Draft Procedure SA-116, "Periodic Meetings Between IMPEP Reviews"

Procedure SA-116 Periodic Meetings between IMPEP Reviews.docx

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Draft Procedure SA-116, "Periodic Meetings Between IMPEP Reviews"

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Office of Nuclear Material Safety and Safeguards

Procedure Approval



Periodic Meetings between IMPEP Reviews-SA-116





Issue Date:


Review Date:




Daniel S. Collins, Director

Division of Material Safety, State, Tribal

and Rulemaking Programs

Date:



Paul Michalak, Acting Branch Chief

Agreement State Programs Branch

Division of Material Safety, State, Tribal

and Rulemaking Programs

Date:



Lisa Dimmick, Procedure Contact

Division of Material Safety, State, Tribal

and Rulemaking Programs

Date:



ML16034A390

NOTE

Any changes to the procedure will be the responsibility of the NMSS Procedure Contact. Copies of the NMSS procedures will be available through the NRC website.

Shape6



    1. INTRODUCTION


This procedure describes the general objectives and process to be followed when scheduling, staffing, conducting, and documenting a periodic meeting with an NRC Region or Agreement State radioactive materials program.


    1. OBJECTIVES


      1. To designate the frequency for periodic meetings.


      1. To establish protocols for scheduling and conducting a periodic meeting.


      1. To identify the appropriate participants for a periodic meeting, including the staff responsible for conducting the meeting.


      1. To define the scope of activities and areas for discussion during a periodic meeting.


      1. To define the methods and the timing for documenting and communicating the results of a periodic meeting.


      1. To specify the appropriate actions to take when performance concerns are identified during a periodic meeting.


      1. To establish the mechanism to communicate periodic meeting results to the Management Review Board (MRB).


      1. To provide guidance on the issuance of “letters of support.”


    1. BACKGROUND


Periodic meetings were created to help NRC Headquarters, the NRC Regions, and the Agreement States remain knowledgeable of the others’ respective programs and to plan for future Integrated Materials Performance Evaluation Program (IMPEP) reviews.

Periodic meetings serve as forums to exchange information, to identify potential areas of improvement for NRC Headquarters, the NRC Regions, and the Agreement State programs, and to address or define significant actions. Periodic meetings are not formal evaluations but are open, interactive discussions of program status and performance.


These meetings should provide for identification and discussion of any program areas experiencing difficulties or program changes (e.g., loss of staff) that could potentially affect performance.



The periodic meeting process has evolved from its early beginnings, to an effective avenue for gathering important performance information. The evolution is attributable to an increased scope of discussions and focus on early indications of performance challenges when present. As a result of the evolution of periodic meetings, Agreement States now have a greater role in the coordination of the periodic meetings, and more actively participating at the MRB meetings.


This procedure documents the expectations for periodic meeting practices which include: (1) increased scope of discussion allowing a better sharing of information between the NRC and the Agreement States; (2) briefing the MRB on the meeting’s results with active participation from Agreement State staff; and (3) earlier identification of program challenges (e.g., staffing shortage, inspection backlogs) and implementation of corrective measures and (4) issuance of “letters of support” that:


  1. Identify early indications of potential program challenges;

  2. Support program requests for additional resources; or,

  3. Recognize the benefits, contributions, success, or history of good performance of a program.



    1. ROLES AND RESPONSIBILITIES


      1. IMPEP Project Manager:


        1. Informs NRC managers, NRC staff, and the Agreement States of the proposed periodic meetings schedule for each fiscal year.


        1. Tracks the issuance of periodic meeting summary reports.


        1. Coordinates and schedules the presentation of the results of periodic meetings to the MRB.


        1. Tracks any action items that result from a periodic meeting or the presentation of results of periodic meetings to the MRB.


        1. Drafts “letters of support,” as directed by the MRB, with support from the Regional State Agreements Officer.

      1. Regional State Agreements Officer (RSAO):


Note: The RSAO’s responsibilities only apply to periodic meetings with Agreement States.




        1. Schedules meetings with each of those Agreement States in his/her Region at the appropriate frequency (as defined in Section V. A of this procedure).


