ML20207A317
| ML20207A317 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1999 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20207A262 | List: |
| References | |
| NUDOCS 9905260262 | |
| Download: ML20207A317 (5) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 8
A REGION lil O"
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LISLE, ILLINOIS 605324351 k.....,/
April 29, 1999 MEMORANDUM TO:
Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards James E. Dyer, Regional Administrator, Rllt h((8V FROM:
SUBJECT:
COMMENTS ON DRAFT 1999 REGION lll INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM (IMPEP) REPORT AND RESPONSE TO RECOMMENDATIONS We have reviewed the subject draft report and have provided our specific comments as to this memorandum. In addition, we have reviewed the recommendations and have provided a description of the specific actions that we have implemented to address each of the recommendations that pertain to Region lli performance. This description is included as to this memorandum.
t Thank you for the opportunity to comment on the draft report. The team that performed the Region lil IMPEP was very professional, and this report is of very high quality.
We understand that this memorandum and its attachments will be included as part of your final report when it is issued. If you have any questions concerning Region lli comments, please call Monte Phillips of my staff at (708) 829-9806.
Attachments: As stated cc w/att:
S. Moore, NMSS/IMNS
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9905260262 990519 PDR ORG NOMA PDR
COMMENTS ON DRAFT 1999 REGION lll INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM (IMPEP) REPORT 1.
Paae 8. second full caraaraoh: The following sentence, which appears in the middle of the paragraph, is not clear: "The review team found that several of Rlli's in-process inspections included corfirmatory surveys, although NRC policy emphasizes "in-process" inspections more than confirmatory surveys." is it complimentary that the Region also does confirmatory surveys, or critical in that additional resources are used?
Please clarify what is meant by this sentence.
2.
Pace 9. Section 3.3. second oaraaraoh: The sentence discussing the licensing assistance staff is in error. For a portion of the review period (from last IMPEP to January 1998), a separate Administrative Support Branch existed. In January 1998, the administrative staff were detailed to the licensing and inspection branches. After the i
IMPEP, the Region's March 28,1999, reorganization permanently assigned the remaining administrative support staff, including the licensing assistant, to the Materials Licensing Branch.
3.
Paae 10. Section 3.3. carry-over oaraaraoh: The section discussing vacancies is in error. DNMS reported 3 vacancies, with an additional GG-14 titled position (Lead Inspector) to be filled via a solicitation from the current GG-14 staff. This really consists of a re-titling of a current GG-14 position.
4.
Pace 10. Section 3.3. oaraaraoh discussina license reviewer aualifications: The text in the previous paragraph also applies to this puagraph, namely, that DNMS management has elected not to exempt the reviewers from the course, and the remaining reviewers who can take the course will complete the training during or prior to FY2000.
5.
Paae 16. Section 3.5. third oaraaraoh from end of section: Suggest that the reference to " members of the Licensing Assistance staff" be replaced with " administrative staff" since we have no designated unit by the name of " Licensing Assistance staff."
6.
Paae 19. Section 4.1. first paraaraoh concernina resource utilization: As written, this section implies that an NMSS recommendation is warranted to work with the appropriate headquarter's staff to develop a tracking system to match FTE expenditures with budget line items in Operating Plans.
7.
Paae 21. Section 4.1. second from last paracraoh: In the discussion of resource utilization, mention is made of the resources we have devoted to the guidance consolidation project, the VA Master Materials License, and DOE external regulation pilot. However, no mention is made of the unusual number of resources we have expended in supporting and preparing for Ohio to become an Agreement State, especially since Ohio is running 7 months behind schedule. During the review period, we have copied approximately 200 licenses that will remain NRC licenses after Ohio becomes an Agreement State, conducted one week training sessions for 9 Ohio Department of Health personnel, and done a 100 percent quality assurance check of each Ohio docket file. In addition, we have written to all Ohio licensees with temporary job sites to determine if they wish to maintain an NRC license for work outside of Ohio.
Some mention of this effort is probably appropriate for this section.
c-
8.
General Comment concernina all of Section 4.2 and its Suboarts: The terms " generally" and "in general" are used throughout these sections. This is not the case in other areas.
Based upon the team's positive exit meeting results, we would suggest that the use of these terms is not necessary.
9.
Pace 24. Sections 4.3.1 and 4.3.2: Both of these sections are in error es they state that Region ill has no project management for any SDMP sites. Region til does maintain project management status for the Advanced Medical System facility in Cleveland, Ohio, as noted in our response to question 27 of the questionnaire.
