ML21061A344
| ML21061A344 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/2021 |
| From: | Mary Muessle, Kevin Williams Division of Nuclear Materials Safety IV |
| To: | |
| References | |
| Download: ML21061A344 (5) | |
Text
JOINT NRC/AGREEMENT STATE WORKING GROUP CHARTER:
UPDATING THE FUEL CYCLE AND MATERIALS DECOMMISSIONING INSPECTION PROGRAM PURPOSE The working group (WG) will: (1) update the fuel cycle, uranium recovery, and materials decommissioning inspection program guidance to implement Commission policy regarding risk-informed, performance-based inspections; (2) identify and incorporate recent decommissioning guidance and regulatory changes into the inspection program; (3) develop new decommissioning inspection procedures (IPs) for select inspection areas as needed; (4) create inspection efficiencies in the decommissioning program; and (5) provide training and introductory seminars for NRC staff, Agreement States, and other stakeholders prior to full implementation of the revised inspection program.
The WG will ensure that the revised inspection program guidance is consistent with the mission of the NRC and that the revised program remains protective of public health and safety, the environment, and security of licensed material. The WG will evaluate and incorporate risk and performance insights as well as operating experience associated with each inspection area (uranium recovery, fuel facilities, etc.). All changes will be reviewed for policy considerations and communicated for review and/or approval as warranted.
BACKGROUND Inspection Manual Chapter (IMC) 2602, Decommissioning Oversight and Inspection Program for Fuel Cycle Facilities and Materials Licensees, was last revised in July 2008. This IMC includes decommissioning inspections for licenses issued under Title 10 to the Code of Federal Regulations (10 CFR) Parts 30, 40, 70, and 72. The WG plans to update and modernize IMC 2602. In addition, the WG will incorporate the decommissioning inspection guidance for uranium recovery and 11e.(2) byproduct materials licenses currently provided in IMC 2641, In-Situ Leach Facilities Inspection Program, and IMC 2801, Uranium Recovery and 11e.(2)
Byproduct Material Facility Inspection Program, into IMC 2602.
In 2020, other NRC inspection-related WGs conducted work on the Fuel Cycle Smarter Inspection Program, Independent Spent Fuel Storage Installation (ISFSI) Inspection Program Enhancement Initiative, operating uranium recovery inspection program, and reactor decommissioning inspection program. These WGs implemented risk-informed and performance-based changes to their respective inspection oversight programs. Similarly, the Materials Inspection Program WG is currently implementing changes to the materials inspection program as described in IMC 2800, Materials Inspection Program. Under this charter, the Fuel Cycle and Materials Decommissioning Inspection Program WG would similarly revise IMC 2602 and its related IPs.
MEMBERSHIP The WG will be established and managed in accordance with NRC Management Directive (MD) 5.3, Agreement State Participation in Working Groups, dated June 22, 2016.
The MD can be found on the NRCs public website at: https://www.nrc.gov/reading-rm/doc-collections/management-directives/. The WG will also adhere to the instructions provided in NRC Procedure SA-801, Agreement State Participation in Working Groups. This procedure can be found at https://scp.nrc.gov/procedures.html.
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The NRC sponsor for the WG is the Division of Nuclear Materials Safety (DNMS), Region IV Office (RIV). The Business Line owner is the Division of Decommissioning, Uranium Recovery, and Waste Programs (DUWP), Office of Nuclear Material Safety and Safeguards (NMSS). The NRC executives who will provide high-level oversight of the WG include the Director, RIV/DNMS and Director, NMSS/DUWP. The NRC executive staff will be supported by the Organization of Agreement States Executive Board or its designee.
The WG will be led by one or two individuals serving as chair or co-chairs, ideally with one representative from Region IV and a second representative from an Agreement State. The WG will consist of individuals as described below (the names and titles of the individuals will be specified in the project plan):
x Three staff members from NMSS x One staff member from Region I DNMS x One staff member from Region II Division of Fuel Facility Inspection (DFFI) x One staff member from Region III DNMS x One staff member from Region IV DNMS x Up to three Agreement State staff members The primary qualities required for the WG members are knowledge of the decommissioning inspection program and openness to innovative ideas. Technical experts may be needed for specialized work such as groundwater remediation, disposal cell construction, radioactive material transportation, and statistics. These technical experts may be requested to support the WG as needed. An information technology specialist will support the WG but will not be a formal member of the group.
The WG will be supported by a guiding coalition of NRC and Agreement State staff members at the supervisory level. The guiding coalition will provide perspectives to the WG and serve as change agents during the process. As possible, the guiding coalition will consist of eight individuals as described below (the names and titles of the individuals are provided in the project plan):
x Four branch chiefs (or designee) from each of the four NRC regions x Two branch chiefs from NMSS x One Agreement State supervisor x One NMSS riskSMART representative The guiding coalition includes a riskSMART representative to ensure that the WG considers the risks associated with the decision-making processes.
