ML20153E967
| ML20153E967 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/1998 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20153E911 | List: |
| References | |
| NUDOCS 9809280306 | |
| Download: ML20153E967 (28) | |
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INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM FOLLOW-UP REVIEW OF NEW MEXICO AGREEMENT STATE PROGRAM JULY 7-10,1998 PROPOSED FINAL P.EPORT I l
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U. S. Nuclear Regulatory Commission l
l ATTACHMENT 1 9009290306 990900 ,
PDR STPROESy
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i L New Mexico Proposed Final Report - Page 1 i
1.0 INTRODUCTION
l l This report presents the results of the follow-up review of the New Mexico radiation control program conducted July 7-10,1998. The follow-up review was conducted by a review team l I - comprised of technical staff members from the Nuclear Regulatory Commission (NRC). Team i members are identified in Appendix A. The follow-up review was conducted in accordance with l the " Policy Statement on Adequacy and Compatibility of Agreement State Programs," published in the Federal Reaister on September 3,1997 (62 FR 46517), and the November 25,1997, NRC Management Directive 5.6, " Integrated Materials Performance Eva.uation Program (IMPEP)." The follow-up review covered the State's response to, and resolution of,29 i recommendations and suggestions made during the July 14-18,1997 IMPEP review. The
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follow-up review covered the status of the program since the 1997 review. Preliminary results l were discussed with New Mexico management on July 10,1998.
[A paragraph on the results of the Management Review Board (MRB) meeting will be included here in the final report.]
The New Mexico Environment Department is the agency within the State of New Mexico that regulates, among other public health issues, radiation hazards. The New M'exico Environment Department Secretary is appointed by and reports to the Governor. Within the Environment l Department, the radiation control program is administered by the Radiation Licensing and
,- Registration Program (RLRP) under the direction of the Hazardous and Radioactive Materials Bureau (HRMB). The New Mexico Environment Department and HRMB organization charts are j included as Appendix B. The New Mexico program regulates approximately 245 specific l
licenses, including a megacurie pool irradiator, manufacturers, broad academic programs, ,
! broad medical programs, nuclear pharmacies and industrial radiographers. I The primary intent of this follow-up review was to close out programmatic deficiencies identified during the 1997 IMPEP review. Although not specifically evaluated during this review, the team observed other evaluation criteria, under the various indicators, to ensure those portions of the radiation control program remained adequate since the last review.
l The review team's general approach for conduct of the follow-up review included:
l (1) evaluation of the State's implementation of their program improvement plan that was accepted by the MRB at the October 23 and December 11,1997 MRB meetings; (2) the status of the program during the period of July 19,1997 - July 10,1998; (3) review of the status of applicable New Mexico statutes and regulations; (4) review of quantitative information from the l radiation control program licensing and inspection database; (5) technical review of selected l inspection, licensing and incident response program documentation for response to issues identified during the previous review; and (6) interviews with staff and management to answer questions or clarify issues. The team evaluated the information that it gathered against the
' lMPEP performance criteria for each common and non-common performance indicator and l made a preliminary assessment of the radiation control program's performance. !
2.0 STATUS OF PREVIOUS REVIEW i
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! The previous routine IMPEP review, conducted on July 14-18,1997, resulted in a finding for
- New Mexico that the radiation control program was " adequate to protect public health and i
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t New Mexico Proposed Final Report Page 2 safety but needs improvement, and compatible with NRC's program " Due to the significance and number of deficiencies found in the New Mexico program, which included a finding of unsatisfactory in one performance indicator, the review team recommended a period of probation for a duration to be established after consultation with the New Mexico radiation control program management.
The MRB met on October 23,1997 to consider the proposed fint' report. At the time of the review, the IMPEP team found the State's performance to be satmiactory for the indicators, Technical Quality of Licensing Actions and Legislation and Regulations Required for Compatibility; satisfactory with recommendations for improvements for the indicators, Status of Materials Inspection Program, Technical Quality of Inspections, and Technical Staffing and Training; and unsatisfactory for the indicator, Response to incidents and Allegations. The review team recommended that the New Mexico program be found adequate, but needs improvement, and compatible. Because of the significance of the concerns, the team also recommended that New Mexico be placed on probation and noted that heightened oversight was warranted. During the MRB meeting, three main issues were identified that New Mexico should address in terms of programmatic improvements: (1) level of program staff and amount of resource support; (2) technical quality of staff and training needs; and (3) level of management support, involvement, and oversight of New Mexico Agreement program activities.
The MRB found the New Mexico program adequate, but needs improvement, and compatible with the NRC's program. The MRB concluded that it would be appropriate for NRC management to meet with upper management of the New Mexico program before the MRB voted on the recommendation for probation status for the program.
On December 4,1997, Hugh L. Thompson, Jr., NRC Deputy Executive Director for Regulatory Programs and other NRC managers met with Secretary Mark Weidler, New Mexico Environment Department and his staff to discuss performance concerns associated with the New Mexico Agreement program. l l
On December 11,1997, the MRB reconvened to discuss probation for the New Mexico program. Based on the New Mexico actions at the time of the meeting, and the commitments by Secretary Weidler, the MRB concluded probation was not warranted. Based on implementation of new procedures for response to incidents, the MRB directed the team to revise the finding for the common performance indicator, Response to incidents and Allegations, to satisfactory with recommendations for improvement. The MRB directed that the follow-up review be conducted within one year of the IMPEP review, that monthly conference calls take place with New Mexico staff, and requested that written progress reports be submitted by the State every other month.
Monthly telephone conference calls, and one meeting at the Conference of Radiation Control Program Directors annual meeting, were held with New Mexico management and staff. The calls were effective in maintaining communication between NRC and New Mexico during the period of heightened oversight.
Three bi-monthly progress reports were submitted by New Mexico on January 21, March 27 and May 29,1998. The reports chronicled the progress made by the State on the 29 recommendations and suggestions made during the 1997 review, including the hiring of two staff, response to incidents, and improvements made to the inspection program. The progress reports may be found in Appendix C.
New Mexico Proposed Final Report Page 3 Results of the follow-up review of the State's response and resolution of the 29
' recommendations and suggestions encompassing the IMPEP common and non-common -
performance indicators are presented in Sections 3 and 4, respectively. Section 5 summarizes the review team's findings and recommendations during the follow-up review.
3.0 COMMON PERFORMANCE INDICATORS l
The IMPEP process uses five common performance indicators in reviewing both NRC Regior i and Agreement State programs. These indicators are: (1) Status of Materials inspection l . Program; (2) Technical Quality of Inspections; (3) Technical Staffing and Training; (4) Technical Quality of Licensing Actions; and (5) Response to incidents and Allegations.
L 3.1 Status of Pendina lssues identified under " Status of Materials Inspection Procram" l ..
! The review team focused on the four recommendations from the July 1997 IMPEP review.
Each recommendation and its current status is addressed below. New Mexico's performance, l with respect to this indicator, Status of Materials inspection Program, was found to be l satisfactory with recommendations for improvement during the 1997 review.
! Recommendation The review team recommends that the nuclear pharmacy inspection frequency be
. modified from 2 years to 1 year.
Current Status i
i The State indicated, in its October 10,1997 response to the draft review report, that the two-l year inspection frequency for nuclear pharmacies was based on an out-dated copy of Inspection Manual Chapter (IMC) 2800 " Materials inspection Program," which was believed to l be current. . The frequency was changed to 1 year immediately after identification by the team i
during the 1997 IMPEP review. IMCs are now centralized in a file maintained by a technical staff person. The review team verified that the State now inspects nuclear pharmacies on a one-year inspection frequency. The staff also has access to the NRC inspection manual via the l NRC's website. All of New Mexico's inspection frequencies are now at least as frequent as L NRC's.
Based on the follow-up review, the team considers this recommendation to be closed.
i 1- Recommendation l
The review team recommends that initial inspections of licensees be performed within 6 months of license issuance or within 6 months of the licensee's receipt of material and commencement of operations, consistent with IMC 2800.
L Current Status
[ The review team evaluated the timing of initial inspections for six now licenses issued during the
- review period. All six were inspected within 6 months of issuance. The Program Manager
New Mexico Proposed Final Report Page 4 maintains a tickler file for all new licenses issued by the Program. He p?rsonally calls licensees at two-month intervals to determine if radioactive material has been received. If so, he schedules an inspection. If the licensee has not yet received licensed material, he updates the
' telephone log in the inspection file and schedules another call in 2 months. The Program .
Manager stated that, if licensed material was not received within 1 year, he would schedule an inspection regardless. This situation has not been encountered to date. Additionally, a standard license condition is added to new licenses instructing licensees to notify the Program within 10 days after receipt of radioactive material.
