ML20203D211
| ML20203D211 | |
| Person / Time | |
|---|---|
| Issue date: | 01/19/1999 |
| From: | Schneider K NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | NRC |
| References | |
| NUDOCS 9902160075 | |
| Download: ML20203D211 (4) | |
Text
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UNITED STATES y-NUCLEAR REGULATORY COMMISSION
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Igy WASHINGTON, D.C. 20555 0001
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January 19, 1999 MEMORANDUM TO:
IMPEP Team Leaders IMPEP Team Members d,
3'p FROM:
Kathleen N. Schneider Senior Project Manager for IMPEP Coordination Office of State Programs
SUBJECT:
QUARTERLY IMPEP TELECONFERENCES, ADDITIONAL GUIDANCE FOR CONDUCTING IMPEP REVIEWS AND GUIDANCE FOR CLOSURE OF RECOMMENDATIONS DURING PERIODIC REVIEWS In an effort to keep all IMPEP team members informed of program changes on a more timely basis, OSP and NMSS are instituting quarterly teleconferences for IMPEP team leaders and team members. These teleconferences will feature discussions on recent IMPEP program revisions, as well as any issues involving IMPEP implementation difficulties. Communications such as this one or, as a minimum, an agenda will be sent to all IMPEP team participants prior to the teleconferences and will form the bases of the teleconferences. All team leaders and team members are invited to participate. The first teleconference will be scheduled during the first week of February, after the January 25,1998 IMPEP training for new IMPEP team members. Additionalinformation on scheduling of the first teleconference will be forthcoming.
The November 25,1998 revision of Management Directive 5.6, " Integrated Materials Performance Evaluation Program (IMPEP)" will be issued as an Agreement State letter and will be placed on the Office of State Programs home page. Handbook Part IV, " Programmatic Assessment" was revised to expand the guidance for the Management Review Board and to incorporate the experience gained from past IMPEP reviews. The guidance has been written so that Agreement States may perform self-assessments of their programs with the knowledge that NRC reviews will be likely to produce similar conclusions.
Based on Commission direction, we have developed guidance in three areas to assist the IMPEP teams during their evaluations. The background and guidance follows:
1.
The new Commission " Policy Statement on Adequacy and Compatibility of Agreement State Programs" was published September 3,1997. Management Directive 5.9, Handbook, Part V, provides that Agreement States should adopt regulations issued prior to September 3,1997 as expeditiously as possible, but no later than 3 years after the I
effective date of the new Policy Statement. The following language should be included in IMPEP reports in the discussions on the non-common performance indicator, Legislation and Program Elements Required for Compatibility,if the Agreement State 4
has not adopted the required regulations:
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9902160075 990119 PDR STPRG ESGGEN k
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g IMPEP Team Leaders i IMPEP Team Members 1
It is noted that Management Directive 5.9, Handbook, Part V, paragraph l
(1)(c)(iii), provides that regulations required prior to September 3,1997, should j
be adopted by the State as expeditiously as possible, but not later than 3 years after the effective date of the new Commission Policy Statement on Adequacy 4
and Compatibility, i.e., September 3,2000.
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2.
In SECY 98-068, " Consideration of Application of Federal Government-wide Conflict of Interest or Ethics Requirements and NRC Enforcement Policy on Licensee Integrity lssues to Agreement State Programs," the issue of potential conflicts of interest with the membership and statutory authority of State radiation control advisory or oversight boards was addressed. The Commission approved the staff's plan to examine the membership and statutory responsibilities of State radiation oversight boards and the boards' actions for the potential of conflict of interest during IMPEP reviews. When reviewing Agreement State programs, the IMPEP teams should determine whether I
there is a radiation control program oversight board and examine the board and the board's actions during the review period for potential conflict of interest issues. This includes reviewing board meeting minutes and conflict of interest statements of board members, if available. Information on radiation control program oversight should be included in the write-up on the common performance indicator, Technical Staffing and Training.
3.
In response to SECY 98-098," Guidelines for Providing Assistance to Agreement States and Alternatives for Training," the Commission commented on the continuation of reviewing Agreement State training programs under IMPEP and identification of courses j
utilized by Agreement States. IMPEP reviews of Agreement States should identify, l
whenever possible, available quality training courses that could be attended by NRC personnel and thus reduce NRC training cost. If such training is identified during an IMPEP review, the review team should note it as a good practice and bring it to the attention of the Management Review Board in order to share such information with the NRC Regions and other Agreement States.
On September 3,1998, Office of State Programs Procedure, SA-116," Periodic Meetings with i
Agreement States Between IMPEP Reviews" was revised based on our experience in 1998.
For open IMPEP review findings that the Regional State Agreements Officer (RSAO) and Agreement State Project Officer (ASPO) conclude have been resolved, a recommendation for closure should be included in the meeting summary letter. Formal closure will be completed only at the time of the next IMPEP review. Chronic program deficiencies should not be recommended for closure until sufficient time has passed to demonstrate that the problem is properly addressed. Also, those items where it is necessary to perform file reviews should not be recommended for closure until the IMPEP review. In several instances during the first year j
of these meetings, items were recommended for closure without sufficient basis for the closure, i
The following format and language should be used in the summary letter for the periodic meetings as appropriate:
1.
Open items: It is recommended that this comment remain open, i
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lMPEP Team Leaders 1 IMPEP Team Members 2.
Items recommended for closure: It is recommended that this comment be i
closed at the next IMPEP review.
3.
Item to be verified: It is recommended that these actions be verified at the next IMPEP review.
if you have any questions before the teleconference, please contact me at 301-415-2320 or Lance Rakovan at 301-415-2589.
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lMPEP Team Leaders IMPEP Team Members 2.
Items recommended for closure: It is recommended that this comment be closed at the next IMPEP review.
3.
Item to be verified: It is recommended that these actions be verified at the next IMPEP review.
If you have any questions before the teleconference, please contact me at 301-415-2320 or Lance Rakovan at 301-415-2589.
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Distribulion:
DIR RF (8S260)
SDroggitis 0AS Liaisons PDR (YES/)
LRakovan SMoore, NNMSS IMPEP Filost
- via e-mail (attached)
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