1 L
i REGION lli RESPONSE TO RECOMMENDATIONS IN DRAFT 1999 IMPEP REPORT As noted in the report, of the five recommendations made, Recommenr%tions 1 and 3 apply to NMSS. The remaining recommendations apply to Region Ill, and our actions concerning those recommendations are as follows:
Recommendation 2:
The review team recommends that Rill implement the tools prescribed in the Decommissioning Handbook for ensuring that decommissioning and license termination reviews are complete and fully documented.
fleaion 111 Actions:
Promptly after the IMPEP exit, reviewers were instructed to use the checklists contained in the Decommissioning Handbook. On April 19,1999, a divisional procedure was issued in final.
This procedure, entitled " Procedure for Handling Terminations, Location of Use Changes, and Notifications of Intent to Decommission - DNMS Only," describes the methodology for processing and evaluating termination requests and notifications of intent to decommission.
The use of the Decommissioning Handbook is described in that procedure, including the use of the required (Appendix F) and optional (Appendix E) checklists.. the Handbook. This procedure should ensure that all license terminations will include a completed Appendix F checklist in the docket file, and licensee's providing notification of intent to decommission will include a completed Appendix E as well-Recommendation 4:
The review team recommends that Rlli develop and implement a process to remove allegation l
material from the docket files.
Reaion 111 Actions:
By memorandum dated April 23,1999, a temporary procedure was issued to all DNMS technical staff to conduct a review of the docket files when they are accessed to either complete a licensing action or prepare for an inspection. This review is intended to determine if any allegation-related material is present in the file, and then alert division management so that appropriate action can be taken regarding the maies! that is found (e.g., shredding, redacting the inappropriate material from the document, or leaving the document in the file if appropriate).
Recommendation 5 The review team recommends that Rlli t.ain the DNMS staff on what allegation language, if any, is acceptable to place into the docket files.
Reaion lil Actions:
On April 6,1999, a memorandum was issued to all DNMS technical staff describing what language should be used.% reports and other documents that would eventually be placed in the docket file. The memorandum was titled " Acceptable Language for Closing Allegations in Field Notes, inspection Reports, or Other Documents to be Placed in the Docket File." This guidance L
is scheduled to be incorr rated into the Region's allegation management procedure, RP 0517A, before the W of this fiscal year. A training sessico has been set up during the upcoming Inspector Seminar in June 1999 to discuss allegation documentation.
u
V Agenda for Management Review Board Meetina Monday. May 24.1999. 2:00 p.m. - 4:00 p.m.
Room T2B-5 1.
Conver, tion. MRB Chair convenes meeting (FMiraglia) 2.
New Business - Consideration of Rlll IMPEP Report A.
Introduction of R!ll IMPEP Team Members (SMoore)
B.
Introduction of Rlli representatives and State representatives (SMoore)
C.
Findings regarding Rlli Program (IMPEP Team)
S!atus of Materials inspecticn Program Technical Quality of Inspections Technical Staffing and Training l
Technical Quality of Licensing Actions Response to incidents and Allegations Performance Against Operating Plan Gcals i
l Regional Fuel Cycle Inspection Program l
Site Decommissioning Management Plan D.
Questions (MRB Members)
E.
Comments from Rlli F.
MRB Consultation / Comments on Issuance of Final Report (FMiraglia)
Recommendation for next IMPEP review 3.
Status of Upcoming Reviews (OSP) i 4.
Adjournment invitees:
Frank Miraglia, Jr., MRB Chair, DEDR Carl Paperiello, MRB Member, NMSS Paul Lohaus, MRB Member, OSP Karen Cyr, MRB Member, OGC Roland Fletcher, State of Maryland James Dyer, Rlli Regional Administrator Cynthia Pederson, Rlli, DNMS Director Martin Virgilio, NMSS Deputy Director Donald Cool, NMSS/IMNS Director Elizabeth Ten Eyck, NMSS/FCSS Director John Greeves, NMSS/DWM Director Scott Moore, Team Leader, NMSS/IMNS Kevin Hsueh, Team Member, OSP Sheri Minnick, Team Member, OSP Cynthia Sanders, Team Member, Georgia Garrett Smith, Team Member, NMSS/FCSS James Kennedy, Team Member, NMSS/DWM Kathleen Schneider, OSP Lance Rakovan, OSP l
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