ML20137Z948

Draft Impep Review of Region IV Matls Program,970312-21

ML20137Z948
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Issue date:	03/21/1997
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i INTEGRATED MATER!ALS PEP"'9MANCE EVALUATION PROGRAM REVIEW OF REGION IV MATERIALS PROGRAM MARCH 12 21,1997 DRAFT REPORT Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 9704250152 970418 PDR ORG NOMA PDR

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Region IV Draft Report Page 1 1.0' INTRODUCTION i

1 This report presents the results of the review of the Region IV (RIV) radioactive materials l licensing and inspection program as well as the RIV fuel cycle inspection, Site l Decommissioning Management Plan (SDMP), and uranium recovery programs. The review was conducted by an interoffice team from the. Offices of Nuclear Material Safety and Safeguards (NMSS) and State Programs (OSP), Regions I and 11, and an Agreement State team member from the State of Tennessee, over the period of March 12-14,1997, at the i Walnut Creek, California, Field Office (WCFO), and March 17-21, in Arlington, Texas.

Members of the review team are listed in Appendix A. The review approach was based on the common performance indicators of the Integrated Materials Performance Evaluation )

Program (IMPEP) as described in SECY-94-011, Management Directive (MD) 5.6, l

" Integrated Materials Performance Evaluation Program," and the various non-common

indicators circulated to the Region in advance of the review. Preliminary results of the ,

review -- which covered the period of April 1995 to March 1997 -- were discussed with i RIV management through the Deputy Regional Administrator on March 21,1997. The Region will have the opportunity to comment on this draft, and the comments will be .

factored into the final version of this report following a Management Review Board meeting.

[ Paragraph on results of MRB meeting will be included in th'e final report. The Region's response will also be included in the final report.]

The RIV materials, fuel cycle, SDMP, and uranium mills programs are administered by the Division of Nuclear Materials Safety (DNMS) in Arlington, Texas, and through the field office in Walnut Creek, California. Within DNMS, responsible branches include the Nuclear Materials Licensing Branch (NMLB), the Nuclear Materials Inspection and Fuel Cycle / Decommissioning Branch (NMi&FCDB), and the WCFO Materials Branch (WCFO MB).

The RIV organization is shown in Appendix B.

The RIV materials program included licensing, inspection, and enforcement for approximately 860 materials licenses at the time of the review. This figure accounts for approximately 13 percent of all materials licenses under Nuclear Regulatory Commission (NRC) jurisdiction.

Section 2.0 below discusses RIV's actions relative to the findings of the previous IMPEP review held in Spring 1995. The results of the current review for the common performance indicators of the IMPEP are presented in Section 3.0 below. Section 4.0 discusses the results of the review outside the common performance indicators, including the fuel cycle inspection, SDMP, and uranium recovery programs. Finally, Section 5.0 summarizes the review team's findings and recommendations.

2.0 STATUS OF ITEMS IDENTIFIED IN THE 1995 IMPEP REVIEW Seven recommendations were identified as part of the April 1995 IMPEP review. The status of these recommendations was formally addressed by RIV in a memorandum dated

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Region IV Draft Report Page 2

August 29,1995. The 1997 review team assessed the status of these items.to determine l whether or not the RIV program took actions to close the recommendations. A brief

discussion and evaluation of each recommendation is summarized below:

4 Recommendation 1. Continue to monitor the materials licensing and inspection statistics to determine the optimum time to shift resources from licensing back to j the inspection program,

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Current Status: This recommendation is closed. The review team determined that RIV's licensing backlog still exists and is unlikely to be completely eliminated over

the next year. The Region will continue to emphasize eliminating the backlog over I the next review period, so RIV is not likely to shift resources from licensing back to i

inspection in 1994, RIV management developed a formal plan to reduce the licensing backlog, which originally moved resources from the materials inspection program to licensing and formed the basis " this 1995 IMPEP recommendation.

During this 1995-1997 review period, some of those resources were moved back to inspection, because the earlier resource shift did not prove to be entirely effective and because the Region acquired additional responsibilities (e.g.. the Syncor multi-

, site license). The current balance between licensing and inspection staff should remain stable, at least over the next 1 - 1.5 years, as RIV continue's to cmphasize backlog reduction. Therefore, this recommendation is no longer applicable.

Recommendation 2. Assure that license reviewers include copies of the checklists

they use in the docket files.

3 i Current Status: This rscommendation is closed. In the RIV response to the IMPEP questionnaire, the Region states that additional checklists have been developed and

implemented (Answer 14.C.). The Region also states that complex licensing cases,'

i and cases where' deficiency letters are written, will have completed checklists included as part of the licensing record package (Answer 25 A.2., and 8/29/95 response to 1995 IMPEP Report). The review team examined cases where

checklists should have been completed, according to the RIV commitments, and confirmed that license reviewers in both Arlington and WCFO are completing and i

including copies of the checklists in the docket files,in the manner described by the j Region.

. Recommendation 3. Assure the completeness of the reciprocity inspection files.

Current Status: This recommendation is closed. While on-site, the review team requested 15 reciprocity inspection filer. Fourteen of the files were provided

' immediately, or provided by fax from WCFO to the RIV Arlington office. The one file that could not be found was subsequently determined to be an initialinspection of a lice.nsee, instead of a reciprocity inspection. The review team examined these i fourteen reciprocity files and found that they included all pertinent reciprocity filing

and inspection information, organized in an orderly manner.

< Recommendation 4. Develop a more consistent policy between WCFO and

Region IV Draft Report Page 3 Arlington on the use of NRC Form 591 versus the use of the inspection cover letter.

NMSS will support this effort by providing clearer direction on the use of 591's in the forthcoming revision to inspection Manual Chapt'er (IMC) 2800, " Materials

' inspection Program."

Current Status: This recommendation is closed. The review team noted that both the WCFO and Arlington inspectors are using the current inspection guidance issued in IMC 2800 regarding the use of NRC Form 591. Also, NMSS issued a final revis on to IMC 2800 on April 17,1995.

Recommendation 5. Resolve the inconsistency between the levels of documentation in WCFO and Arlington inspection field notes.

Current Status: This recommendation is closed. The review team noted that several meetings between WCFO and Arlington inspectors were held to discuss the documentation differences and how to correct these differences, it was noted during the review that all of the inspection field notes were complete, and the review team observed that the current minor differences in the details of the report are more closely tied to individual inspector differences than office differences. The review team observed a shift to a more consistent level of documentation between the two RIV offices during the review period.

Recommendation 6. Continue the effort to assure that new, more reliable equipment (i.e., calibrated survey instruments and check sources) is available to materials inspectors.

Current Status: This recommendation is closed. The review team found that new survey instruments and check sources have been purchased since the last review.

Both RIV offices have contracts to perform calibrations of the instruments. The instrument calibrations are staggered to insure the availability of calibrated instruments, and different types of instruments were available to inspectors at the time of the on-site review.

Recommendation 7. Provide more management attention to assure that annual supervisory accompaniments of inspectors are performed.

Current Status: This recommendation remains opert. The review team found that, while most of the inspectors were accompanied twice or more during the review period by their supervisors, two inspectors in NMI&FCDB were not accompanied after June 1995. One of those inspectors has only limited inspection certification.

The other is a senior radiation specialist who was on detail to the Office of the Executive Director for Operations for four months during 1996, so he did not perform inspections during portions of the review period. Likewise, two individuals who have part time inspection responsibilities'in WCFO MB also were not accompanied at any time during the review period. One, a senior health physicist, is a qualified reactor inspector vvho performs decommissioning inspections and  ;

assists on fuel cycle inspections, for a limited portion of his time, among other

2 Region IV Draft Report Page 4 assignments. The other individual performs reciprocity inspections, about 20% of the time, with the rest of his effort devoted to materials licensing. The issue of supervisory accompaniments of inspectors was raised on the 1993 National Program Review, in addition to this open recommendation on the 1995 IMPEP review. RIV Branch Chiefs report on accompaniments to DNMS management, on a regular basis, but the Region does not appear to formally track which inspectors have been accompanied during the year. This continues to be an area needing management attention, although regional management was satisfactoriN accompanying most inspectors dor!ng tb ' 7 view period, i

l In summary, the team considers all of the above 1995 recommendations closed, with the exception of Recommendation 7.

, 3.0 COMklON PERFORMANCE INDICATORS The IMPEP is based on five common performance indicators to be used in the review of both NRC Regional and Agreement State materials programs. .These indicators include: 1)

Status of Materials inspection Program; 2) Technical Staffing and Training; 3) Technical Quality of Licensing Actions; 4) Technical Quality of Inspection; and 5) Response to

, Incidents and Allegations. In preparation for the review, NMSS issued a questionnaire to .

RIV on January 21,.1997. RIV. responded to the questionnaire on February 24,1997. A

copy'of that response, without its enclosures, will be included in the final version of this report. t

. The review team's approach consisted of: 1) examination of the regional response to the' questionnaire; 2) review of selected quantitative information from the Licensing Tracking System (LTS); 3) technical review of selected licensing, inspection, incident, and allegation files; and 4) interviews with staff and management to clarify issues raised by 1),2), and 3) above. With assistance from inspectors in RI and Rll, the team also accompanied four RIV inspectors to observe their conduct of inspections at 11 f acilities. Finally, a team member also attended a RIV inspection trip debriefing. The team evaluated the information that i

, was gathered against the performance criteria contained in MD 5.6 and made a preliminary assessment of regional performance.

3.1 Status of Materials inspection Proaram The team focused on four factors in reviewing this indicator: (1) inspection frequency, (2) overdue inspections, (3) initial inspections of new licenses, and (4) timely dispatch of

inspection findings to licensees. The review team examined the RIV questionnaire 4

responses relative to this indicator, reviewed data gathered independently from the NMSS Licensing Tracking System (LTS), and examined docket files. In addition, the team interviewed the DNMS Director, the three DNMS Branch Chiefs, and the two senior inspectors in WCFO and Arlington who have principal responsibility for. scheduling inspections.

Region IV Draft Report Page 5 The team's review of RIV's inspection priorities found that the inspection frequencies for different types of RIV licenses are established in the LTS. The LTS inspection frequencies are managed by the Division of Industrial and Medical Nuclear Safety (IMNS), NMSS, and are based on the inspection frequencies in IMC 2800. Therefore, the Region is using exactly the same standard frequencies in IMC 2800. The team determined that the Region is aggressively implementing the IMC 2800 policies that direct individual licensee inspection frequencies to be extended or reduced, based on inspection findings and previous licensee performance. The Region implements this performance-based measure through a standard form that inspectors and supervisors complete following each inspection, and file in the docket file. Printouts for both Arlington and WCFO of the-

" inspection due lists" from LTS showed numerous examples where RIV had extended or reduced inspection frequencies, and appropriately coded the change in the LTS. Based on a rough review of the Arlington inspection data, the Region appeared to extend about twice as many inspections than it reduced, which is consistent with IMPEP teams' observations in other N5'.C regions that extensions exceed reductions. A few minnr discrepancies in the inspection frequencies, where extension or reduction codes were not shown in the LTE, were resolved and corrected while the review team was on-site by obtaining documentation from the docket files that showed an extension or reduction decision. In general, the review team determined that RIV is following the IMC 2800 inspection frequencies and is actively extending or reducing individual licensee inspection intervals, based on licensee performance.

In its response to the questionnaire, the Region indicated that (as of the date of the questionnaire) it had no inspections overdue by more than 25 percent of the assigned frequency in IMC 2800. The review team checked this response by reviewing the

" inspection due lists" from the LTS while in on-site. The only non-initial RIV inspections the review team identified that were outside of the 25 percent criterion were a very small number of special cases (2-3), such as a decommissioned reactor site where surveys had -

been performed but no formalinspection extension decision had been documented, and a decommissioning licensee where specialinspections had been completed but the LTS had not been updated at the time of the on-site review. The routine inspection frequency criteria in IMC 2800 for operating facilities are difficult to apply to such licensees, and no routine inspections were identified by the review team in Ar!ington or WCFO that were outside the 25 percent criterion in IMC 2800 at the time of the review. This finding is notable in that it applies to all of RIV's core and non-core inspections. The IMPEP evaluation criteria only specifies overdue core inspections. The review team observed exemplary performance by RIV inspection managers and staff on scheduling and performing inspections in a timely manner, and RIV is far below the 10 percent criterion for overdue core inspections in MD 5.6.

With respect to initial inspections, the review team examined an LTS listing of 71 new licenses issued by RIV between April 1995 and March 1997, and cross-checked the new licenses with dates of initial inspections. Of the 71 new licenses issued, 66 were inspected with'in the time frames for initial inspections specified in IMC 2800. Of the remaining four licensees inspected late, regional management decided to inspect one of those outside of the IMC 2800 standards to use regional inspection resources most efficiently. That licensee is a portable gauge used in Alaska that is transported by air to

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. Page 6 Region IV Draft Report remote locations. Two of the remaining three late initialinspections had been completed by the time of the on-site review. The review team observed strong regional performance on this area. The Region is well-within the IMPEP evaluation criteria that inspections of new licenses are " generally conducted" within six months of usuance or in accordance J with IMC 2800 provisions. ,

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The timeliness of inspection findings was evaluated during the inspection file review. Out of the 25 inspection files examined, all of the inspection correspondence (either NRC Forms 591 or notices of violation) had been issued to the l'icensees within 30 days after completion of the inspection. In interviews, the review team learned that the DNMS technical assistant routinely tracks timeliness of inspection reports in the "DNMS Quarterly Report." In the quarterly report for the first quarter, FY97, DNMS identified 16 of 38 l

inspection reports that had exceeded the 30 day mark (or 45 days for team inspections).

However, the review team examined this list and found most of these cases (11) were either escalated enforcemerd aases., which involve extensive coordination with Headquarters offices, or terminated site surveys, which are a low priority in the Regional Operating Plan. The team considered all of this information regarding the timeliness of inspection findings, and determined that RIV is raeeting the IMPEP evaluation criteria that "a large majority" of inspection findings are communicated to licensees in a timely manner.

In its response to the questionnaire, RIV provided statistics regarding the numbers of reciprocity inspections completed in calendar years 1995 and.1906. In 1995, the Region fell far short of the inspection pnorities in IMC 1220, " Processing of NRC Form 241,

' Report of Proposed Activities in Non-Agreement States,' and Inspection of Agreement State Licensees Operating Under 10 CFR Part 150.20." For instance, the Region reported that they conducted inspections of.2 radiographers out of 25 radiography reciprocity

' applications that year. The IMC 1220 priority is to inspect 50% of Priority 1 licensees, such as radiographers. In total, RIV performed 10 reciprocity inspections in 1995, of which half (5) were for high-priority licensees (radiographers, well loggers, and some service licensees). The Region demonstrated marked improvement in conducting reciprocity inspections in 1996, and the review team verified that RIV met all of the priorities for reciprocity inspections in IMC 1220 in 1996. RIV conducted 37 reciprocity inspections in 1996', of which 25 were for the high-priority licensees. In f act, in 1996 RIV inspected 14 of 25 radiography reciprocity licensees,2 of 2 decontamination reciprocity licensees,4 of 12 welllogging . reciprocity licensees, and 5 of 11 service reciprocity licensees, including 100% of the service licensees performing medical teletherapy or irradiator source service in the RIV geographic area. The review team attributes RIV's vast improvement in 1996 to management emphasis, and inspector perseverance, on conducting reciprocity inspections. The Region's improvement in this area iuring the review period is commendable.

Based on the evaluation criteria contained in MD 5.6, the team recomniends that the Region's performance with respect to this indicator, Status of Materials inspection Program, be found satisfactory.

4 Region IV Draft Report Page 7 3.2 Technical Staffino and Trainina Issues central to the evaluation of this indicator include the DNMS materials program staffing level, technical qualifications of the staff, training, and staff turnover. To evaluate

these issues, the review team examined the HIV questionnaire response relative to this indicator and met with the DNMS Branch Chiefs to discuss staffing and training issues, l including the qualification status of license reviewers and inspectors.

Technical and licensing support staff in the RIV materials program are organized into the l t three branches within DNMS: NMLB, NMISFCDB, and WCFO MB. The official branch titles j no longer reflect the division of tasks within the Arlington office. For instance, NMLB '

conducts most decommissioning work, including inspections, and NMl&FCDB had no active fuel cycle facilities at the time of the on-site review. Regional management reported that they are in the process of changing the branch titles.