Based on the follow-up review, the team considers this recommendation to be closed Recommendation i The review team recommends that the tracking system be revised to allow initial inspections to be readily identified to staff and management.
Current Status As discussed in the previous recommendation, the Program Manager tracks, in a hard copy tickler file, all new licenses issued. The Bureau Chief, who signs all new licenses, has also )
- established a hard copy file in his office to track new license inspections. Both tracking files were observed during the follow-up review. ' The computer database has been completely ;
revamped using a Microsoft Access-based program. Monthly reports are generated for Program managers to alert them of inspections which are due, including initial inspections.
Since licenses are produced on the same database, the issuance dates on licenses are used to generate the inspection due date reports.
Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State increase the number of reciprocity )
, inspections to better evaluate the health and safety implications of out-of-state I campanies working in New Mexico.
Current Status Reciprocity inspections are now a priority for the New Mexico program. Since the review, greater than 75 percent of Priority 1 and approximately 50 percent of Priority 2 and 3 reciprocity I licensees were inspected by the program. (Note: All New Mexico licensees are categorized as Priority 1,2 or 3). In most cases the reciprocity inspections were unannounced. A log is maintained of all reciprocity requests with the date of inspection and the inspector's name or, if l
. an inspection was not performed, the reason for the missed opportunity. l t Some of the reciprocity inspections resulted in violations identified, including one out-of-state !
radiographer, where the New Mexico inspector identified significant health and safety concerns l
- resulting from poor radiation safety practices by the licensee. New Mexico informed the '
) Agreement State, which licenses the radiographer, of the violations identified during the l- reciprocity inspection.
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New Mexico Proposed Final Report Page 5 Based on the follow-up review, the tearn considers this recommendation to be closed.
The primary intent of this follow-up review was to close out programmatic deficiencies identified during the 1997 IMPEP review. Although not specifically evaluated during this review, the team observed that other evaluation criteria, under this indicator, which were identified as satisfacton/ ,
during the last review remained adequate and did not show deterioration. These areas include '
inspection backlog and inspection repcrt timeliness.
Based on the team's findings during the follow-up review and the IMPEP evaluation criteria, the review team recommends that New Mexico's performance with respect to the indicator, Status of Materials inspection Program, be upgraded to a finding of satisfactory.
3.2 Status of Pendina issues identified under " Technical Quality of Inspections" The review team focused on the seven recommendations and four suggestions from the 1997 .
IMPEP review. New Mexico's performance with respect to the indicator, Technical Quality of '
Inspections, was found to be satisfactory with recommendations for improvement during the l 1997 review.
The review team evaluated casework for 12 inspections, including the following types of licenses: well logging, industrial radiography, medical, portable gauge, research and development, and nuclear pharmacy. There were no inspections of broad scope licensees ,
during the review period. !
Recommendation i The review team recommends that the State inspectors attempt to observe licensee
- operations or demonstrations during all inspections.
Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that Program management has begun more frequent accompaniments of inspection staff and will continue doing so as new staff are hired. The " Standard Operating Procedures Manual for License Inspections" has been revised and a copy has been given to each staff member. The importance of performance-based inspections has been discussed at staff meetings and inspection forms have been finalized to reflect performance-based inspections. With the relocation of all but one inspector to a centralized location in Santa Fe, the Program Manager will now be able to discuss inspections with inspectors and more readily determine what was found during inspections and what additional areas need to be addressed The inspector located in the Albuquerque office brings all inspection reports to Santa Fe at least weekly to discuss findings with the Program Manager as inspections are accomplished.
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The review team verified that inspectors are now observing licensee activities during inspections and documenting such observations in the inspection report. The inspection report forms have been revised to include a section to document observation of activities, and list various activities to observe. The team also verified during staff interviews that all inspectors
! have copies of the " Standard Operating Procedures Manual for License Inspections" and have i been instructed in all aspects of the manual.
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I New Mexico Proposed Final Report Page 6 Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State inspectors conduct independent measurements on all inspections.
Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that the staff has been advised of the importance of performing independent measurements during all inspections.
The review team found that independent measurements were routinely performed by the inspectors, and when independent measurements were not performed, inspectors provided an acceptable explanation in the inspection reports. The team verified, during staff interviews, that each inspector was aware of the importance of performing independent measurements as a part of the licensee evaluation process. The location of the independent measurements appeared appropriate for the type of licensed program.
Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State increase the rigor of reviewing technical l health physics issues during inspections, and increase the breadth and scope of inspections.
' Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that the inspection report forms and inspection guidance documents have been revised to reflect the importance of in-depth inspections. Weekly staff meetings are used to discuss the revised forms and guidance documents.
The review team found that the depth and scope of technical health physics reviews have improved since the last review. The inspectors evaluated programs in more detail, reviewing applicable technical issues related to the type of program, including such areas as surveys,
-' storage and shielding of radioactive material security
, , and dosimetry Staffinterviews ide
. n tifi ed that all inspectors have increased the technical rigor of their inspections. Training received by the staff since the last review has resulted in a greater knowledge of licensee operations, resulting in more in-depth inspections. The inspection reports have also been revised to include more technical health physics issues.
Based on the follow-up review, the team considers this recommendation to be closed.
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New Mexico Proposed Final Report Page 7 Suaaestion The review team suggests that the State inspectors attempt to interview ancillary workers during inspections. l Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that staff have been reminded of the importance of interviewing ancillary workers during inspections. ;
The staff was provided training in the regulations which pertain to consultation with workers during inspections. I The review team verified, during staff interviews, that all of the New Mexico inspectors routinely attempted to interview ancillary personnel during inspections. In some cases, this was not possible as the inspection was at a field site or was a reciprocity inspection, where no encillary personnel were present. There were two inspection reports of medical facilities where interviews of ancillary personnel or a nurse were not documented, however, the inspectors indicated that they had interviewed these personnel. The Program Manager stated that he would encourage staff to ensure that all such discussions are documented in the inspection report.
Based on the follow-up review, the review team notes the actions taken by the State in response to this suggestion, and considers this suggestion to be closed.
Recommendation The review team recommends that the State inspectors attempt to conduct formal exit meetings with the senior licensee management on all inspections.
Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that the inspection forms and inspection guidance documents now indicate that the closeout conference should be held with the licensee's highest level of licensee management available and that inspectors should s; ways contact upper management upon entering a facility. This issue has also been discussed at staff meetings.
The review team found that the inspection forms now include a section to note those present at the exit meeting or who was contacted. The review team found that inspectors were regularly exiting with a high level of licensee management. If licensee management officials were not available during an inspection, attempts were made to follow up with them after the inspection.
Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State develop a formal process for reviewing licensee responses to deficiency letters and closing open deficiencies.
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l New Mexico Proposed Final Report Page 8 l I
l Current Status l
New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that all l responses will be tracked using a tickler file; the Program Manager and the Bureau Chief will i
sign off on the adequacy of licensee responses; and requests for additional information are now made in writing, with copies of all correspondence placed in license folders. l l 1
! The review team found that staff have been made aware of the tickler file and the process for I using the file. The inspection files contained complete documentation for follow up of violations, with the exception of one file, which was corrected during the review Program management signs off on the adequacy of alllicensee responses. The system appears adequate to evaluate and track licensee responses.
Based on the follow-up review, the team considers this recommendation to be closed.
Suaaestion The review team suggests that the State develop a formal process for inspectors and license reviewers to document and transmit pertinent information to each other for follow up.
Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that weekly staff meetings are held to discuss the previous week's activities. Any need for documentation is satisfied in writing.
The review team found that the inspection forms include a section entitled " License Reviewer Alert Memo," which is used to address any licensing issues. Only one of the files reviewed raised issues requiring the use of this system. In this case, the system worked very wellin communicating an inspection-identified issue to the license reviewer. A memorandum in the file thoroughly documented the licensing issue and the licensing action was completed appropriately.
Based on the follow-up review, the review team notes the actions taken by the State in response to this suggestion, and considers this suggestion to be closed.
Suaaestion The review team suggests that the State develop a process for ensuring that inspection files are complete, that all appropriate State documents are prepared and filed, and that licensee responses are received and filed.
Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that each inspector will be held responsible for ensuring that all inspection files assigned to him or her are complete and that responses to letters of violation are received in a timely manner. The Program Manager and the Bureau Chief now approve the adequacy of licensee responses.
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. l' New Mexico Proposed Final Report Page 9 l~
' Letters in reply to licensee responses are signed by the Program Manager. The Program Manager is reviewing license files each time a " circle of correspondence" is completed pertaining to licensing actions, inspections, or incidents.
- The review team found that inspection files were complete, with the exception of one file, which was corrected during the review (as discussed in a previous recommendation above). ;
Inspection reports, deficiency letters, and responses to deficiency letters were found, '
appropriately filed, in the license file.