OBJECTIVES The primary objectives of the WG are to: (1) design a fuel cycle and materials decommissioning inspection program that is both risk-informed and performance-based; (2) incorporate the decommissioning program requirements for uranium recovery and 11e.(2) byproduct material sites from IMCs 2641 and 2801 into IMC 2602; (3) update IMC 2602 and associated IPs accordingly; and (4) provide training and introductory seminars for stakeholders (NRC staff, the 2
Agreement States, and other stakeholders) prior to implementation of the revised inspection program.
The WG will not develop decommissioning procedures for 10 CFR Part 72 licenses, including ISFSI licensees, because there are no IFSFIs that will be decommissioned in the near term.
If an ISFSI begins decommissioning in the near term, the NRC will develop a site-specific inspection plan as needed.
OPERATING RULES The WG chair(s) are responsible for implementation of the WG as described in MD 5.3,Section III.E. All members assigned to the WG will fulfill their responsibilities in accordance with MD 5.3,Section III.G. Members of the WG should expect to provide a substantial commitment to this project until its objectives are completed.
The WG effort began with an introductory meeting in early February 2021. Priority tasks include finalizing the charter and project plan. In mid-February, a 3-day project launch was conducted to develop a comprehensive understanding of the project, construct the conceptual backbone or model of the IMC and IPs, brainstorm means by which to solicit input from the inspection staff, establish milestones, and gain alignment on the path forward. By March 5, 2021, the WG should provide the Executive Sponsor and Business Line owner with a high-level schedule for the proposed work activities.
The WG will conduct regular briefings with the guiding coalition and with NRC management to provide updates of the project. Updates will include significant activities completed, resource needs, and milestone changes. If the WG encounters any policy issues or challenges, these issues will be discussed with the guiding coalition and/or management as needed. The WG will provide updates to the guiding coalition and NRC/OAS EB management at least monthly. The WG chair(s) will be prepared to brief the NMSS Front Office at least every other month during the life of the project.
The WG will identify and update the core and discretionary IPs. The core procedures include fuel cycle facilities (IP 88104), uranium recovery (IP 87654), and materials (IP 87104) decommissioning procedures. By March 31, 2021, the WG will also identify all discretionary procedures that will need to be updated. The list of procedures and the status of the revision process for each IP will be tracked by the WG in the project plan. The WG is expected to revise and publish all procedures by December 31, 2021.
The WG will ensure that terminology used in the revised inspection program is consistent with agency-wide definitions. Any terminology that is inconsistent with standardized meanings will require approval by the Business Line owner (NMSS/DUWP) prior to implementation.
STAKEHOLDER INVOLVEMENT The WG and guiding coalition include Agreement State representatives. The WG should broadly solicit ideas and comments from stakeholders including NRC staff and other State agencies not participating in the working group. The WG should consider interactions with external stakeholders including other Federal agencies, Tribes, industry, and the public. These interactions may occur at the beginning of the process to provide transparency regarding the WGs activities and/or may occur toward the end of the process to describe the results of the 3
WGs efforts. The WG will develop a communication strategy and associated communication plans for any meetings, presentations, or discussions involving external stakeholders.
As noted above, the WG should consider soliciting comments or input from other government agencies and Tribes. As necessary, the WG will be supported by NRC staff who act as liaisons between the NRC and these other agencies. These liaisons may include NMSS/SALB staff, the regional government liaison officers, and the regional state liaison officers.
TAC Number: All NRC time expended on WG activities may be charged to CAC A35009 and EPID V-2021-IMC-0000.
Digitally signed by Mary C.
Mary C. Muessle Muessle Date: 2021.03.02 18:42:18 -06'00' Mary Muessle, Director,Digitally NRC/RIV/DNMS signed by Patricia K. Date Patricia K. Holahan Date: 2021.03.03 10:52:46 Holahan -05'00' Patricia Holahan, Director, NRC/NMSS/DUWP Date Digitally signed by Kevin Williams Kevin Williams Date: 2021.03.03 11:00:57 -05'00' Kevin Williams, Director, NMSS/MSST Date Mary Muessle for Mary C. Digitally signed by Mary C.
Muessle Muessle Date: 2021.03.03 17:09:36
-06'00' William Irwin, Designee, OAS EB Date Organization of Agreement States Executive Board 4
_ SUNSI Review ADAMS: Non-Publicly Available _ Non-Sensitive Keyword:
By: RJE _ Yes No _ Publicly Available Sensitive NRC-002 OFFICE DNMS:MLDB C:MLDB D:NMSS/DUWP D:NMSS/MSST NAME RJEvans HJGepford THolahan KWilliams SIGNATURE /RA/ /RA/ /RA/ /RA/
DATE 02/12/21 02/19/21 03/03/21 03/03/21 OFFICE OAS EB D:RIV/DNMS NAME WIrwin, VT MMuessle SIGNATURE /RA/ /RA/
DATE 03/03/21 03/03/21