The. Arlington office has five materials inspectors for industrial and medical inspections, I

i. five license reviewers, and one licensing assistant. The Arlington office also has an additional four inspectors who primarily perform decommissioning, terminated site, or j uranium recovery inspections, and some of these staff members also assist in the routine materials program. For instance, a Senior Health Physicist in NMI&FCDB, who primarily j performs uranium recovery inspections, is also the project manager for the U.S. Air Force .

Master Material License. WCFO has two materials inspectors, two license reviewers, one individual who has dual inspection and licensing responsibilities, and one licensing assistant. WCFO also has one fuel cycle facility inspector and one senior health physicist who primarily performs decommissioning-related tasks. The review team observed that the regional technical staff is roughly divided in thirds, with inspection, licensing, and specialty materials efforts (decommissioning / fuel cycle / uranium recovery) given approximately equal staffing levels. The staff assigned to decommissioning efforts also cover nuclear power plant decommissioning issues and inspections. In the area of routine industrial and medical byproduct m'aterials licensing and inspection, the review. team concluded that the Region has a good mix in staffing for licensing and inspection activities. Both RIV offices app' ear to have adequate administrativo support. Additional discussion of resource utilization

. ap' pears in Section 4.1 of this report.

In its response to the IMPEP questionnaire, the Region reported that no new technical staff members were hired during the review period. In addition, the Region reported that no l technical staff had left the program during the review period, so no vacancies were experienced in the materials program. The review team observed that the Region's technical staffing has been extremely stable over the review period.

During the review period, regional staff completed severallong details or additional assignments that, effectively, removed them from materials licensing or inspection duties temporarily. One DNMS staff member is currently assigned to a two-year detail to assist the RIV Enforcement Coordinator, and one NMi&FCDB inspector conducted a'4-month rotation to the Executive Director for Operation's office in 1996. In addition, a senior

, license reviewer is assigned to work nearly full time on IMNS' Business Process Redesign (BPR) program. Regarding the first two ir.dividuals' details, the review team did not note a

riegion IV Draft Rerort Page 8 performance-relatec impact. DNMS has been able to absorb these losses and still maintain a high quantity anc quality of work. The senior license reviewer's involvement with IMNS' BPR effort has cle rly impacted NMLB's pace at reducing the licensing backlog, as discussed in Section 4.1 of this report. However, regional managers indicated strong support for the BPR effort, and they were hopeful that this temporary staff loss for RIV would result in improved licensing processes and increased savings, in the longer term, for RIV and the agency, as a whole.

With respect to qualifications, NMSS and tne regions undertook a major effort during the review period to establish formal training standards for most materials-staff positions, culminating in the issuance of IMC 1246, " Formal Qualification Programs in the Nuclear Material Safety and Safeguards Program Area," on June 7,1996. This resulted in the training requirements for m::ny of the region::! meterials insr'.sctors and license reviewers changing in the middle M ims ieview perbd. Inuiv: duals aready qualified in a discipline were given three years to complete any & " fornial :lassroom training requirements.

Personnel in the process of qualifying when IMC 1246 was issued were allowed to continue to qualify unc!er the enginal requirements, with three years from the revision date to complete any new requiremerts. Reg.onal Administrators may waive or extend any IMC 1246 requirements, ar.d materials staff with prior experience and education may, on rare occasions, request to complete equivalency examinations in lii u of course attendance.

The Region reported in its response to the questionnaire that none of the NMLB license reviewers have been qualified under IMC 1246. Three of the NMLB license reviewers were previously certified fc.r broad licensing signature authority, and the Region plans to grant them waivers based en prior experience or have these reviewers attend the formal IMC 1246 courses over the remaining time period (more than two years) for re-qualification.

The other two NMLB license reviewers and the licensing assistant were granted limited signature authority before IMC 1246 was issued. The Region plans to qualify both reviewers under the IMC 1246 requirements, and RIV reported that both individuals have already completed aiiicquired core trai~ning courses in IMC 1246. The Region reported 4

that all WCFO M3 ticense reviewers meet the qualifications. The one WCFO MB staff member who is e ssigned oual inspection / license review responsibilities is net certified for license review, reo hie !1ensing work is reviewed and signed by one of the 'NCFO MB senior license reviewers.

The Region also reported that all but two of the Arlington materials inspectors were previouny certified under the inspector training requirements existing before IMC 1246-was issued. Regional management decided that the two inspectors being certified, who already have been granted limited certification to inspect certain types of licensees, will continue the process under the older training requirements. The Region reported that all of the Arlington materials inspectors have met the core training requirements of IMC 1246, with the exception of Site Access Training (H-100), which regional managers say will be provided during an upcoming "all-hands" meeting in July 1997. The Region reported that all WCFO MB materials inspectors meet the qualifications for their assigned positions, but the review team identified that, in one case, this meant that a staff member previously certified as a reactor inspector is conducting reactor and materials decommissioning inspections. WCFO MB and NMLB are focusing on having some inspectors and license

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Region IV Draft Report Page 9 4

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reviewers complete the qualifications for decommissioning inspectors and decommissioning ,

license reviewers created last year in IMC 1246. This would result in some RIV staff being

. qualified over the next 2+ years in more than one materials discipline.

The review team spot checked a sampling of certification letters, completed training lists, i and individual 1997 training plans, and interviewed the three Branch Chiefs regarding staff training. The review team determined that RIV has a well-organized system for planning, approving, and tracking training. Regional managc .s were fully cognizant of the qualification status and training plans for their staff, and management displayed a commitment to training. Technical staff regularly attended specialty training courses'and refresher training, and appeared to maintain technical currency for their assigned positions.

All technical staff appeared to the review team to have the basic technical skills to perform

- their jobs adequately, and some RIV staff have advanced training or certification (e.g., one WCFO MB inspector is a Certified Health Physicist). The review team determined that RIV adequately implemented the trainMg requiremenn ';troduced by the issuance of IMC 1246 i during the middle of the review period, and RIV staff is making solid progress toward l qualification or re-qualification under the new IMC 1246 requirements.

Based on the evaluation criteria contained in MD 5.6, the review team recommends that -

l the Region's performance with respect to this indicator, Technical Staffing and Training, be j found satisfactory. l 3.3 Technical Quality of Licensina Actions The review team examined license. files and related documentation and interviewed the

~ responsible license reviewers for 20 specific licenses that had licensing actions completed during the review period. The team also reviewed the status of the U.S. Air Force Master ,

Material License. The 24 licensing actions examined by the team included 6 new licenses, i 1 renewal,15 amendments,1 termination and 1 notification that an authorized user had been added to a medical use license. The team also reviewed licensing actions for t'he Syncor international, Inc., multi-site nuclear pharmacy license. Ten of the licensing actions involved complex license types, including the fol!owing:

e 2 academic broad scope e 4 medical institutions, therapy quality management plan required e 2 nuclear pharmacies

• waste disposal service, packaging and/or repackaging e industrial radiography, temporary job sites Completed casework from each license reviewer was included in the team's evaluation.

The cases were selected in an effort to establish as wide a range of licensing actions and reviewers as possible within the time available. A list of the licensing actions reviewed is contained in Appendix D. In addition, the team interviewed license reviewers and supervisors, am necessary, to supply additional information regarding the team's questions on licendog decisions or docket file contents.

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Region IV Draft Report Page 10 The licensing actions were reviewed for completeness, consistency, proper isotopes and quantities, qualifications of authorized users, adequate facilities, operating and emergency procedures, and authorized user training sufficient to establish the basis for the licensing action. Casework was reviewed for timeliness, adherence to good health physics I

practices, reference to appropriate regulations, documentation of the basis for the licensing decision, and consideration of enforcement history on renewals. The files were checked for orderliness and retention of necessary documents and supporting data.

The licensing actions were thorough, complete, consistent, and of acceptable quality with .

I health and safety issues properly addressed. Tie-down and specific conditions were clearly i stated, backed by information contained in the file and considered to be inspectable. The team noted that license reviewers provided information to the inspectors for followup during the next inspection. The Region is completing the analysis of licensing actions against criteria which may warrant early inspection due to changes as mandated by Policy

' & Guidance Directive 94-04, " Identification of Lie-es Where Significant Licensing i Actions Warrants Onsite Inspection." New license issued contain the necessary license conditions, as appropriate. The Region's practice of including lic'ensing checklists in cases involving complex licensing issues or deficiency letters was verified by the review team.

This practice has been implemented in WCFO, as well. ,

RIV has transferred some licensing actions to WCFO in an effort to reduce the licensing casework backlog. WCFO licensing staff complete a group of licensing actions, then request or are assigned another group from Arlington. Generally, all these renewals have been sent to WCFO in individual State groups. WCFO licensing staff devote a significant segment of their licensing time to the backlog-reduction effort. The licensing backlog issue is addressed in more detail in Section 4.1 of this report. With regard to the technical quality of licensing actions, the review team found that the Region's focused effort to reduce the backlog has not resulted in a decrease in licensing quality.

As a result of December 1994 amendments to 10 CFR Part 35 and Section 32.72, changes commonly known as "the Radiopharmacy Rule," NMSS determined that changes were needed in licensing practices regarding medical use. The changes first were provided in a draft Regulatory Guide. After comments by the regulated community, NMSS withdrew the guidance, except as needed for radiopharmaceutical therapy (10 CFR Section 35.300). In telephone conference ca'Is on February 7 and April 4,1996, between NMSS and the regions, NMSS provided verbal directions on changes needed in licensing 635.300 use. The changes involved the manner of listing the isotope, form, and quantity for iodine-131 and all other therapy radionuclides'with half-lives less than 120 days, on the official license document. The conference calls were followed-up by distribution of written minutes to the organizations participating on the calls. The review team determined, from a review of medicallicenses, that RIV (both Arlington and WCFO licensing staff) has not y implemented these licensing changes, because written licensing guidance has not been issued by NMSS. The review team recommends that NMSS issue formal, written guidance in final form to all Regional Offices regarding changes in procedures for licensing medical use f acilities, including radiopharmaceutical therapy (635.300) users. Such guidance would enhance consistency across all regions and license reviewers.

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Region IV Draft Report Page 11 The review team examined RIV. licensing actions regarding terminated sites to determine if i sufficient radiological surveys were performed before license termination and release, to  ;

ensure that residual radioactivity levels comply with release criteria, and to ensure that l licensee survey results were validated through use of a closeout inspection or confirmatory i survey, as required. All of the files that the team reviewed were for facilities that did not require final status surveys or decommissioning plans. Most of RIV's terminated licenses were facilities that possessed radioactive materials in the form of sealed sources or gauges, with documented leak tests, and the sources were shipped back to the manufacturer for disposal. Based on a samplir.g of terminated license files, the review team determined that the license reviews for these terminations were conducted properly by the Region. In addition, the regional staff, on their own initiative, prepared a document entitled, "Information That Should Be Submitted To The NRC Staff For Decommissioning And Termination Of Licensed Facilities" (see Attachment 1). This document, for distribution to the licensee community, lists the sections of 10 CFR Parts 30,40 and 70 applicable to decommissioning sites. The regional document also provides information regarding surveys duri.ng and after license termination. The review team identifies this document for terminating licensees as'a good practice and recommends that its use be considered by other regions and Agreement States. '

l The RIV decommissioning financial assurance instrument program was evaluated in WCFO and Arlington for routine, non-SDMP decommissioning projects and active licensees, to determine if fmancial assuranc;e instrument security programs are in place and to ensure that complete instrument files are being maintained. The evaluation was performed in accordance with MD 8.12, " Decommissioning Financial Assurance Instrument Security Program."

in both WCFO and Arlington, the staff provided the review team complete, detailed, well-organized inventories that listed individual financial assurance instruments. Access to the safes in both offices was controlled, and two staff members have the combinations. A Financial Assurance Instrument Custodian (FAIC) and an alternate (AFAIC) have been appointed in both offices. NRC Security Forms 702 (Security Checklist) were observed to be used, and a log for removal or input of financial assurance instruments has been developed for each office. The Region performed audits of the financial assurance instrument files for both offices in May and November of 1996. During the IMPEP review, the Region corrected minor documentation and tracking issues identified by the review team, by entering the data in the LTS and updating financial assurance file information, where information was missing. The review team did not identify any performance-based issues regarding those minor corrections.

MD 8.12, Section E, requires that the financial assurance instruments be maintained in a

" fire rated safe." The WCFO staff provided notarized papers showing that the safe in WCFO is fire rated. The Arlington staff could not demonstrate that the Arlington safe is fire rated. Subsequent to the on-site review, the Region attempted to identify specific criteria for " fire ratings," in order to procure a suitable " fire rated" safe, and found that the General Services Administration (GSA)' discontinued requirements for fire ratings on certain classes of safes several years ago. The Region reported a chronology of their attempts to identify the meaning of " fire rated" and " secure storage" to the review team leader on

Region IV Draft Report Page 12 April 4,1997. Until the Region can obtain the meaning of " fire ratea" as used in MD 8.12, the Region has put its procurement request for a " fire rated safe" on hold. The review team recommends that NMSS clarify the meaning of " fire rated" in MD 8.12. Following that clarification, the review team recommends that RIV either provide evidence to NMSS' Division of Waste Management (DWM) that the Arlington safe meets DWM's guidance for fire protection of the financial assurance instruments, or obtain a security container for financial assurance instruments that meets the fire protection guidance.

The review team found that any deficiencien .n % licensing actions reviewed were minor, isolated or administrative in nature, and most deficiencies were corrected ducing the on-site review. The Region's system for licensing remains formal, structured, clear, and appears to work well, as noted in the 1995 IMPEP review. No potentially significant health and safety issues were identified in the team's review of RIV's licensing practices.

Based on the evaluation criteria in MD 5.6, the raview team recommends that the Region's performance with respect to this indicator, T(chnical Quality of Licensing Actions, be found satisfactory.

3.4 Technical Quality of Inspections I

The team reviewed the inspection field notes and follow-up documentation and interviewed the responsible inspectors, when available, for 25 materials inspections conducted during the review period. These inspections were performed by 9 RIV inspectors and two inspectors from different regions working on R!V licenses (i.e., Syncor's multi-site license and the U.S. Air Force's Master Material License). The reviewed cases covered a range of license types to include medical, academic, broad scope, gauges and industrial licenses. In its file review, the team observed that RIV inspectors used the appropriate and most recent version of the inspection field notes and the Quality Management field notes to document inspections. Appendix E provides a list of the inspection cases reviewed in full.

l A senior health physicist and a team member from Regions I and 11, respectively, accompanied four RIV inspectors on a total of 11 inspections, inspector accompaniments were performed at the following license types: hospitals, gauges, and a nuclear pharmacy.

On the accompaniments, the RIV staff demonstrated appropriate inspection techniques and knowledge of the regulations. The inspectors were well-prepared and thorough in their reviews of the licensees' radiation safety programs. Overall, the technical performance of the inspectors was satisfactory, and their inspections were adequate to assess radiological health and safety at the licensed facilities.

The team determined that RIV is performing inspections of materials licensees on an unannounced basis, except for initial inspections or when necessary to insure the presence of licensee personnel (i.e., geographically distant licensees or inspections when licensee personnel are in the field most of the time). Field notes prepared by inspectors were found to be thorough and completed in a timely manner after the inspection. Generally, inspection results were reviewed and signed off by the supervisors within a fe'w days after completion of the field notes.

Region IV Draft Report Page 13 I The review team examined the feedback between RIV licensing and inspection staff and found that appropriate information was flowing in both directions between inspectors and license reviewers. The inspection information flow from the RIV licensing staff to inspectors appeared to be more formal, written communication, and was observed to be documented frequently in the docket files. Team interviews with both licensing and inspection staff indicated that the information flow from inspectors to licensing staff tended to be more immediate, verbal communications following inspections, supplemented by distribution of copies of inspection correspondence and infrequent written documentation in the docket files. The review team discussed with RIV management areas for improving communications between the inspection and licensing staff, but the review team observed strong positive performance on the technical quality of inspections and licensing, and therefore, has no formal recommendations on this issue.

The docket files appeared to be complete and in order. In almost all cases inspection results were well c:ganized and easily retrievable. RIV also keeps a set of "inspectinn files" that inc!ade a copy of the current license and the previous two inspection reports for each licensee, for the inspectors to take to the field. The review team cross-checked a sampling of the " inspection files" with the docket files and found that all of the inspection files reviewed were current and complete. The 1995 review of the RIV program noted that several requested records of reciprocity inspections could not be found at the time of the review. RIV still maintains reciprocity files in a separate location from the docket files. A review of 15 reciprocity inspection reports requested by the review team found that all of the reciprocity files were available except for one, which was actually an initialinspection mis-characterized as a reciprocity inspection. The initial inspection report was on file.

