ML20149H492
| ML20149H492 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/1997 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Piccone J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9707250001 | |
| Download: ML20149H492 (9) | |
Text
.
e July 7, 1997 MEMORANDUM TO: Josephine M. Piccone, Chief Operations Branch, IMNS FR'OM:
John W. Hickey, Chief [0riginal signed by]
Low-Level Waste and Decommissioning 4
Projects Branch, DWM
SUBJECT:
REVIEW OF INSPECTION PROCEDURE 64900 DWM provided informal comments on IMNS Inspection Procedure 84900 per request from S.
Sherbini. IMNS transmitted a comment resolution package with the revised procedure to DWM i
for review and concurrence. We have reviewed your response to our comment on the need to identify the regulatory requirements for the inspection criteria in the procedure. Your comment response indicates that the applicable regu!ations for this inspection "..are the usual radiation protection regulations that are applicable to any radiation protection situation..." and therefore, j
ther'e is no need to identify them in the procedure. We believe that identification of the regulatory requirements would improve the procedure and assure that inspections are l
conducted in a consistent manner.
inspection Procedure 84900, Section 84900-02, " Inspection Requirements," contains subsections 02.01-Management Controls and Surveys,02.02-Adequacy of Storage Area, and 02.03-Package Integrity and Labeling. We believe the appropriate requirements from Part 20 and Part 61 should be explicitly identified in these sections. For example, see Section 83822-
)
02 in the attached Inspection Procedure 83822. Our comment was discussed with S. Sherbini on Friday June 20,1997.
Attachment:
As stated CONTACT:
John Hickey, NMSS/DWM 415-7234 John Buckley, NMSS/DWM
/
MjI f
415-6607 TICKET:97498/LLLP-7/3 /
d/7 DISTRIBUTION:
Central File DWM r/f-t/f MVFederline NMSS r/f LLDP r/f PUBLIC DOLUMENT NAME:s:\\dwm\\lldp\\jtb\\lMNS. TIC
- see previous concurrence 0FC DWM DWM DWMn
//
JHikey NAME JBuckley*
LBell*
DATE 7/ /97 7/ /97 7/ 7 /97
/ /
OFFICIAL RECORD COPY LSS. YES NO X
s ACNW: YES NO X
IG' : YES NO X
Delete file after distribution:
Yes X No
.C40 89YES X
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' *****,o July 7, 1997 MEMORANDUM TO: Josephine M. Piccone, Chief Operations Branch, iMNS i
'/
FROM:
John W. Hickey, Chief Low-Level Waste and De missioning Projects Branch, DWM
SUBJECT:
REVIEW OF INSPECTION PROCEDURE 84900 DWM provided informal comments on IMNS inspection Procedure 84900 per request from S.
Sherbini. IMNS transmitted a comment resolution package with the revised procedure to DWM for review and concurrence. We have reviewed your response to our comment on the need to identify the regulatory requirements for the inspection criteria in the procedure. Your comment response indicates that the applicable regulations for this inspection "...are the usual radiation protection regulations that are applicable to any radiation protection situation..
- and therefore, there is no need to identify them in the procedure. We believe that identification of the regulatory requirements would improve the procedure and assure that inspections are conducted in a consistent manner.
inspection Procedure 84900, Section 84900-02, " Inspection Requirements," contains subsections 02.01-Management Controls and Surveys,02.02-Adequacy of Storage Area, and 02.03-Package integrity and Labeling. We believe the appropriate requirements from Part 20 and Part 61 should be explicitly identified in these sections. For example, see Sectic i 83822-02 in the attached Inspection Procecure 83822. Our corrmnt was discussed w!* S.c? 'rbin' on Friday June 20,1997.
Attachment:
As stated CONTACT:
John Hickey, NMSS/DWM 415-7234 John Buckley, NMSS/DWM 415-6607
July 7 1997 0
MEMORANDUM TO: Josephine M. Piccone, Chief Operations Branch, IMNS FROM:
John W. Hickey, Chief [0riginal signed by]
Low-Level Waste and Decommissioning Projects Branch, DWM SUBJEOT:
REVIEW OF INSPECTION PROCEDURE 84900 DWM provided informal comments on IMNS Inspection Procedure 84900 per request from S.
