ML20057A542
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FEB I 31990 MEMORANDUM FOR:
Billie R. Gruszynski Licensing Assistant FROM:
William L. Fisher, Chief Nuclear Materials Licensing Section
SUBJECT:
DELEGATION OF REVIEWER RESPONSIBILITY I am delegating to you the responsibility for reviewing new license applications, amendments, and renewals included in the below identified program codes.
This delegation as written does not imply signature authority, and all cases must be reviewed under the oversight of the license reviewer, senior license reviewer, or section chief.
I intend that minimum oversight will be
-required by these persons.
If you have any questions in regard to a particular case, you should discuss the matter with Jack, Vivian, or myself before proceeding with the action.
Additional casework will be assfgned which has not been included in this delenatien.
APPLICATION PROGRAM CODE Measuring Systems / Fixed Gauges 03120 Measuring Systems /Porte 'e Gauges 03121 Measuring Systems / Analytical Instruments 03122 Measuring Systems / Gas Chromatographs 03123 Measuring Systems /Others 03124 Civil Defense 03710 Amendments in the following p ogram codes may be processed with close oversight by the license reviewer, senior license reviewer, or section chief Before processing such amendments, each requested action must be examined in detail and discussed with one of the above senior staff members.
APPLICATION PROGRAM CODE Academic Type A Broad 01100 Academic Type B Broad 01110 l
Academic Type C Broad 01120 Medical Institution Broad 02110 DR b RIV:C:NHLSY WLFisher AB ch A /l3/90 9309140376 930830 1 (9 H')
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Bil' lie R. Gruszynski '
APPLICATION PROGRAM CODE Medical Institution Other - Group 02120 Medical Institution Other - Nongroup 02121 Medical Private Practice - Group 02200 Medical Private Practice - Nongroup 02201 Medical Institution / Private Practice 02209 In Vivo Studies Eye Applicators Strontium-90 02210 Nuclear Medicine Vans 02220 Teletherapy 02300 Veterinary Nonhuman 02400 In Vitro Testing Laboratories 02410 Nuclear Pharmacies 02500 Leak Test Services 03220 Instrument Calibration Services Only/
03221
<100 curies Instrument Calibration Services Only/
03222
>100 curies Leak Test and Instrument Calibration 03223 Services /<100 curies Leak Test and Instrument Calibration 03224 Services />100 curies Industrial Radiography / Fixed 03310 Industrial Radiography / Temporary Job Sites 03320 Irradiators Self Shielded /<10,000 curies 03511 Research & Development Type A Broad 03610 Research & Development Type B Broad 03611 1
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Biliie R. Gruszynski "
APPLICATION PROGRAM CODE Research & Development Type C Broad 03612 Research & Development /Other 03620 Source Material Other/<150 Kilograms 11200 Source Material Shielding 11210 SNM Plutonium - Neutron Source /
22120
- <200 Grams Pacemaker Byproduct end/or SNM 22160 Medical Institution Pacemaker Byproduct and/or SNM 22161 Individual This delegation of responsibility becomes effective this date.
Licenses which have primary program codes listed above and which also have secondary codes not listed above must also follow the protocol of this delegation.
The basis for this delegation of responsibility rests on the following:
A.
Work experience gained in reviewing these program coded cases, B.
Training you received by attending the Troxler portable gauge training cour:,e, and C.
On-the-job training received during your tenure as LA (see training profile sheet).
If you have any questions regarding the delegation, please see me.
fy g',; r w WILL;A L f
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William L. Fisher, Chief i
Nuclear Materials Licensing Section
Attachment:
As stated bec:
JEGlenn ABBeach LAYandell CLCain WLFisher JEWhitten VHCampbell BRGruszynski l
ATTACHMENT 3
TRAINING PROFILE SHEET Billie R. Gruszynski Licensing Assistant TRAINING COMPLETED DATE PROJECTED DATE 1.
Training conducted by NHLS:
Reviewer training conducted by using applicable licensing guides, policy guides and directives, and applicable Parts of 10 CFR.
Senior staff review and oversight.
(A) Gas Chromatographs 89 89/90 (B) Fixed Gauges 89 89/90 (C) Portable & Semiportable 89 89/90 (D) Medical (Private Practice) 89/90 (E) Medical (Sr-90 eye applicator) 89/90 (F) Medical Institutions 89/90 (35.100 through 35.600)
(G) Well Logger (H) Radiographer (See attached for in-house training protocol) 2.
Troxler/ Campbell Pacific 89 89 3.