Because the regional staff could produce all requested reciprocity files, the Region appears l to have corrected the reciprocity file issue observed on the 1995 IMPEP review.

The review team supplemented its case review with a review of the survey meter calibration and availability. Adequate instrumentation was available for use in both Arlington and WCFO The team reviewed the process used by regional staff to ensure that meters are calibrated in a timely manner and found it to be adequate. The 1995 review recommended that RIV continue the effort to assure that new and more reliable equipment (i.e., calibrated survey instruments and check sources) is available to materials inspectors.

RIV has improved its instrumentation by purchasing more radiation detection instruments and calibration sources during the review period.

The review team is recommending that a finding from the 1995 IMPEP regarding supervisory accompaniments remain open. See Section 2.0 of this report for the team's findings.

Based on the evaluation criteria in MD 5.6, the review team recommends that the Region's performance with respect to this indicator, Technical Quality of Inspections, be found satisfactory.

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l 3.5 Resoonse to incidents and Alleaations l In evaluating the effectiveness of the Region's actions in responding to incidents and 1 allegations, the review team examined the Region's response to the IMPEP questionnaire i relative to this indicator and reviewed the incidents reported for RIV in the " Nuclear j Material Events Database (NMED)" against those contained in the casework files, the

! license. files and supporting documentation, as appropriate, for.15 incidents. The team also reviewed the Region's' response to 9 allegations. The review of incident and allegation

{

casework files covered medical'and industrial issues handled by the RIV staff in Arlington

! and WCFO. Interviews were conducted with Division level staff, the Chief, NMI&FCDB, l and other members of the technical staff. A list of incident casework with case-specific I comments is included in Appendix F.

I The management and coordination of materials events is the responsibility of NMi&FCDB.

i Initial responses to reports nf avents are received by staff from both the Arlington office and WCFO. The review team examined several sources of information utilized by the RIV

staff in their handling of incidents. These included

morning reports, preliminary notices j and monthl,y events briefing reports. The review team examined the Region's response to i 15 incidents'that included vari.ous events reported 'since the last IMPEP review. The incidents involved medical misadministrations, damaged equipment, equipment failures, I leaking sources, and personnel overexposures.

The review team found that incidents were properly categorized with regard to their health l -and safety significance, responded to promptly, were well documented in the case files,

! and when appropriate, consultants were retained within 3-5 days. Licensees were l informed of investigation findings, and follow-up measures were taken, when required, j The staff closed-out incident cases in a prompt manner. All fifteen incident case files

! reviewed were found in the NMED system. The review team commends the RIV staff for j their diligence in providing event data for entry into the NMED system.

l The Regional Administrator's Office has overall responsibility for managing the allegations j i program in RIV. The Senior Allegations Coordinator (SAC) manages the receipt,  !

i. documentation and tracking of allegations until cases are closed. The SAC also forwards j j allegations to other NRC programs, and other Federal and State agencies, and coordinates i allegation activities with these organizations. During the review period, the staff completed a revision to the Regional Office Policy Guide PG 0858.5, " Management of j Allegations". This revision, dated May.23,1996, reflects,several changes in the NRC's  ;

policy on the handling of allegations. The review team noted the following changes: 1) 1 4

guidance on preparing for Allegation Review Board Meetings; 2) documentation and follow-up of referrals to other Federal agencies; 3) c~ommunication with allegers, protecting the

[ alleger's identity and a new Allegations Receipt Form; and 4) guidance on the disposition j

f of investigation reports.. The review team confirmed that these changes are consistent with agency-wide policy as detailed in MD 8.8, " Management of Allegations," and that the j revised Regional Policy provides appropriate guidance to the staff. During the review 1 period 117 allegations were opened. At the time of the on-site review,93 cases were i closed and 24 remained open.

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Region IV Draft Report Page 15 The review team examined the health and safety aspects of allegations handled by NMi&FCDB af ter the allegations were reviewed and dispositioned by the allegation panels.

< The review team examined 9 allegation cases. These cases involved several technical and administrative issues on allegations filed since the last review. The review confirmed that actions taken were prompt, well coordinated and appropriate with regard to their health and safety significance. Cases involving Agreement State licensees were examined to determine that the appropriate notifications were made to the States and that the RIV staff 3

took action to close the allegations. The review team confirmed that the staff was consistently applying the revised agency and regional guidance on the management of allegations. The review team found that RIV is maintaining an effective and current Allegations Management System (database).

The review team found that allegations were responded to promptly, and actions were taken to coordinate allegation reports and investigation findings, both within NRC and with other Federal and State agencies. Information was controlled in accordance with proper procedures. Cases were documented and well maintained in the allegation files, docket files, and in the Allegation Management System. The review team interviewed the acting Senior Allegations Coordinator, the Chief, NMi&FCDB, and several members of the technical staff assigned to allegation and ie.cident response. Good lines vf communication exist between the staff in Arlington and the staff in WCFO.

Based on the cases reviewed, the review team found that the Region's response to incidents and allegations satisfied the performance criteria for this indicator. On incident follow-up, the level of the response was appropriate to the type of incident. The Region addresses allegations in a reasonable time frame from the time of initial notification until close-out. The Region notified States when appropriate, in accordance with NRC guidance.

Allegations were responded to with appropriate investigations and follow-up actions, and the person or the organization that notified the Region of the allegation was notified about the results.

Based on the evaluation criteria in MD 5.6, the review team recommends that the Region's performance with respect to this indicator, Response to Incidents and Allegations, be found satisfactory.

4.0 NON-COMMON PERFORMANCE INDICATORS in addition to the common performance indicators addressed in the preceding Section 3.0, the review team also examined RIV's performance relative to various NMSS programs or initiatives. For RIV, the team examined the Region's performance relative to operating plan goals, its use of NMSS program resources, the fuel cycle inspection program, SDMP program, and uranium recovery inspections. These areas are discussed in the following sections:

4.1 Performance aaainst Ooeratina Plan Goals Materials Licensina, in FY95, RIV completed 736 materials licensing actions, compared

Region IV Draft Report Page 16 with a goal of 610. RIV received 613 actions during the fiscal year leading to a significant decrease in the number of reviews pending from 371 to 248. The number of backlogged cases (i.e., those which exceeded the timeliness goals) also dropped from 142 to 106.

In FY96, performance goals no longer measured completions against a prescribed target.

Rather, the emphasis was shifted to control of pending casework and reduction of backlog.

In this light, RIV completed 593 licensing reviews, while receiving 494. This resulted in a decrease in the number of pending cases to 149 by the end of the fiscal year. Similarly, the backlog was reduced further to 76 cases, in the first four months of FY97, these positive trends continued. Pending cases dropped slightly (from 149 to 137), and backlog dropped to 66, of which 51 are older renewals.

While these numbers represent considerable improvement in all areas since the time of the last IMPEP review, the number of old cases (particularly renewals in excess of 2 3 years) continues to represent a challenge for tha Dagion.

The review team discussed the licensing backlog, and RIV's plans to eliminate the backlog, with the DNMS Director and with the NMLB and WCFO MB Branch Chiefs. Progress on the licensing backlog was discussed in the 1995 IMPEP review report, and DNMS has been working diligently for several years to reduce the backlog, with steady success. In a review of RIV's licensing statistics, collected by the NMLB Branch Chief at regular intervals, the review team determined that the licensing backlog dropped from a high of 107 cases to about 68 cases during the review period. Nearly all of the backlogged cases are difficult licensing actions, some involving technical assistance requests to NMSS/IMNS.

Backlog reduction remains a very high priority for RIV and NMSS managers, who both stated a preference for more' rapid progress. At the demonstrated rate of completion and considering the status of the backlogged cases currently being reviewed by regional staff, the Chief, NMLB, predicted that the licensing backlog could be worked down to approximately 20 cases in about one year from the review. The review team believes that to be an extremely high, but achievable, goal. Without a change that would free more tHe for RIV license review (such as redistribution of non-licensing work from licensing to inspection staff, or decreased involvement of the senior license reviewer on the BPR effort), RIV will continue to make steady, moderate progress at eliminating the backlog.

The review team believes that the actual rate of progress over the coming revi~ew. cycle may be somewhat slower than RIV management's expectation, but the licensing backlog should be worked down to low levels (i.e., less than 20) by the time of the next IMPEP review. Toward the end of the IMPEP review, the IMNS Director met with RIV management specifically to discuss progress on the licensing backlog. RIV and IMNS management will continue to watch this issue and consider all available options to eliminate the backlog at a faster rate.

Materials inspections. See Section 3.1. Regional performance on materials inspections is compared in Section 3.1 to timeliness goals, rather than total numbers of inspections performed. The RIV FY97 Operating Plan also provides DNMS' nuclear materialinspection assignments and standards in terms of inspection timeliness and quality, rather than gross numbers of inspections com' eted.

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Resource Utilization. in FY96, RIV expended 23.4 full time equivalents (FTEs) vs. 20.8  ;

FTEs budgeted for NMSS program activities (113 percent). Based.on expenditure data )

through January 1,1997, RIV had expended resources at a rate that would exceed its aggregate NMSS budget allocation by about 17 percent. Last year's regional expenditures for materials licensing and inspection and event evaluation were accountable for the totals l (with nearly 20 FTE expended last year vs.14.5 budgeted). Similar expenditure trends are l developing in FY97 with almost 20 FTE projected vs.15 budgeted for materials licensing l and inspection and event evaluation. These expenditures helped reduce the regional l licensing backlog, while allowing the Region to maintain the currency of its materials inspection program.

l Based on a review of budget information provided by NMSS' Program Management, Policy Development, and Analysis Staff (PMDA), the Region appeared to not expend all of its budget in the fuel cycle, or uranium recovery areas, although these programs comprise only about 4 FTEs between them. FY96 data show only about 2 FTE expended. The review team could not draw conclus!cns from the budget data, because the manner that regional staff coded time expenditures may have been a factor in the low expenditures on i the RIV fuel cycle and uranium recovery areas. For instance, WCFO staff performing decommiss'ioning surveys at fuel cycle f acilities rep'ortedly coded time to decommissioning, rather than fuel cycle inspections. Similarly, it was unclear to the review team whether  !

reactive inspections at fuel cycle and uranium recovery facilities are coded to those (

program areas, or to event evaluation. Performance in the fuel cycle and uranium recovery I inspection areas is discussed in ' subsequent sections of this report (Sections 4.2 and 4.4, l respectively), but the Region did not appear to suffer performance problems due to l apparent low expenditures in these areas, in fact, the Region's apparent ability to conduct l the fuel cycle and uranium recovery inspection programs at less-than-budgeted levels, and l redirect resources toward event evaluation and backlog elimination, indicates that RIV is I responsibly reprogramming resources toward its higher priority areas and efficiently executing its fuel cycle and uranium recovery programs. Expenditures in the ,

decommissioning area were more closely aligned with the budget .in each year. On balance, the review team found the Region's resource utilization to be responsive to program needs, and in accordance with program office goals. Attachment 2 presents this data in more detail in tabular form.

The Region's FY97 Opemting Plan specifies that, " Priority will be given to reactive inspections, core licensing, core inspections, decommissioning activities associated with the Site Decommissioning Management Plan (SDMP) sites, non-core licensing, non-core inspections, and non-routine decommissioning activities not addressed in the SDMP, in that i order." The RIV FY97 Operating Plan also states, " Emphasis should be placed on eliminating the number of backlogged licensing actions ..." RIV managers clearly emphasize event response and evaluation, and core licensing and inspection, and the materials licensing staff is steadily reducing the number of backlogged licensing actions, in accordance with the Operating Plan Based on the review team's interviews with regional managers, examination of PMDA's budget data, and consideration of the Region's performance across all materials areas in both regional offices, the review team concluded that RIV is closely adhering to the priorities given in the Operating Plan in accomplishing DNMS' mission.

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Region l\/ Draft Report Page 18 l

Based on the review team's analysis of the resource expenditures and the Region's productive use of the resources, the reviev, team recommends that the Region's performance with respect to this non-common indicator, Performance Against Operating Plan Goals, be found satisfactory.

4.2 ' Fuel Cycle Inspection Proaram 4.2.1 Introduction The RIV IMPEP review was the first opportunity to pilot-test a new draft non-cornmon performance indicator land accompanying evaluation criteria) for regional fuel cycle inspection programs. This indicator is composed of four sub-indicators covering:

(1) Status of, Fuel Cycle inspection Program, (2) Technical Staffing and Training, (3)

Technical Quality of Inspections, and (4) Responsa to incidents and Allegations. These sub-indicators parallel the corresponding commor, performance indicators for the materials program, with the exception of the fuel cycle licensing function which is performed exclusively by the Division of Fuel Cycle Safety and Safeguards (FCSS) in NMSS.

All fuel cycle f acilities in the RIV fuel cycle inspection program are inspected by the WCFO staff, who are responsible for most aspects of RIV fuel cycle inspection program. The RIV Arlington office, however, is re.sponsible for approving all inspection reports, conducting enfort:ement actions, and managing responses to incidents and allegations.

In exercising the pilot-test of the draft non-common performance indicator, the review team found the draft indicator generally useful as a t'ool for evaluating the RIV fuel cycle inspection program. The Region has been requested to provide detailed comments regarding the draft indicator by April 30,1997, following completion of the onsite portion of this IMPEP review.

The fuel cycle inspection program at WCFO, and NRC-wide, has undergone significant modifications during the revhw period. Two new FCSS inspection programs for nuclear criticality safety (NCS) and enemical safety were initiated by FCSS, with the regions  !;

retaining responsibility for operational aspects of NCS inspections.

A Master Inspection Plan (MIP) now encompasses all fuel cycle facilities regulated by the NRC. This plan coordinates fuel cycle inspections conducted by all regions and FCSS. As part of this new, integrated approach, inspectors are now conducting inspections across regional boundaries in a process called " Cross-Fertilization." This program broadens the experience base of the inspectors, and helps promote cross-regional consistency. It also provides a larger cadre of inspectors who are knowledgeable of all the fuel cycle f acilities,

-which may be important in incident response.

l l

A new Fuel Cycle Licensee Performance Review (LPR) Program also has been initiated by FCSS. This LPR Program is designed to render a " big picture" view of licensee j performance for senior NRC management, and provide a basis for adjusting the fue' cycle l f acility inspection program, including such areas as inspection focus, f aquency, and

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Region IV Draft Report Page 19 1 resources. It also informs licensees of NRC management perceptions of their performance l

. in protecting public health and safety. Each region has the lead responsibility for conducting LPRs for its own facilities. The details of the program are described in a new IMC 2604, "L!censee Performance Review," which was issued on August 26,1996.

During the review period, FCSS also developed, and is in the process of refining, a new

, Fuel Cycle Inspection Management System (FCIMS), which will provide automated tools 1 for better managing the fuel cycle inspection program, both in the regions and FCSS.

FCIMS is used to schedule inspections', commi+ specific inspectors to each inspection, and specify what functional areas the inspections are to cover, i

IMC 2600, " Fuel Cycle Facility Operational Safety and Safeguards inspection Program,"

l and severalinspection procedures were revised, and new inspection procedures were I developed during the review period. The draft non-common performance indicator for the regional fuel cycle inspection programs also recognizes these new developments.

J 4.2.2 Status of Fuel Cvele inspection Proaram l l

The WCFO staff responsible for conducting the fuel cycle inspection program mainly l consists of a single senior. fuel cycle inspector who conducts inspections 'for three facilities:

- Siemens Power Corporation in Richland, Washington; General Electric - Vallecitos Nucleat

! Center (GE) at Vallecitos, California; and General Atomics (GA) at San Diego, California.

Of these, the Siemens facility is the only one actively processing nuclear material.

3 Additional inspections for physical protection at the Siemens facility are conducted by staff from the' Arlington office, on a three-year cycle. Physical security inspections were performed in February,1997,'at Siemens; and will not be conducted for another three l

years, j The GA facility is now operating under a " possession only" license, and is preparing for

final decommissioning in the near future. The GE-Vallecitos facility is in the process of l decommissioning areas that are no longer in use, while still conducting limited-scale analytical activities for the non-destructive and destructive examination of low-enriched

. reactor fuel. Much of the activity at GE-Vallecitos involves radioactive materials licensed by the State of California.

