ML20216J914

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Rev 0 to Internal Procedure D.24, Annual Meetings W/ Agreement States Between Impep Reviews
ML20216J914
Person / Time
Issue date: 09/08/1997
From: Bangart R, Lohaus P, Lance Rakovan
NRC OFFICE OF STATE PROGRAMS (OSP)
To:
Shared Package
ML20216H586 List:
References
D.24, NUDOCS 9709180150
Download: ML20216J914 (10)


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State Agreements Program Standard Approval I The attached Office of State Programs internal Procedure D.24, Revision 0, Annual Meetin(p with Agreement States Between IMPEP Reviews, is submitted for final approval.

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OFFICE OF STATE PROGRAMS INTERNAL PROCEDURE DIVISION l Post Agreement D 24 Annual Meetings With Activities Agreement States Between IMPEP Reviews

1. Introduction This procedure describes the general objectives and procedures for an annual meeting with Agreement States, including scheduling, assigning personnel, conducting, and reporting, ll, Oblectives The objectives of this procedure are:

A. Establish procedures for scheduling and conducting an annual one day meeting with each Agreement State not scheduled for an Integrated Materials Performance Evaluation Program (IMPEP) review that fiscal year.

B. Identify the NRC staff and requested State staff who should participate in an annual meeting, including staff responsible for leading the meeting.

C. Define the scope of activities and areas that should be discussed during an annual meeting.

D. Identify methods and timing for documenting and communicating the results of the meeting to the State.

E. Specify the correct steps to take when concerns are raised during an annual m'eeting.

Ill. Backaround in their respective Management Review Board (MRB) meetings, Agreement States consistently commented on the need for NRC presence on a more frequent basis than once every four years. At the September 1996 Annual Agreement States Meeting, the issue of conducting a mid cycle or annual meeting was discussed. In SECY 96 234, " Status Report on Implementation of the Integrated Materials Performance Evaluation Program,"

November 12,1996,it was proposed that an annual one day meeting with each of those Agreement States not scheduled for IMPEP review in that year take place in order to help all parties to remain knowledgeable of the respective programs and to conduct planning for the next IMPEP review, 1 Revision O 9/8/97

IV. Procedures A. RSAO's will be responsible for scheduling meetings with each of those Agreement States in their Region not scheduled for an IMPEP review that fiscal year. The project manager in charge of IMPEP coordination willinform the RSAOs of the proposed IMPEP schedule for the year. ,

B. The RSAO for the respective Agreement State will coordinate with Regional management, Agreement State management, and the OSP Agreement State Project Officer (ASPO) to assure that a suitable date for the meeting is chosen.

C. Once a proposed meeting date has been chosen, the RSAO will send a letter to the Agreement State Radiation Control Program Director a minimum of 60 days before the meeting confirming the date for the meeting. The letter should include a draft agenda, as well an, a request for additional specific meeting discussion topics. Appropriate Regional management, the Deputy Director, OSP, the ASPO, and the senior manager responsible for IMPEP coordination should be on distribution for the letter. A sample letter is attached as Appendix A.

D. In scheduling and planning for the meeting, the RSAO should assure that State attendance at the meeting willinclude at least one radiation control program representative who can speak on behelf o'f the Agreement State program. Preferably, the Agreement State Radiation Control Program Director will attend the meeting. Agreement State program staff attendance at the meeting will be determined by the Agreement State.

E. The RSAO will normally serve as lead for the meeting, if the RSAO cannot serve as lead, the RSAO will reschedule the meeting, or request that the ASPO assume lead responsibility.

F. The ASPO will normally attend the meeting. An alternate OSP staff member may attend the meeting if the ASPO cannot attend.

G. The scope of discussions during the meeting should include (but is not limited to):

1. Agreement State action on previous IMPEP review findings.
2. Strengths and/or weaknesses of the State program as identified by the State or NRC.
3. Status of recently completed State program or policy changes under development including:

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a. Changes in program staff
b. P.ogram reorganizations
c. Legislative changes
d. Redistribution of responsibilities
e. Changes in program budget / funding.
4. Status of NRC program changes that could impact Agreement States.
5. Any internal program audits /self assessments conducted by the Agreement State Radiation Control Program.
6. Status of all allegations previously referred by NRC to the Agreement State radiation control program for action, and methods used to resolve allegations that have been closed.
7. Compatibility of Agreement State regulations.
8. Nuclear Material Events Database (NMED) reporting
9. Schedule for the next IMPEP review.

H. The annual meeting is for discussions and information exchange only, not for a formal evaluation. The annual meeting is not intended to include reviews of licensing, inspection, incident or allegation files.

1. During the meeting, NRC representatives should request introductions to new staff or to staff that they have not met.

J. As time permits, open idea exchanges between NRC and Agreement State staff not in attendance at the meeting is encouraged.

K. The meeting lead should dispatch a summary letter of the meeting to the Agreemert State Radiation Control Program Director within 30 days and provide a copy to appropriate Regional management, the Deputy Director, OSP, the ASPO, and the IMPEP coordinator. The letter should include a list of meeting attendees, a general synopsis of what was discussed during the meeting, and a detailed summary identifying any key facts or changes, both positive and negative, from the meeting which could affect the focus and timing of future IMPEP reviews, or program implementation. The State should be requested to provide comment if they believe that the letter content does not accurately reflect the meeting discussions. A sample letter is attached as Appendix B.

