ML18107A150

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Ohio Department of Public Safety
ML18107A150
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 04/12/2018
From: Salz C
State of OH, Dept of Public Safety
To: Allan Barker
NRC/RGN-III
Barker A
References
Download: ML18107A150 (3)


Text

~ OHIO DEPARTMENT John R. Kaslch. Govemo,

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  • Emergency Medical Services
  • Office of Criminal Justice Services Emergency Management Agency
  • Ohio Homeland Security 2855 West Dublin-Granville Road
  • Ohio State Highway Patrol Columbus, Ohio 43235-2206 (614) 889-7150 www.ema.ohio.gov April 12, 2018 Mr. Allan Barker State and Government Affairs for Region Ill Nuclear Regulatory Commission 2443 Warrensville Road Lisle, Illinois 60605-4351

Dear Mr. Barker:

This letter requests permission to observe the NRC Inspection scheduled for the week of April 23, 2018 at the Perry Nuclear Power Plant. In support of Utility Radiological Safety Board Joint Inspection Observation Program activities, Ohio Department of Health would like to send a representative to that inspection to cover In-Plant Airborne Radioactivity Control & Mitigation and Occupational Dose Assessment and asks that you please coordinate this request with the lead NRC inspector, Steve Bell.

The person who will be observing this inspection for Ohio Department of Health is Craig Helm, a Senior Health Physicist in the Health and Safety Section of the Bureau of Environmental Health & Radiation Protection.

Sincerely, Christopher M. a State Liaison Officer CS/lbw Enclosure Mission Statement RECEIVED APR 1 7 2018 To coordinate activities to mitigate, prepare for, respond to, and recover from disasters

Protocol Agreement for State Observation ofNRC !11,pections NR(

  • Protornl:
  • The Regional State liaison Offa:er (RSLO) will norn1,tlly be the lead individual rc~ponsible for tracking reqm:sts fo1 State r,bservatit1n. assuring consislem:y regarding these request:.. and for advising the Regional Admimstrator on the dispositioM oftlte:-e requests. Tlw nppropriatc tecl!nical representative or Division Director will communicate with the State 0n specific is~ues coneeming the inspcctions(s).
  • Requests for ubservatious of Heudquarter-based inspections will also be coordinated tlu-ough the RSLO.

!le11dqullrters-hased inspection.-: ,;hould be referred through the RSLO to a technical representative designated by the Region.

  • NRC wili process written re4uests to the Regional Administrator through the Slate Liaison Officer (SLO).

Requests should iden!ily the type of inspection activity and facility the State wishes to observe.

  • Limits ,m srnpe and dt1ration of the observation period may b.- imposed if~ in rhe view nf the Regional Administrator, they compromise the efficiency or effec!iveness of rhe inspection. Regions should u~e their discrcriou a~ to which. if any. inspections will be* e;,..dudcd from ohsen*ations.
  • Statt' v.ili he informed they must 1w1 release information conc~~rning: the rime and purpose ofunanmmnced inspection~.
  • The Region wiil make it dear to the Hcen~ec that the Staie views arc not necessarily endorsed by NRC. The Region ,viii also make it clear that only NRC has regulatory authority for inspection findings and enforcement actions regarding radiological health and safoty.

State Pwtocol:

  • A State will make advance armngemcnts with the licensee for site access training and badging (subject to fitness for duty requirements). prior to the actual irn,pectkm.
  • Normaliy. 110 more than one individual wiil be allowed to observe an NRC inspection.
  • The Stare will b" responsible for <letemiining ihc technical and professional competence of its rcpresemativcs who accompany NRC in,;pecwrn.
  • An ohscrvet's rnmmunication with the iicensee will"be through the appropriate NRC team member, usually the senior residem inspector or 1he team leader.
  • When infom1ed of an unam1our1c1::d inspection, a State must m:,t reka:::e infom1ation concerning i1s time and purpose:.
  • An ohserver \\"ill remain in the company ofNRC personnel throughout the course of the inspection.
  • State observation may he terminat,'d by the NRC if the observer's conduct interferes with a fair and orderly inspection.
  • f\n observe; will not be provided "ith proprit:tary or *s.aleguards informati_on. Observers will not remove any material from the site without NRC or lice11see approval.

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  • The Siatc ohrerver, in ac(*ompanying the NRC inspec_tors. does so al his or her own risli.. NRC will not be responsible for injuries or exposures to harmful substances which may occur to the accompanying individual during 1he inspection and will assume no liability for any incidents associated with !he accompanimcm.
  • The State observer will be expected to adhere to the same conduct as NRC inspectors during an inspection accompaniment.
  • If the State observer notices any apparent non-coufonnance with safety or regulatory requirements during the inspections, he/she will make those obsen,ations promptly kM\Vn to the NRC team leader or lead imipector.

Likewise, when overall conclusions or views of the State obseiver are substantially different from those of the NRC inspectors, the State will advise the team leader or lead inspector and forward those views, in \\Titing. 10

!he NRC Region. This will allow NRC to take any necessary regulatory actions.

  • Under no circumstances should State communications regarding these i11spe{:tio11s be released Lo the public or the licensee before they are reviewed by tl1e NRC and the inspection report is isl'ued. State communications may be made publicly available, similar to NRC inspection reports. after they have been transmitted to and reviewed by NRC.

Adjacent Stale Protocol:

  • A11 adjacent State is a State within the plume exposure pathway emergency planning zone (EPZ) (within approximately a IO-mile radius) ofan NRC-licensed facility located in another State. A host State is a State in which an NRC-Jicensed facility is located. A.11 adjacent State may request pemlbsion to obseive NRC inspections at an NRC-licensed facility in a host State.
  • The adjacent Stare SLO must communicate his/her request for observation to the Regional Administrator for the region in which the facility is located.
  • The ~jacent State SLO must also communicate his/her request to the ho:-1t State SLO so that each State is aware of the other's intentions.
  • If a host State and an adjacent State request observation of the same inspection, the Regional Administrator will make the final detcnninalion on the number of State observers who may attend the inspection. Jf there i~ a need to limit the numbers of observers, the Regional Administrator will routinely give preference 10 the host State observers.
  • Adjacent State observers will abide by the same protocol in all aspec.ts of the inspection as host States under this agreement.

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11 Signature f Slate Observer