ML20248L718
| ML20248L718 | |
| Person / Time | |
|---|---|
| Issue date: | 03/16/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9803240108 | |
| Download: ML20248L718 (4) | |
Text
__ _ _ _ - _ _
e y,
March 16, 1998 MEMORANDUM TO:
Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards FROM:
Hubert J. Miller (Original Signed by William Axelson for:)
Regional Administrator
SUBJECT:
COMMENTS ON DRAFT 1998 REGION I INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM (IMPEP) REPORT This is in response to your memorandum of February 27,1998 which requested our review and comments on the draft 1998 IMPEP report for Region 1. As you know, Region I was the first Region to be evaluated under the pilot indicators in 1994 and this represents our third review under IMPEP. We have seen considerable change and refinement in the program over time.
As a result these reviews represent a significant opportunity to improve our performance in implementation of NMSS programs. The 1998 team was thorough and professional in its -
approach to and execution of the review, resulting in relatively little impact on the staffs ability to continue its ongoing work.
Our specific comments on facts contained in the report are relatively limited and are contained in the Attachment. We would like to comment here on actions taken and planned to address the two recommendations for Region I action resulting from the review.
With respect to the first recommendation, that Region i ".. continue efforts to improve its timeliness in conducting initial inspections in accordance with IMC 2800 guidelines..."
we have taken several steps since the team's visit was completed on January 30,1998. First, j
we have inspected all initial licensees that were identified as overdue by the team as well as several others that were beyond the scope of the team's inquiry. We have also made modifications to the staffs entry of data into the Licensing Tracking System (LTS) to assure that initial inspections take place within the 12 months identified in IMC 2800. In addition, DNMS management has conducted root cause analysis in an effort to better understand the circumstances that led to this finding not being closed out during the review. Further, we intend
})
to ensure that all DNMS self-audits will evaluate our effectiveness and conformance relative to 3
overall program guidance, as delineated in the Inspection Manual, Management Directives and other documents. The combination of these activities along with a planned audit every six months of all new licenses issued by the Division to assure that inspections have been conducted as required give us confidence that we will be in compliance with the requirements of IMC 2800.
CONTACT:
George Pangbum, DNMS (610) 337-5283 Q1 0FFICIAL RECORD COPY ge980316
)
PDR r,
e
CarlJ. Paperiello 2
With respect to the second recommendation, that Region i ".. implement a process to ensure that each NOV receives a licensee response in a timely manner...", we are conducting a i
thorough review of our inspection report records and are implementing appropriate followup actions. We believe that the existing administrative processes are sufficient to prevent j
recurrence, but that we need to provide greater management attention in this area. Specifically, we plan to provide the Branch Chiefs with a report from the Inspection Planning System each week that identifies each inspection where a licensee response has not yet been received.
Those inspections which are approaching the 30 day response will be discussed as part of our weekly planning meeting. In addition, we plan to have the Licensing Assistance Team review the suspense copies of inspection reports at the end of each month to identify and provide to the Branch Chiefs any reports for which licensee responses to NOVs are due or overdue.
We look forward to discussing these recommendations as well as other aspects of our materials and decommissioning program with you at the Management Review Board meeting.