2 In addition to conducting fuel cycle f acility inspections, the senior fuel cycle inspector at WCFO also h responsible for planning and tracking completed fuel cycle inspections. The i inspector develops the WCFO fuel cycle inspection schedule in a manner that ensures IMC 2600 inspection frequency requirements are met. The review team determined that these inspection plans, and subsequent changes, are coordinated with FCSS and other regions for inclusion in the MlP. While the senior inspector manually ensures that the WCFO portion of the MIP meets IMC 2600 inspection frequency requirements, autornatic checks for this purpose are expected to be available using FCIMS in the near future.

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Region IV Draft Report Page 20 The review team found that, in addition to satisfying the inspection frequency requirements of IMC 2600, the RIV plan for inspecting the Siemens facility reflects the results of the recent LPR for Siemens, which RIV conducted as a pilot effort during the development of IMC 2604.

4.2.3 Technical Staffina and Trainina During the reviaw period, RIV experienced no changes in the fuel cycle inspection program staff. Potential unexpected turnover in a smell ~ff, in this case, just one inspector, could seriously affect the RIV fuel cycle inspection program. The " Cross-Fertilization" program referred to in Section 4.2.1 above, was implemented during this review period to allow inspectors in the regions to conduct inspections in other regions so that they could gain familiarity with a wider variety of fuel cycle facilities and processes. This program was designed for effective use of fuel cycle inspection resources. Over a penod of time, this program will result in a pool of inspectors from other regions who will be famihr with the Siemens facility. This will allow inspectors from othes regions to more effectively assist in performing inspections at the Siemens facility. During the review period, an inspector from Region 111 (Rlll) participated in an inspection of Siemens, and the RIV fuel cycle inspector also participated in an inspection of a Rlli fuel cycle f acility. RIV intends to continue the inspector exchange program on a regular basis.

The review team found that the senior fuel cycle inspector is well-qualified, and is up to date on required refresher training (as described in IMC 1246). He is required under the new provisions of IMC 1246, over the next two years, to complete two additional courses that are not currently offered by the NRC Techr.ical Training Division in the Office of Analysis and Evaluation of Operational Data. One of these courses covers " Integrated Safety Analysis." A course that had been identified by NMSS as meeting this requirement was conducted by a commercial training organization in mid-1996 in Rockville, Maryland.

FCSS notified the RIV training coordinator of this opportunity by electronic mail, but the review team could not determine that the senior inspector or his branch chief had been notified of this training opportunity (because the appropriate divisional training coordinator who would have provided this information has retired and was unavailable to the review team for comment). Consequently, the senior inspector did not take the course, in the future, FCSS will ensure that all fuel cycle program managers are apprised directly of such training opportunities, in addition to the regional training coordinators.

4.2.4 Technical Quality of inspections Reviews of fifteen completed fuel cycle inspection reports, and intervieves with the senior fuel cycle inspector and his branch chief, demonstrated a high level of technical quality and thoroughness in the conduct of the inspections, and timeliness in issuing reports.

Inspection followup items were consistently reexamined and closed. The tenior inspector tracks additional issues for his branch (WCFO MB) that do not rise to the level of an inspector Followup item (IFI), as determined by RIV management. He uses this additional information to refine his specific plans for future inspections,'in consideration of the licensee's observed strengths and' weaknesses. Inspection reports consistently exhibit a s focus on the more important safety risks associated with the facility, and on the licensee's

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Region IV Draft Report Page 21 performance in protecting the health and safety of workers and the public.

WCFO management ensures the continuing high quality of fuel cycle inspections through

. debriefings of inspectors following their return to the office, and through accompaniments.

The senior fuel cycle inspector was accompanied by the branch chief on inspections three times during the review period.

{

The review team identified one problem in FCSS's recent issuance of revised inspection procedures that resulted in unintended omissions of certain inspection requirements for

, radiation safety, industrial safety, and fire protection. The Region is continuing to inspect i these areas until FCSS reissues corrected inspection procedures. Originally, FCSS requested and received extensive regional comments on tuo draft inspection procedures.

. The procedures were issued in final form with significant rey!sions, and with the above noted areas. inadvertently omitted. The procedures should have been redistributed for a second round of-comments following the extensive revisions. Further, FCSS staff should have documented the resolution of the regions' commen;s, which also would have provided an opportunity to identify the inadvertent omissions, in the future, FCSS will ensure that r9 solution of regional comments (on Manual Chapter and Inspection Procedure revisions).is properly documented, and that regions are given another opportunity to comment on inspection procedures involving extensive revision after the first round of comments.

l_ 4.2.5 Resoonse to Incidents and Alleaations During the review period, there were no incidents affecting the fuel cycle inspection program which required immediate response b the RIV WCFO staff. The senior inspector is available on a continuous basis by pager, in case hc is needed for immediate response to an incident. The review team determined that the RIV Incident Response Center has the most recent, version of the Siemens Emergency Plan and related documents.

During the review period, no allegations were rece;ved regarding RIV fuel cycle facilities which required technical evaluation by the RIV fuel cycle inspection staff. Overall implementation of the RIV allegation management program is discussed in Section 3.5 of this report, under the corresponding common performance indicator for the materials program.

4.2.6 Summary Based on the draft evaluation criteria for the fuel cycle inspection program non-common performance indicator, the review team recommends that the Region's performance with respect to this indicator, Fuel Cycle inspection Program, be found satisfactory.

4.3 Site Decommissionina Manaaement Plan (SDMP)

This non-common indicator was reviewed in a pilot program to evaluate the SDMP program at the RIV offices in Arlington and WCFO. The non-common performance indicator for

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- j Region IV Draft Report Page 22 evaluating the SDMP includes: 1) quality of SDMP decommissioning reviews; 2') financial assurance for decommissioning: 3) termination radiological surveys; 4) inspections; 5) staff qualifications; and 6) SDMP Milestones, in performing this review the review team conducted interviews with the RIV decommissioning inspection and licensing staff and examined records in the Arlington and WCFO offices. RIV staff interviewed in WCFO included license reviewers and decommissioning inspectors. RIV staff interviewed in the Arlington office included the Chief, NMLB, and a decommissioning inspector (by telephone). In addition, during the review SDMP project managers in the Low Level Waste and Decommissioning Projects Branch (LLDP), Division of Waste Management (DWM),

~ NMSS, were interviewed by telephone regarding the licensing and inspection process for SDMP sites located in RIV.

4.3.1 Quality of SDMP Decommissionino Reviews At the present time, WCFO has no sites on the SDMP list, so no assessment of this sub-indicator was performed for the field office. The review team's findings on this sub-indicator apply only to RIV's Arlington office. Sites on the SDMP list are inspected by the Arlington office staff, with project management and licensing performed by DWM\LLDP.

Five SDMP sites are inspected by the RIV Office in Arlington: Sequoia Fuels Corporation in Gore, Oklahoma; the Kaiser Aluminum Corporation in Gore, Oklahoma; Fansteel, incorporated in Muskogee, Oklahoma; Cimmaron Corporation in Oklahoma City, Oklahoma; and the Kerr McGee, Cushing, f acility also Imated in Oklahoma City, Oklahoma.

The quality of SDMP actions taken in RIV was assessed by performing an evaluation to determine if significant decommissioning activa at facilities listed on the SDMP (and inspected in RIV) were reviewed and approved m 'dvance of actual decommissioning activities by the licensee. Second, a determination was made to evaluate if decommissioning plan reviews are conducted by RIV staff in accordance with IMC 2605, "NMSS Handbook for Decommissioning' Fuel Cycle and Materials Licensees.

Regional success with the first element requires coordination between RIV inspectors and DWM licensing project managers, because the staff and licensing project manager responsibilities are functionally and physically separated. The review team found indications that this communication process is working well, as evidenced by donmentation in the docket files showing that many inspections were conducted just before significant decommissioning actions. RIV was also found to. conduct inspections fo!:owing requests from the licensing project managers. Information obtained from interviews with licensing project managers and inspectors indicate that RIV inspectors often contact the licensing project managers when issues are raised on inspections regarding the meaning or intent of conditions in the SDMP facility's license or when policy

' issues are raised during inspections.

Regional success with the second element is demonstrated by insper, ting decommissioning sites at appropriate milestones, and performing the inspections in eccordance with the guidance in IMC 2605. RIV was evaluated by determining: 1)if inspections that were conducted following issuance of the IMC 2605 (November 1996) used the methodology a

Region IV Draft Report Page 23 contained in the manual chapter, and 2) if decommissioning inspection reports covered ,

areas referenced in the two new inspection procedures (IP 87104, "Decomrnissioning inspection Procedure for Materials Licensees," and IP 88104, " Decommissioning Inspection Procedure for Fuel Cycle Facilities") identified in IMC 2605.

i An examination of 6 licensing files and 6 inspection files in the WCFO, and 6 inspection files in Arlington, identified that IP 87104 and IP 88104 were used on only one inspection conducted after July 15,1996 (the date of issuance for the new decommissioning inspection procedures). This single inspection report was the only report examined by the review team which referenced IMC 2605 and the new decommissioning inspection procedures. More importantly, it appeared to be the only inspection report which covered most areas recommended by the two new procedures, such as fire protection and inspection of key decommissioning activity (including areas such as identification and demarcation of areas undergoing decommissioning, SNM inventory, cleanout, and removal of licensed material, implementation of the licensee's decommissioning organization, and compliance with decommissioning timeliness requirements). Interviews with inspectors from WCFO and the Arlington office reveled that, with the exception of one WCFO inspector, RIV inspectors were not using the new inspection manual chapter, check lists, or new inspection procedures. The inspectors perceived the 1996 decommissioning guidance to contain too many details that they thought were not applicable to inspections of RIV's decommissioning sites, even though the Region had participated in the development of this guidance. The one inspector who used the new procedures indicated to the revicw team that he found the procedures useful, once he became familiar with them. The review team recommends that RIV adopt the guidance contained in the new IMC 2605 on inspections of SDMP and non-SDMP decommissioning licensees and terminated sites, and implement the new decommissioning inspection procedures

'(especially IP 87104 and IP 88104) referenced by IMC 2605.

The review team observed that RIV decommissioning inspectors are usually aware of major inspection issues regarding decommissioning activities and are using older, approved inspection guidance in an effective manner.

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4.3.2 Financial Assurance for Decommissionina This sub-indicator contains three areas for examination by the review team: 1) has adequate financial assurance for the decommissioning of SDMP sites been established in accordance with regulatory requirements: 2) has financial assurance been provided for the estimated costs for an independent third party to perform decommissioning; and 3) have financial assurance mechanisms been reviewed and maintained properly.

Financial Assurance documentation :nd instruments for the SDMP sites located in RIV are located in NRC headquarters. These documents were not reviewed as part of the RIV IMPEP evaluation. Financial assurance documentation and instruments for non-SDMP sites are maintained by WCFO and the Arlington office. The review team's examination of these instruments is discussed in Section 3.3 of this report.

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Region IV Draft Report Page 24 j l

4.3.3 Termi' nation Radioloaical Survevs 1

This sub-indicator assesses how the Region insures that sufficient radiological surveys are l conducted, as outlined in IMC 2605, for license termination. The sub-indicator also verifies l whether licensee survey results are validated by the Region through a closecut survey.

There are no SDMP sites in the WCFO geographic area of responsibility. SDMP sites in the i Arlington office's area of responsibility are not yet at the point of license termination, so this sub-inuicator has limited application to the current RIV SDMP program. However, in the cases where decontamination of partially contaminated areas has taken place, the review team found evidence that NUREG 5849, " Manual for Conducting Radiological Surveys in Support of License Terminaticn" was used, as recommended in IMC 2605.

4.3 4 !nsoections This sub-indicator for the regional SDMP , ogram establishes whether the Region conducte decommissioning inspections in accordance with established frecluencies and procedures contained in IMC 2605 and IPs 87104 a,nd 88104. (See the review team's recommendation in Section 4.3.1). The review team examined whether RIV decommissioning inspections focus on safety of licensee procedures, release 'of effluents to

. the environment, public and worker exposure, and suitability of. decontaminated areas and structures for release.

As discussed in Section 4.3.1, evaluation of RIV against this sub-indicator reveals infrequent use of IMC 2605, IP 87104, and IP 88104 by RIV staff and managers.

However, the review team found that inspections are performed in accordance with frequencies established in older inspection procedures, such as IP. 83890, " Closeout Inspection and Survey." The review team examined the decommissioning inspection files i and observed that RIV decommissioning inspections often cover areas such as safety of 4

license procedures and release of effluents to the environment.

4.3.5 Staff Qualifications A(I of the decommissioning inspectors in RIV are qualified as materialinspectors and are pursuing additional qualification courses in IMC 1246 for decommissioning inspectors. The staff has a 3 year period, following issuance of IMC 1246 in June 1996 to complete qualification course requirements. At WCFO a member of the licensing staff is preparing to provide training to WCFO materials staff on IMC 2605.

4.3.6 SDMP Milestones i Successful performance under this sub-indicator would require that decommissioning milestones summarized in the SDMP and applicable to the Region are being met, that any delays are identified in the SDMP database, that mechanisms are in place to ensure that appropriate corrective actions are taken by the Region, that policy issues affecting the decommissioning of SDMP sites are being ioantified to DWM, and that regional staff are updating the SDMP database in a timely maneer.

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Region IV Draft Report Page 25 With the exception of identifying policy issues to the SDMP site project managers in DWM, the areas of this sub-indicator are not applicable to RIV, because the licensing functions are ,

managed by DWM. The regional office only has inspection responsibility for SDMP sites. l Regarding communication of policy issues to DWM, the review team verified that regional inspectors have raised important policy issues for resolution. DWM project managers indicated to the review team that RIV inspectors often provide recommendations which help to speed licensing actions.

4.3.7 Summary i

Based on the draft evaluation criteria for this non-common performance indicator, the review team recommends that the Region's performance with respect to this indicator, Site Decommissioning Management Plan, be found satisfactory.

i 4.4 Uranium Recovery Proaram The Uranium Recovery non-common indicator was piloted on the RIV IMPEP review. The indicator includes five sub-indicators of the uranium recovery regulatory program:

1) Status of the Uranium Recovery inspection Program; 2) Technical Staffing and Training:

3) Technical Quality of Licensing; 4) Technical Quality of the Uranium Recovery inspection l Program, and 5) Response to incidents and Allegations. Sub-indicators 1,2, and 4 are discussed in this section of the report. The fifth sub-indicator, response to incidents and ,

allegations involving uranium recovery facilities, was reviewed by the team as part of the common performance indicator. DNMS' performance on incidents and allegations is discussed in Section 3.5 of this report. RIV does not conduct uranium recovery licensing, so sub-indicator 3 was not addressed for this review.

Until three years ago, the NRC's uranium recovery licensing and inspection program was c'onducted out of the Uranium Recovery Field Office (URFO) in Denver, Colorado. RIV was responsible for oversight of the field office. NRC closed URFO in the summer of 1994 and ,

significantly reorganized the agency's uranium recovery program. The uranium recovery licensing functions were transferred to NMSS/DWM and are conducted by the Uranium Recovery Branch (URB). The uranium recovery inspection function was transferred to DNMS in RIV.

URFO had routinely performed comprehensive inspections of engineering, geo-sciences (such.as hydrology), environmental, and health physics / radiation protection issues associated with the licensed facilities. RIV's uranium recovery inspection staff does not incWe technical expertise in engineering and geo-sciences, so the review team observed thaf HIV's uranium recovery inspections have focused primarily on the health physics / radiation protection areas. Occasionally technical staff from DWM's Uranium Recovery Branch have accompanied RIV inspectors to provide support for the other disciplines.

Region IV Draft Report Page 26 Since URFO was' closed, the uranium recovery regulatory program has been evolving. Both NMSS and RIV have identified, and continue to identify, areas that require attention and or improvement for the entire program to be more effective and efficient. Several of these areas were highlighted by the review team and are discussed in detail under the individual sub-indicators below.

'4.4.1 Status of the Uranium Recoverv inspection Prooram The review team focused on four factors in evaluating RIV's performance for this sub-indicator: (1) inspection frequency, (2) overdue inspections, (3) timely dispatch of inspection findings to licensees, and inspection follow up, and (4) retrievability of uranium recovery inspection materials. The review team's evaluation is based on a review of RIV's responses to the questionnaire, the uranium recovery inspection schedule, inspection casework files, and interviews with inspection staff and the DNMS technical assistant, who provides supervisory oversight of the RIV uranium recovery inspection program.

During the review period, RIV was responsible for inspecting 28 licensed uranium recovery facilities of various types and stages of operation. For most of the review period, only five of the facilities were operating, including several in-situ leach (ISL) mines, a conventional uranium mill that operated intermittently during the review period, and Envirocare of Utah, the nation's only facilic/ for the disposal of 11e(2) byproduct material (residual material remaining after tha rxtraction of uranium and thorium). The remaining sites are primarily non-operating conv.sntional uranium mills that are in various stages of decommissioning and reclamation.

