ML20127C475

Responds to 850115 Request for Comments on Rev to IE 2800 Matls Insp Program.Changes in Priority Assignment in Encl Table 3 Program Codes & Alternate Insp Methods Recommended

ML20127C475
Person / Time
Issue date:	02/07/1985
From:	Chapell D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Cobb L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20127A504	List: ML20127A502 ML20127A686 ML20127A703 ML20127A708 ML20127A724 ML20127A757 ML20127C120 ML20127C415 ML20127C475
References
FOIA-85-69 NUDOCS 8502250147
Download: ML20127C475 (9)

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UNITED STATES NUCLEAR REGULATORY COMMISSION j WASHINGTON, D.C. 20555 FEB  ? 1985 MEMORANDUM FOR: Leonard Cobb, Chief Safeguards and Materials Programs Branch, IE FROM: Donald R. ChapeIi, Deputy Director Division of Fuel Cycle and Material Safety

SUBJECT:

REVISION OF IE 2800, MATERI ALS INSPECTION PROGRN4 This is in response to your memorandum of January 15, 1985 +ha+ asked for comment on IE 2600, Ma+erlais inspection Program.

We recommend changes in the priority assignment in " Table 3 Program Codes." The changes are on the attached markup.

Section 2800-03.03 should begin "When a new license is issued by +he regional office . . .

Sections 2800-04, 2800-05, and 2800-06 deal with changing an assigned inspection frequency. You should identify wno is authorized to make changes, and provide more concrete guidance about when changes are Indicated.

On a broader plane, we reiterate our concern, which has been raised in the past, that materials licensees are not receiving sufficient inspection oversight. We also recognize that you must operate within budget limits. Given these dichotomous needs, we recommend tnat we meet to discuss +he feasibill+y of alternative inspection methods, for example:

1. Triggered Inspection--precipitated by a significant program change such as new Radiation Safe +y Officer or authorized user or significant change in type of use or inventory 1imit.

2. Announced telephone inspection--sul+able for licensees tha+ have a good afety record or where the main hazard is loss of control of

_u or self-shielded irradiator.

A

Leonard Cobb FD 7 1985 l l

In this vein, it is also appropriate to consider wha + precipitates non-compliance. In many cases it appears that non-compliance may be caused by unclear standards, ignorance, or forgetfulness rather than laziness or cost-cutting. If the former are the causes ra+her than the latter, perhaps some licensing and inspection time would be better spent on alternative measures. We would like to meet to discuss this.

The licensing staff is also reviewing the inspection procedures and would like to comment on them at a later date.

Donald R. Chapell, Depu+y Director Division of Fuel Cycle and Material Safety

Enclosure:

As stated i

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• l 2800. TABLE 3 MATERIALS INSPECTION PROGRAM l Table 3 PROGRAM CODES Inspection Programs Code Category Title ' Category Priority -

t 01100 Academic Typi A Broad FIA 2 01110 , Academic Typ'e B Broad F1B 3 01120 Academic Type C Broad FIC 5 01200 Academic Other (Secondary Code) ---

' " 02110 Medical Institution Broad G1 2 02120 Medical Institution Other - Group G' 3 02121 Medical Institution Other - Nongroup G2 5

- Includes Diagnostic-Limited

. Therapeutic 02200 Medical Private Practice - Group G 3 02201 Medical Private Practice - Nongroup G2 5

- Includes Diagnostic-Limited Thera-peutic 02210 Eye Applicators Strontium-90 G2 5 02220 Nuclear Medical Vans G 3

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02300 Teletherapy G3 3 02400 Veterinary Nonhuman G2 5 02410 In Vitro Testing Laboratories G2 5 .

02500 Nuclear Pharmacies G1 d.

4 02510 Medical Product Distribution - 32.70 B 02511 Medical Product Distribution - 32.72 B 02512 Medical Product Distribtulon - 32.73 B 1 ')

l '02513 Medical Product Distribution - 32.74 B 03110 , Well Logging Byproduct and/or SNM

> . Tracer and Sealed Sources E 3 l 03111 Well Logging Byproduct and/or SNM Sealed Sources Only E 3 03112 Well Logging Byproduct only-Tracers 1 .