Texas Nuclear, Ohmart, Kay-Ray, 90 Accu 8ay, or LFE Complete a training course provided by one of the above manufacturers to include training in basic health physics; sealed source leak testing procedures; field surveys of installed fixed gauges; field calibration checks of survey instruments; instructions in the removal, installation, and relocation of fixed gauges; and emergency procedures.
Training Profile Sheet
- 4.
Well Logging Training Course 91 5.
Radiography Training Course 91 6.
Training provided by NMIS:
Onsite visit with or accompany inspector to the following licenses:
(A) Gas Chromatograph 90 (B) Portable and Semiportable 90 Gauges (C) Fixed Gauges 90 (0) Medical (Private Practice) 90/91 (E) Medical (Institution) 90/91 (F) Sr-90 Eye Applicator 90/91 I
(G) Radiographer 90/91 (H) Well Logger 90/91 t
D
t Tra'ining Profile Sheet
- NHLS Training for Licensing Assistant:
A.
Licensing Assistant (LA) will read current licensing guides, draft working papers, in-house memos, and selected Parts of 10 CFR.
B.
Senior Reviewer (SR) or Reviewer (R) will review guides with the LA, emphasizing problem areas and specific points of interest.
C.
Casework (renewals and amendments) in specific program codes will be selected by tFe SR to be examined and discussed.
After discussion of this selected casework, the LA will complete the licensing activity requested, When the requested licensing activity is completed, the SR or R will review the LA's work and discuss any incorrect assumptions or any areas of weakness.
D.
When each program code category is completed, the NHLS Section Chief will review the LA performance with the SR. When the SR and Section Chief are satisfied that full performance potential has been obtained in this program code, the Section Chief will then give the LA authorization to proceed with casework with limited oversight.
All casework completed by the LA will be reviewed by senior staff members before release.
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,j44/u-q William L. Fisher, Chief Nuclear Materials Licensing Section 4
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NATIONAL PROGRAM REVIEW - 1990 RESPONSES TO QUESTIONNAIRE NUCLEAR MATERIALS INSPECTION SECTION O
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t 1.
Percentage of time assigned to various program areas:
Linda Kasner:
90% materials inspection 10% materials licensing Mike Vasquez:
90% materials inspection 10% materials licensing Wes Holley:
95% materials inspection 5% fuel facilities inspection Selvan Rajendran:
95% materials inspection 5% fuel facilities inspection Tony Gaines 100% materials inspection 2.
See Attachment 1.
3.
Currently, there is no request made to change forecasted workload for materials inspections.
However, estimates of the number of inspections coming due during the remainder of the fiscal year indicate a possible shortfall in the number of inspections necessary.
4.
Regional administrative support has been timely for materials inspection support.
This mainly has been in the form of typing inspection reports and travel administration.
No changes are currently needed.
During the coming year an attempt will be made to supply more inspectors with word processing capability in their offices to expedite report preparation.
5.
Interaction with headquarters has generally been good.
We continue to believe that monthly conference calls are of limited usefulness and might be of better value if used for ad hoc topical discussions as the need arises.
Annual counterpart meetings continue to be very beneficial; therefore, we recommend continuance of these. We also support the practice of headquarters personnel accompanying materials inspectors during inspection trips.
The only possible need for improvement is the need for additional time to review and comment on document drafts sent to the regional office for comment.
6.
Recent regional initiatives to improve the quality of materials inspections have included the following:
a.
Region IV is using the Form 591 less in favor of formal correspondence with licensees, even when no violations are identified.
Formal letters and NOVs are now being used for all medical licensees and larger industrial licensees.
b.
Region IV is attempting to perform more temporary job site inspections than in the past, particularly for well loggers.
Several offshore inspections have been conducted during the past year.
This effort also should better serve to evaluate licensee compliance with 00T requirements.
-2 Region IV has begun a more detailed scrutiny of well loggers in c.
regard to dosimetry use and sealed source handling.
7.
We review Module No. 86740 for virtually every licensee we inspect; therefore, the total number of transportation inspections during FY 89 is estimated to be the same as the number of inspections conducted (355).
Since RITS requires module reporting in whole hours, we usually report zero against this module even though some inspection effort was made.
We estimate 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> devoted to the transportation module per materials inspection.
We recall no violation referrals from the waste burial sites during FY 89.
8.
Training summaries for each inspector are included as Attachment 2.
None of the inspectors, except Wes Holley, have attended the Whole-Body Counting and Internal Dosimetry Course (H-312) or equivalent.
None of the inspectors have attended the Panoramic Pool-Type Irradiators Course.
Region IV has no such facilities.