The review team examined uranium recovery inspection scheduling and learned through interviews that extreme and unpredictable weather conditions during the winter at most of the sites creates a defacto " inspection season" for the uranium recovery inspections. The Region does not normally schedule inspections in December, and schedules only a few inspections in November and' January. The review team found that since most of the uranium recovery facilities are in remote areas, inspections are normally announced, to ensure that necessary personnel are available to the inspectors.

NRC has not developed an inspection Manual Chapter that establishes requirements apcifically for inspections of uranium recovery facilities. In the absence of a directly applicable IMC, RIV's uranium recovery inspection staff use IMC 2801, "11e.(2)

Byproduct Material Disposal Site and Facility inspection Program," to provide guidance in establishing inspection frequencies for all of the uranium recovery licensees. In coordination with NMSS/DWM/ URB management, RIV managers decided that the operating uranium recovery facilities were to be inspected twice each fiscal year, and the non-operating facilities were to be inspected each fiscal year, for a total of approximately 33 planned or routine inspections per fiscal year. Additional special inspections are to be conducted on an "as required" basis.

To evaluate the Region's performance in this area, the team reviewed the uranium recovery inspection schedule that is developed each calendar year as an independent p'lanning tool by the uranium recovery inspection staff. The RIV inspection staff also use the schedule to

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l record completed inspections. The uranium recovery inspection schedule is not '

incorporated in DMNS's computer tracking system for materials inspections. The review l team determined that for the period covered by the IMPEP review, RIV conducted all i uranium recovery inspections at the proper frequency. There were no overdue inspections j during the review period. '

IMC 2801 establishes inspection frequencies for different IPs and ties the procedures specifically to the preoperational, operational, and closure phases of operations of 11e.(2) byproduct material disposal facilities. RIV inspection staff have adopted some of the IPs given in IMC 2801 to conduct their inspections of uranium recovery licensees. The review team observed that the inspection areas and frequencies that are used by RIV appear to ensure protection of the public health and safety, and the environment for uranium recovery licensees. However, the lack of formal specific guidance on inspection areas and frequencies,, particularly for the in situ leach (ISL) facilities (which will be increasing in number), is a significant problem for the uranium recovery program.

NMSS, DWM, and RIV are aware of the a'gency's lack of guidance for uranium recovery inspections and have been working to develop guidance. RIV drafted a Manual Chapter for inspections of ISLs, with field notes to facilitate inspections. That draft is cu,rrently in NMSS/DWM for review, and for DWM to add guidance on the hydrological portions of uranium recovery inspections. The review team recommends that NMSS proceed to issue inspection guidance for in'spections of uranium recovery licensees, including uranium mills and ISL facilities.

The timeliness of the issuance of inspection findings was also evaluated during the inspection file review. Out of the 16 inspection reports that were reviewed, all but three of the reports were issued within 30 days after completion of the inspection. One was a week late. The two others were a month late. Both involved decisions regarding the issuance of violations that required coordination with URB. The review team also reviewed other correspondence in the inspection files related to follow up actions required in response to violations, and found those documents also had been issued by RIV in a timely manner.

The uranium recovery inspection files appear to the review team to be in order. Of the 16 narrative inspection reports reviewed,13 were in the central files, and the other three were readily produced by the RIV staff when requested. Because the narrative reports document the inspections in detail, the files do not contain the inspectors' field notes. The files do contain follow-up documentation in response to notices of violations.

4.4.2 Technical Staffino and Trainina in reviewing this sub-indicator, the review team considered the uranium recovery program staffing level, the technical qualifications of the staff, staff training, and staff turnover.

RIV has two primary inspectors who perform the uranium recovery inspections, and both are assigned to NMI&FCDB. A third inspector has been on a two year rotation to assist the RIV enforcement coordinator, and has not performed uranium recovery inspections over

Region IV Draft Report Page 28 the last year. A certified fuel cycle facility inspector in NMLB supplements the uranium recovery effort by performing short, non-complex uranium recovery inspections.

All of the uranium recovery inspectors are supervised bv their respective Branch Chiefs, but functionally for uranium recovery tasks, they report to the Technical Assistant to the .

DNMS Director. The technical assistant reviews uranium recovery inspection reports and l provides supervisory review and signature, on most of the uranium recovery documents issued by RIV. )

l The review team considered this cross-supervision arrangement to determine if it negatively affected the consistency or quality of the inspection program in RIV. The  ;

review team found no evidence that the lack of a RIV organizational unit for the uranium  !

recovery inspections program had negatively impacted the Region's performance in this I area. The inspectors work closely with each other and with the DNMS technical assistant, i to keep each other well-informed. l The RIV uranium recovery inspectors all have reactor health physics or materials radiation safety backgrounds, so the health physics focus of the inspections has been strong.

However, expertise in other areas, such as engineering and geo-sciences, is also required  ;

to perform the range of inspections necessary at many of the operating uranium recovery j facilities. Occasionally during the review period, this expertise was provided by DWM tec.hnical staff, but there was not a concerted effort to ensure that these areas were l

regularly inspected at uranium recovery facilities. DWM and RIV managers are working to resolve the issue of the availability of the full complement of necessary expertise for the inspections of uranium recovery facilities.

Until IMC 1246 was recently issued, NRC had no specific written requirements for staff involved in the uranium recovery inspection program. Even now, IMC 1246 only covers DWM staff conducting inspections of engineering and groundwater aspects for uranium recovery facilities, but does not have specific qualification standards for uranium recovery inspectors reviewing health physics aspects. In lieu of specific guidance, RIV determined that the qualifications for Fuel Cycle Facility inspectors would most closely match the training needed for the uranium recovery inspectors. All three of the uranium recovery inspectors have been certified by the RIV Regional Administrator's Office as fuel cycle inspectors. The review team recommends that NMSS and RIV jointly develop training requirements for regional uranium recovery inspectors and issue those requirements in a revision to IMC 1246. .

4.4.3 Technical Quality of Licensina Actions Since RIV does not conduct uranium recovery licensing, this sub-indicator was not reviewed during the IMPEP review.

2 Region IV Draft Report Page 29 4M.4 Technical Quality of Uranium Recoverv Insoections 3

In reviewing this sub-indicator, the review team examined inspe: tion files, inspection reports, and enforcement datumentation for 16 inspections conducted during the review period by each of the three active inspectors. The cases selected for review covered 8 licensees representing a range of uranium recovery licensing activities in different stages of operation. The entire inspection file for the review period (including 4 inspection reports each) was examined for two of the operating licensees - 1) Power Resources, Inc.,

Highlands ISL (PRI), and 2) Cogema Mining, Inc., Irigaray and Christensen Ranch ISL (Cogema), to assess inspector follow-up on open issues and violations. Inspectors were interviewed to assess the adequacy of their preparation for the inspections, the depth and content of the actualinspections, and the appropriateness of inspection findings. The review team's findings are discussed below.

For the more complicated licensees, two RiV uranium recovery inspectors frequently will conduct the inspections together, in order to cover more inspection areas in more depth.

Since the inspectors have different technical expertise, this practice appears to have enhanced the content and scope of the inspections, as well as the quality and comprehensiveness of the inspection reports that the team reviewed. The uranium recovery inspectors prepared very good reports at the beginning of the review period, and the more recent ones have become even better.

The inspectors indicated that they take several days or more to plan and prepare extensively for inspections. They review relevant manual chapters, inspection procedures, previous inspection reports, licenses, incident reports, NOV's, and other background information, and often consult with the licensing staff in URB before inspections. The review team learned that both primary uranium recovery inspectors have developed their own checklists to facilitate their preparation for inspections. In most cases, the review team found that inspection plans covered or focused on specific licensee conditions and procedures. The review tearrifound that inspection preparation was limited by the files that are available in the Region. In many cases, copies of documents like the uranium i recovery licensees' applications, operating plans, and amendment requests, are maintained by URB and not filed in the RIV records. The inspectors frequently have to review those documents on the licensee's site, using the limited inspection time for inspection preparation. Once on site, the inspectors may deviate from the inspection plans to examine licensee performance in greater or lesser depth, as needed. The inspectors need not rigidly adhere to the inspection plans, and may make mid-course corrections.

The review team found that the inspectors observe licensee operations, interview workers, managers, and contractors, review facility records, examine site operating plans and

_ procedures, and normally make independent measurements during inspections. Although the RIV inspectors primarily focus on health physics and radiation safety issues, they also routinely inspect for environmental monitoring, management and organizational issues, and general housekeeping practices. The inspectors typically observe a broad spectrum of licensee operations. As the RIV inspectors became increasingly familiar during this review period with uranium recovery facility operations, especially at the operating ISL's, they expanded their reviews to include observations about relevant engineering and geo-science

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issues at the licensees' sites, and RIV staff has developed a set of draft field notes to be used for inspections of ISLs.

The review team noted that the inspection reports did not always indicate that independent j measurements were being performed during inspections. The RIV inspectors reported to the review team that independent measurements were consistently being performed. The review team concluded that uranium recovery inspectors could improve documentation of l their independent measurements in the inspection reports. l l

The review team found that the RIV uranium recovery inspection staff writes and issues very high quality inspection reports. The reports were well written and provided appropriate depth. They addressed compliance conditions for the licensees, and demonstrated that the inspectors pursued root causes where problems or violations were identified. The inspectors also noted licensee good practices in the reports. In mid-1996, the uranium recovery inspection staff changed the inspection report format to accommodate the new guidance provided in IMC 0610, inspection Reports".

Part 40.36 requires materials iicensees to maintain records of information important to the safe and effective decommissioning of their facilities. Licensees are required to maintain detailed records on the locations and consequences of any spills, accidents, or other incidents that could result in contamination of their site or facilities, and that would require cleanup as part of decommissioning. This licensee information is necessary to ensure proper clean-up for decommissioning and is necessary to the licensee when preparing annual financial surety update submittals. Although inspectors have been directed by NMSS to review licensees' decommissioning records at every inspection (as noted in the 1993 IMPEP review of RIV), the review team observed that none of the 16 uranium recovery inspection reports examined made any reference to such- a review. The review team discussed this requirement with the inspectors and the DNMS Technical Assistant to determine if the uranium recovery inspectors reviewed decommissioning files routinely, but just had not recorded these reviews. The review team determined that the decommissioning records were not consistently reviewed on all uranium recovery inspections. The review team recommends that RIV uranium recovery inspectors should review licensee decommissioning records on all routine inspections to ensure that required information is being maintained by the licensee, and should document the decommissioning record review and findings in the uranium recovery inspection reports.

The review team found that during the review period, the two primary and one supplemental uranium recovery inspectors had been accompanied by the DMNS Technical Assistant, who manages the uranium recovery inspection program, as well as by their respective Branch Chiefs, The review team found that the DNMS Technical Assistant routinely meets with the uranium recovery inspectors after their inspections to go over inspection findings and to plan follow-up ' strategy. Last year, RIV began a weekly debriefing for the DNMS Director and managers on the inspections conducted during the prior week. During these weekly management debriefings, follow-up is also discussed. A review team member attended a weekly management debriefing that addressed an ISL inspection at PRI. This debriefing

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1 practice appears to be particularly useful when the inspector has identified violations,

. because it allows all cognizant staff and managers to participate in. decisions regarding appropriate follow-up.

Uranium recovery licenses, most of which were originally issued many years ago, are not .

I standardized. As a result, the license conditions are not always clearly written or-

? consistent. During the review period, the RIV uranium recovery.in'spection staff identified license conditions that are difficult to inspect against, and notified RIV and DWM/ URB

} management and licensing staff, about the deficient license conditions. RIV staff also I i assisted the licensing staff in crafting appropriate language for new and replacement i license conditions. This communication significantly improved the licenses that were issued during the review period. . The review team found clear evidence of a healthy dialog, both

. written and informal, between RIV and DWM/ URB. l j . 4.4.5 Response to Irkcidents and Alleaation_g For this sub-indicator, the review team evamined the information on the uranium recovery ,

l incidents and allegations listed in the Region's response to the questionnaire to determine if l the list was' complete. The review team also informally compared the description and '1 '

1- status of incidents and alleg'ations reported by the Region to the incident and allegation i information generally available to URB. The review team found the listed uranium recovery 1 incidents and allegations to be complete and also found that RIV is in general agreement

i. with the issues and status of incidents and allegations known to URB.  ;

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[ RIV's process, procedures, and overall performance in this area were reviewed under the l common indicator for Response to incidents and Allegations, and discussed in Section 3.5 L of this report. -

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.4.4.6 Summarv i

Based on the draft evaluation criteria for this non-common performance indicator, the l' ~ review team recommends that the Region's performance with respect to this indicator, Uranium Recovery Program, be found satisfactory.

5.0

SUMMARY

i i As noted in Sections 3.1 through 3.5, the review team found the Region's performance l with respect to each of the common performance indicators to be satisfactory. In addition, the team found that RIV was making appropriate use of budgeted resources and that the quality of the fuel facility inspection program was satisfactory. The review team also found that RIV's implementation of its SDMP and uranium recovery. programs was

satisfactory. Accordingly, the review team recommends that the Management Review l Board find the RIV program to be adequate to protect public health and safety.

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Region IV Draft Report Page 32 Recommendations. Below is a summary list of recommendations, as mentioned in earlier ,

parts of this report, for action by RIV, or NMSS:

1. The review team recommends that NMSS issue formal, written guidance in final form to all Regional Offices regarding changes in procedures for licensing medical

, use facilities, including radiopharmaceutical therapy (535.300) users (Section 3.3).

2. The review team recommends that NMSS clarify the meaning of " fire rated" in MD ,

8.12 (Section 3.3).

3. The review team recommends that, following NMSS' clarification of " fire rated," 3 RIV,either provide evidence to DWM that the Arlington safe meets DWM's guidance for fire protection of the financial assurance instruments, or obtain a security j container for financial assurance instruments that meets tho fire protection guidance

- (Section 3.3).

4. The review team recommends that RIV adopt the guidance contained in the new l IMC 2605 on inspections of SDMD and non-SDMP decommissioning licensees and terminated sites, and implement the new decommissioning inspection procedures i

(especially IP 87104 and IP 88104) referenced by IMC 2605 (Section 4.3).

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5. .The review team recommends that NMSS proceed to issue inspection guidance for l j inspections of uranium recovery licensees, including uranium mills aad ISL facilities i (Section 4,4).

, 6. The review team recommends that NMSS and RIV jointly develop training l requirements for regional uranium recovery inspectors and issue those requirements in a revision to IMC 1246 (Section 4.4).

The review team recommends that RIV uranium recovery inspectors should review 7.

licensee decommissioning records on all routine inspections to ensure that required information is being maintained by the licensee, and should document the decommissioning record review and findings in the uranium recovery inspection reports (Section 4.4).

Good Practice. Along with the recommendations for RIV or NMSS improvement, the review team identified the following good practice in WCFO:

1. The review team identified the RIV document entitled "Information That Should Be Submitted To The NRC Staff For Decommissioning and Termination of Licensed Facilities," for distribution to terminating licensees, as a good practice, and l recommends that its use be considered by other regions and Agreement States. l l

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LIST OF APPENDICES AND ATTACHMENTS APPENDIX A: REGION IV. IMPEP TEAM MEMBERS .

APPENDIX B: REGION IV ORGANIZATIONAL CHART APPENDIX C: REGION IV RESPONSE TO QUESTIONNAIRE APPENDIX D: LICENSING FILES REVIEWED APPENDIX E: INSPECTION FILES REVIEWED L

APPENDIX F: INCIDENT FILES REVIEWED APPENDIX G: DECOMMISSIONING FILES REVIEWED APPENDIX H: URANIUM RECOVERY INSPECTION FILES REVIEWED ATTACHMENT 1: GOOD PRACTICE DOCU.AENT: "INFORMATION THAT SHOULD BE SUBMITTED TO THE NRC STAFF FOR DECOMMISSIONING AND

. TERMINATION OF LICENSED FACILITIES" 1

ATTACHMENT 2: TABULAR

SUMMARY

OF REGION IV MATERIALS BUDGET AND EXPENDITURES i

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APPENDlX A j REGION IV IMPEP TEAM 17 EMBERS .