        1. Coordinates a meeting date with the Agreement State program and any other NRC attendees.


        1. Informs the IMPEP Project Manager and appropriate Regional management of the meeting date.


        1. Develops a draft agenda for the meeting in coordination with the Agreement State’s Radiation Control Program Director (RCPD).


        1. Issues, once a meeting date has been established, a letter to the RCPD a minimum of 30 days before the meeting, confirming the date for the meeting. The letter should include the draft agenda that was developed in coordination with the RCPD, as well as a request for any

comments on the draft agenda and/or additional specific meeting discussion topics. A sample scheduling letter and draft agenda for a periodic meeting with an Agreement State can be found on the State Communication Portal webpage (https://scp.nrc.gov/) under the IMPEP Toolbox, as well as, in Appendix A of this procedure.


        1. Schedules and plans the meeting to ensure that Agreement State attendance will include at least one radiation control program representative who can speak on behalf of the Agreement State program. Agreement State staff attendance at the meeting will be determined by the Agreement State.


        1. Reviews all open recommendations from the most recent IMPEP review (if a previous periodic meeting had been held, review the program’s progress on addressing the recommendations as of the date of the meeting).


        1. Obtains and reviews a detailed printout of all Nuclear Material Events Database (NMED) entries since the last IMPEP review or periodic meeting for the respective Agreement State.

        1. Becomes familiar with all allegations and concerns referred to the respective Agreement State since the last IMPEP review or periodic meeting. This information can be obtained from the Regional Senior Allegations Coordinator and the Headquarters Allegations Team in the Office of Enforcement.


        1. Reviews the status of the Agreement State’s regulations as detailed in the State Regulation Status Sheet maintained by NMSS.


        1. Serves as lead facilitator for the meeting. If the RSAO cannot serve as the lead, the RSAO will reschedule the meeting, or request that an alternate NRC attendee lead the meeting. If the RSAO is unfamiliar with an Agreement State for any reason (e.g., RSAO is new to the position or the RSAO was not a member of the previous IMPEP review team), NMSS and/or NRC Regional management may choose to send an alternate staff member who is more knowledgeable about the Agreement State to the meeting. This decision will be made on a case-by-case basis.


        1. Meets with senior State managers to provide a summary of the discussions held with the Agreement State program staff, as appropriate.


        1. Issues the final periodic meeting summary.


        1. Leads the presentation of the results of the Agreement State periodic meeting to the MRB.


        1. Recommends to the MRB issuance of “letters of support”.


        1. Works with the IMPEP Project Manager to draft “letters of support.”



      1. NMSS Designee:


        1. Attends and participates in assigned periodic meetings with NRC Regions and Agreement States. Assignments will be made on a case-by-case basis, depending on expertise of an individual and/or existing performance issues in an NRC Region or Agreement State.

        1. For periodic meetings with Agreement States, coordinates and assists the RSAO in meeting preparation and development of specific information areas to be covered during the meeting, such as event reporting, allegations, and the status of regulations.

        1. Leads the periodic meeting with an Agreement State, if necessary or when requested.




        1. Meets with senior State managers to provide a summary of the discussions held with the Agreement State program staff, as appropriate.


        1. For periodic meetings with NRC Regions, prepares for, conducts, and documents all aspects of the meeting. This includes scheduling the meeting and preparing the agenda in coordination with the Regional Division of Nuclear Materials Safety (DNMS) management, as well as review of Regional self-assessments, operating plan performance, and monthly Regional reports.


        1. Leads the presentation of the results of the NRC Regional Office periodic meeting to the MRB, as appropriate.


      1. Management Review Board (MRB):


        1. Provides a senior-level review of the results of the periodic meetings.


        1. Provides direction on a course of action when performance concerns are identified during a periodic meeting (see Section V.F. below). Any decisions regarding a course of action in response to performance concerns will be communicated directly to the RCPD or DNMS Director either at the MRB meeting or after the meeting by correspondence.