Attachment:
Specific Comments on Factual Statements in the Draft RIIMPEP Report cc w/ attachment:
S. Moore, NMSS D. Cool,, NMSS F. Combs, NMSS J. Piccone, NMSS G. Deegan, NMSS 1
i I
t_
L o
CarlJ. Paperiello 3
Distribution:
PUBLIC H. Astwood R. Bellamy F. Costello J. Kinneman M. Shanbaky l
l DOCUMENT NAME: G:%I\\98-39.GCP To recalve a copy of this -r= :--- _.;. inacate in uw box: "c" = copy without anachmenWonclosure "F = Copy wnh attachmelt/ enclosure "N" = No copy 0 FICE Rl/DNMS/#
l RI/DNMS O l
Rl/R% L/(, t l /
l l
NAME GPangbuhf' RBlough T HMillfpg DATE 03/13/98 03/ga/98 03/ ////98 03/
/98 03/
/98 0FFICIAL RECORD COPY I
l
-___---_--_--__a
SPECIFIC COMMENTS ON FACTUAL STATEMENTS IN THE Paoe/Paraoraoh/Line Comment Page 7, Paragraph 3, Line 3 The report states that "RI grants reciprocity for a single calendar year, and closes the files at the end of each calendar year." This statement may give the impression that RI is unique in this regard, when in fact, all Regions and the regulations themselves are geared toward dealing with reciprocity on a calendar year basis. We suggest that the statement be modified by adding the introductory phrase, " Consistent with the regulations contained in 10 CFR Part 150,.. "
Page 8, Paragraph 5, Line 9 This line mentions that the overhire situation in RI may grow, in part, "...because of the reduc 9d number of inspections needed with Massachuseta as an Agreement State.. " There is, indeed, potential for vowth in our overhire situation, but not for the reason stated. The FY98 Budget and Operating Plan have already accounted for the loss of these former RI licensees to the Commonwealth of Massachusetts in its capacity as an Agreement State and therefore, this factor will have no additional effect on the overhire situation. We suggest that this phrase be deleted.
Page 9, Paragraph 3, Line 1 The referenced training on the Decommissioning Handbook took place in February,1998, as scheduled.
Page 14, Paagraph 2, Line 5 The biweekly ARB meetings are not intended "..to review any existing allegation files for closure...." These meetings focus on review and action plan / assignment of new allegations received in the previous two weeks as well as specific allegations for which newly-received information warrants a "repaneling." Review of existing allegations for closure is accomplished as part of a monthly review which is discussed in paragraph 3 of page 5.
Page 14. Paragraph 3, Line 2 This line indicates that the "... Senior Allegations Coordinator generates statisticalinformation on allegations on a monthly basis.. " and that this information is the basis for a meeting between DNMS management and the allegations staff. In fact, reports developed by the SAC include statistical information (i.e., allegation performance indicators) and detailed status of all open allegations. Our monthly meeting uses the detailed status report to focus on management actions necessary to assure prompt and procedurally correct followup of those allegations.
Attachment
SPECIFIC COMMENTS ON FACTUAL STATEMENTS IN THE DRAFT RI IMPEP REPORT Paae/Paraaraoh/Line Comment Page 7, Paragraph 3, Line 3 The report states that "RI grants reciprocity for a single calendar year, and closes the files at the end of each calendar year." This statement may give the impression that RI is unique in this regard, when in fact, all Regions and the regulations themselves are geared toward dealing with reciprocity on a calendar year basis. We suggest that the statement be modified by adding the introductory phrase, " Consistent with the regulations contained in 10 CFR Part 150,..."
Page 8, Paragraph 5, Line 9 This line mentions that the overhire situation in RI may grow, in part, "...because of the reduced number of inspections needed with Massachusetts as an Agreement State...." There is, indeed, potential for growth in our overhire situation, but not for the reason stated. The FY98 Budget and Operating Plan have already accounted for the loss of these former RI licensees to the Commonwealth of Massachusetts in its capacity as an Agreement State and therefore, this factor will have no additional effect on the overhire situation. We suggest that this phrase be deleted.
Page 9, Paragraph 3, Line 1 The referenced training on the Decommissioning Handbook took place in February,1998, as scheduled.
Page 14, Paragraph 2, Line 5 The biweekly ARB meetings are not intended "...to review any existing allegation files for closure...." These meetings focus on review and action plan / assignment of new allegations received in the previous two weeks as well as specific allegations for which newly-received information warrants a "repaneling." Review of existing allegations for closure is accomplished as part of a monthly review which is discussed in paragraph 3 of page 5.
Page 14, Paragraph 3, Line 2 This line indicates that the "... Senior Allegations Coordinator generates statistical information on allegations on a monthly basis..." and that this information is the basis for a meeting between DNMS management and the allegations staff. In fact, reports developed by the SAC include statistical information (i.e., allegation performance indicators) and detailed status of all open allegations. Our monthly meeting uses the detailed status report to focus on management actions necessary to assure prompt and procedurally correct followup of those allegations.
Attachment d