions.
I suggest that our staffs discuss these initiatives further before Region IV takes any further action on them.
Please call me if you have further questions on these matters. John Hickey and Jack Metzger (49-23424) will be the NMSS staff contacts.
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
Enclosure:
Comments on Initiatives cc: Regional Administrators E. Jordan, AE0D J. Lieberman, OE DISTRIBUTION: NHSS88-131 CJenkins JMetzger DACool RFonner CEstep VLMiller JHickey RBurnett IM0B r/f GSjoblom RECunningham MKnapp IMNS Central HMSS R/F NMSS Office R/F Editor: EKraus IMAb :
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DATE:03ho/88
- 03/u/88:03/ /88:03/ /88: 03/ /88
- 03/ /88:03/ /88 :03/ /88 0FFICJAL RECORD COPY
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5' ENCLOSURE I..
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NMSS COMMENTS ON REGION IV IMITIATIVES A.
RENEWALS 1.
We agree in principle that both the licensee and the NRC staff should take a "fresh icok" at a program when the license is due for renewal. However, many licensees' files and programs are in good order, and in these cases it may be counterproductive to require complete new applications.
The focus curing the renewal should be on evaluating which areas of the program are in good order and which areas require close scrutiny.
Rather than requiring a complete new license application, which in some cases might not be an improvement over the old application, perhaps we could require a comprehensive description of the program evaluation performed by the licensee. We would like to discuss this concept further with the Region IV staff.
2.
hMSS currently dispatches all renewal notices.
There would be an administrative discrepancy if Region IV dispatched differently worded notices, and the other Regions did not.
A readily available a
alternative is for Region IV to call each licensee due for license renewal and discuss needed information, Region IV already calls each licensee prior to renewal.
3.
The regulations specifically permit licensees to reference previously submitted material in license rerewals (10 CFR 30.32(a)).
Therefore, the Region IV proposal would be in conflict with the regulations.
B.
ENF_0RCEMENT HISTORY OF LICENSEES 1.
The Region IV proposal involves the "wrongdoer issue," which is a major unresolved policy question.
Therefore, it may be premature to initiate a pilot program on the wrongdoer issue at this time.
2.
The proposal on licensees' use of consultants is very general. The NMSS staff would like to discuss this proposal further with Region IV, to learn more details.
C.
SITE VISITS BY NON-INSPECTORS While we can see the advantages of inspectors-in-training making site visits, the Region IV proposal appears to suggest that persons other than the inspection staff would make site visits.
This raises questions about the qualifications of the non-inspectors, and the differences between a site visit and a routine inspection.
There are also questions about the implications of a "non-qualified" NRC representative visiting a licensee where significant safety problems might exist and yet not be recognized by the NRC representative.
The NMSS staff would like to discuss this proposal further.