Name Areas of Responsibility l

Scott Moore, NMSS/IMOB Team Leader Technical Staffing and Training Status of TAaterials inspection Program Operating Plan / Resource Utilization David Collins, Region 11 Technical Quality of Licensing inspector Accompaniments Allen Grewe, Tennessee Technical Quality of Inspections Lloyd Bolling, OSP Response to incidents and Allegations i

Lance Lessler, NMSS/FCSS Fuel Cycle inspection Program LeRoy Person, NMSS/DWM Decommissioning /SDMP Ja' net Lambert, NMSS/DWM Uranium Recovery Program Duncan White, Region i Inspector Accornpaniments

APPENDIX B REGION IV ORGANIZATIONAL CHART (Will be added to final version of the report) l l

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APPENDIX C REGION IV RESPONSE TO QUESTIONNAIRE l l

(Will be cdded to final version of the report) i l

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APPENDIX D I l

REGION IV LICENSING FILES REVIEWED File No.1 Licensee: Konitz Contracting, Inc. 1.icense No.: 25-26948-01 Location: Lewiston, Montana Amendment No.: 1  !

License Type: Portable Gauges Type of Action: Amendment l Date Amendment issued: 7/24/95 License Reviewer: MCH/VC File No. 2 l Licensee: Bic;;cnetic Services, Inc. License No.: 40-26983-01 Location: Brookings, South Dakota Amendment No.: 3 License Type: Research & Development - other Type of Action: Amendment

Date Amendment issued

7/3/96 License Reviewer: MCH File No. 3 Licensee: University of Oklahoma License No.: 35-03176-05 l Location: Oklahoma City, Oklahoma Amendment No.: 13 License Type: Waste Processing Type of Action: Renewal Date Amendment issued: 1/16/96 License Reviewer: JW File No. 4 .

Licensee: Memorial Hospital of Sheridan County License No.: 49-10982-02 l Location: Sheridan, Wyoming Amendment No.: 13 License Type: Med; cal Institution, QMP Type of Action: Amendment Date Amendment issued: 9/30/96 License Reviewer: VC l

File No. 5  !

Licensee: University of Wyoming License No.: 49-0995510 i Location: Laramie, Wyoming ' Amendment No.: 34 l Lic'ense Type: Broad Scope . Type of Action: Amendment Date Amendment Issued: 5/24/96 License Reviewer: VC File No. 6 l Licensee: Montana' College of Mines License No.: 25-15640-01 i Location: Butte, Montana Amendment No.: 16 License Type: Research & Development Type of Action: Amendment Date Amendment Issued: 8/18/95 License Reviewer: VC File No. 7 Licensee: Infinity Analytical Services, LLC License No.: 35 12636-03 Location: Gore, Oklahoma Amendment No.: 23 License Type: Measuring Systems, Other Type of Action: Amendment Date Amendment issued: 7/24/96 License Reviewer: JB e

Region IV Draft Report Page D.2 Licensing Files Reviewed File No. 8 i Licensee St. James Community Hospital License No.: 25-13173-02  !

Location: Butte, Montans Amendment No.: N/A i License Type: Medical Institution, QMP Type of Action: 35.14(a) Notification l Date Action issued: 9/12/96 License Reviewer: BG File No. 9 LNenP:;; Syrcor, Incorporated License No.: 35-23359-01 MD l Location: Oklahoma City, Oklahoma Amendment No.: 9 .

License Type: Nuclear Pharmacy Type of Action: Termination Date Amendment issued: 3/26/96 License Reviewer: BG l

File No.10 Licensee: Navajo Fc,icst Products License No.: 02-27546-01 I Location: Ft. Defiance, Arizona Ameadment No.: N/A License Type: Measu1ng Systems, Other ' Type of Action: New  !

Date Amendment issued: 10/2/96 .

License Reviewer: AG File No.11 Licensee: Mid America Healthcare, Inc. License No.: 35-13058-01 .

Location: Shawnee, Oklahoma Amendment No.: 28 License Type: Medical Institution, QMP Type of Action: Amendment Date Amendment issued: 1/27/97 License Reviewer: MCH File No.12 Licensee: Granite Construction Co. License No.: 42-27528-01 Location: Grapevine, Texas Amendment No.: N/A License Type: Portable Gauge Type of Action: New

- Date Amendment issued: 9/22/95 License Reviewer: AG/BG File No.13 Licensee: Frontier Logging Corporation License No.: 35-21110-02 Location: Oklahoma City, Oklahoma Amendment No.: N/A License Type: Well-logging Type of Action: New Date Amendment issued: 12/4/95 License Reviewer: JB ,

File No.14 Licensee: Black Hills State University License No.: 40-27513-01 Location: Spearfish, South Dakota Amendment No.: N/A License Type: Research & Development - Other Type of Action: New Date Amendment Issued: 04/12/95 License Reviewer: JB

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Region IV Draft Report Page D.3 l Licensing Files Reviewed i

File No.15 Licensee: U.S. Air Force License No.: 42-23539-01 Location: Brooks Air Force Base, Texas Amendment No.: N/A License Type: Master License Type of Action: 1996 Annual Review Date Amendment issued: N/A License Reviewer: Not Applicable File No.16 Licensee: Perforating Services, Inc. License No.: 49-19585-01 Location: Casper, Wyoming Amendment No.: 3 License Type: Well-logging Type of Action: Amendment Date Amendment issued: 8/12/96 License Reviewer: BP File No.17 Licensee: Arctic Slope inspection Services License No.: 50-29015-01 ,

Location: Anchorage, Alaska Amendment No.: 7 License Type: Radiography Type of Action: Amendment Date Amendment issued: 11/30/P5 License Reviewer: KP/BP File No.18 Licensee: Madigan Army Medical Center License No.: 46-02645-03 Location: Tacoma, Washingtoo Amendment No.: 58 License Type: Medical Institution, QMP Required Type of Action: Amendment Date Amendment Issued: 4/12/JS License Reviewer: JM File No.19

. Licensee: Central Peninsula General Hospital License No.: 50-29075-01 Location: Soldotna, Alaska Amendment No.: N/A License Type: Medical Institution, No OMP Type of Action: New Date Amendment issued: 9/1/94 License Reviewer: KP/BP File No. 20 Licensee: Department of the interior License No.: SMB-539 Location: Albany, Oregon Amendment No.: ----

License Type: Decommissioning Source Material Facil. Type of Action: Amendment Date Amendment issued: 5/19/95 License Reviewer: BP File No. 21 Licensee: Syncor Inte1 national License No.: 04-26507-01 MD Location: Woodland Hills, California Amendment No.: 4 License Type: Nuclear Pharmacy Type of Action: Amendment Date Amendment issued: 2/26/97 License Reviewer: JM Comment: Change of address amendment request

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Region IV Draft Report Page D.4 Licensing Files Reviewed ,

File No. 22 Licensee: Syncor International License No.: 04-26507-01 MD i Location: Woodland Hills, California Amendment No.: 3 i

License Type: Nuclear Pharmacy ~ Type of Action: Amendment Date Amendment issued: 2/5/97 License Reviewer: JM.

! File N o. 2 3 j Licensee: Syncor international License No.: 04-26507-01 MD '

l Location: Woodland Hills, California Amendment No.: 2 l License Type: Nuclear Pharmacy Type of Action: Amendment

Date Amendment issued

7/26/96 License Reviewer: JM

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File No. 24 Licensee: Syncor International License No.: 04 26507-01MD Location: Woodland Hills, California Amendment No.: N/A I License Type: Nuclear Pharmacy Type of Action: New Date Amendment Issued: 3/26/96 License Reviewer: JM l

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! APPENDlX E l

REGION IV INSPECTION FILES REVIEWED )

i File No.1 Licensee: Department of the Intenor: Geological Survey, Western Region j, City, State: Menlo Park, CA j License Number: 04-06674-07 3 4

Insoection Prioritv: 2 j Lead insoector: KP Tyoe of Insoection: Routine, Unannounced -

Insoection Date: July 18-20 & 24,1995 J lssuance Date: August 18,1995 i

. Proaram Code /Tvoe: 3610 - Research and Development, Type A Broad j

1) one violation found, failure tu secure material Comments: ,

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, File No. 2 ,

Licensee: Department.of Veterens Affairs Medical Center 4

City, State: San Diego, CA ,

License Number: 04-15030-01 insoection Priority: 1 i

Lead insoector:

• JM Tvoe of Insoection: Routine, Unannounced 4

Insoection Date: September 18-21,1995  :

lssuance Date: October 3,1995 Proaram Code /Tvoe: 02110 - Broad Scope Medical I

Comments: 1) three previous violations closed out '

File No. 3

Licensee

The Queen's Medical Conter a

City, State: Honolulu, HI

! License Number: 53-16533-02

. Insoection Prioritv: 1

! Lead Insoector: DS Tvoe of Insoection: Special (misadministration), Routine (HDR), Announced

(portions), Unannounced (portions) l Insoection Date

December 13-15 & 18 19,1995, January 5,1996, and March 6-7,1996 Issuance Date: March 11,1996 and March 7,1996 (HDR only)

. Proaram Code /Tvoe: 02120 & 02230- Medical Institution OMP Required and High Dose Rate Remote Afterloader

' 1) initial reactive inspection to follow-up on misadministration Comments:

2) exit done by teleconference 4

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Region IV Draft Report - Page E.2 Inspection Files Reviewed l

File No. 4 l l Licensee: Syncor International Corporation l City, State: Miamisburg, OH License Number: 04-26507-01 MD insoection Priority: 1 Lead insoector: DP, Region ill ,

! Tvoe of Insoection: Routine, Unannounced Insoection Date: June 26-27,1996 )

l lssuance Date: August 2,1996

Proaram Code /Tvoe

02500 - Nuclear Pharmacies Comment: 1) inspection done under Syncor's combined license File No. 5 Licensee: Hawaii Agriculture R2 = arch Center -

City, State: Aies, HI License Number: 53-00515-01 Insoection Priority: 5 Lead insoector: EG Tvoe of Inspection: Routine, Unannounced Insoection Date: April 30 - May 1,1996 issuance Date: May'1,1996 Proaram Code /Tvoe: 03620 - Research and Development - Other 1

l File No__6 I

Licensee: NDC Systems City, State: Irwindale, CA License Number: 04 23264-01  :

Inspection Priority: 4 -

Lead Insoector: KP Tvoe of Inspection: Routine, Special, Unannounced ,

inspection Date: June 25-27 and September 16,1996 Issuance Date: September 25,1996 )

Proaram Code /Tvoe: 03225 - Other Services l File No. 7 Licensee: Citizen Watch Company City, State: Los Angeles, CA l License Number: 04-19004-02E

Inspection Priority

5 l Lead Insoector: DS f

Tvoe of insoection: Routine, Unannounced inspection Date: October 31,1996 Issuance Date: November'18,1996 Proaram Code /Tvoe: 03251 - Exempt Distribution i

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i Region IV Draft Report Page E.3 Inspection Files Reviewed i

File N o. 8 Licensee: Alaska industrial X-ray, Inc.

City. State: Anchorage, AK i License Number: 50-16084-01 Insoection Priority: 1 I

Lead Inspector: RL 4 Tvoe of insoection: Routine, Unannounced inspection Dste: July 17,1996 i Issuance Date: July 17,1996

Proaram Code / Type

03320 -Industrial Radiography Temporary Jobsites i

i File No. 9

Licensee

CTl Alaska, Inc.

City, State: Anchorage, AK .

4 License Number: 50-192022-01

Insoection Priority

1

~

Lead inspector: DS i Tvoe of inspection: Special, Announced Inspection Date: January 17 - July 2,1996 Issuance Date: July 12,1996 Proaram Code'/Tvoe: 03320 -Industrial Radiography Temporary Jobsites Comments: 1) inspection due to incident j 2) file well documented i

j File No,10

) Licensee: Guam Memorial Hospital Authority i City, State: Oka, Tamuning, GU

{ License Number: 56-18134-01 Insoection Prioritv: 3 Lead Insoector: EG Tvoe of inspection: Routine, Announced Insoection Date: May 17,1996 Issuance Date: May 17,1996 Proaram Code /Tvoe: 02120 - Medical Institution OMP Required Comments: 1) inspected at reduced frequency due to finding on previous inspection

Region IV Draft Report Page E.4 Inspection Files Reviewed File No.11 Licensee: Grede-Pryor,Inc.

City, State: Pryor, OK License Number: 35-18099-01 Inspection Priority: 1 Lead insoector: RL Tvoe of inspection: Routine, Unannounced Insoection Date: April 21,1995 Issuance Date: June 12,1995 Proaram Code /Tvoe: 03310 - Industrial Radiography - Fixed Comments: 1) inspection dates on field notes inconsistent, apparently wrong date used on report initially an inspector corrected some but not all of the dates. -

File No.12 Licensee: Schlumberger Technology Corporation Citv, State: Sugarland, TX License Number: 42-27055-01 Inspection Prioritv: 5 Lead insoector: RL Tvoe of insoection: Routine, Announced insoection Date: September 24,1996 issuance' Date: September 24,1996 Proaram Code /Tvoe: 03121 - Measuring Systems Portable Gauges Comments: 1) corporate office inspection

2) one previous violating left open, this item to be closed out during field location inspection.

File No.13 Licensee: Central State University City, State: Edmonds, OK License Number: 35-11132-01 Insoection Priority: 5 Lead Insoector: JC Tvoe of inspection: Routine, Unannounced Inspection Date: November 27,1995 issuance Date: December 11,1995 Proaram Code /Tvoe: 22140 - SNM Plutonium - Sealed Sources in Devices Comments: 1) license in timely renewal

Region IV Draft Report Page E.5 Inspection Files Reviewed File No.14 Ligenser- Chicago Bridge and Iron QMJttc: Houstoa, TX License Number: 42-13652-01 Insoection Prioritv: t Lead insoector: RB Tvoe of insoection: Routine, Unannounced insoection Date: June 5,1995 issuance Date: August 4,1995 Proaram Code /Tvoe: C3320 -Industrial Radiography - Temporary Jobsites Comments: 1) corporate office inspection

2) requested Region l's assistance to do field office inspection, Region I inspection indicated that material no longer in use at field office.

File No.15 Licensee: Pairie Lakes Health Care Systems City, State: Waterstown, SD License Number: 40-16775-01 Insoection Prioritv: 3 Lead Inspector: RB/J'C Tvoe of insoection: Routine, Unannounced Inspection Date: October 12,1995 issuance Date: October 12,1995 Proaram Code /Tvoe: 02120 - Medical Institution - QMP Required Comments: 1) independent surveys could not be done due to dead battery in Xetek survey meter.

File No.16 Licensee: OHM Medical Center City, State: Okmulgee, OK License Number: 35 16189-01 Inspection Prioritv: -3 Lead Insoector: JC ,

Tvoe of insoection: Routine, Unannounced Insoection Date: February 27,1996 issuance Date: March 11,1996 Proaram Code /Tvoe: 02120 - Medical Institute - QMP Required Comments: 1) telephone close-out on 3/7/96 e

. . .-. - - . --- . -. .-~ -. -.. - - - - - . - . - . - . - . . .- -

f Region IV Draft Report *

~ Page E.6 Inspection Files Reviewed 1

File No.17 f'

Licensee: Mills Biopharmaceuticals i City, State: Oklahoma City, OK

! License Number: 3 i

Insoection Priority

3

Lead insoector: MS

Tvoe of insoection

Initial, Announceo inspection Dele: April 25,1996 Issuance Date: April 25,1996 Proaram Code /Tvoe: 02511 - Medical Product Distribution 1

i

File No.18 Licensee

Department of Veterans Affairs, VA Medical Center i

< City, State: Oklahoma City, OK License Number: 35-00526-04 Insoection Prioritv: 1

! Lead Inspector: MS 3 Tvoe of inspection: Routine, Unannounced .

insoection Date: January 11,1996 .

l Issuance Date: January 11,1996

, Proaram Code /Tvoe: 02110 - Medical Institution Broad i

Commerits: 1) shipping paperwork reviewed under pharmacy license.

V i File No.19 ,

f' Licensee: University of Oklahoma '

- City, State

Oklahoma City, OK j License Number: 35-03176-01 >

. Insoection Prioritv: 2

[ Lead inspector: JC ,

j- Tvoe of inspection: Routine, Unannounced

{

inspection Date: December 16-19,1996 issuance Date: February 24,1996 i - Proaram Code /Tvoe: 01100 - Academic Type A Broad

. Comments: 1) field notes missing pages A.-12&13, later found and replaced in file i

s i

i i

^

\

l Region IV Draft Report Page E.7 I inspection Files Reviewed File No. 20 Licensee: Edwards Pipeline Testing, Inc.

