ML20196F577
| ML20196F577 | |
| Person / Time | |
|---|---|
| Issue date: | 06/17/1988 |
| From: | Knapp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 601, NUDOCS 8812130303 | |
| Download: ML20196F577 (1) | |
Text
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ARUNGTON. TEXAS 79011 JUN l 7 588 MEMORANDUM FOR: Richard E. Cunningham, Director Division of Industrial and Medical Safety, NMSS FRON:
Malcolm R. Knapp, Acting Director Division of Radiation Safety and Safeguards RIV SUIMECT:
INTERIM "3M LESSONS LEARNED" REPORT In response to your June 9,1988, memorandum, we suggest the following lessons learned from the 3M static elimination device case:
1.
Significant inequities may have been caused by the timing of NRC's extension of the deadline for returning the devices to 3M. Many licensees who complied with the Order had to shut down their operations, while licensees who violated the Order benefited from the eleventh hour extension.
It would have been preferable to have extended the deadline as soon as it became apparent that general licensees could not get prompt delivery of replacement devices.
2.
It is not clear that NRC actions were coordinated adequately with Agreement States, whose regulations also include general license provisions.
3.
Agreement States may not be adequately informed of generclly licensed devices shipped into those states.
4.
Perhaps there should be some form of accountability, other than the manufacturer's records, for significant, generally licensed devices.
5.
NRC's handling of the 3M problem appeared to suffer from "too many fingers in the pie."
Given the origin of the problem in Region I, the responsibility of Region III for the licensee, the involvement of all Agreement States and all other NRC regions, and the huge number of devices and general licensees, the problem was bound to be unwieldy. A lesson te be learned is how to cope with w despread problems, perhaps i
the agency could accomplish that best by forming an ad hoc orgc11zatio9 compristag all of the Headquarters and Regional personnel necessary for effective resolution of the problem.
Any questinns regarding these coments may be referred to Bill Fisher (728-8215).
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yf Malcolm R. Knapp, Acting Director opt 48hhCO 00 g8121h03 Division of Radiation Safety ppn PDR and Safeguards