Sherbini. IMNS transmitted a comment resolution package with the revised procedure to DWM for review and concurrence. We have reviewed your response to our comment on the need to identify the regulatory requirements for the inspection criteria in the procedure. Your comment response indicates that the applicable regulations for this inspection "..are the usual radiation protection regulations that are applicable to any radiation protection situation..." and therefore, there is no need to identify them in the procedure. We believe that identification of the regulatory requirements would improve the procedure and assure that inspections are conducted in a consistent manner, inspection Procedure 84900, Section 84900-02, " Inspection Requirements," contains subsections 02.01-Management Controls and Surveys,02.02-Adequacy of Storage Area, and 02.03-Package Integrity and Labeling. We believe the appropriate requirements from Part 20 and Part 61 should be explicitly identified in these sections. For example, see Section 83822-02 in the attached Inspection Procedure 83822. Our comment was discussed with S. Sherbini on Friday June 20,1997.
Attachment:
As stated CONTACT:
John Hickey, NMSS/DWM 415-7234 John Buckley, NMSS/DWM 415-6607
~
TICKET:97498 DISTRIBUTION:
Central File DWM r/f-t/f MVFederline NMSS r/f j
LLDP r/f PUBLIC l
DOCUMENT NAME:s:\\dwm\\1ldp\\jtb\\IMNS. TIC
- see previous concurrence 0FC DWM DWM DWMn t./
NAME JBuckley*
LBell*
JHikey DATE 7/ /97 7/ /97 7/ 7 /97
/ /
OFFICIAL RECORD COPY LSS YES NO X
ACNW: YES NO X
IG YES NO X
Delete file after distribution:
Yes X No PDR, YES X
NO
UNITED STATES fl k NUCLEAR REGULATORY COMMISSION
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.j WASHINGTON, D.C. 20566-0001 o
R 4.....f NRC INSPECTION MANUAL nsSS INSPECTION PROCEDURE 83822 RADIATION PROTECTION PROGRAM APPLICABILITY:
2600, 2800 83822-01 INSPECTION OBJECTIVE To determine-whether the licensee is complying with regulatory requirements related to radiation protection, and to evaluate the adequacy of certain aspects of the licensee's radiation protecuon program.
83822-02 INSPECTION REQUIREMENTS 02.01 Radiation Protection Proaram. Verify that a radiation protection program commensurate with the licensee's activities is being implemented and documented, and that the program is being reviewed at least annually, both for content and implementation.
02.02 Radiation Protection Procedures. Verify that changes in the radiological protection procedures made since the last inspection are consistent with regulations and license requirements.
02.03 ' Instruments and Eouioment. Verify that radiation protection instruments and equipment are operable, have the proper alarm settings (if applica-ble), and are calibrated in accordance with license requirements and licensee orocedures.
02.04 Exoosure in.rols a.
External Exoosure.
Determine compliance with the following regulatory requirements:
1.
10 CFR 20.1501 & 20.1502 (surveys and monitoring) l 2.
10 CFR 20.1201 (occupational dose limits) l 3.
10 CFR 20.1206 (planned special exposures) 4.
10 CFR 20.1207 (exposure of minors) 5.
10 CFR 20.1208 (dose to an embryo / fetus) 6.
10 CFR 20.1203 (external dose from airborne material)
Issue Date:
03/07/94 83822
b.
Control.
Determine compliance with the following regulations, license e
requirements,'and licensee procedures:
4 1.
10 CFR 20.1601 (high radiation area access) 2.
10 CFR 20.1602 (very high radiation area access) l 3.
10 CFR 20.1801 (security of stored material) 4.
10_CFR 20.1802 (control of material not in storage) 5.
Radiological Work Permit system specified in license requirements or licensee procedures 6.
Controls for radioactive, or contaminated areas and equipment specified in license requirements or licensee procedures c.
Postino of Notices. Determine compliance with 10 CFR 19.11.
02.06 Surveys a.
Reauirements. Determine compliance with the following regulations:
1.
10 CFR 20.1501(a) & (b) (survays) 2.
10 CFR 20.2103 (survey records) b.
Leak Tests. Verify compliance with license requirements.for leak testing of radioactive sealed sources.
02.07 Notifications and Reports a.
To the NRC.
Determine compliance with the following regulations and license requirements:
1.
10 CFR 20.2201 & 2202(b) (loss or theft of material) 2.
10 CFR 20.2202 & 2203 (incidents) 3.
10 CFR 20.2202(a) & 2203 (overexposure) 4.
Other radiation protection reports required by the license and by applicable provisions of 10 CFR 30-39, 40, and 70.
b.
To the Individual. Determine compliance with 10 CFR 19.13.
02.08 As low As Is Reasonably Achievable ( ALARA1.
Paragraph 20.1101(b) of 10 CFR 20 states that persons engaged in NRC licensed activities shall, to the extent practicable, maintain occupational doses and doses to members of the public ALARA.