Based on the follow-up review, the review team notes the actions taken by the State in response to this suggestion, and considers this suggestion to be closed.
i Recommendation The review team recommends that the State begin documenting all trips to licensees' or
! applicants' facilities when inspecting licensed activities, performing special inspections, j or performing pre-licensing site visits during construction.
l Current Status L New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that this
! issue has been discussed with all staff. All information gained through trips to licensed facilities L is now documented via memoranda to file, which are signed by the Program Manager.
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The review team found that this recommendation has been implemented. Since the last review, there was only one case of a special inspection involving the addition of a new site to a license.
l The inspection was documented in the license file. Additionally, the State instituted a telephone
- l. log for each license file as needed to document communications with the licensee.
l Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State management exercise more stringent supervisory review of inspection reports.
i l Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that by relocating all but one of the inspectors to the central office in Santa Fe, inspection reports are no longer being allowed to accumulate without management review in the Albuquerque office.
The Program Manager and Bureau Chief are reviewing licensee responses to cited violations for adequacy and are signing off on reviews. The Program Manager is signing off on all
- documents entered in the files.
- The review team found that inspection reports were generally signed by management and that
, deficiency letters were signed by the Bureau Chief. Of the 12 inspection reports evaluated, two i did not appear to have been reviewed by management. Both were inspections in which no S
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New Mexico Proposed Final Report Page 10 violations were identified and both were conducted by the inspector in the Albuquerque office.
The Program Manager stated that some communication problems still existed between the Santa Fe and Albuquerque offices. The Bureau Chief stated that the Department is planning to close the Albuquerque office and consolidate the staff into the Santa Fe office, which should eliminate communication difficulties.
Interviews with the Bureau Chief and Program Manageridentified an awareness of the content of inspection reports. The managers provided feedback to the inspectors to improve the inspection reports and to instill a health and safety focus, This increased management involvement in the inspection process resulted in more performance-based inspections.
Based on the follow-up review, the team considers this recommendation to be closed.
Suoaestion The review team suggests that the State complete its revision of the inspection report forms, insuring that each set of forms covers all key areas for the type of licensee being inspected, and that RLRP inspectors begin using the standardized form (s).
Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that all inspection report forms were being finalized and distributed to the staff. Staff have been advised as to how inspection forms are to be completed during staff training meetings.
The review team found that the State has updated and revised the inspection forms.
Specifically, the following forms have been implemented:
- General Inspection Report Form, dated June 1998; Industrial Radiographer inspection Report Form, dated September 1997;
- Medical Inspection Report Form, Revision 2, dated January 1998; and
- Density Moisture Gauge inspection Report Form, dated October 1997.
The review team noted that the general inspection report form was used for two nuclear pharmacy inspections as the State does not yet have a specific nuclear pharmacy inspection form. In one case, the inspection report did not document certain technical areas, such as dose calibrator calibrations. The review team showed the staff how to download NRC's inspection field notes from the Internet for their use, as needed.
Based on the follow-up review, the review team notes the actions taken by the State in response to this suggestion, and considers this suggestion to be closed.
The primary intent of this follow-up review was to close out programmauc deficiencies identified during the 1997 IMPEP review. Although not specifically evaluated during this review, the team observed that other evaluation criteria, under this indicator, which were identified as satisfactory during the last review remained adequate and did not show deterioration. These areas include supervisory accompaniments of inspectors and appropriate regulatory actions resulting from inspection findings.
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! New Mexico Proposed Final Report Page 11 Based on the team's findings during the follow-up review and the IMPEP evaluation criteria, the review team recommends that New Mexico's performance with respect to the indicator, Technical Quality of Inspections, be upgraded to a finding of satisfactory.
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Status of Pendina issues identified under " Technical Staffina and Trainina" The review team focused on the three recommendations from the 1997 IMPEP review. New l' Mexico's performance with respect to the indicator, Technical Staffing and Training, was found to be satisfactory with recommendations for improvement during the 1997 review, Recommendation l
The review team recommends that the State maintain the RLRP staffing level to at least '
the level which existed throughout the review period.
Current Status ,
l During the 1997 review exit meeting, Secretary Weidler committed to fill the two vacant Environmental Specialist positions in the radiation control program. Effective February 16, 1998, the positions were filled by Stanley Fitch and Mark Garcia, both with health physics i
experience. The program is now fully staffed. '
New Mexico program management acknowledged, during the 1998 follow-up review, the need to maintain the radiation control program staffing level to at least the current level.
- Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State provide training to technical personnel in the areas of medical brachytherapy and irradiator technology.
Current Status in October 1997, a one-day brachytherapy training course was presented to staff by the University of New Mexico Cancer Treatment Center. Refresher training is planned annually at the University. In June 1998, a nuclear medicine / brachytherapy safety training course was received from ProTechnics, a consultant. Staff indicated that both training courses were beneficial.
The NRC-sponsored Teletherapy and Brachytherapy course (H-313) is part of New Mexico's core training program. The Program Manager intends to have staff attend this one-week course or an equally comprehensive alternative training course.
l- In June 1998, ProTechnics also provided a one-day training course on irradiator safety to the New Mexico staff. The training was coordinated with a visit to the Ethicon EndoSurgery pool I
irradiator in Albuquerque. Staff will also attend a Nordion irradiator training course at Ethicon in Autumn 1998.
New Mexico Pmposed Final Report Page 12 The Program Manager plans to send one or two stan members to the NRC-sponsored irradiator Technology course (H-315), if training funds are received.
Discussions with inspection and licensing staff, during the follow-up review, indicated an increase in knowledge and comprehension in brachytherapy and irradiator technologies.
On April 15,1998, the New Mexico Environment Department formally petitioned the NRC for funding assistance in the pursuit of training. NRC responded to the request, in a June 11,1998 letter to Secretary Weidler, asking for additionalinformation in support of the request. This issue is pending.
Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State develop a formalized training program comparable to IMC 1246, " Formal Qualification Programs in the Nuclear Material Safety and Safeguards Program Area."
Current Status The State developed a " Radiation Protection Licensirig and Inspection Training Procedure."
The procedure provides a formal qualification protocol for inspectors and license reviewers.
The procedure is modeled after IMC 1246 and specifies core and specialized training courses, requires oral qualification boards, and provides a qualification joumal to each inspector and license reviewer. Version 1 was approved by the Program Manager on July 6,1998.
The team verified during interviews that all staff have been given copies of the procedure and their own qualification journals. The two new staff members, hired in February 1998, are presently in training status and are not yet performing independent inspections or license reviews.
Based on the follow-up review, the team considers this recommendation to be closed.
The primary intent of this follow-up review was to close out programmatic deficiencies identified during the 1997 IMPEP review. Although not specifically evaluated during this review, the team observed that other evaluation criteria, under this indie 'or, which were identified as satisfactory during the last review remained adequate and did no; " deterioration.
Based on the team's findings during the follow-up review and the IMPEP evaluation criteria, the review team recommends that New Mexico's performance with respect to the indicator, Technical Staffing and Training, be upgraded to a finding of satisfactory.
3.4 Status of Pendino Issues identified under" Technical Quality of Licensina Actions" The review team focused on the one suggestion from the 1997 IMPEP review. New Mexico's i performance with respect to the indicator, Technical Quality of Licensing Actions, was found to l be satisfactory during the 1997 review.
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.New Mexico Proposed Final Report .Page 13 The team evaluated casework for 10 licenses, including the following types: pool irradiator, well logging, medical institution, broad scope academic, research and development, industrial
- radiography, source manufacturer, and nuclear pharmacy.
Suaoestion The review team suggests that documentation of license reviewers' actions be maintained in license files.
Current Status f
The State responded in its monthly progress report, dated January 21,1998, that several of the - j i' documents that appeared to be missing from the files, were, in fact, present in the Albuquerque i office. Since the IMPEP review, all files have been returned to the centralized office in Santa l
Fe. The importance of documentation for every action taken by staff has been discussed with 1 the staff. A telephone log is being used to document any conversations with licensees
. Additionally, all requests for additional material from licensees will be in writing.
Documentation of license reviewers' actions has improved since the last review. Telephone !
logs are used to document conversations with licensees. Deficiency letters are used to request l additional information from licensees. Additionally, license application evaluation forms are '
used to review applications and complicated amendments. The evaluation form includes the
.l criteria, any comments by the license reviewer, and what is needed, either from the licensee or l in the license, as part of the amendment or application. '
Based on the follow-up review, the review team notes the actions taken by the State in ;
response to this suggestion, and considers this suggestion to be closed. I I
Based on the team's findings during the follow-up review and the IMPEP evaluation criteria, the review team recommends that New Mexico's performance with respect to the indicator, Technical Quality of Licensing Actions, remain as satisfactory.