City, State: Tulsa, OK ,

_Ucense Number: 35-23193-01 )

Inspection Priority: 1 i Lead Inspector: JC Tvoe of insoection: Routine, Unannounced Insoection Date: March 20',1996 issuance Date: April 23,1996 Pr_o. gram Code /Tvoe: 03320 - Industrial Radiography - Temporary Jobsites Comments: 1) office inspection only ,

2) telephone exit on 4/19/96 l l

File No. 21 Licensee: Pro-Technics intarnational City, State: Houston, TX 42-26928-01 License Number:

Insoection Prioritv: 3 Le_.ad Inspector: WR/MS Tvoe of inspection: Routine, Unannounced Inspection Date: December 6-7,1995 issuance Date: January 23,1995 Proararn Code /Tvoe: 03112 - Well Logging Byproduct Only - Tracers Only Comments: 11 corporate office inspection

2) file not in order File No. 22 Licenseg: Front Range Mobile Imaging Inc.

City, State: Cheyenne, WY I feense Num_b_er: 49-27531-01 Insoection Prioritv: 2 Lead insoector: WR Tvoe of inscection: Initial, Announced insoection Date: May 8 & 11,1996 Issuance Date: May 11,1996 Proaram Code /Tvoe: 02220 - Mobile Nuclear Medicine Service Comments: 1) inspection also included temporary jobsite in Douglas, WY

2) page 2 of the 591 form missing in document file, copy in inspection file (copy placed in document file)

i.

i Region IV Drrft Report Page E.8 Inspection Files Reviewed i

. File No. 23

)

Licensee: WeGo Perforators, Inc. -

City, State: Ada, OK License Number: 35 12400-03

! Insoection Prioritv: 3 i Lead insoector: JC

- Tvoe of inspection: Routine,. Unannounced insoection Date: September 30,1996 lssuance Date: September 30,1996

, Proaram Code /Tvoe: 03800 - Byproduct Material Possession Only - No Operations l Authorized Comments: 1) possession only, waiting to dispose of source File No. 24 Licensee: Mid America Healthcare

Citv, State

Shawnee, OK j License Number: 35-13058-01 l

Insoection Priority: 3

^

Lead insoector: DS Tvoe of inspection: Routine, Announced

Insoection Date

August 29,1996 i Issuance Date: August 29,1996

Proaram Code /Tvoe

02120 - Medical Institutions - QMP Required File No. 25 3

Licensee: Department of Air Force j City, State: Moody AFB, GA 4

License Number: 42-23539-01 AF j Insoection Prioritv: 1 Lead insoector: LF, Region ll i Tvoe of insoection: Routine, Unannounced inspection Date: February 13,1997 j issuance Date: February 28,1997 i Proaram Code /Tvoe: 03613 - Research and Development Broad - Multisite -

Multiregional Comments: 1) Region 11 inspection of the U.S. Air Force's Master Material i License i

4 0 4

)

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Region l\/ Draft Report Page E.9 i inspection Files Reviewed I

1 a

in addition to the inspection files reviewed, the following inspection accompaniments were  !

made in advance of the on-site IMPEP review l

l i

Accompaniment No.1 i Licensee: Tuboscope Vetco International, Inc. l City, State: Oklahoma City, Oklahoma License Number: 42-02084-02 l Insoection Priority: 7 Insoector: RL l Tvoe of Insoectic : Routine i insoection Date: 3/5/97 l License Tvoe: Measuring Systems, nther l Comments: This was an accompaniment performed by David J. Collins a) Thorough inspection of licensee operations. Inspector demonstrated proficiency in examining inspection areas.

b) Record reviews was thorough.

l c) Inspection unannounced. Observation of licensee operations not conducted i because this is a field office, not an operation site. No operators at this location i during inspection.

1 1

Accomoaniment No. 2 )

Licensee: The Terracon Companies, Inc.

Citv. State: Oklahoma City, Oklahoma License Number: 15-27070-01 Inspection Prioritv: 5 Insoector: RL Tvoe of Inspection: Routine inspection Date: 3/5/97  :

l License Tvoe: Portable Gauge Comments: This was an accompaniment performed by David J. Collins a) Inspection unannounced. Inspector demonstrated thorough control over inspection activities.

b) Surveys taken in transportation vehicles and storage location.

c) Inspection concentrated on review of licensee documentation and recordkeeping. No field operations conducted during inspection, despite four visits over two days to field job location.

d) Information and safety issues clearly communicated to licensee during inspection and at exit interview. RSO at home office contacted by telephone for exit.

e) Branch office inspection.

Region IV Draft Report Page E.10 Inspection Files Reviewed Accompaniment No. 3 Licensee: Veterans Administration Medical Center City, State: Long Beach, California License Number: 04-00689-07 Inspection Prioritv: 1

. Inspector: EG Tvoo of insoection: Routine insoection Date: 3/11-12/97 4

License Tvoe: Medical Institution, Broad, OMP Required Commenis: This was an accompaniment performed by David J. Collins a) Inspection announced, inspector demonstrated thorough control over inspection activities.

, b) Surveys taken in all areas where radioactive materials used.

c) Inspection concentrated on observation of licensee operations. Reviews of licensee documen:ation and recordkeeping limited d) Information and safety issues clearly communicated to licensee during inspection J and at exit interview.

e) Inspector demonstrated knowledge and skillin controlling interviews and documenting observed licensee operations.

Accomoaniment No. 4 Licensee: Quest Associates City, State: Pocatello, Idaho License Number: 11-27411-01 Insoection Prioritv: 5 Inspector: JC Tvoe of Insoection: Routine, unannounced Insoection Date: 2/25/97 License Tvoe: Portable Gauge .

Comments

This was an accompaniment performed by Duncan White, a) No licensed material possessed by licensee at the location i

Accompaniment No. 5 License JUB Engineering City, State: Twin Falls, Idaho

License Number

11-27319-01 Inspection Prioritv: 5 Insoector: JC Tvoe of Inspection: Routine, unannounced Inspection Date: 2/25/97 License Tvoe: Portable Gauge

, Comments: This was an accompaniment performed by Duncan White, a) Inspection of field office; central office inspected in March 1996 b) Security issue and expectations clearly communicated to licensee during inspection and at exit meeting

i.

h Region IV Draft Report Page E.11 Inspection Files Reviewed Accomoaniment No. 6 Licensee: Idaho Testing & Inspection ,

City, State: Nampa, Idaho License Number: 11-27552-01 Insoection Priority: 5 Insoector: JC Tvoe of insoection: Initial, announced 7 Insoection Date: 2/26/97 License Tvoe: Portable Gauge Opmments: TNs was an accompaniment performed by Duncan White.

a) Inspection included obseive' ions of licensed activities at a temporary job site Accomoaniment No. 7 Licensee: U.S. Department of literior City, State: Boise, Idaho License Number: 11-16934-01 Insoection Prioritv: 5 1 Insoector: JC Tvoe of Insoection: ' Routine, unannounced Insoection Date: 2/26/97 License Tvoe: Portable Gauge Comments: This was an accompaniment perforrned by Duncan White. l a) No licensed material possessed by licensee at the location I Accompaniment No. 8 Licensee: Nuclear Pharmacy of Idaho Citv, State: Boise, Idaho  !

License Number: 11-27398-01'MD l Insoection Prioritv:' 1

)

Inspector: JC Tvoe of Inspection: Routine, unannxnced 1 Inspection Date: 2/;26-27/97 License Tvoe: Nuclear Pharmacy Comments: This was an accompaniment performed by Duncan White.

a) Inspector spent a significant portion of the inspection observing the operation and handling of licensed material b) Verification of licensee's compliance to public dose limit from effluents and direct exposure not fully confirmed c) Deficiencies in licensee's handling of waste held for decay-in storage was skillfully uncovered by inspector e

6 -

Region IV Draft Report Page E.1 ?

Inspection Files Reviewed 9

Accompaniment No. 9 Licensee: Bass Memorial Baptist Hospital Citv. State: Enid, Oklahoma l 35-13821-02 License Number:

Insoection Prioritv: 2 Insoector: WR Tyne of Insoectimp Routine, unannounced l Inspection Date: 3/17/97 i License Tvoe: Medical institution l Comments: This was an accompaniment performed by Duncan White. l a) Inspector spent a significant portion of the inspection observing the operation a'nd i handling of licensed material b) Select records were verified through interviews with users and ancillary workers l

l Accomoaniment No.10 Licensee: BJ Services.Co.

City, State: Clinton, Oklahoma ,

License Number: 42-19649-01 Insoection Prioritv: 5 Insoector: WR Tvoe of Ins'oection: Routine, unannounced Insoection Date: 3/17-18/97 l License Tvoe: Fixed Gauge Comments: This was an accompaniment performed by Duncan White, a) Inspection of field office b) Inspection included observations of licensed activities at a temporary job site c) Security issue promptly corrected and expectations clearly communicated to-licensee during inspection d) Select records were verified through interviews with users Accompaniment No.11 Licensee: Clinton Memorial Hospital i Citv State: Clinton, Oklahoma License Number: 35-17654-01 Insoection Priority: 3 Inspector: WR Tvoe of Insoection: Routine, unannounced l Insoection Date: 3/18/97  !

License Tvoe: Medical Institution Comments: This was an accompaniment performed by Duncan White.

a) Security issue and expectations clearly communicated to licensee during inspection and exit meeting b) Inspection included observations of operations and handling of licensed material I

APPENDlX F REGION IV INCIDENT FILES REVIEWED 4

i File Number: 1 incident Log Number: 941644 Licensee: Syncor License Number: 3519583-01 MD Site of Event: Tulsa, OK Type of Event: Equipment Failure Date of Event: 12/26/94 investigation Type: Phone Investigation Date: 12/28/94 Summary of incident: Fume hood needed for compilance with Part 20 failed. electric motor burned-out. Although no radioactive materialin use, licensee was cited for failure to notify NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required in Part 30. This case is closed.

File Number: 2 incident Log Number: 970014 Licensee: St. John's Medical Center License Number: 35-00376-02 Site of Event: Tu!::::., OK Type of Event: Misadministration Date of Event: 8/28/95 Investigation Type: Inspection Investigation Date: 1/5/97 Summary of incident: Misadministration involving manual brachytherapy, discovered during routine inspection during review of Radiation Safety Committee Meeting minutes. The implant became dislodged and the misadministration involves the wrong site. This case remains open pending receipt of a technical assistance request response and medical consultant report.

File Number: 3 incident Log Number: 950962 Licensce: H & G Inspection Co., Inc. License Number: 42-26838-01 Site of Eve'nt: Salt Lake City, UT Type of Event: Equipment Failure i Date of Event: 5/15/95 Investigation Type: Phone Investigation Date: 7/10/95 Summary of incident: Radiography source failed to retract after an exposure. Source recovered by area supervisor with no overexposures. Proper notifications made. This case is closed.

File Number: 4 Incident Log Number: 960205 Licensee: Globe X-Ray Servicea, Inc. License. Number: 35-15194-01 Site of Event: Catoosa, OK Type of Event: Equipment Failure Date of Event: 12/2/96 investigation Type: Inspection investigation Date: 12/16/96-1/22/97 Summary of incident: Failure of two radiography source guide tube end stops. One item of non-compliance for failure to file 30 day report on the first incident. This case is closed.

e

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v Region IV Draft Report Page F.2 Incident Files Reviewed File Number: 5 Incident Log Number: 960816 i Licensee: Tulsa Gamma Ray, Inc. License Number: 35-17178-01 j Site of Event: Tulsa, OK . Type of Event: Overexposure 2

Date of Event: 11/20/96 Type of Investigation: Inspection investigation Date: 12/9/96-1/9/97 Summary of incident: Radiography overexposure (8.3 rem) due to failure to properly secure

! source and tailure to conduct a close-out survey. This case remains open pending licensee's response to notice of violation which is not yet ~due.

l Fi% Number: 6 incident Log Number: 960300 i Licensee: Department of the Army License Number: 30-02405 10 Site of incident: White Sands Missile Range, NM Type of Event: Leaking Source

Date of Event: 4/24/96 Type of Investigation: Inspection

Investigation Date: 4/30/96 Summary of incident: Large irradiator Co-60 source (2,000 Curies) discovered leaking j' during routine licensee test. The leak test sample measured 1.0 microcuries. This case remains open pending completion of a thorough engineering analysis of the source failure l for a possible generic cause.

3 File Number: 7 incident Log Number: 960284

{ Licensee: Fairbanks Memorial Hospital License Number: 50-13648-01 i Site of Incident: Fairbanks, AK Type of Event: Misadministration

Date of Event

6/21/96 Type of Investigation: Inspection j Investigation Date: 6/26/96

Summary of incident

Radiopharmaceutical (I-131) 6.6 millicuries administered versus 100

' microcurier. prescribed. No written directive. This case remains open due to pending escalated enforcement actiori.

4

{ File Number: 8 incident Log Number: 960055 Licensee: CTI Alaska, Inc. License Number: 50-19202-01

Site of incident: Endicott Island, AK Type of Event: Equipment Failure Date of Event: 12/23/95 Type of Investigation: Inspection investigation Date: 1/17-7/2/96 Summary of incident: Radiography camera lock malfunction with possible overexposure to worker. A review of filmbadge records showed no indication of an overexposure. Seven items of non-compliance were noted during a specialinspection and this case was referred for escalated enforcement. The licensee has paid a civil penalty. This case is closed.

Region IV Draft Report Page F.3 I incident Files Reviewed File Number: 9 incident Log Number: 951166 Licensee: Central Plains Clinic License Number: 40-26865-01 Site of Incident: Sioux Falls, SD Type of Event: Misadministration Date of Event: 9/18/95 Type of Investigation: Inspection :

Investigation Date: 10/10-30/95 l Summary of incident: Radiopharmaceutical (1-131) underdose, 2.5 millicuries administered to three patients versus 5.0 millicuries prescribed. Due to inadequate Quality Management Program. Notice of violation issued. This case is closed.

l l

File Number: 10 incident Log Number: 951120  !

Licensee: Diamond H Testing Company Licensee Number: 11-27316-01 Site of incident: Chubbuck, ID Type of Event: Equipment Failure Date of Event: 8/27/95 Type of Investigation: Inspection Investigation Date: 8/28/95 Summary of incident: Radiography sour ~ cable break with no report of personnel overexposure. Five items of non-compliance found during investigation. Referred for escalated enforcement action with issuance of civil penalty. Possible generic, equipment issue (manufacturing defect) reported to proper authorities. This case is closed.

File Number: 11 incident Log Number: 950644 Licensee: Department of the Air Force License Number: 42-23539-01 AF Site of incident: Keesler AFB, MS Type of Event: Misadministration Date of Event: 4/25/95 Type of Investigation: Inspection Investigation Date: 5/17/95- 3/14/96 Summary of Incident: High Dose Rate Afterloader brachytherapy misadministration.

Radiation to an unintended site due to an error in measuring source catheter length, inadequate Quality Manegament Program. This case is closed.

File Number: 12 Incident Log Number: 960096 Licensee: Philip Lee, M.D. License Number: 53-04935-01 Site of incident: Honolulu, HI Type of Event: Misadministrations Date of Event: 5/6/96 Type of Investigation: Inspection investigation Date: 11/16/96-2/3/97 Summary of incident: Manual brachytherapy (Sr-90) Eye applicator misadministrations, to sixteen patients, discovered by inspector during routine inspection. Licensee erred in calculation of decay rate for SR 90 in determining the required treatment times. This case remains open pending licensee's response (not yet due) to NRC consultant's report.

J Region IV Draft Report Page F.4 l Incident Files Reviewed ,

1 e4 Number: 13 Incident Log Number: 960703

Licensee

VA Medical Center License Number: 04-00181-12 Site of incident: West Los Angeles, CA Type of Event:' Misadministration j

Date of Event: 11/27/96 Type of investigation: Inspection  !

! Investigation Date: 12/4/96

Summary of incident

Teletherapy (Co-60) underdose due to a loose wire which caused J

intermittent movement of the source drawer No items of non-compliance found during investigtuico. Equiprnent failure information sent to appropriate Federal agency. This case l

, remains open pending the licensee's response to inspection report findings (not yet due). ,

, File Number: 14 Incident Log Number: 951311 I 4

. Licensee: Queens Medical Center License Number: 53-16533-02 Site of incident: Honolulu, HI Type of Event: Misadministration Date'of Event: 12/6/95 Type of Investigation: Inspection Investigation Date: 12/13/95-1/5/96 Summary of incident: Radiopharmaceutical (P-32) chromic phosphate underdose due to inadequate' written directive. Six items of non-com~pliance cited. This case is closed.