Attachments:
As stated
REGION NMSS FTE USAGE FY89 BUDGET
_ USAGE FY90 BUDGET FY90 USAGE (09/25/-
01/2i/9 Safety Fuel Facility Licensing 0
0 0
0 Fuel Facility Inspection 0.9 0.24 1.2 0.24 Materials Licensing 1.7 3.39 2.3 1.22 Materials Inspection 6.9 5.72 7.0 1.37 Event Evaluation 0.5 0
1.2 0
Safeguards Transportation Safeguards
.02 0
.02 0
Transportation Inspection
.04 0
.04 0
Low-Level Waste Low Level Inspections
.15 0
0.2 0
Uranium Recovery Licensing 9.50 7.38(Includes 1.29 7.7 1.78(Includes.23 UMTRAP)
UMTRAP)
Uranium Recovery Facility Inspection 1.90 1.81 1.90
.17 Decomissioning Material Facility Decomissioning Casework
.10 0
.10
.02 R: actor Decommissioning Inspection 0
0
.10 0
S ction Supervision 1.5 1.05 1.60
.69 Total NMSS Program:
23.21 19.59 23.36 5.49
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Page 1 of 3 TRAINING
SUMMARY
INSPECTOR: Mike Vasquez EOD:
1/15/09 Course Name Date BASIC COURSES Medical Use of Dyproduct Material (H-304)
Jul 1989 Safety Aspects of Industrial Radiography (H-305)
Jul 1989 Transportation of Radioactive Materials (H-308)
Oct 1989 Fundamentals of Inspection (G-102) or Apr 1989 Inspection Procedures (SLITP)
Safety Aspects of Well Logging (SLITP)
Nov 1989 Portable Gauges (Troxler)
Feb 1989 Radiotherapy (H-313)
Sep 1989 Fire Protection and Life Safety (DSHA)
May 1989 Qual journal and Qual board review is incomplete.
Granted interim certification to conduct all materials inspections 6/16/09.
TRAINING
SUMMARY
INSPECTOR: Tony Gaines EOD:
12/6/87 (RIV)
Course Name h
BASIC COURSES Medical Use of Byproduct Material (H-304)
Aug 1987 Safety Aspects of Industrial Radiography (H-305)
Mar 1987 Transportation of Radioactive Materials (H-308)
Nov 1987 Fundamentals of Inspection (0-101) or Jul 1987 Inspection Procedures (SLITP)
' Safety Aspects of Well Logging (SLITP)
Nov 1987 Portable Gauges (Troxler)
Feb 1989 Radiotherapy (H-313)
Sep 1989 Fire Protection and Life Safety (OSHA)
May 1989 SUPPLEMENTARY COURSES Health Physics (Dak Ridge National Labs)
Jul - Aug (5 weeks) 1988 Granted interim certification to conduct all materials inspections except broad licenses on 3/18/88. Oral Board held February 8, 1990.
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Page 2 of 3 l
TRAINING
SUMMARY
INSPECTOR: Linda Kasner EOD:
10/23/88 Course Name p_aig a
BASIC COURSES Medical Use of Byproduct Material (H-304)
Safety Aspects of Industrial Radiography (H-305)
Jul 1989 Transportation of Radioactive Materials (H-308)
Oct 1989 Fundamentals of Inspection (0-101) or Apr 1989 Inspection Procedures (SLITP)
Safety Aspects of Well Logging (SLITP)
Feb 1989 Radiotherapy (H-313)
Sep 1989 Hazardous Materials (OSHA)
Apr 1989 SUPPLEMENTARY COURSES FDA Regulation of Drugs and Radiopharmaceuticals Jan 1989 Granted interim inspection certification 6/23/89.
Qual journal incomplete and Qual board not yet scheduled.
TRAINING
SUMMARY
INSPECTOR: Selvan Rajendran EOD: 6/12/89 (RIV)
Course Name p.a_te BASIC COURSES Medical Use of Byproduct Material (H-304)
Oct 1987 Safety Aspects of Industrial Radiography (H-305)
Aug 1988 Transportation of Radioactive Materials (H-308)
Dec 1987 Fundamentals of Inspection (0-101) or Feb 1988 Inspection Procedures (SLITP)
Safety Aspects of Well Logging (SLITP)
Hov 1989 Portable Gauges (Troxler)
Radiotherapy (H-313)
Dec 1989 Cobalt Teletherapy Unit Calibration (H-301)
Oct 1987 Inspector certification issued by Region I.
Page 3 of 3 1
TRAINING
SUMMARY
INSPECTOR:
Wes Holley EOD: 6/12/74 Course Name PJLt.r.