3.5 Status of Pendina Issues identified under " Response to incidents and Alleaations" The review team focused on the six recomrnendations and two suggestions from the 1997 ;
IMPEP review. New Mexico's performance with respect;o the indicator, Response to incidents and Allegations, was found to be satisfactory with recommenactions for improvement during the 1997 review.
The team evaluated seven factors pertinent to this indicator: responsiveness, investigative procedures, documentation, corrective actions, follow up, compliance, and notifications. To evaluate the indicator, the team interviewed program management and staff, evaluated the casework for the 10 incidents that occurred since the 1997 IMPEP review, and evaluated the State's response to the 1997 IMPEP review.
During the 1997 review, the team found frequent examples of incomplete, inappropriate, poorly documented, or delayed responses to incidents, including cases which had the potential to result in health and safety problems. Therefore, at the time of the review, based on the IMPEP evaluation criteria, the review team recommended that New Mexico's performance with respect
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New Mexico Proposed Final Report Page 14 to the indicator, Response to incidents and Allegations, be found unsatisfactory. With their October 10,1997, response to the draft report, the State furnished copies of new incident response procedures that appeared adequate to address the concerns. During the December 11,1997, MRB meeting, it was noted that New Mexico had successfully implemented the new procedures. Based on the implementation of the new procedures, the MRB directed the finding to be revised to satisfactory with recommendations for improvement.
Recommendation The review team recommends that the State make on-site, documented investigations of incidents, allegations, or misadministrations with potential health and safety effects (i.e., source disconnects, possible overexposures, lost sources, contamination, etc.).
Current Status The State's new procedures offer specific guidance on determining the need for on-site investigations. Evaluation of the casework showed that on-site investigations were indicated in four of the ten incidents. In each case, the State responded promptly and appropriately. The incidents were well documented, followed up, and closed out with signed and dated notations of management review.
Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State create an incident and allegation reporting form that would, at a minimum, identify the person taking the initial report, list the name and telephone number of the reporting party, provide the details of the incident or allegation as reported, record the State's conversation with the licensee or individual, describe corrective actions taken by the licensee, describe the investigation conducted by the State and the results, list citations or other regulatory actions, show the date the investigation was closed out and justification for closure, show date(s) incident was reported to the NRC or other agencies, and provide spaces for the signatures of the investigator and supervisor. A copy of the form should be maintained in the incident file and in the license file.
Current Status in the response letter dated October 10,1997, the State furnished a newly designed form,
" Incident Report for Radioactive Material Licensees," to the NRC for review. Examination of the form showed that it meets the criteria specified in the recommendation. During the evaluation of casework, fV team found that the form is being properly used by the investigators and that copies were appropriately filed in the incident chronological file as well as the licensee's file.
Based on the follow-up review, the team considers this recommendation to be closed.
New Mexico Proposed Final Report Page 15 Recommendation The review team recommends that the State establish a protocol for making independent investigations and evaluations of the licensee's actions.
Current Status The protocol for making independent investigations and evaluations of the licensee's actions was provided to the NRC in New Mexico's letter dated October 10,1997. Appropriate incident investigations and evaluations of licensee's actions were performed for all of the incidents reviewed.
Based on the follow-up review, the team considers this recommendation to be closed.
Recommendation The review team recommends that the State initiate procedures to ensure incidents are followed up at the next inspection to verify that the licensee's corrective actions have been implemented.
Current Status A section entitled, " Incidents / Reports" has been added to the inspection forms to ensure that inspectors review events that may have occurred since the last inspection of the licensee. Of the 21 incidents reviewed during the 1997 and 1998 reviews, the team identified eight licensees which had subsequent inspections. Although one was missed early in the review period, seven had been followed up appropriately.
Based on the follow-up review, the team considers this recommendation to be closed.
Succestion The review team suggests that when evaluating incidents, the State cite appropriate deficiencies when app?icable.
Current Status in their October 10, '1997, response to the NRC, the State committed to sending deficiency letters or citations when indicated. Of the incidents which occurred since the last review, citations were appropriate for only one incident. That incident investigation was in process at the time of this review, and a Notice of Violation had not yet been sent, but was planned for the near future. The Program Manager stated that formal Notices of Violation would be issued for deficiencies, found during incident investigations as is done in the routine inspection program.
Based on the follow-up review, the review team notes the actions taken by the State in response to this suggestion, and considers this suggestion to be closed.
)
1 New Mexico Proposed Final Report Page 16 Recommendation l
The review team recommends that the State: (a) set up a separate incident and allegation file system in the Santa Fe office, keeping all documents and records '
pertaining to an incident in one location, with the data cross-referenced to the t license / inspection files there and in the Albuquerque office, and (b) establish a system I to centrally log and track the progress of incidents and allegations.
1 Current Status The team found that the incident and allegation file system has been moved to the Santa Fe office. Copies will be kept in the Albuquerque files until that office is closed. The team verified that documents are cross-referenced to licensee files in both offices. A new computer system I has been estab!ished to log and track the progress of incidents and allegations. The staff was able to successfully demonstrate the system by sorting and printing the information as requested by the team. The team also compared the printed list with the incidents reported for New Mexico in the " Nuclear Materials Events Database (NMED)" and found that they agreed.
Based on the follow-up review, the team considers this recommendation to be closed.
FJ&9mmendation The review team recommends that the State develop and implement written procedures for responding to events involving radioactive material and conduct training sessions until all technical staff are fully trained and qualified in emergency response.
Current Status Three newly developed procedures: " Standard Operating Procedure for Response to incidents involving Radioactive Materials,"
- Incident Investigation Procedures," and " Incident Reporting System / Abnormal Occurrence Criteria" were found adequate by the NRC after they were included with the October 10,1997, letter from the State. The team verified that the procedures were being followed by the investigators. The team also verified during staff interviews that all responders had been given copies of the procedures and that they had been instructed in j emergency response during weekly meetings and discussions that take place after each event.
Based on the follow-up review, the team considers this recommendation to be closed.
Suoaestion The review team suggests that the State keep expanding the allegation procedures to include procedures for notifying the person making the allegation of the results of the investigation and including the allegation procedures in the event reporting form, tracking system, and emergency response procedures.
l l
m _ _ . _ . _ . _ - _._ _.._ ___ _ _ . _ _ . _. _ _ _ _ _ _ _ .
i ,
New Mexico Proposed Final Report Page 17 Current Status The team found that the State's allegation procedures have been completely rewritten. There ,
l are provisions for notifying the person making the allegation of the results of the investigation. I l The procedures have been changed to include allegations in the event tracking system and emergency response procedures.
l Based on the follow-up review, the review team notes the actions taken by the State in l response to this suggestion, and considers this suggestion to be closed.
The primary intent of this follow-up review was to close out programmatic deficiencies identified during the 1997 IMPEP review. Although not specifically evaluated during this review, the team observed that other evaluation criteria, under this indicator, which were identified as satisfactory during the last review remained adequate and did not show deterioration. These areas include notifications of incidents to NRC and other Agreement States.
Based on the team's findings during the follow-up review and the IMPEP evaluation criteria, the review team recommends that New Mexico's performance with respect to the indicator, Response to Incidents and Allegations, be upgraded to a finding of satisfactory.
4.0 NON-COMMON PERFORMANCE INDICATORS The team reviewed one non-common performance indicator that applied to the New Mexico l program, Legislation and Program Elements Required for Compatibility 4.1 Status of Pendina Issues identified under"Leaislation and Proaram Elements Reauired for Compatibility" The review team focused on the one recommendation and one suggestion from the 1997 IMPEP review. New Mexico's performance with respect to the indicator, Legislation and Program Elements Required for Compatibility, was found to be satisfactory during the 1997 review.
Recommendation The review team recommends that the State expedite promulgation of the compatibility-related regulations now overdue and those which are due within the next 12 months.
Current Status The overdue compatibility regulations and those due through May 16,1999, are in the process of being adopted. Drafts of the 11 regulations listed below were sent to the NRC for review on June 15,1998, and the State was awaiting the results of that review at the time of the follow-up IMPEP review. The State missed their projected adoption date for these regulations of June 1998 and have extended it to October 1998.
" Decommissioning Recordkeeping and License Termination: Documentation Additions,"
l 10 CFR Parts 30,40,70, and 72 amendments (58 FR 39628) that became effective on
. I
- i. New Mexico Proposed Final Report Page 18 October 25,1993, and became due on October 25,1996.
"Self-Guarantee as an Additional Financial Mechanism," 10 CFR Parts 30,40, and 70 amendments (58 FR 68726 and 59 FR 1618) that became effective on i January 28,1994, and became due on January 28,1997.