        1. Directs NRC staff on the issuance of “letters of support.”


        1. Membership, additional responsibilities, and protocols of the MRB are defined in NMSS Procedure SA-106, The Management Review Board (MRB).


    1. GUIDANCE


      1. Frequency of Periodic Meetings for NRC and Agreement State Programs


  1. For NRC Headquarters, the NRC Regions and the Agreement State programs that have been rated as Adequate and Compatible for two consecutive IMPEPs with all indicators rated Satisfactory and no recommendations, there is the opportunity to not hold a periodic meeting. In lieu of a periodic meeting, the NRC and Agreement State programs can provide a self-assessment documenting the status of their program. This self-assessment will review all IMPEP indicators for the time period between the last IMPEP review and the mid-point prior to the next full on-site IMPEP review. The review can take into account the items listed in the sub-sections B or C of this guidance section. The self-assessment should be sent to the IMPEP Project Manager. The NRC will have 45 to 90 days to review, depending on the scope of the materials program and will schedule a conference call to discuss the results of the review. If a periodic meeting is not held, the self-assessment and NRC’s review will serve to document the status of the program. There will not be an MRB.


  1. Programs that do not meet the criteria listed above (e.g. have been rated satisfactory and adequate the last IMPEP with recommendations, have been rated less than satisfactory, and/or have been placed on heightened oversight or probation), will be required to hold a periodic meeting.


  1. For those programs on a 4-year IMPEP review cycle, a periodic meeting should take place approximately 24 months after the IMPEP review. For those programs on a 5-year IMPEP review cycle, a periodic meeting should take place approximately 30 months after the IMPEP review.


  1. If additional meetings are required or requested by the MRB, NMSS management, the NRC Region, or the Agreement State, the meeting frequency may be adjusted on a case-by-case basis.


  1. Agreement States may request additional informal meetings, as NRC resources allow. A summary of the discussion held during any informal meeting should be documented in a short letter to the State’s RCPD to serve as a record of the meeting. Special MRBs are not convened to disposition the results of these additional informal meetings. However, if performance issues are identified either through an informal meeting or through day to day interactions, the concerns should be documented and handled in accordance with Section V.F. of this procedure.


      1. Scope of Discussions During Periodic Meetings


As appropriate, topic areas for discussion during the meeting should include the following:


        1. Status of the Region/State’s actions to address all open IMPEP review findings and/or open recommendations.


        1. Feedback on NRC’s program as identified by the State, including identification of any action that should be considered by NRC.


        1. Status of the Region/State Program, including:


          1. Program reorganizations:


  1. Discuss any changes in program organization, including program/staff relocations and new appointments.


          1. Changes in program budget/funding.


          1. Technical Staffing and Training:


            1. Number of staff in the program and status of their training and qualifications

            2. Program vacancies;

            3. Staff turnover;

            4. Adequacy of full-time equivalents (FTE) for the materials program; and

            5. Procedures for inspection and license reviewer qualifications, and their compatibility to equivalent NRC procedures.


          1. Status of Materials Inspection Program:

  1. Number of inspections completed on time and overdue since the last IMPEP.

  2. Number of initial inspections completed on time and overdue since the last IMPEP.

  3. Number of reciprocity inspections completed each year since the last IMPEP.

  4. Inspection frequencies (changes to or those that differ from NRC’s inspection frequencies).


          1. Technical Quality of Inspections


  1. Status of inspector accompaniments.

  2. Management review process.

  3. Significant inspection activities/challenges


          1. Technical Quality of Licensing Actions


  1. Number of licensing actions and types performed since the last IMPEP review.

  2. Large, complicated, or unusual authorizations for use of radioactive materials.


          1. Compatibility Requirements


  1. Changes to legislation affecting the program, if any

  2. Status of State’s regulations and actions to keep regulations up to date, including the use of legally binding requirements and sunset requirements.


  1. Technical Quality of Incident and Allegation Activities:


          1. Number of reportable events received since the last IMPEP and event reporting, including follow-up and closure information in NMED.