During inspections:
Determine if high level management has made a commitment to minimize a.
exposure to workers and has clearly defined procedures and policies to implement the ALARA philosophy.
b.
Determine that licensee personnel are made aware of management's commitment to keep occupational exposures ALARA.
Issue Date: 03/07/94 83822
. - -. ~
' Regulatory Guides 8.8 and 8.10 may be discussed in terms of. providing useful guidance to the licensee regarding ALARA.
If the licensee has a documented commitment to ALARA, implementation of the program should be discussed with management.
With respect to implementing ALARA commit-ments, citations will not be made for failure to achieve " limits" (or goals) that are more restrictive than regulatory requirements.
1 The licensee may have. submitted certain of his radiation protection procedures, or his radiation protection manual, along with the license application and, in some cases, those procedures or the manual may be incorporated into license requirements. There are references to. licensee
. procedures throughout this inspection procedure; however,-this is not done for all inspection areas.
The absence of a notation regarding licensee procedures is not intended to preclude the inspector _from inspecti. g a n
given area against licensee procedures if there is an applicable license requirement 03.02' Radiation Protection Procedures.
Review all substantive' changes to l
procedures which have been implemented since the last inspection verify that limits, precautions,' controls, etc., specified in the procedures are consistent with regulations and license requirements.
l 03.03 Instruments and Eauioment Randomly select instruments of each major type and examine them to a.
verify operability and proper alarm settings, if alarm settings are applicable.
These may include portable survey instruments, fixed monitoring' equipment, constant air monitors, portable air samplers, l
i film badges and TLDs, pocket dosimeters, and alarming dosimeters.
b.
Review the most recent calibration records of the instrument (s) selected for inspection to assure that the calibration and surveil-lance program for these instruments are being accomplished in accordance with license requirements or licensee procedures.
Verify that the licensee has a system (a schedule, card file, etc.)
c.
which identifies all the instrument: and identifies when they are due for calibration or functional testing.
t d.
Verify that the procedures used to calibrate the instruments selected above comain:
review wd approval requi. aments of the licensee's procedural system or license requirements, acceptance criteria including values for trip settings that conform to license require-ments, if applicable, and detailed stepwise instructions.
Verify that the licensee uses survey instruments that are appropriate e.
for the type and intensity of radiation' measured.
l 03.04 Exoosure Controls-a.
External Exposure 1.
Examine any changes made in procedures for control and use of I
personnel monitoring equipment; verify that limits, precautions, controls, etc., specified in the procedures are consistent with regulations and license ~ requirements.
l Issue Date:
03/07/94 83822
m 4 -.-
.l c.-
Resoiratory Protection 1.
- Determine that the equipment _is certified by NIOSH/MSHA
)
2.
' Determine proper selection of equipment.
l 3.
Determine by review of records and by discussions that a maintenance l
and training program is conducted and that-it is administered and conducted in accordance with written procedures. Determine by' review of records, discussions, and observations that respirator users are individually fitted for respirators and that respiratory equipment is' operationally. tested immediately prior to each use.
3
' 4.
Randomly select several control requirements and' determine compli-i ance; by review of records, by discussions, or observation.
l 5.
In the selection and use of respiratory protective equipment, 'the ALARA statement of 10 CFR 20.1702 is met by selection of equipment I
)
to provide a protection factor greater'than the rrc.;1tiple by which peak concentrations are expected to exceed the values of Table l, Appendix B, Column 3 of 10 CFR Part 20.
4 03.05 Postina. Labelina. and Control l
a.
Postina and Labelina. Inspect representative areas to verify compliance;.
pay particular attention to " temporary" work areas that may be required j
i for maintenance activity, newly established work areas, etc.
I Inspect a random sampling of containers in work or. storage areas.
Control s
b.
1.
Randomly sele'ct high radiation or very high radiation areas to verify that access is controlled in accordance with regulations or license requirements.
2.
Inspect areas where radioactive material is located or stored in an d
unrestricted area.
i 3.
Review a random selection of radiation work permits (R' ?s) on file and those currer.tly in effect.
4.
Review a random selection of records and inspect work areas-to determine compliance with controls, c.
Postina of Notices.
Determine, by questioning of management, how the
- licensee complies with the requirements of 10 CFR 19.11; inspect bulletin boards or other ' places where notices are posted; question a few individuals to determine if they are aware of the posting of notices.
03.06 Surveys a.
Reauirements.
Verify that the licensee has established schedules for periodic surveys of work areas of the plant and facility site; verify that surveys are conducted using approved procedures; review a random selection of survey records to see that surveys are being performed according to schedules; verify that the survey results are reviewed by appropriate supervision; verify that corrective actions have been taken, as Issue Date:
03/07/94 83822
?
exposures.
