ML20237H904
| ML20237H904 | |
| Person / Time | |
|---|---|
| Issue date: | 05/29/1987 |
| From: | Bangart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Sjoblom G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20237H486 | List: |
| References | |
| FOIA-87-402 NUDOCS 8708170406 | |
| Download: ML20237H904 (2) | |
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Glen L. Sjoblom compnion step needs to be taken to adeqtately deal with some problem or potential problem licensees in addition to the counselling described in the draft inspection procedure and increased inspection coverage. This companion step shculd be an e/aluation of the problem. indicators from a licensing
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ciewpoint. In addition to informal inspection counselling, it may be important-
' to establish a firm regulatory base by adding'or revising licensing conditions that will address a deficient aspect of the licensee's operation. (e.g. ,
training, audits, and management involvement). Thi.s could be done through an Order, if necessary, or through the vehicle of a letter requesting the licensee to amend his license by adding a condition that is agreed to as necessary. This latter technique is used in the reactor and uranium mill licensing areas, but is rarely used in materials licensing. We support the increased use.of this licensing approach in the materials program.
The licensing aspects of this subject are deserving of further comment. For example, in the background section of the transmittal memo, it is' stated that t "... licensing staffs ascertain whether the licensee is fully qualified and dedicated to carrying out his responsibilities.. and fully understand what NRC requirements are, what NRC expects by way of performance and what NRC actions
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will be taken if violations occur." We contend that premise is false, at least in large part. We have not established, as an egency, a licensing process that establishes the level of confidence described in the quoted statement. However, that is at the very heart of the matter and the area in most need of our good thinking and focussing of effort. We should revise our j
licensing process so that it does address those very fundamental questions, <
If those questions are not satisfactorily answered, NRC should not issue a license or should issue only an~ appropriately conditioned license. We urge an integrated licensing / inspection approach in dealing with many materials program issues. The instant subject of performance indicators is an ideal candidate for application of such an approach.
Indicators that might be considered in addition to those listed in Section 05 l l! are:
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- Licensee attitudes during inspection 5
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- Quality of response to NOV l1l
- Quality of reports to NRC I
- Allegations
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- Feedback from Agreement States
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- Company changes (name, address, personnel, financial, corporate, etc.)
We suggest that the procedure be redrafted, as a result of these and other ,
l Regions' comments, and that the redraft be sent to the Regions for review.
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{ck&tk Richard L. Bangart, Dire or ~
Division of Radiation Safety ~ ~ ~
and Safeguards l .
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