          2. Status of allegations and concerns referred by NRC for action;

          3. Significant events and generic implications.


  1. Status of the following program areas, if applicable:


  1. Sealed Source and Device Evaluation Program;

  1. Technical Staffing and Training

  1. Number of qualified SSD reviewers and their signature authority.

  2. Number of current or anticipated program vacancies.

  3. Staff turnover since the last IMPEP review.

  1. Technical Quality of the Product Evaluation Program

  1. Number of cases since the last IMPEP review to include new cases, amendments, in-activations and transfers.

  1. Evaluation of Defects and Incidents Regarding SS&Ds

  1. Cases noted involving manufacturing defects since the last IMPEP review.


  1. Low-level Radioactive Waste Disposal Program and/or Uranium Recovery Program (LLRW/UR)


  1. Technical Staffing and Training

    1. Number of staff in the program and status of their training and qualifications.

    2. Any program vacancies.

    3. Staff turnover since the last IMPEP review.

    4. Adequacy of FTEs for the materials program.

    5. Status of implementation of IMC 1248.


  1. LLRW/UR Status of the Inspection Program


  1. Number of inspection performed overdue since the last IMPEP review.

  2. Number of inspections currently overdue.

  3. Number of initial inspections completed on time and overdue since the last IMPEP review.


  1. LLRW/UR Technical Quality of Inspections


  1. Status of inspector accompaniments.

  2. Management review process

  3. Significant inspection activities/challenges


  1. LLRW/UR Technical Quality of Licensing


  1. Number of licensing actions and types performed since the last IMPEP review.


  1. LLRW/UR Technical Quality of Incidents and Allegations


  1. Status of allegations and concerns referred by the NRC for action.

  2. Significant events and generic implications.

  3. Event reporting, including follow-up and closure information in NMED.


  1. LLRW/UR Compatibility Requirements


  1. Regulations

  2. Discuss status of State’s regulations and actions to keep regulations up to date, including the use of legally binding requirements.

  3. Legislative changes affecting the program.


  1. Information exchange and discussion:


          1. Current State initiatives;


i) Technical Staffing and Training;

ii) Technical Quality of the Product Evaluation Program; and

iii) Evaluation of Defects and Incidents regarding SS&Ds.”


          1. Emerging technologies

i) Technical Staffing and Training;

ii) Status of Low Level Radioactive Waste Disposal Inspection;

iii) Technical Quality of Inspections;

iv) Technical Quality of Licensing Actions; and

v) Technical Quality of Incident and Allegation Activities;


          1. Large, complicated, or unusual authorizations for use of radioactive materials;


i) Technical Staffing and Training;

ii) Status of the Uranium Recovery Program;

iii) Technical Quality of Inspections;

iv) Technical Quality of Licensing Actions; and

v) Technical Quality of Incident and Allegation Activities


          1. Major decommissioning and license termination actions;


          1. State’s mechanisms to evaluate performance; and,


          1. Current NRC initiatives.


  1. Schedule for the next IMPEP review.


  1. Action items resulting from the periodic meeting (these should be documents in the meeting summary report). [Note: the meeting should not be used by the States to refer major policy issues to NRC since these are addressed through other mechanisms].


  1. Additional topics, next steps, meeting summary and question and answer session.


  1. Exit with Senior Management if requested by the Agreement State.


  1. Evaluation of Casework during Periodic Meetings


  1. As discussed in Section III of this procedure, periodic meetings are not formal evaluations of program performance. Reviews of licensing, inspection, or incident casework does not need to be performed. Review of some documents, however, may be useful to clarify points made in discussions and/or to determine the status of open recommendations from previous IMPEP reviews (e.g., summary of printouts of inspection information, close-out letters in incident files, or status of regulations).



  1. In some cases, casework for allegations may need to be reviewed in order to ensure that appropriate followup action was taken. All casework for allegations and concerns referred directly to the State by NRC in which the alleger’s identity has been withheld should be reviewed. Performance concerns closed through STP Procedure SA-400, Management of Allegations, do not need to be reviewed in depth.