" Timeliness in Decommissioning of Materials Facilities," 10 CFR Parts 30,40, and 70 amendments (59 FR 36026) that became effective on August 15,1994, and became due on August 15,1997.
" Preparation, Transfer for Commercial Distribution and Use of Byproduct Material for Medical Use," 10 CFR Parts 30,32 and 35 amendments (59 FR 61767,59 FR 65243, 60 FR 322) that became effective on January 1,1995, and became due on January 1, 1998.
" Low-Level Waste Shipment Manifest Information and Reporting," 10 CFR Parts 20 and 61 amendments (60 FR 15649,60 FR 25983) that became effective March 1,1998, and became due on March 1,1998.
"Frequenca of Medical Examinations for Use of Respiratory Protection Equipment,"
10 CFR Part 20 amendments (60 FR 7900) that became effective on March 13,1995, and became due on March 13,1998. '
" Radiation Protection Requirements: Amended Definitions and Criteria," 10 CFR Parts 19 and 20 amendments (60 FR 36038) that became effective August 14,1995, and which will become due on August 14,1998.
" Medical Administration of Radiation and Radioactive Materials" 10 CFR Parts 20 and 35 amendments (60 FR 48623) that became effective on October 20,1995, and which will become due on October 20,1998.
" Clarification of Decommissioning Funding Requirements," 10 CFR Parts 30,40, and 70 amendments (60 FR 38235) that became effective November 24,1995, and which will become due on November 24,1998.
" Compatibility with the International Atomic Energy Agency," 10 CFR Part 71 amendment (60 FR 50248,61 FR 28724) that became effective April 1,1996, and which will become due on April 1,1999.
" Termination orTransferof Licensed Activities: Recordkeeping Requirements," 10 CFR Parts 20 and 30 amendments (61 FR 24669) that became effective on May 16,1996, and which will become due on May 16,1999.
In addition, the State plans to add the rule, " Licenses for Industrial Radiography and Radiation Safety Requirements of Industrial Radiography Operations," 10 CFR Parts 30 and 34 amendments (62 FR 28947) that became effe' /e on June 27,1997, to the current package.
l This rule covers all previous Part 34 requirements, some of which were apparently overlooked in previous rule changes.-
I L
, . _ - = - . - _ . . _ _~
l:
l .. l
. l New Mexico Proposed Final Report Page 19 it is noted that Management Directive 5.9, Handbook, Part V, paragraph (1)(c)(iii), provides that ;
L the above regulations should be adopted by the State as expeditiously as possible, but not later l l
. than 3 years after the effective date of the new Commission Policy Statement on Adequacy and Compatibility, i.e., September 3, 2000.
4 Until the overdue regulations become effective, the team considers this recommendation to be open.
! Suaoestion The review team suggests that a file be maintained with the cover letters and ensuing correspondence of all draft or final regulations sent to the NRC.
.Ourrent Status The State created a regulation correspondence file to track the progress of the promulgation and review process. In reviewing the file,- however, the team found that a cover letter was not sent for the recent package of regulations presently under NRC review. The State explained that this was apparently an oversight, and that the policy is to maintain cover letters in the regulation file.
Based on the follow-up review, the review team notes the actions taken by the State in response to this suggestion, and considers this suggestion to be closed.
Based on the team's findings during the follow-up review and the IMPEP evaluation criteria, the
- review team recommends that New Mexico's performance with respect to the indicator, Legislation and Program Elements Required for Compatibility, remain as satisfactory.
! 5.0
SUMMARY
The New Mexico radiation control program has made significant strides since the July 1997 IMPEP review. The program is now fully staffed with experienced personnel, training i-deficiencies are being addressed, and program management is providing an appropriate amount of oversight and support.
i The follow-up review team found the State's performance in responding to and resolving 28 of the 29 recommendations and suggestions to be satisfactory. The only remaining open recommendation concems the promulgation of regulations required for compatibility, i
! Funding for the program is still a major issue, especially regarding the training budget.
- f. Secretary Weidler committed to submit a budget request for additional training funding or to pursue a statutory amendment to initiate a licensee fees program with proceeds directed to a dedicated program fund. Requested funding assistance from the NRC is seen as an interim measure until an appropriate course of action is approved by the State legislature.
L i
n
- . . . _ . . - ~ _ - _ _ _ - . - --. . . . . _ _ . - . ..
New Mexico Proposed Final Report Page 20 As discussed earlier in this report, the follow-up review team considers all of the common performance indicator recommendations and suggestions to be closed. Progress has been made on the one non-common performance indicator reviewed (the indicator was found satisfactory during the 1997 review) and compatibility-required regulations should be adopted by October 1998.
The review team recommends to the MRB that for each of the five common performance indicators and the one non-common performance indicator, New Mexico's performance be found satisfactory and that the program as a whole be considered adequate to protect public health and safety and compatible with NRC's regulatory program. The team also recommends that the heightened oversight of the New Mexico radiation control program be discontinued.
Below is the one remaining recommendation which is not considered closed, as mentioned earlier in the report, for consideration by the State.
Recommendation The review team recommends that the State expedite promulgation of the compatibility-related regulations now overdue and those which are due within the next 12 months. (Section 4.1)
s i
l LIST OF APPENDICES Appendix A IMPEP Follow-up Review Team Members
~ Appendix B New Mexico Organizational Charts Appendix C New Mexico Progress Reports, January 1998, March 1998, and May 1998 Attachment 1 Letter dated August 18,1998 from Ed Kelley, Ph.D., Director, Water and Waste Management Division, New Mexico Environment Department i
4 l
l
4 APPENDIX A IMPEP FOLLOW-UP REVIEW TEAM MEMBERS l
Name Areas of Responsibility James Lynch, Rill Team Leader Status of Materials inspection Program J
Technical Staffing and Training Jack Homor, RIV/WCFO Response to incidents and Allegations Legislation and Program Elements Required {
for Compatibility M. Linda McLean, RIV Technical Quality of Inspections Torre Taylor, NMSS Technical Quality of Licensing Actions i
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l APPENDIX B NEW MEXICO ENVIRONMENT DEPARTMENT l
AND HAZARDOUS RADIOACTIVE MATERIALS BUREAU j ORGANIZATION CHARTS
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4 APPENDlX C i.
1 i
NEW MEXICO PROGRESS REPORTS i
i JANUARY 21,1998, j- MARCH 27,1999,
- AND
] MAY 29,1998
)
i 4'l
State ofNewMexico
.? q ENVIRONMENTDEPARTMENT A Hazardous & Radioactive Materials Bureau j, }It'
. 2044 Galistro .-
i xxxxxx '
P.O. Box 26110 s
+ ea- Santa Fe, New Mexico 87502 (505)8271557 -
GARYEJORNSON Fax (505)8271544 saxz. wswun awmamm sacarra r saan r.rmoaxtox.m a u vrrascarra r January 21,1998 r
Richard L.Bangart, Director E
05ce ofState Programs 3o U.S.NuclearRegulatoryCm- uion _ $
i:
Washington, DC 20555-0001 9
Dear Mr.Bangart:
As per Mr. Hugh L. Thompson's request in his letter dated Dewids 30,1997, to New Mexico Environment Secretary Mark E. Weidler, I am submitting the first of the requested bi-monthly progress reports addressing the IMPEP team's suggestions and recommendations.
I appreciate the courtesy and concern expressed by the IMPEP review team and the =mhars of the MRB and thank all of you for the advice and recommendations given to improve the new Mexico Ra&ation Control Program We look forward to working coop.Gvely with the NRC in the future.
Please call me at (505)827-1862 should you have any questions.
Sincerely,
(/)(15E44. (.
- Q William M. Floyd ProgramManager cc- Mark Weidler, Secretary NewMexico Environment Department j~ . Ed Kelley, Director Water and Waste Management Division Benito J. Garcia, Chief Hazardous and Radioactive Materials Bureau 3 .
_ 'f86^#ia% IQ
ACTIONS DOCUMENTATION AND PROCEDURES ADOPTED BY NEW MEXICO RCP TO ADDRESS MRB CONCERNS INTRODUCTION: Belowis a annmary list orsuggestions and recommendations identi5ed by the l IMPEP Review Team as requiring action by the State:
j 1.
De review team recommends that the nuclear pharmacy inspection frequency be modified firom 2 years to 1 year. (Section 3.1) i j Reeps: As Anseh 1 indicates, inspection frequency for nuclear ph.c-edes has been increased from once every 2 years to annuaDy. The two-year inspection frequency being used previously was based on that recommended in out dated copy ofIMC i 2%.
2.