.The following guidance should be used as applicable. or at the
-inspector's discretion.
l
~ exposures to workers ALARA.
The commitment should appear in policy
, a.
Facility personnel should be made aware of management's commitment to keep l
statements, instructions to personnel, and similar documents.
As a i
minimum, workers should be familiar with the ALARA commitment so that they can explain ~ what the commitment is, what ALARA means, why it is recommended, and how they have been advised to implement it on their jobs.
Examine a-selection of policy standards ~and instructions (if they exist) and interview workers to determine if they understand the ALARA philosophy and what it means at the work place.
t b.
As a minimum, management-should be able to discuss which operating procedures were reviewed, in' which locations most exposures are being
~
received, what groups of workers are receiving the highest exposures, what l
discussions they have had with the radiation protection staff or outside.
consultants, and what steps have been taken to reduce exposures. Examine a random sample of records and interview personnel to determine what has been done to reduce exposures.
c.
No guidance.
4 d.
No guidance, e.
_ Radiation workers should understand how radiation protection relates to their job and should be tested on this understanding at least-annually, or as otherwise stated in the license application.
Training should be t
sufficient to ensure that workers can correctly answer questions' on radiation protection as it relates to their jobs.
Interview workers-(consistent with the size of the program) to determine'if the workers understand radiation protection as it relates to their jobs and if they have an opportunity to discuss radiation safety with the radiation protection staff.
f.
Inquire if modifications have been made to facilities and equipment to reduce exposures. Randomly examine any procedures or records that' reflect mcdifications and attempt to determine the extent of the benefits gained through modifications (for example, modifications may have been ben.eficial l
if'exposvees of 50 mrems/ hour were reduced by.a factor of 10 to 5 mrems/
hour.
It' mav not be bereficial to reduce 1 mrem / hour to 0.1 mrem / hour, consideri..g ost and risk. In both of the above examples, consider ation L
must be given to costs of modification and risk to the population).
g.
Examine Radiation Safety Committee records or other records on ALARA l policies to determine whether source-term surveys have been conducted and actions taken to reduce significant exposures.
h.
No guidance.
L l
i.
Examine equipment and supplies to determine if they adequately protect l'
personnel. from unnecessary radiation.
Such equipment and supplies may include, but are not limited to, decontamination supplies, survey meters, protective.. clothing, ventilation systems, air. sampling equipment, and l
supplies:used for posting areas, such as radiation areas.
i END Issue Date:
03/07/94 83822 o
... - ~
r l
4 ME!MORANDUM TO: Donald A. Cool, Director l
Division of Industrial and Medical Nuclear Safety, NMSS FROM:'
John T. Greeves, Director Division of Waste Management, NMSS
SUBJECT:
REVIEW OF INSPECTION PROCEDURE 84900 I
f DWM provided informal comments on IMNS Inspection Procedure 7900 per request from S.
Sherbini. IMNS transmitted a comment resolution package withjhe revised procedure to DWM
' for review and concurrence. We have reviewed your responspfo our comment on the need to identify the regulatory requirements for the inspection criterja in the procedure. Your comment response indicates that the applicable regulations for thipspection "...are the usual radiation protection regulations that are applicable to any radia n protection situation..." and therefore, there is no need to identify them in the procedure.
believe that identification of the regulatory requirements would improve the pro re and assure that inspections are conducted in a consistent manner.
Inspection Procedure 84900, Section 84
-02, " Inspection Requirements," contains
' subsections 02.01-Management Contro and Surveys,02.02-Adequacy of Storage Area, and 02.03-Package Integrity and Labeling e believe the appropriate requirements from Part 20
= and Part 61 should be explicitly ide fied in these sections'. For example, see Section 83822-02 in the attached Inspection Pro dure 83822. Our comment was discussed with S. Sherbini on Friday June 20,1997.
Attachment:
As stated CONTACT:
John Buc y, NMSS/DWM 415-6607 TICKET:97498 DISTRIBUTION:
Cen al File DWM r/f-t/f MVFederline NMSS r/f LLDP r/f PUBL Br,,i
- DOCUMENTNAMEJ.dwm\\lldp\\jtb\\IMNS. TIC 78 0FC DWM M DWM Nh DWK[
h D9hk f
JBuche[
LBell JHhey kves NAME j
i e
DATE 7/l/97 7///97 7/[/97 7/c1/97
/ /
0FFICIAL RECORD COPY j
LSS : YES N0 X
l ACNW: YES NO X
IG YES NO X
Delete file 'after distribution:
Yes X No PDR YES X
N0 l
l.
.