  1. Documentation of Periodic Meetings


  1. The meeting lead should prepare, issue, and distribute the periodic meeting summary and transmittal correspondence within 30 days of the date of the meeting. A sample periodic meeting summary and transmittal letter can be found on the State Communication Portal webpage (https://scp.nrc.gov/) under the IMPEP Toolbox, as well as, in Appendices B, C, and D of this procedure.


  1. Prior to issuance of the periodic meeting summary, the meeting lead should share a draft of the periodic meeting summary with the Director, DNMS, or Agreement State RCPD and any other attendees for factual review and comment.


  1. For each open recommendation from the previous IMPEP review, the meeting lead should review the status of the actions that have been taken, or are in progress, in regards to the recommendation. All recommendations remains open during periodic meeting reviews. Recommendations involving chronic performance issues should not be closed until a continuous period of adequate performance has been demonstrated. (NOTE: Closure of recommendations occurs at the IMPEP review; not at the periodic meeting.)


  1. No specific information regarding any allegations or concerns discussed at the periodic meeting that could potentially identify an alleger should be contained in the periodic meeting summary or transmittal correspondence. The periodic meeting summary should only state the number of allegations and concerns discussed and whether the casework has been handled adequately. (If an Agreement State is not handling allegations or concerns in a manner consistent with the guidance provided in Management Directive 8.8, Management of Allegations, the RSAO or NMSS designee at the meeting should report this fact separately to NMSS management.)



  1. Presentation of the Results of the Periodic Meetings to the MRB


  1. The MRB will be convened to review the results of periodic meetings on an as-needed basis. Typically, the results of the periodic meetings from a few material programs will be presented in a single session.


  1. NRC Regional and Agreement State representatives of programs that are being discussed will be invited to participate in the MRB meeting.


  1. Performance Concerns Identified during a Periodic Meeting


  1. If concerns about adequacy or compatibility are identified during a periodic meeting, the concerns should be documented in the periodic meeting summary and presented to the MRB as part of the discussion of the results of the periodic meeting.


  1. The MRB will decide on the appropriate course of action. Possible actions may include any or all of the following:


  1. Altering the schedule for the next IMPEP review;

  2. Scheduling an additional meeting with the program;

  3. Conducting a special review of selected program areas;

  4. Placing the Agreement State on Heightened Oversight or Monitoring (see STP Procedure SA-122, Heightened Oversight and Monitoring, for additional information); and,

  5. Issuing a “letter of support” to bring declining program issues to the attention of Agreement State leadership (see Appendix C).


  1. If the concerns have the potential to immediately affect public health and safety, the meeting lead should immediately inform NMSS management, NRC Regional management, and the IMPEP Project Manager of the findings and propose a course of action. NMSS management should notify the Chair of the MRB of the concerns identified and the proposed course of action. The Chair of the MRB may request that the MRB convene to discuss the concerns and vote on the proposed course of action.


  1. If performance issues in an Agreement State are identified through day-to-day interactions, the RSAO will document the program’s issues in writing to present to the MRB. The written documentation should provide a complete description of the program performance issues and any other supporting information sufficient to allow the MRB to determine an appropriate course of action, as outlined in V.F.2.


VI. APPENDICES


Appendix A Sample Scheduling Letter and Agenda

Appendix B Sample Letter Documenting a Periodic Meeting with No Declining Performance

Appendix C Sample Letter Addressing a Potential Decline in Agreement State Performance Noted During a Periodic Meeting

Appendix D Sample Template Format for Periodic Meeting Summary


VII. REFERENCES


  1. NMSS Procedure SA-106, The Management Review Board (MRB)

  2. IMPEP Toolbox – https://scp.nrc.gov/impeptools.html

  3. NRC Management Directive 8.8, Management of Allegations

  4. STP Procedure SA-122, Heightened Oversight and Monitoring

  5. STP Procedure SA-400, Management of Allegations

  6. IMC 1248 Qualification Programs for Federal and State materials and Environmental Management Programs


VIII. ADAMS REFERENCE DOCUMENTS


For knowledge management purposes, all previous revisions of this procedure, as well as associated correspondence with stakeholders that have been entered into NRC’s Agencywide Documents Access and Management System (ADAMS) are listed below.


