ML20149L214

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Responds to Memo to Cd Pederson Dtd 970305 Requesting Regional Review & Comment Re Draft non-common Performance Indicators for Reviews of Site Decommissioning Mgt Plan & Fuel Cycle Program
ML20149L214
Person / Time
Issue date: 04/28/1997
From: Caniano R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Cool D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20149J917 List:
References
NUDOCS 9707310196
Download: ML20149L214 (2)


Text

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g/*%g*g UNITED STATES NUCLEAR REGULATORY COMMISSION

.. A S REGloN ill 3

I 801 WARRENVILLE RoAo

]; ,/ UsLE. ILUNots 60632-4351 April 28, 1997 MEMORANDUM TO:' /D nald A. Cool, Director Division of Industrial and Medical Nuclear Safety Nuclear Materials Safety and Safeguards l FROM:

Roy J. Caniano, Acting Director Division of Nuclear Materials Safety,

[ 2 wk

SUBJECT:

i COMMENTS ON THE IMPEP NON COMMON INDICATORS FOR THE SITE DECOMMISSIONING MANAGEMENT PLAN j AND THE REGIONAL FUEL CYCLE PROGRAM (Rill AlTS #97-0039)

This is in response to your memorandum to C. D. Pederson dated March 5,1997, 4

requesting regional review and comment concerning the draft non-common performance

' indicators for reviews of the Site Decommissioning Management Plan (SDMP) and the Fuel Cycle Program as part of the integrated Materials Performance Evaluation Program (IMPEP).

l As suggested in your memo, we focused our review on issues of proper depth and detail l for the indicators, to sufficiently address the target focus areas and .to fit into the overall IMPEP guidance.

Overall, we concluded that the indicators were well constructed hom the perspective of depth and detail and we believe they address the target focua as..:s quite well. They include sophisticated guidance involving trend and root-cause reviews where appropriate.

, in addition, they appear to fit well into the overall IMPEP review structure.

The attachment to this memorandum contains our specific comments, along with notes of j a minor, editorial nature, i

i-We appreciated the opportunity to provide feedback on this document. An electronic copy of these comments was forwarded to Scott Moore on the date of signature.

Attachment:

as stated cc w/att: A. Randolph Blough, RI

, Bruce S. Mallett, Ril Ross A. Scarano, RIV John T. Greeves, DWM CONTACT: B. L. Jorgensen (BLJ) 630/829-9615 i

?

Q73g196970724 SSD PDR

COMMENTS ON IMPEP NON-COMMON PERFORMANCE INDICATORS FOR FUEL CYCLE FACILITIES AND SDMP PROJECTS General

1. For the Fuel Cycle program, Part ll (page 6) recognizes the difficulties in scheduling and paying for specialized courses for the small number of fuel facilities inspectors who may need unique training at any one time. The same sort of consideration should be included in the Part 111 Evaluation Criteria for staff training and qualification.

2 Both Part il and Part 111 should, in addressing response to incidents (pages 7 and 20, respectively) make reference to regional capabilities to respond in coniunction with NMSS. These are mutual responsibilities; the region should be judged on holding up its end.

3. Accountability for SDMP project management functions is assigned to the Division ,

of Waste Management: Part 11 should limit its focus to the responsibilities l assigned to the Region. i f;itorial Attachment 1

1. Page 2, third paragraph, first line: "sub-element"
2. Page 3, second-last line: "lMC Q610" i
3. Page 9, third-last line: suggest "acorooriately updated" vs. " frequently" ,
4. Page 10, first full sentence: replace with "There are few differences inspections scheduled and completed and what is currently intended for each of the facilities."
5. Page 18, second-last line of first bullet: " demonstrates" l Attachment 2
6. Page 1, .ltem 1, second-last line: "... Statements, Safety ..."
7. Page 3, second line: delete repetitive " discussion of the"  ;
8. Page 3, item 3, last line: add space before the word " clarity" l

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