BASIC COURSES Medical Use of Byproduct Material (H-304)
Feb 1986 Safety Aspects of Industrial Radiography (H-305)
Jul 1985 Transportation of Radioactive Materials (H-308)
Mar 1983
' Fundamentals of Inspection (0-101) or Nov 1985 Inspection Procedures (SLITP)
Safety Aspects of Well Logging (SLITP)
Nov 1985 Portable Gauges (Troxler)
Radiotherapy (H-313)
Sep 1989 Hazardous Materials (OSHA)
Apr 1989 SUPPLEMENTARY COURSES BWR Technology (R-104B)
Nov 1981 PWR Technology (R-104P)
Feb 1982 BWR/PWR Radwaste (H-302)
May 1982 Personnel Radiation Dosimetry May 1983 In-Place Filter Workshop Aug 1984 Respiratory Protection at Nuclear Power Plants Apr 1987 Internal Dosimetry for Fixed Nuclear Facilities Apr 1987 Radiological Emergency Response May 1989 Certified inspector on 4/27/87.
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NATIONAL PROGRAM REVIEW - 1990 ENFORCEMENT OFFICE QUESTIONNAIRE 1.
Formal training was provided to the entire region by the enforcement officer twice during FY 89, in conjunction with resident inspector meetings. The two training sessions focused on repetitive violations and enforcement discretion under V.G.I. of 10 CFR 2, Appendix C.
This training was supplemented by Regional Office Policy Guide (ROPG) 0558, "Similar Violations" dated October 5, 1989, and R0PG 0557, " Documenting Violations for Which no Citation is Issued (Non-Cited Violations or NCVs)"
dated July 20, 1989.
The enforcement officer also provides notes from the OE conference calls to the divisions for information and guidance.
Training for new employees is done as part of the qualification journal, and is conducted by the immediate supervisor and supplemented by the enforcement officer.
2.
Repetitive violations are being identified to licensees during exit briefings and to the Chief, NMIS, upon return to the office.
3.
Repetitive violations are identified as such in the NOV and in the cover letter as well, but not as a boilerplate.
If there are multiple repeats or a single important repeat, escalated enforcement action is considered.
ROPG 0558 provides direction on the handling of these matters.
4.
In accordance with paragraph C.3.c of R0PG 0558, "An enforcement conference should be conducted and either a civil penalty or an order should be issued." We do not remember any examples of third repeats, but one case is pending at this time.
5.
Yes, inspectors have identified repeat violations in recent cases.
6.
Discretion has been exercised in accordance with the enforcement policy, and ROPG 0557.
7.
The use of Form-591 is being limited to smaller industrial and medical licensees, and identifies only non-repetitive Severity Level V and Severity Level IV violations that would not require extensive corrective actions.
In all other cases, a formal Notice of Violation would be issued.
8.
All violations are tracked, but the system does not identify those that are repetitive. Non-cited violations are not tracked. Open items are only used with the Sequoyah Fuels effort and they are tracked. To track
-2 enforcement history, the Region relies on the inspector and the section chief to review previous inspection findings in conjunction with the current inspection effort. Other items for followup are identified and handled in accordance with R0pG 90068, " Intersectional Communication in the Nuclear Material Safety Branch" dated September 13, 1988.
9.
Although a formal tracking system for some of the items in Question 8 does not exist, inspectors do review enforcement history prior to an inspection, close out old violations, and flag repeats as discussed in the previous response.
- 10. &
- 11. Not applicable.
- 12. &
- 13. No formal record is kept of this information, but a small number of violations have been disputed by licensees. To the best of our memory, of the number disputed, only one or two have been withdrawn in the past year.
- 14. We consider the normal concurrence process, which goes through the division director, to be an internal audit process.
In addition the enforcement officer receives a copy of all inspection reports containing enforcement actions and performs a review of a selected sample of reports for consistency with the enforcement policy.
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Tra'ining Profile Sheet '
NHLS Training for Licensing Assistant:
A.
Licensing Assistant (LA) will read current licensing guides, draft working papers, in-house memos, and selected Parts of 10 CFR.
B.
Senior Reviewer (SR) or Reviewer (R) will review guides with the LA, emphasizing problem areas and specific points of interest.
C.
Casework (renewals and amendments) in specific program codes will be selected by the SR to be examined and discussed.
After discussion of this selected casework, the LA will complete the licensing activity requested. When the requested licensing activity is completed, the SR or R will review the LA's work and discuss any incorrect assumptions or any areas of weakness.
D.
When each program code category is completed, the NHLS Section Chief will review the LA performance with the SR. When the SR and Section Chief are satisfied that full performance potential has been obtained in this program code, the Section Chief will then give the LA authorization to proceed with casework with limited oversight.
All casework completed by the LA will be reviewed by senior staff members before release.
b, /,j.
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,;A % q William L. Fisher, Chief Nuclear Materials Licensing Section T
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