No.

Date

Document Title/Description

Accession Number

1

10/9/03

STP-03-077, Opportunity to Comment on Draft Revisions to STP Procedure SA-116

ML032820578

2

2/6/04

STP Procedure SA-116

ML040620604

3

2/6/04

Summary of Comments on SA-116

ML040620654

4

7/28/05

STP-05-061, Draft Revision of STP Procedures to Incorporate Letters of Support Guidance

ML052100400

5

10/5/05

STP Procedure SA-116

ML061310327

6

10/5/05

Summary of Comments on SA-116

ML061310346

7

9/12/07

FSME-07-086, Opportunity to Comment on Draft Revision to FSME Procedure SA-116

ML072470343

8


Summary of Comments on SA-116


Appendix A


SAMPLE LETTER SCHEDULING A PERIODIC MEETING AND AGENDA


[NAME]

[TITLE, STATE SENIOR MANAGEMENT] [ADDRESS]


Dear [NAME]:


In order to help the Agreement States and the U.S. Nuclear Regulatory Commission (NRC) remain knowledgeable of each other’s program and to initiate planning for the next Integrated Materials Performance Evaluation Program (IMPEP) review, the NRC conducts one-day periodic meetings with Agreement States between IMPEP reviews.


In accordance with the Office of Nuclear Material Safety and Safeguards (NMSS) Procedure SA-116, “Periodic Meetings between IMPEP Reviews,” and after previous coordination with you and your staff, we have scheduled the periodic meeting for [DATE]. The meeting will be held at the [Agency/Department] Program offices in [CITY, STATE]. In addition to myself, staff and management from NMSS and NRC’s Region [I, III, OR IV] office may also attend the meeting.


Based on our previous discussions, the likely topics for discussion at the meeting are listed on the enclosed agenda. If there are any additional specific topics you would like to cover, or if you would like to focus on a specific area, please let me know. If you have any questions, please call me at [PHONE NUMBER WITH AREA CODE], or via e-mail at [EMAIL ADDRESS].



Sincerely,





[NAME OF RSAO]

Regional State Agreements Officer

Division of Nuclear Materials Safety



Enclosure:

Agenda for Periodic Meeting

SAMPLE AGENDA


Agenda for Periodic Meeting with [Agency/Department].

[DATE]


Topic areas for discussion during the meeting may include:


  1. Status of the State’s actions to address all open IMPEP review findings and/or open recommendations.


  1. Program reorganizations:


Discuss any changes to the program organization, including program/staff relocations and new appointments.


  1. Changes in program budget/funding.


  1. Feedback on the NRC’s program, including identification of any action that should be considered by NRC.


  1. Status of the State’s program, including:


  1. Technical Staffing and Training


    1. Number of staff in the program and status of their training and qualifications.

    2. Any program vacancies.

    3. Staff turnover since the last IMPEP review.

    4. Adequacy of FTEs for the materials program.

    5. Status of implementation of IMC 1248

b. Status of the Materials Inspection Program


  1. Number of inspection completed on time and overdue since the last IMPEP review.

  2. Number of initial inspections completed on time and overdue since the last IMPEP review.

  3. Number of reciprocity inspections completed each year since the last IMPEP.

  4. Inspection frequencies (changes to or those that differ from NRC’s inspection frequencies).


c. Technical Quality of Inspections

  1. Status of inspector accompaniments.

  2. Management review process

  3. Significant inspection activities/challenges


d. Technical Quality of Licensing


  1. Number of licensing actions and types performed since the last IMPEP review.

  2. Large, complicated, or unusual authorizations for use of radioactive materials.

e. Technical Quality of Incidents and Allegations


  1. Status of allegations and concerns referred by the NRC for action.

  2. Significant events and generic implications.

  3. Number of reportable events received since the last IMPEP and event reporting, including follow-up and closure information in NMED.


f. Compatibility Requirements


  1. Regulations

    1. Compatibility requirements

    2. Discuss status of State’s regulations and actions to keep regulations up to date, including the use of legally binding requirements.