Only E ,

03113 Field Flooding Studies E 03120 Measuring Systems Fixed Gauges K -

l 03121 Measuring Systems Portable Gauges El 5 03122 Measuring Systems Analytical .

Instruments E2 6

03123 Measuring Systems Gas Chromatographs K 7 t

03124 Measuring Systems Other K 7 -

03211 Manufacturing and Distribution Type A

. Broad B 1 03212 Manufacturing and Distribution Type B

Broad E 3 T3-1 Issue Date

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MATERIALS INSPECTIOR PROGRAM TABLE 3, 2800

, Inspection Programs Code Category Title Category Priority

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03213 Manufacturing and Distribution Type C

' . Eroad E1C 5 03214 Manufacturing and Distribution E 3 Other (includes small quantities

<10 millicuries per container) or

• Medical Distribution but no Manufac- .

. turing E 3 03218 Nuclear Laundry E 3

, 03220 Leak Test Services Only K 7 03221 Instrument Calibration Services Only

<100 Curies K 7 03222 Instrument Calibration Services Only 03223

>100 Curies Leak Test and Instrument Calibration E

h7 Services <100 Curies K 7 03224 Leak Test and Instrument Calibration Services >100 Curies E 3 03225 Other Services K 03232 Waste Disposal Service Prepackaged Only D1 2 1' 03233 Waste Disposal Sarvice Incineration D 03234 Waste Disposal Service Processing and/ -

or Repackaging D 1 03235 Incineration-Noncommercial (Secondary Code) 03240 General License Distribution -32.51 E -3 03241 General License Distribution -32.53 E 3 03242 General License Distribution -32.57 E 3 03243 General License Distribution -32.61 E 3 03244 General License Distribution -32.71 E 3 03250 Exempt Distribution -32.11 E2

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, 03251 ,. Exempt Distribution Time Pieces -32.14 E 3 1

03252 Exempt Distribution -32.17 E 3 03253 Exempt Distribution -32.18 E 3 03254 Exempt Distribution -32.22 E 3 03255 Exempt Di'stribution -32.26 E 3 03310 03320 Industrial Radiography Fixed Industrial Radiography Temporary C @ 2. '

Job Sites C1 1 .

03510 Irradiators Self Shielded <10,000 Curies E @ O i

03511 Irradiators Other <10,000 curies E

@3 03511 Irradiators Under Construction E4 WR Issue Date: _ _ _ _ . . _ ___ _ _ . . __T3-2__ _ _ _ ._ _. _ __________ _ _ _ _ _ _ _

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280'0 TABLE 3 MATERIALS INSPECTION PROGRAM Inspection Program Code Category Title Category Priority s

03520 Irradiators Self Shielded >10,000 -

03521 Curies t Irradiator Other >10,000 Curies E

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@51 03521 Irradiators:,Under Construction E4 W R 03610 ' Research and Development Type A Broad E1A 3 03611 '

Research and Development Type B Broad ElB 3 03612 Research and Development Type C Broad E1C -

5 03613 Research and Development Multisite- -

m Multiregional Type A Broad (Secondary B1 1 Code) 03620 Research and Development Other E 3 03710 Civil Defense K 7 11200 Source Material Other <150 Kilograms E 11210 Source Material Shielding E 7 11220 Source Material Military Munition Test 11230 Source Material General License K

3 Distribution - 40.34 E 3 11300 Source Material Other >150 Kilograms E i 11700 Rare Earth Extraction and Processing E 3 2, ~

1 21310 SNM Plutonium - Neutron Source -

Greater Than 200 Grams at -

1 Universitie's Elc 5 21320 SNM Plutonium - Neutron Source Greater Than 200 Grams Other Than Universities E1C 5 22110 SNM Plutonium - Unsealed, Less Than

,- Critical A 2 22111 SNM U-235 and/or U-333 Unsealed, Less Than Critical A 2 22120 SNM Plutonium - Neutron Source Less than 200 Grams E2 22130 Power Sources Byproduct and/or SNM K 7 -

22140 SNM Plutonium - Sealed Sources in Devicer F '6 22150 SNM Plutonium - Sealed Sources q-Less Than Critical F 6 I

.22151 SNM U-235 and/or U-233 Sealed Sources Less Than Critical F 22160 Pacemaker Byproduct and/or SNM ..

