ML20154F045
| ML20154F045 | |
| Person / Time | |
|---|---|
| Issue date: | 09/01/1998 |
| From: | Virgilio R NRC |
| To: | Frazee T WASHINGTON, STATE OF |
| References | |
| SP-98-070, SP-98-70, NUDOCS 9810090053 | |
| Download: ML20154F045 (2) | |
Text
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. From: Rosetta Virgilio To: "tcf 0303 @ doh.wa. gov" @ G ATED.nrcs mtp Date: Tue, Sep 1,1998 5:05 PM
Subject:
Re: SP-98-070 Terry -
Thank you for your e-mail response to SP-98-070 AND for the updated e-mail address.
Rosetta
- >>> "Frazee, Terry" <tcf0303Odoh.wa. gov > 09/01 1:55 PM >>>
This is in response to your request for comments on "NRC and Agreement State Coordinaticn and Communication on inspection, investigation and Enforcement information" as provided in Office of State Programs letter SP-98-070.
- 1. Communications involving investigation Activities Re: Question 1 - We agree that it is appropriate for NRC to protect the integrity of its investigations. This is with respect to NRC licensees operating or located in the state of Washington. We support NRC's
' intended changes in its management directives and procedures manuals to specify that States will be promptly notified of immediate health and safety issues, and will be provided a synopsis of all NRC investigations involving NRC licensee activities in the Agreement State (with a redacted version of the full report available on request).
Re: Question 2 - With regard to our investigations of State licensees, we have similar restraints on our ability to share sensitive investigational information: you'!! get nothing in advance or during the investigation, with redacted information available upon request after the investigation is complete.
Re: Question 3 - We are not sure we understand what would be accomplished by a " reciprocal Agreement State exchange of investigative information ... with NRC". is this for specific intelligence gathering about an individual licensee who might be operating in NRC jurisdiction, or for broadcasting of " lessons learned" to all states? During, and certainly upon completion of an investigation, any significant health and safety concerns we find will b3 communicated to any other responsible agency. After the investigation, any broadly applicable " lessons learned" could be_ shared with fellow regulators through presentations at the Organization of Agreement States Meeting, the Conference of Radiation Control Program Directors Annual Meeting, written up for the CRCPD Newsbrief, etc. We would expect that toutine communication with our Regional State Agreements Officer could be a useful mechanism for identifying appropriate investigational highlights. The Integrated Materials Performance Evaluation Program should also capture worthwhile -h
" lessons learned" during its review. U
- 11. Communications involving inspection and Enforcement Activities Re; Question 1 - We agree that current NRC guidance and practice appears sufficient.
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[Ksthdeen K:rr - Rai SP-98-070 Pagi21l Re: Question 2 - We do not need telephone or e-mail notification in addition to the existing practice of sending hardcopy of enforcement correspondence pertaining to NRC actions taken against our licensees when operating under NRC jurisdiction.
Pertaining to Agreement States notification to NRC:
Re: Question 1 - We agree that the general exchange of information that already occurs between the Agreement States and NRC is sufficient.
Re: Question 2 - We do not believe it is appropriate to routinely provide NRC with information which includes the names of prohibited individuals and significant actions taken against our own licensees when NRC's intention is to " share" the information. This " broadcasting" could result in defamation of our licensee's business reputation, unwarranted increases in inspection frequency at our licensee's facilities in other states, and other negative attention which is " unfair" or falls outside "due process" for that jurisdiction. While we support broadcasting of
" lessons learned", we are concerned that requiring the Agreement States to provide names and specific actions taken against our own licensees is ;
one stop away from requiring or even expecting us to take action against licensees based solely on this same information from the other states or from NRC.
111. Communications on Significant Pubile Health and Safety issues Re: Question 1 - We agree that existing guidance and practice appears ,
sufficient to mutually inform Agreement States and NRC of information !
having significant public health and safety significance.
This message frw : Terry Frszee tcf0303@doh.wa.aov Please note: a slight change in e-mail address.
You rhould update your address booki Quick ways to reach me:
Voice = 360 236-3221 FAX = 360-236-2255 Also, visit our Home Page at
-> htto1/www.doh.wa.nov/ oho /ro CC: Bangart, Richard, Davis, Gwendolyn, Kerr, Kathle..
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