    3. Part 37 adoption status

  2. Legislative changes affecting the program.

g. Sealed Source and Device Evaluation Program


i) Technical Staffing and Training

a. Number of qualified SSD reviewers and their signature authority.

b. Number of current or anticipated program vacancies.

c. Staff turnover since the last IMPEP review.

ii) Technical Quality of the Product Evaluation Program

a. Number of cases since the last IMPEP review to include new cases, amendments, inactivations and transfers.

iii) Evaluation of Defects and Incidents Regarding SS&Ds

a. Any cases noted involving manufacturing defects since the last IMPEP review?


h. LLRW/UR Technical Staffing and Training


    1. Number of staff in the program and status of their training and qualifications.

    2. Any program vacancies.

    3. Staff turnover since the last IMPEP review.

    4. Adequacy of FTEs for the materials program.

    5. Status of implementation of IMC 1248


i. LLRW/UR Status of the Inspection Program


  1. Number of inspection performed overdue since the last IMPEP review.

  2. Number of inspections currently overdue.

  3. Number of initial inspections completed on time and overdue since the last IMPEP review.


j. LLRW/UR Technical Quality of Inspections


  1. Status of inspector accompaniments.

  2. Management review process

  3. Significant inspection activities/challenges


k. LLRW/UR Technical Quality of Licensing


  1. Number of licensing actions and types performed since the last IMPEP review.


l. LLRW/UR Technical Quality of Incidents and Allegations


  1. Status of allegations and concerns referred by the NRC for action.

  2. Significant events and generic implications.

  3. Event reporting, including follow-up and closure information in NMED.


m. LLRW/UR Compatibility Requirements


  1. Regulations

  2. Discuss status of State’s regulations and actions to keep regulations up to date, including the use of legally binding requirements.

  3. Legislative changes affecting the program.


6. Information Exchange:


Current State initiatives

Technical Staffing and Training;

Technical Quality of the Product Evaluation Program; and

Evaluation of Defects and Incidents regarding SS&Ds.”


Emerging technologies

Technical Staffing and Training;

Status of Low Level Radioactive Waste Disposal Inspection;

Technical Quality of Inspections;

Technical Quality of Licensing Actions; and

Technical Quality of Incident and Allegation Activities.


Large, complicated, or unusual authorizations for use of radioactive materials;

Technical Staffing and Training;

Status of the Uranium Recovery Program;

Technical Quality of Inspections;

Technical Quality of Licensing Actions; and

Technical Quality of Incident and Allegation Activities


Major decommissioning and license termination actions;

State’s mechanisms to evaluate performance; and,


Current NRC initiatives


  1. Schedule for the next IMPEP review.


Action items resulting from the periodic meeting (these should be documented in the meeting summary report). [Note: the meeting should not be used by the States to refer major policy issues to NRC since these are addressed through other mechanisms].


Additional Topics


  1. Next Steps/Meeting Summary/Q&A


Exit with Senior Management if requested by the Agreement State.




Appendix B


SAMPLE LETTER DOCUMENTING A PERIODIC MEETING WITH NO DECLINING PERFORMANCE


[NAME]

[TITLE, STATE SENIOR MANAGEMENT] [ADDRESS]


Dear [NAME]:


A periodic meeting with you and your staff was held on [DATE]. The purpose of this meeting was to review and discuss the status of the [Agency/Department] Agreement State Program. The scope of the meeting was limited to activities conducted by the your [Agency/Department]. The U.S. Nuclear Regulatory Commission was represented by [NAMES] and me.


I have completed and enclosed a general meeting summary, including any specific actions resulting from discussions. A Management Review Board (MRB) meeting to discuss the outcome of the periodic meeting has been scheduled for [DATE] at [TIME] (EDT). Call-in information for the MRB will be provided in a separate transmission.


If you feel that our conclusions do not accurately summarize the meeting discussion, or have any additional remarks about the meeting in general, please contact me at [PHONE NUMBER WITH AREA CODE], or by email at [EMAIL ADDRESS] to discuss your concerns.