Medical Institution K 7

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'MRTERIALS INSPECTIOK PROGRAMS TABLE 3, 2800

' Inspection Program Code Category Title Category Priority 22161 Pacemaker Byproduct and/or Individual K 7 22162 Pacemaker Byproduct and/or Manufacturing and Distribution B 1

.22170 SNM General License Distribution-70.39 8 (j[) j) 05100 Sealed Source Review (none) - -

,_ 05200 Device Review (none) - -

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ENCL 0SURE 6

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INSPECTION TOPICS VS METHODS OF INSPECTION

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Taken from Two Reports of Inspections of Hospitals U

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INSPECTION A INSPECTION TOPICS VS METHODS OF INSPECTION Taken From a Full Report of a Hospital Inspection Topics How Inspected

1. Organization 1. Not stated how compliance was determined.

2. Internal audits 2. Interviews and review of records.

3. Training and qualifica- 3. Asked for names of physicians who read tions of personnel and interpreted diagnostic scans.

4. Radiation protection 4. Report didn't say how compliance was procedures determined.

5. Use of Materials 5. Reviewed records of performance checks of the dose calibrators and the inventory of brachytherapy sources.

6. Storage of Materials 6. Inspector observation

7. Facilities 7. Report didn't say.

8. Instruments 8. Report didn't say.

9. Receipt and transfer 9. Reviewed records of receipts and package of materials surveys.

10. Personnel Protection 10. Reviewed records of radiation exposure, and of surveys of radiation and contami-nation.

11. Waste Disposal 11. Reviewed the waste disposal procedures and records.

12. Notifications and Reports 12. Asked technologist if there had been any misadministrations, overexposures, thefts of material or loss of material that had not been reported.

13. Posting of Notices 13. Observed that required notices were posted.

14. Independent measurements 14. Apparently none were made.

by the inspector

INSPECTION B Topics How Inspected

1. Organization 1. By discussion with hospital Administrator

2. Internal Audits 2. By interview.

3. Training and qualifications 3. Interview of the one nuclear medicine of personnel technician on the staff (had received no formal training)

4. Radiation protection 4. By interview of person who was supposed procedures to execute them.

5. Storage of materials 5. Asked technician to demonstrate how he performed Mo-99 breakthrough test (he couldn't do it). Records indicated the test was performed as required. Observa-tio'n that there were no sources for daily checks of the dose calibrator.

6. Storage of materials 6. Observation.

7. Facilities 7. Observation.

8. Instruments 8. Observation of instrument performance.

9. Receipt and transfer of 9. Records and interview.

materials

10. Personnel protection 10. Review of vendor film badge reports.

Observation of how technician was wearing the badge (improperly).

11. Waste Disposal 11. Interview and independent measurements of waste.

12. Notifications and reports 12. Not mentioned in the report.

13. Posting of notices 13. Not mentioned in the report.

14. Independent measurements 14. Measured radiation levels on surfaces and in areas where radioisotopes were being used.

UNION OF CONCERNED 1346 Connecticut Asenue. N.W. . S. I101. Washington, DC 20036. (202) 2945600 28 January 1985 Mr. J. M. Felton, Director Division of Rules and Records FREEDOM OF INrOhMATION Office of Administration ACT REQUEST U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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Dear Mr. Felton:

Pursuant to the Freedom of Information Act, please make available at the Commission's Washington, D.C., Public Document Room copies of documents in the following categories:

A. All data reports and technical reports concerning the steel containment test series at Sandia National Laboratories.

B. All NRC documents evaluating the results of the steel containment test series.

C. All documents generated by any peer review committees established to advise NRC and/or Sandia National Laboratories concerning the performance of the steel containment test series and interpretation of the test series results.

If there are any questions concerning this request, please contact me directly at 202-296-5600. Thank you for your prompt response to this request.

Sincerely, ,,

A C

Steven C. Sholly Technical Research Associ te

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Main Office: 26 Church Street . Cambridge. Massachusetts 02238 . (617) 547-5552