The review team recommends that initial inspections oflicensees be performed within 6 months oflicensee's receipt ofmaterial and commencement of operations, consistent with IMC 2800. (Section 3.1)
, Response:
The Bureau Chief, who signs all newly issued licenses, has established a hard copy file 4
for new licenses in his office and will track new license inspections on a six month
- basis. The RCP Program manager has established a ticider file and will remind inspectors ofinspections coming due during a two month block at least a month in advance The computer database will likewise flag newly issued licenses which need to be WM within six months AdditionaDy, a standard condition has been added to newly-issued Scenses instructing licensee to notify RCP within ten days ofreceipt oflicensed material.
i 1 3. The review team recommends that the tracidag system be revised to allowinitial Wons to be readily identified to staff'and management. (Section 3.1) 4 i
- 4 I-
< 1 I
a
Response
Computer printouts officensees showing inspections coming due will be generated the last week of every month. A copy of this printout will be given to both management and
%_ staff. This has been done for the month of October and January 1998, and will continue to be donethelast week ofeverymonth 4.
The review team r=e -- =
- that the State increase the number ofreciprocity inspections to better evaluate the health and safety knplications of out4f-state companies working in NewMexico. (Section3.1)
. Respnee:
When notification is received of an out-of-state licensee's imamiing entry into the state, the RCP Program Manager will make a copy ofnotification form and forward to individual assigned that geographical area. Every attempt will be made to conduct an unannounced inspection of the reciprocal licensee If unannounced inspections are not possible due to inability to locate licensee, documented phone calls will be made to obtain directions to field site or to coordinate a meeting ber;;aa RCP Staff and reciprocal licensee to allow sav-yanied visit to field site. If staff workload, unavailability of staff or other considerations do not allow for inspections ofreciprocal licensees in Seld locations, the RCP Program Manager wi'l indicate on notification form why inspection were not conducted. Master reciprodty inspection file will be maintained by RCP Progr Manager in Santa Fe. Reciprocal license inspections will be coordinated with routine iner=+ ions of State licensees whenever possible to maximize use ofin-state travel fuartiag Program goal willbe to conduct on-site inspections of a minimum of 50% of all Priority 1 and 2 reciprocal licenses. As of_% 1997, eight redprocity inspections have been accomplished, including seven ofpriority
. I and 2 licensees This amounts to and inspection ratio of 73% ofall reciprocallicensees entering
- the state.
5.
The review team recommends that the State maintain the RCP staffing level to at least the level which existed throughout the review period. (Section 3.2)
I 2
Response: The two Environmental Specialist positions vacated since the IMPEP review were approved for hire and were advertised for applicant interviews. A total of 19 applications have been received. All applicants have submitted resumes and copies ofstate employment applications. We are in the process ofrequesting a re-ranking ofapplicant qualifications from State Personnel to better reflect actualqualifications.
6.
'Ihe review team recommends that the State provide training personnel in the areas ofmedical brachytherapy and irradiator technology. (Section 3.2).
P ===a=: Dr. Tom Kirby, Medical Physicist at the University ofNew Mexico Cancer Treatment Center, provided brachytherapy training to RCP staffon October 14,1997, and will provide refresher training to program staff annually. There are currently brachytherapy programs at four hospitals in the State.
Paul Ripley, RSO at Ethic on EndoSurgery's 5 million curie Co 60 irradiator in Albuquerque, has approved RCP staff attendance at pool irradiator training to be offered by Nordion sometime in January 1998. This training will be updated on an annual basis. There are currently two pool irradiators in the State: the one at Ethic on and a 20,000 curie Co-60 model used for instructional and research purposes at the Univershy ofNew Mexico.
New Mexico RCP staff observed all operations pertaining to production, assaying, packaging and shipping of radiopharmaceutical kits at Syncor Radiopharmacy o ' n November 6,1997.
RCP staff received training in dose cahirator constancy, accuracy, linearity and geometry
- ='=u, as well as the receipt, assay and radiation monitoring ofincoming radiophar-ia=4 at Los Alamos Medical Center on November 19,1997.
7.
The review team recommaale that the State develop a formafi=4 training program comparable to IMC 1246, " Formal Qualification Pruip.us in the Nuclear Material Safety and
. Safeguard Program Area"(Section 3.2) 4 4
3
- a. .
4
Response
t raining program comparable ne State is in the process ofdeveloping a formativad to IMC 1246. De States ofTexas, Colorado and Arizona have been contacted about the possib ofproviding on-hands training to the New Mexico RCP staff.
8.
De raiew team suggests that dommentation oflicense twiewer's actions be maintained in license files. (Section 3.2) l Pma: Several dommar*= verbally identified by the IMPEP review team as being missing fran license files were in fact present in the Albuquerque RCP of5ce. Since the IMPEP raiew, all files have been returned to the centralized Santa Fe RCP of5ce. The importance of documentation for every action taken by staffin respc, nee to licennaae' requests has been di=~saad at RCP staff meetings A telephone log sheet has been inserted at the front ofevery license folder for docum conversations. All requests for additional material from licennaar will henceforth be in writing 9.
The review team recommends that the State inspectors attempt to observe licensee operation or demonstrations during all inspections. (Section 3.4)
Response
Program Management has begun more frequent accompaniments ofjunior staff and will continue doing so as new staff are hired. A total of 15 license inspections have occurred since the IMPEP rwiew where management has accompanied staff. The Standard Operating Procedu Manual for License Inspections has been revised, and a copy has been made available to each staff member. The importance ofperformance-based-inspections has been hasaad at RCP staffme and inspection forms have been finali*ad reflecting performance-based inspections. The lingsta of interviews with workers, independent measuramaa+=, status of prwious violations, and the
=4=ae> of discussions during exit interviews with management are reflected in the newly-revise inspection report forms.
Wah the relocation ofall but one inspector to a centralized location, the Program Manager will n be able to discuss inspections face-to-face with m* spectors and thereby will be able to ascertain what was found during inspections, and what additional material needs to be addressed The one non-4
central ofEce inspector will personally bring all inspection forms to the central of5cc and discuss findings whh the Program Manager as inspections are accomplished.
10.
De review team recommends that the State lawors conduct independent measurements on alliaWons. (Section 3.4)
P v nse: RCP staffhave been advised of the irupcs.sce of taking independent measurements on a!! inspections. The State %rwific Laboratory Division (SLD) is working more closely with the RCP in detrudolag Program needs (Quarterly meetings are now being held t.m SLD and the RCP to determine analytical needs of the RCP and radic-I=c Wy capabilities of SLD). Independent measurements have been made on all iaWons since the IMPEP Review.
11.
De review team recommends that the State increase the rigor of reviewing technical health physics issues during inspections, and increase the breadth and scope ofinspections. (Section 3.4)
Response
laWon forms and Inspection Cddaw De=*s have been revised to reflect the importance ofin-depth inspections. Monthly staff meetings have been initiated and will to discuss revised forms and guidance documents. Minutes ofthese n==:c5 have been kept showing the scope ofthese rii wssions.
12.
The review team suggests that the State inspectors attempt to interview ancillary workers during inspections. (Section 3.4)
Response
RCP staff have been reminded of the importance ofinterviewing ancillary workers during inspection. The provisions of Subpart 10, Section 2005, New Mexico Radiation Protection Regulations, which pertain to consultation with workers during inspections have been discussed during staffmeetings.
5
s
- 13. The review team recommends that the State inspectors attempt to conduct formal exit meetings with the senior licensee management on aD inspections. (Section 3.4)
Response
1%on forms and inspection guidance dommwnte now indicate that "the closeout conference abould be held with the licensee's highest level of management available," and that Vors should always contact upper management upon entering a facihty." The importance of contacting upper management as a follow-up, if upper management is unavailable at time of mspection, has been discussed at staff Ma-e. Senior Management exit interviews have been held on all inspections conducted since the IMPEP Review.
14.
- Ibe review team i=-x--=* that the State develop a formal prw for reviewing licensee responses to deficiencyletters and closing open deficiencies. (Section 3.4)
Response
All responses will be tracked using tickler file. Both the RCP Program Manager (initially) and the Bureau Chief will sign off on the adequacy oflicensee response. Requests for additional information are now made in writing, with copies of all correspondence placed in license folders.
15.
The review team suggests that the State develop a formal process for inspectors and license reviewers to document and transmit pertinent information to each other for follow-up.
(Section 3.4)
Response
Weekly staff meetings are now being held to discuss the previous week's activities.
RCP Prugr.re Manager and inspectors discuss information resuhing from previous week's inspecti efforts. Any need for documentation is satisfied in writing 16.
The review team suggests that the State develop a pivcess for ensuring that inspection files are complete, that all appropriate State documents are prepared and filed, and that licensee responses are received and filed. (Section 3.4) 6
Response
Each inspector will be held responsible for ensuring that d iaWon Ses masigned to him or her are complete and that responses to letters of violation are received in timely manner.