File Number: 15 incident Log Number: 960241 Licensee: Exxon Company License Number: 25-03375-01 Site of incident: Billings, MT Type of Event: Equipment Damage Date of Event: 4/15/96 Type of Investigation: Phone Investigation Date: 4/19/96 Summary of incident: Industrial gauge accidentally severed from its mount. Licensee late in reporting to NRC as required in Part 30. Manufacturer contacted and repaired device.

No overexposures. This incident will be reviewed during the next rou' tine inspection. This case is closed.

l 4

6

APPENDIX G REGION IV DECOMMISSIONING FILES REVIEWED DECOMMISSIONING INSPECTION'AND LICENSING FILES REVIEWED IN WCFO File No.1 Licensee: Department of Transportation Location: Vancouver, Washington License Number: 46-21202-01 License Type: Density Gauges, Sealed Sources '

File No. 2 l Licensee: Diagnostic Lab Services, Inc. l Location: Honolulu, Hawaii .

License Number: 53-07998-03 )

License Type: Invitro Testing Laboratory l File No. 3 Licensee: Department of the Army Location: Sacramento, California License No.: 04-04279-01 l License Type: Gource Material  !

File No. 4 Licensee: Department of Veteran Affairs j Location: Sepulvada, California License No.: 04-00916-04 License Type: Invitro Testing Laboratory File No. 5 Licensee: General Atomic .

Location: San Diego, California License No.: SNM-696 License Type: Special Nuclear Material File No. 6 Licensee: Interior Department Location: Menlo Park, California License: 04-06674-07 License Type: Source Material 1

Region IV Draft Report Page G.2 Decommissioning Files Reviewed DECOMMISSIONING INSPECTION FILES REVIEWED IN ARLINGTON File No. 7 Licensee: Chicago Bridge and Iron Location: Houston, Texas License: 42-13652-01 License Type: Industrial Radiography File No. 8 Licensee: Kaiser Aluminum Location: Gore, Oklahoma License: STB-472 License Type: Source Material File No. 9 Licensee: Fansteel, incorporated Location: Muskogee, Oklahoma License: SMB-911 License Type: Source Material File No.10 Licensee: Cimmaron Corporation Location: Oklahoma City, Oklahoma License: SNM-928 License Type: Special Nuclear Material File No.11 Licensee: Kerr McGee, Cushing Location: Oklahoma City, Oklahoma License: SNM 1999 License Type: Special Nuclear Material File No.12 Licensee: Sequoia Fuels Corporation Location: Gore, Oklahoma License: SUB-1010 License Type: Source Material

9 APPENDIX H F.EGION IV URANIUM RECOVERY INSPECTION FILES REVIEWED i File No.1 4

Licensee: Energy Fuels Nuclear (EFN), White Mesa City, State: Blanding, Utah License Number: SUA-1358 Insoection Prioritv: NA Lead insoector: MLM i Tvoe 'of Insoection: Special- Announced inspection Date: March 1 - 2,1995 1 I

. Issuance Date: March 31,1995 I

[ Proaram Tvoe: Uranium Recovery / Conventional Mill - Partial Operations Comments: 1) specialinspection prompted by notification of financial difficulties

2) inspector verified no problem File No. 2 l Licensee: EFN, White Mesa City, State: Blanding, Utah License Number: SUA-1358 Inspection Prioritv: NA l Lead Insoector: MLM Tvoe of Insoection: Routine - Announced Insoection Date: August 8-11,1995  ;

Issuance Date: September 15,1995 .

j Proaram Tvoe: Uranium Recovery / Conventional Mill- Partial Operations j Comments: 1) closed four violations  ;

2) identified use of unapproved drying process i File No. 3 Licensee: EFN, White Mesa .

City, State: Blanding, Utah License Number: SUA-1358 ,

inspection Prioritv: NA Lead Inspector: MLM Tvoe of Insoection: Announced - follow-up on NOV inspection Date: January 23- 25,1996 Issuance Date: March 28,1996 -late because of coordination on violation Proaram Tm: UR/ Mill - operating

4 Region l\/ Draft Report Page H.2 Uranium Recovery inspection Files Reviewed File No. 4 Licensee: Power Resources, Inc. - Highlands (PRI)

City. State: Converse, Wyoming License Number: SUA-1511 Inspection Priority: NA Lead insoector: MLM Tvoe of Insoection: Routine - Announced insoection Date: September 9-10,1996 lssuance Date: October 10,1996 Proaram Tvoe: Uranium Recovery /In situ leach (ISL)

File .No. 5 Licensee: Power Resources, Inc. - Highlands (PRI)

City, State: Converse County, Wyoming License Number: SUA-1511 Inspection Priority: NA Lead Insoector: MLM .

Tvoe of Inspection: Routine Announced Insoe'ction Date: August 28 - 31, 1995 issuance Date: September 28,1995 Proaram Tvoe: UR/ISL

' File No. 6 l Licensee: PRI Citv. State: Converse, Wyoming License Number: SUA-1511 Insoection Prioritv: NA Lead insoector: MLM Tvoe of insoection: Routine Announced Insoection Date: April 4 - 6,1995 issuance Date: May 10,'1995 Proaram Tvoe: UR/ISL Comments: 1) in addition to the rout.ine inspection areas, the inspector also looked at radwaste and emergency planning i

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I Region IV Draft Report Page H.3 3 Uranium Recovery inspection Files Reviewed -

. File No. 7 1.icensee

PRI E City, State: Converse, Wyoming License Number: SUA-1511 Insoection Prioritv: NA Lead inspector: MLM Tvoe of insoection: Routine - Announced inspection D_a.Lte: May 14 - 16,1996 issuance Date: June 18,1996

.Proaram Tvoe: UR/ISL File No. 8 Licenset: Envirocare City, State: Sov+h Clive, Utah License Number: 5MC-1559 Insoection Priority: NA Lead insoector: MLM/RE Tvoe of Inspection: Routine - Announced insoection Date: July .11,1996 issuance Date: August 13,1996 Proaram Tvoe: 11(e)(2) byproduct disposal facility Comments: 1) reviewed against performance based license File No. 9 Licensee: Envirocare City, State: South Clive, Utah License Number: SMC-1559

-Inspection Prioritv: NA.

Lead Inspector: RE 3 Tvoe of Insoection: not indicated iri file Insoection Date: Nov.22,1996 issuance Date: Jan. 28,1997 (expanded inspection - violation coordination)

Proaram Tvoe: 11(e)(2) byproduct disposal facility File No.10 Licensee: Atlas City, State: Moab, Utah License Number: SUA-917 Insoection Prioritv: NA Lead Inspector: RE Tvoe of insoection: Routine - Announced insoection Date: March 13 - 14,1996 issuance Date: April 1996 Proaram Tvoe: Conventional millin decommissioning Comments: Had pictures / good report 1

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4, j Region IV Draft Report ,

Page H.4 Uranium Recovery inspection Files Reviewed 4 .

File No.11

] Licensee- Quivera/ Ambrosia Lake Citv, State: Grants, New Mexico License Number. SUA - 1473 I

Insoection Prioritv: NA 3 Lead Insoector: RE Tvoe of Inspection: Routine - Announced

Insoection Date: February 26 - 28, 1996 l lssuance Date: April 25,1996 Proaram Tvoe: UR/ Conventional mill l File No.12 l Licensee: Bear Creek City, State: Converse, Wyoming I

License Number: 40 8452 Inspection Prioritv: NA Lead Inspector: LC Tvoc of Inspection: Routine - dnnounced q Insoection Date: July 16,.1996

Issuance Date: August' 28,1996 Proaram Tvoe: UR/ conventional mill- in reclamation

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l File No.13 l' Licensee: Cogema Mining, Inc. -Irigaray/Christensen Ranch (Cogema)

' City, State: Converse County, Wyoming j License Number: SUA-1341 Insoection Priority: NA i Lead insoector: MLM i i

Tvoe of insoection: Routine - Announced  !

Inspection Date: June 6 - 8,1995 l

issuance Dale.

' July 10,1995 Proaram Tvoe: UR - operating ISL Comments: 1) inspec, tor also iooked at fire protection and emergency procedures t

r i File No.14 i Licensee: Cogema (see 13 above) l Converse County, Wyoming City, State: i

, License Number: SUA-1341 1 Inspection Prioritv: NA j Lead insoector: MLM l Tvoe of insoection: Routine - Announced Insoection Date: September 26-28,1995 ,

Issuance Date: November 1,'1995  !

Proaram Tvoe: UR - operating ISL i

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Region l\/ Draft Report Page H.5 Uranium Recovery inspection Files Reviewed File No.15 i Licensee: Cogema (see 13 above)

City, State: Converse County, Wyoming

License Number: SUA-1341 Insoection Priority: NA

Lead insoector

MLM i Tvoe of Insoection: Routine - Announced 1 1

Insoection Date: May 7 -9,1996 Issuance Date: June 8,1996 Proaram Tvoe: UR - operating ISL a

9 a File No.16 Licensee: Cogema (see 13 above)

' City, State: Converse County, Wyoming License Number: SUA-1341 i inspection Prioritv: NA j Lead insoector: MLM i

Tvoe of Insoection: Routine - Announced . l 2 Insoection Date: September 24 - 25,1996 l Issuance Date: October 23,1996 Proaram Tvoe: UR - operating ISL 1

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1 ATTAC'iMENT 1  :

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GOOD PRACTICE DOCUMEftT l

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'*lNFORMATION THAT SHOULD BE SUBMITTED TO THE NRC STAFF FOR DECOMMISSIONING AND TERMINATION OF LICENSED FACILITIES" -

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) INFORMATION THAT SHOULD BE SUBMITTED l TO THE NRC STAFF FOR DECOMMISSIONING AND TERMINATION OF LICENSED FACILITIES .

The following information is needed from licensees who request authorization from the NRC for the release of a room, building or outdoor area for unrestricted use:

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1 1) A list of the radiological isotopes that were actually used at the site. Tn the extent possible (and reasonable), the quantities and dates of use of these isotopes.should also be provided.

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2) The physical form of each isotope, i.e., was it a sealed source or was the isotope used in a loose form.

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. 3) Ir"ormation regarding major radiological spills of any licensed isotopes such as the location of the spill (s) and pertinent radiological information about the spill (s).

(Major spills for the purpose of this document means a spill that resulted in off-site j contamination or any other spill whue riore than minimal decontamination effort is l required, e.g., spills requiring assista. ice in cleanup and monitoring from persons l other than the user.)

4) Information on any leaking sealed source used or stored at the site being released, including isotope, amount of leakage, contamination of cther areas or personnel, description of cleanup, and disposition of the source. 't no sources were determined to be leaking at the facility, the licensee should state this f act. l

5) The results of the licensee's final surveys as required by 10 CFR Parts 30.35(j)(2),

40.42(j)(2), 70.38(j)(2), and 72.54(l)(2). This includes submitting data in the following units: gamma radiation in units of mSv/hr ( R/hr) at one meter from surf aces, radioactivity in units.of MBa/100cm2 (dpm/100cm 2) (removable and fixed) for surf aces, MBq/rpi (mci /ml) for water, and Bq/g (pCilg) for soils and concrete.

(See Attachments 1 and 2)

6) The surve'y instrumentation used for the final survey along with the certification that each instrument has been properly calibrated and tested and the minimum detectable activity (MDA) for each instrument. This information is needed for instruments used for. measuring exposure rates and for those used for analysis of 4

wipes, soil and water samples, etc. (See Attachment 3)

7) Maps and/or drawings which clearly indicate the locations where wipes and fixed  !

1 measurements were taken. If contaminated drain lines (or other buried and inaccessible pipes) are an issue, blueprints or drawings should be i,cluded that show the locations of the drain lines, including where they originate and end.

8) If other than minimal contamination efforts are necessary, both the before and af ter ,

decontamination survey data should be provided as part of the finv. survey report,  !

including the locations of these areas.

9) The release criteria used as a basis for demonstrating the site can b e released for unrestricted use. (See Attachment 4) i

' . Attach m ent I

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10) If the licensee intends to leave certain cortions of the site contaminatec in excess '

the, release guidelines, a risk assessment of the potential dose consequences.

11) The disposition of radioactive waste resulting from any remediation efforts. Under normal circumstances the NRC will not conduct a closeout or confirmatory inspection until all waste land other licensed materials / sources) have been removed from the site. If these materials have 4,ot been removed prior to the licensee's submittal of the final survey data, then tnese areas will have to be surveyed following removal of the waste and the data submitted and reviewed before an onsite inspection and/or license termination. i i

A'ttachments: (1) 10 CFR Part 30, 40, 70 (as applicable)

(2) Survey information to Support License Termination

. (3) Section 5.0, NUREG/CR 5849, Manual for Conducting Radinlogical Surveys in Support of License Terminations (4) ' Guidelines f'or Dei antamination of' Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source; or Special Nuc, lear Material I

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l ATTACHMENT 2 SURVEY INFORMATION TO SUPPORT LICENSE TERMINATION In performing the decommissioning of its facility the licensee should first identify any areas f

i in the f acility that were involved in licensed material use by reviewing facility records and j conducting a survey of the licensed material use area. This survey should be similar to the routine contamination surveys conducted under the licensee's radiological safety plan. The l

I licensee should then remediate all surfaces in *he areas at the facility that were involved in licensed material use or storage and dispose of all radioactive material and waste as discussed in the NRC regulations at 10 CFR Part 20, Subpart K.

l If the licensee elects to demonstrate that its facility is suitable for unrestricted use by I conducting a Final Status Survev. the licensee chould design the survey so as to be of sufficient scope and quality to make this demonstration. In preparing for the Final Status Survey, the license'e snould establish a method to identify individual measurerrent/ sampling points, such 3s establishing reference grids on oach surf ace in the indoor area that was involved in licensed material. At a minimum, the licensee's termination survey should consist of:

l 1) 100% scanning of all surfaces in the area at the facility where licensed material was used or stored using an appropriate radiation detection instrumen. (including scan sensitivity);

2) evaluations for total and removable radioactive material at each area exhibiting elevated radiation levels or at a frequency of one wipe comprising 100cm2 per gnd; and

3) evaluations of radiation levels at one meter above surf aces Particular attention thould be afforded any dra.: s, air vents or other fixtures or eauipment that may have become contaminated during licensed material use. This is especially significant in situations where renovations have occurred and potentially contaminated

-areas may be inaccessible under current conditions.

The information that should be submitted to the NRC to support the final status survey should consist of:

1) a brief description of the remediation activities undertaken by the licensee;

2) a detailed drawing of the licensed material use areas indicating the sampling l locations; i

3) a table showing the results of the radiation levels and removable l

contamination surveys keyed to the detailed drawing (organized by survey unit);

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4) the training and qual i fications of the individual (si performing the decontamination and surveys: 31d

5) a description of the type of equip ent used ov the licensee to evaluate the )

wipes and perform toe surveys. This description should include all l information require'd to determine the appropriateness of the equipment for determining the radiological status of the facility such as last calibration date, type of radiations detected, sensitivity of detection, efficiency, etc. l D

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TABULkR

SUMMARY

OF REGION IV MATERIALS BUDGET AND EXPENDITURES 4

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t 01/31/97 The following table shows FTE allocations and expenditures for the review period.

REGION IV RESOURCE UTILIZATION FY 1996 FY 1997 ANNUAL ANNUAL BUDGET EXPENDED BUDGET EXPENDED  % BUDGET OCT-DEC OCT-DEC  %

PROGRAM ACTIVITY Materials Lic & Insp 12.70 16.90 133 13.10 3.30 4.20 127 Event Evaluation 1.80 2.90 161 2.10 0.50 0.90 180 Fuel Fac Lic & Insp 1.70 0.90 53 1.60 0.40 0.20 50 0.10 0.20 200 0.20 0 0 0 Fuel Cycle Pgm Asses 0.30 0 0 0.10 0 0 0 LLW Lic & Insp Decommissioning 1 70 1.50 88 1.50 0.40 0.60_ 150 Uranium Rec Fac Insp 2.50 1.00 40 2.30 0.60 0.20 33 TOTAL , 20.80 23:40- 113 21.10 5.20 6.10 117

. NOTES:

1. FY 1996 expenditures from regional input provided in response to the FY 1997 President's budget update during 11/96.

2. FY 1997 expenditures from RWAT report dated 1/29/97. Expenditures are through 12/31/96.

I Attachment 2 l

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