ML20237H883
| ML20237H883 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1987 |
| From: | Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Sjoblom G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20237H486 | List: |
| References | |
| FOIA-87-402 NUDOCS 8708170396 | |
| Download: ML20237H883 (1) | |
Text
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t, NUCLEAR REGULATORY COMMISSION REDON V 1 1450 MARIA LANE,5UITC 210 h4 '
WALNUT CREEK, CALIFORNIA Mbt 6 9
MAY 19 B8T ,
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MEMORANGUM FOR: Glen L. Sjoblom Deputy Director Division of Fuel Cycle, Medical Ac6demic and Comercial bse Safety, NMSS FROM: James L. Montgomery, Chief Nuclear Materials Safety and Safeguerds Branch
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SUBJECT:
DRAFT INSPECTION PROCEDURE 89100, "USE OF PERFORMANCE j l INDICATORS TO IDENTIFY LICENSEES FOR ENHANCED
! INSPECTION / ATTENTION" I
n We have reviewed the draft inspection procedure relative to the above-I subject matter. We have the following coments:
- 1. The procedure does not specifically state that it applies to both the 2600 and 2800 programs. If that was not the intent, perhaps the procedure could be changed to incorporate both program areas. j l 2. Section 05.04 makes reference to a CAL to confim that the licensee had submitted the QA/QC procedures. If a licensee submits the procedures voluntarily, we see no reason for the CAL. However, if the licensee is unresponsive, then the CAL or order would be more appropriate.
- 3. Scction 05.05 makes reference to excessive contamination outshie the .,
restricted area for which the licensee could be cited. 10 CFR 20.105 or J 20.106 does not address this matter as loose contamination. Presently, i the svailable guidance in this. area is contained in Regulatory Guides 8.21, 8.23, and 8.24; however, these RGs are particular to certain types of facilities. Since these documents are for guidance only, they are j not saforceable from the standpoint of'a citation, j l 4e The overall content of the draft inspection procedure appean to be j adequate with the exceptions noted abcVe. .
We appreciate the opportunity to coment on the draft of Inspecticn Procedure 89100, pp gr 4
., L 99 I
y d. Nx & n
, James L. Montgomery, Chie Nuckar Matertals Safety and Safeguards Branch-u / -
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