In wh with Itan 14, adequacy ofresponses is now approved by both Program Manager and Bureau Chiet. I. meters in reply to licensee responses will be signed by Program Manager. Pro Manager is reviewing license ses each time " circle of con 4 Jence"is completed pertaining to E-iag action, inspection, or incident.
17.
The review team recommends that the State begin de-aaa+ias d trips to Econsees' or
[ applicants' facilities when laWa: licensed activities, performing special inspectiona, or '
performing pre-licensing site visits during construction. (Section 3.4)
Response
The importance of documentation has been dimmad at RCP staff meetings All information gained through trips to licensed facilities is now de-a+ad via memoranda to Se signed offon byRCP Program Manager.
18.
7be review team recomnde that the State management exercise more stringent superv review ofinspection reports. (Section 3.4) i
Response
By relocating all but one of the RCP inspectors to a centralized location, inspection reports are no longer being dowed to see-nuiste without management review in field ofEce. Both Program Manager and the Bureau Chief are reviewing licensee responses to cited violations for adequacy and are signing off on reviews. Program Manager is signing off on d documents entered in Ses.
19.
- The review team suggests that the State complete its revision of the laWon report forms, ensuring that each set offorms covers d key areas for the type officensee being inspected and that RCP inspectors begin using the standardized form (s). (Section 3.4)
Response
All inspection report forms are being fiantivad and copies have been distntuted to 7
l.
7.,
staff. Staffhave been advised as to how inspection forms are to be completed during staff training meetings.
20.
The review team recommende that the State make onsite, documented investigations of 3
incidents, allegations, or mi=dmini*ations with potential health and safety effects (i.e.,
! {
source d_ie= =:G, possible over exposures, lost sources, contamination, etc.) (Section 3.5)
Response
A guidance document has been written outlining the standard operating procedures
- to be followed in response to incidents involving radioactive materials. A copy ofthese documents has been provided to each RCP staffmember. The contents of these incident responte guidance h*nant have been discussed at RCP staff m@c. NRC has indicated satisfaction with cur report forn.; r.5 the manner that incidents are now being investigated and docannented.
21.
The review team w+ i aie that the State create an incident and allegation reporting form that would, at a minimum, identify the person taking the initial report, list the name and
)
l telephone number of the reporting party, provide the details of the incident or allegation as reported, record the State's conversation with the licensee or individual, desenh corrective actions taken by the licensee, describe the investigation conducted by the State and the resuhs, list citations or other regulatory actions, show the date the investigation was closed out and justification for closure, show date(s) incident was reported to the NRC or other agencies, and provide spaces for the signatures of the investigator and supervisor. A copy of the form should be maintained in the incident file and in the license file. (Sect Keepcsee:
Incident and allegation report fonns have been developed by the RCP which incorporate all of the above, Additionally, standard oper.Gug procedures have been developed fo both incident and allegation investigations and made available to Program Staff.
4 22.
The review team recomm=4 that the State establish a protocol for anWg independent j investigations and evaluations of the licensee's actions. (Section 3.5)
- 8 i
.' P = =, = = :
A ymieccl has been developed for making independent investigations and evaluating the licensee's actions.
- 23. The review team recommends that the State initiate procedures to ensure incidents are followed up at the next Won to verify that the licensee's corrective actions have been implemarwad. (Section 3.5)
Response
A separate section entitled %M-*/Raports" has been ir.cor r ersted into inspection forms giving information on types ofincidents that may have mM since last inspection and to L
l address notification reports and corrective actions. The *-.yc41.sce ofcompleting this section has '
been stressed with RCP staff. I l
24.
The review team suggests that when evaluating incidents, the State cite appropriate items of deficiencies when applicable. (Section 3.5)
Response
Deficiency letters are being sent to any licensee where a breakdown ofprocedures ocanted resulting in a reponable incident. Management interviews are being held to discuss cause ofincident, results and corrective actions taken.
1 25.
The review team rge +ds that the State: (a) set up a separate incident and allegation Se system in the Santa Fe ofBee, keeping all documents and records pertaining to an incident in one location, with the data cross-referenced to the license /mspection Ees there and in the Albuquerque office, and (b) establish a system to centally log and track the progress of incidents and allegations. (Section 3.5)
Response
Theinddent and allegation Ee system has been moved from the Albuquerque office to the Santa Fe o5ce. A new Incident / Allegation CWW has been developed, as well as a new Incident / Allegation Report Form. The NMED database is being utilized to track all incidents and I allegations and forwarded to NRC. A chronology Ee (hard copy) will also be kept in the Santa Fe l 9
7 i e i
d of5ce, and a tickler Sie has been established to track the progress ofincidents and degations. .
i 26.
De review team recommana that the State develop and implement written procedures for respcoding to evets involving radioactive material and conduct training sessions until all staff
} are fully trained and qualified in emergency response. (Section 3.5)
- P&: Wrium procedums are in place for responding to events invoMag radioactive material and staffhas been lastructed in their use.
i i 27.
i De review team suggests that the State keep expanding the degation procedures to include s procedures for notifying the person making the allegation of the results of the investigation
- and including the allegation in the event reporting form, tracking system, and sawgy
- response procedures (Section 3.5) i
! Response:
A guidance document is now in place covering various aspects of allegation procedures, including the notification of the person making the allegation. Allegations are being I
tracked by the Program Manager & entered into database as ifit were reportable incident.
- 28 The review team recommends that the State expedite promulgation of the compatibility-related regulations now overdue and those which are due within the next 12 months. (Section
{ 4.1.2) 1 j Response:
Subpart 3, Section 311. G.4.a through d (pages 3-32 through 3-33) contains the compatibility language for hmmissioning Record keeping and ihea Termination; i
Documentation Additions" and was adopted by the New Mexico EIB, April 3,1995, and became
! cffective May 3,1995.
l 1*agnge from the Federal Register (61 FR 24669) was approved by the Radiation Technical i
Advisory Council (RTAC) for inclusion under Subpart 3, Section 311.G (page 3-32) NMAC3.1. The 4
RTAC will recommend adoption of these changes by the EnviromnentalImprovement Board.
10 i
1 1
a j' Self-Ouarantee as an Additional Fmancial Mvhani m. "10 CFR Parts 30,40, and 70 mmandmanta (58 PR 68726 and 59 FR 1618) that became affective on January 28,1994, and which became due on January 28,1997. Language from the Federal Register (58 FR 68726 and 59 FR 1618) was approved by the Radiation Technical Advisory Council (RTAC) at their September 24, 1997 meeting forinclusion in Subpart 4, NMAC3.1. The RTAC will recommand adoption of these changes to the Environmantal Improvement Board.
j Work -ninnes on inserting language for the following amendmante to the New Mexico Radiation j Protection Regulations. Once the insertions have been made, the amended regulations will be taken i befbre the RTAC for approval prior to submittal to the Ensc =^mi I,uyis usat Board. (These i
will be adopted no later than May 1998):
)
1 1.
Timeliness in Decommissioning ofMaterials Facilities, "10CFR Parts 30,40 and 70 J
amendments.
j 2. Preparation, Transfer for C+ ..+2 Distribution and Use ofByproduct Material for l Medical Use, "10 CFR Parts 30,32, and 35 mmandments."
- 3.
I.nw-I.evel Waste Shipment Manifest Information and Reporting, "10 CFR parts 20
- and 61 amendments."
! 4.
Frequeacy ofMedica19= min >+ ions for Use ofRespiratory Protection Equipment, j! "10 CFR Part 20 amendments."
- 5. Radiation ProtectionRegtimusEs: Amended Definitions and Criteria, "10 CFR Parts 3- 19 and 20 amendments."
- 6. Medical Adminie tion n ofRadiation and Radioactive Materials,10 CFR Parts 20 and l
k 35 amandmanta " -
- 7. Clarification for Decommissioning Punding Requirements, "10 CFR Parts 30, 40, and 1
70 amendments."
l 8. Compatibility with the International Atomic Energy Agency, "10 CFR Part 71 1,
1 amendment."
! 9.
Termination or Transfer ofUcensed Activities: Record keep'mg Requirements,"10 i
l CFR Parts 20 and 30."
11 l
i
29.
The review team suggests that a Se be maintainart with the cover letters and ensuing w,i.wycs.dence of all draR or final regulations sent to the NRC. (Section 4.1.2).