L. If concerns about an Agreement State program are raised during the meeting:

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1.- The RSAO and ASPO should immediately inform OSP management, and recommend a course of action.

2.- OSP management along with the RSAO and ASPO will agree on a

. course of actioni Possible actions include altering the schedule for the next IMPEP review of the specific State, conducting a special review of selected program areasi or setting up additional correspondence or meetings with the State.

3. - Once a formal course of action has been decided, en additional letter signed by the Director, Office of State Programs should be sent to the Agreement State Radiation Control Program Director along with the meeting summary letter. The letter should include an explanation of the specific course of action decided upon by OSP management, the RSAO, and the ASPO, as well as a detailed summary of the reasons behind the decision. A sample letter is attached as Appendix C.

Attachments:

Appendix A

-Appendix B Appendix C a

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l Appendix A l

[ RADIATION CONTROL PROGRAM DIRECTOR) l

Dear (Director):

Since (State)is not scheduled for an Integrated Materials Performance Evaluation Program (IMPEP) review for FY [yearl, we request a meeting, no longer than one day, to discuss your Agreement State program and share programmatic information. This letter confirms that, after previous coordination, the meeting is scheduled for [datel and will be held in your offices. [ASPO], Office of State Programs assigned as Project Officer for (Statel, will be the other NRC representative in attendance.

The topics to be discussed at the meeting willinclude:

1. Agreement State action on previous IMPEP review findings.
2. Strengths and/or weaknesses of the State program as identified by the State or NRC. ,
3. Status of recently completed State program or policy changes under development including:
a. Changes in program staff
b. Program reorganizations
c. Legislative changes
d. Redistribution of responsibilities
e. Changes in program budget / funding.
4. Status of NRC program changes that could impact Agreement States.
5. Any internal program audits /self assessments conducted by the Agreement State Radiation Control Program.
6. Status of all allegations previously referred by NRC to the Agreement State radiation control program for action, and methods used to resolve allegations that have been closed.
7. Compatibility of Agreement State regulations.
8. Nuclear Material Events Database (NMED) reporting.

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9. . Schedule for the next IMPEP review. l 1

If there are any additional specific topics you would like to cover, or if you would like to l focus on a specific area, please let me know, if you have any questions, please call me at IRSAO phone number), or e-mail to IRSAO e-mail address).

Sincerely, IRSAO) cc: ISLO)

[ASPO) 6 Revision 0 9/8/97 4

Appendix B

[ RADIATION CONTROL PROGRAM DIRECTOR) -

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, . Dear'!Directorli.

This year's' annual meeting with (State) was held on (date). The purpose of this meeting was to review and discuss the status of IState's) Agreement State program. The NRC was represented by [ASPO and/or other OSP staff) from the NRC's Office of _ State Programs,-

4 lany additional NRC staff in attendance including Regional staffj and me.~ Specific topics and issues of importance discussed at the meeting included (list a few topics discussed at

- the meeting that were particularly noteworthy).

I have completed and enclosed a general meeting summary, including any specific actions that will be taken as a result of the meeting, if you feel that our conclusions-do not accurately summarize the meeting discussion, or have any additional remarks about the meeting in general, please c,ontact me IRSAO phone

number), or o' mall to (RSAO e mail address) to discuss your concerns.

Sincerely, IRSAO)

Enclosure:

As stated cc:. ISLO)

[ASPO) h 1

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AGREEMENT STATE ANNUAL MEETING

SUMMARY

FOR ISTATE)  !

. DATE OF MEETING: IDATE)

ATTENDEES: NfiG STATE ,

(RSAO)

(ASPO)

DISCUSSION:

[ list main discussion topics of importance individually) l CONCLUSIONS:

Conclusion #1 (conclusion as applicable)

' Action #11(as applicable)

Cuncluslen #2:(conclusion as applicable)

Action #2: las applicable)

Conclusion #3:lecnclusion as applicable) -

Action #3: las applicable) 8 Revision O 9/8/97

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i Appendix C (RADIATION CONTROL PROGRAM DIRECTOR) i

Dear (Director):

This letter is to inform you that concerns abed your program have beers reised due to discussions at the annual meeting with (State) held on (date). The annual meetings were created to help all parties involved remain knowledgeable of an Agreement State's radiation control program and to conduct planning for the next IMPEP review. In the case that concerns are raised due to discussions at en annual meeting, the Office of State Programs can decide to alter the schedule for the next IMPEP review of the specific State, conduct a special review of selected program areas, or set up additional correspondence or meetings i with the State.

The concerns about your program include:

llist in detail each individual concern ahnut the prog c.r)

Due to these concerns, the Office of State Programs has decided to Igive a detailed description of what action will be taken). ,

We ask that you respond to this letter in writing within 30 days, if you have any questions, please contact IRSAO), RSAO of Region (reglon), or the.

Sincerely, ,

IDirector, Office of State Programs) cc: IRSAO) .

ISLO)

[ASPO) 9 Revision 0 9/8/97

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