Sincerely,

[NAME]

Regional State Agreements Officer Division of Nuclear Materials Safety

Enclosure:

Periodic Meeting Summary


cc: [STATE LIAISON OFFICER] [RADIATION CONTROL PROGRAM DIRECTOR] [OTHER]


Appendix C


SAMPLE LETTER ADDRESSING A POTENTIAL DECLINE IN AGREEMENT STATE PERFORMANCE NOTED DURING A PERIODIC MEETING


[NAME]

[TITLE, STATE SENIOR MANAGEMENT] [ADDRESS]


Dear [NAME]:


I am writing to discuss the results of a periodic meeting held in your [Agency/Department] on [DATE] with staff of the [Bureau of Radiation Control/Radiation Control Program/other]. Periodic meetings are held to enable the U.S. Nuclear Regulatory Commission (NRC) and Agreement States to remain knowledgeable of each other’s program and to conduct planning for the next Integrated Materials Performance Evaluation Program (IMPEP) review. NRC has an oversight responsibility to periodically review Agreement State programs for adequacy to protect public health and safety and compatibility with NRC’s program and conducts these reviews under IMPEP.


NRC also uses the periodic meeting process to gather important performance information and increase focus on identifying performance issues before they escalate into serious problems. This process includes an enhanced meeting coordination process, with effective and active participation of the Management Review Board (MRB), a panel of NRC managers with an Agreement State manager liaison, in the process and active Radiation Control Program Director participation in the discussion of meeting results and decision making process.


The MRB met on [DATE] to discuss the results of the [STATE]’s [DATE] periodic meeting. Potential performance concerns identified in your radiation control program during the periodic meeting were discussed. I have enclosed a copy of the [DATE] letter to [Program Director], summarizing the results of the [DATE] periodic meeting. Highlights of the concerns identified during the meeting are presented below.


The Program is experiencing difficulty in [DESCRIBE PROGRAM ISSUES]. Given these developments, we have concerns regarding the program’s ability to maintain an adequate and compatible radiation safety program.



Your support in helping ensure that the [STATE] Agreement State Program has the necessary resources and support to continue to manage an effective program is crucial. I want to assure you that the Commission supports the mission of the [STATE] Agreement State Program and that NRC staff will continue to work closely with your program. We thank you for your commitment to this effort.

Sincerely,

[NAME]

Deputy Executive Director for Materials, Waste, Research, State, Tribal, Compliance, Administration, and Human Capital (DEDM) Office of the Executive Director for Operations

Enclosures: As Stated

cc: [STATE LIAISON OFFICER] [RADIATION CONTROL PROGRAM DIRECTOR] [OTHER]


Appendix D


SAMPLE TEMPLATE FORMAT FOR PERIODIC MEETING SUMMARY


PERIODIC MEETING SUMMARY FOR THE

[STATE] AGREEMENT STATE PROGRAM

DATE OF MEETING: [DATE]


U.S. Nuclear Regulatory Commission (NRC) Attendees

[AGREEMENT STATE PROGRAM NAME] Attendees

[NAME, TITLE, OFFICE]

[NAME, TITLE, OFFICE]






DISCUSSION:

TOPICS COVERED DURING THE MEETING INCLUDED:

    • Program Challenges

    • Feedback on NRC’s Program

    • Program Reorganizations

    • Program Budget/Funding

    • Technical Staffing and Training ([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Status of Materials Inspection Program (([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Technical Quality of Inspections ([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Technical Quality of Licensing Actions ([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Technical Quality of Incidents and Allegations ([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Regulations and legislative changes ([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Sealed Source and Device (SS&D) Evaluation Program ([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Low level Radioactive Waste Disposal Program ([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Uranium Recovery Program ([YEAR OF LAST IMPEP] IMPEP: [RATING])

    • Information Exchange

    • Current State Initiatives

    • Current NRC Initiatives

    • Emerging Technologies

    • State’s Mechanism for Evaluating Performance

CONCLUSIONS:

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSA-116 - Periodic Meetings Between IMPEP Reviews
AuthorMarilyn Langston
File Modified0000-00-00
File Created2021-01-24
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