Response
All NRC-related consspondence pertaining to regulation development is kept in separate se for easyaccess.
t 12
1 State efNewMexico \
q ENVlRONMENTDEPARTMENT
- t ' Hasardous & Radioactive Msterials Bureau g$.
l l 2044 Galisteo (
P.O. Box 26110 \
Santa Fe, New Mexico 87502 (505) 827 1557 GARYE.JonNs0N fax (505)8271544 MAar1.wsmiss sovsame sacarrARY zoaxa r.ruoanron.m l marurrascarra r i March 27,1998 $
n Richard L.Bangart, Director 57 o Office ofState Programs '*
j !
U.S. Nuclear Regulatory Commission !,8 '
Washington, D.C. 20555-0001
Dear Mr.Bangart:
As per Mr. Hugh L. Thompson's request in his letter dated December 30,1997, to New Mexico Environment Department Secretary Mark E. Weidler, I am submitting the second of the requested bi monthly progress reports addressing the Ih&EP Team's suggestions and recommendations.
i Please note that for the suggestions and recommendations identified by the IMPEP Review Team requiring action by the State, those with responses reading "no further action required" indicate that they were addressed in the first bi-monthly progress report, and that either additional action was required, or that there have been no changes to the material previously submined..
Please call me at (505) 827-1862 should you have any questions.
Sincerely; i
/4xtaea24. L William M.Floyd i Program Manager l
cc. Mark E. Weidler, Secretary hWED Ed Kelley, Director Water and Waste Management Division Benito J. Garcia, Chief Hazardous and Radioactive Materials Bureau l
nob 5(hf h
- - = . - . - -
r ACTIONS, DOCUMENTATION AND PROCEDURES ADOPTED BY NEW MEXICO i
( , RCP TO ADDRESS MRB CONCERNS INTRODUCTION: Below is a summary list of suggestions and recommendations identified by i the IMPEP Review Team as requiring action by the State: l
- 1. The review team recommends that the nuclear pharmacy inspection frequency be modified from 2 years to 1 year. (Section 3.1)
Response: Nothing additional to report since last response.
- 2. The review team recommends that initial inspections oflicensees be performed within 6 l
months oflicensee's receipt of material and commencement of operations, consistent with IMC 2800. (Section 3.1) )
l Response: All radioactive material licenses issued since the IMPEP Review have been inspected, or will be inspected, within six months ofissuance. (i.e.,
Issued: Inspected: No material: .
Phase One Molecular 04/97 09/97 l Avid Engineering 12/97 As of 01/98 City of Alamogordo 12/97 As of1/29/98 J Bizzell Power,Inc. 12/97 As of 02/98 ,
Evans Engineering 1/98 As of 02/98 Wyland X-Ray Service 03/98 As of 02/98).
- 3. The review team recommends that the tracking system be revised to allow initial inspections to be readily identified to staff and management. (Section 3.1) l Response: Nothing additional to report since last response. i
- 4. The review team recommends that the State increase the number of reciprocity inspections l to better evaluate the health and safety implications of out-of-state companies working in
' New Mexico. (Section 3.1)
Response: Since August 1997, a total of 25 reciprocal licenses have entered New Mexico. Of these, fifteen have been inspected on-site. The majority of the reciprocal licensees which were not inspected were due to insufficient notification time. Following is a listing of reciprocal licensees which have entered the State:
1
- _-. -. - - - . -- = _. .
(
Hamt 139.c Date Entering NM Inspected If not. Reason Westex IR 09/97 09/97 Production Logging WL 08/97 InsuEnotification time.
Transystem Corp. DM 08/97 Insuf notificationtime.
BPB Wireline WL 08/97 Insufnotification time.
Gammametrics DM- 08/97 Insufnotificationtime.
Agra, Earth &
Environmental IR 08/97 Insufnotificationtime. -
Dakota Geophysics WL 12/97 12/97 l ThermNuclean(SoilVolume 08/97 08/97 i Reduction). I Nucletron(HDRReloading) 10/97 10/97 i Amarillo Testing DM 10/97 10/97 l Nordion(Poolhradiator)) 11/97 11/97 ;
Transystems DM 01/98 01/98 l Nucletron(HDRReloading) 01/98 01/98 l Production Logging WL 01/98 01/98 El Paso Nat'l Gas IR 03/98 03/98 El Paso Inspection IR 03/98 03/98 CenturyGeophysical WL 03/98 03/98 Highlands Environ (NORM) 02/98 Insufnotificationtime.
Agra, Earth, & Env. IR 03/98 Insuf.notificationtime.
BPB Wireline WL 02/98 Insulnotificationtime.
Speedie Associates DM 03/98 03/98 Welenco WL 01/98 Onlandunderexclusive Federaljurisdiction.
Tm-Tec Division DM 01/98 Insufnotificationtime.
Dakota Geophysics WL 01/98 Work canceled due to inclement weather.
- 5. The review team recommends that the State maintain the RCP staffmg level to at least the level which existed throughout the review period. (Section 3.2)
Response: The two Environmental Specialist positions vacated since the IMPEP Review were ;
filled effective February 16,1998. The resumes of the two newly- hired staff members are attached (See Attachment 1). Both Mr. Garcia and Mr. Fitch are proving to be excellent employees, being both knowledgeable and highly motivated.
('
2
I
~ 6. The review team recommends that the State provide training personnel in areas of medical brachytherapy and irradiator technology. (Section 3.2)
Response: Bill Floyd, Program Manager for the Radiation Licensing & Registration Section, will meet with Mr. Larry Stephenson, P.E., Director of Environmental Compliance for Protechnics, a Core laboratories Company, on April 2,1998, to discuss traimng for RLRS staff in inspecting pool irradiators, industrial radiographers, gauge operators, and radiation safety for radioactive material laboratory operators. *Iraining in these areas will be from the regulator's perspective (See Attachment 2 for the course outline of Subsurface Tracer Operations for State Regulatory Personnel; this training was provided to RLRS staff on March 24 and 25; similar outlines will be provided by Mr. Stephenson for training in the other areas). Mr. Stephenson worked for more than 8 years in the Texas Radiation Control Program and consequently has valuable experience in teaching from the regulator's point of view). In regards to further training options, RLRS staff will be attending a three-day course on Advanced Radioactive Material Transportation, March 31 - April 2 (See Attachment 3). Also, information on courses available through Los Alamos National Laboratories and Sandia National Laboratories has been received and is being evaluated for usefulness (See Attachment 4 and 5). Additionally, Arthur Tate with the Texas Radiation Control Program has been contacted about sending New Mexico RLRS staff to Texas to accompany Texas inspectors as a training exercise. Nordion of Canada will present a two-day training course in Albuquerque on August 24 and 25 on pool irradiators. Also, RLRS staff attended a 5-day EPA sponsored Safety Course on Radiation Safety at Superfund Sites, March 16-20 (Attachment 6).
- 7. The review team recommends that the State develop a formalized training program comparable to IMC 1246, " Formal Qualification Programs in the Nuclear Material Safety and Safeguard Program Area." (Section 3.2)
Response: As shown in Attachment 7, progress continues on developing a formalized trauung program comparable to IMCl246. A RLRS Training Policy Statement has been completed, as well as a Master Training Matrix. Qualification Journals for all RLRS staff are in the process of being completed.
- 8. The review team suggest that documentation oflicense reviewer's actions be maintained in license files. (Section 3.2).
Response: No further action since last response.
3
- - . w. - w-. -
- 9. De review team recommends that the State inspectors attempt to observe licensee operations or demonstrations during all inspections. (Section 3.4).
Response: . No further action since last response other thao the fact that an additional five management-accompanied inspections have been performed.
- 10. De review team recommends that the State inspectors conduct independent measurements on allinspections. (Section 3.4).
Response: No further action since last response (i.e., independent measurements have been conducted at all licensees inspected since the last response).
I1. He review team recommends that the State increase the rigor ofreviewing technical health physics issues during inspections, and increase the breadth and scope ofinspections. (Section 3.4).
Response: No further action since last response.
! 12. He review team suggests the State inspectors attempt to interview ancillary workers during inspections. (Section 3.4).
Response: When available, ancillary staff have been interviewed during all inspections conducted since the last response.
1 I 13. The review team recommends that the State inspectors attempt to conduct formal exit i meetings with the senior licensee management on all inspections. (Section 3.4).
l Response: No further action since last response.
- 14. The review team recommends that the State develop a formal process for reviewing licensee responses to deficiency letters and closing open deficiencies.
Response: Nothing additional to report since last response, i
- 15. He review team suggests that the State develop a formal process for inspectors and license reviewers to document and transmit pertinent information to each other for follow-up.
. (Section 3.4).
Response: Nothing additional to report since last response.
i 4 l
i _ ._ _ . ._
l p,
s 1
- 16. The review team suggests that the State develop a process for ensuring that inspection files are complete, that all .yymydate State documents are prepared and filed, and that licensee l responses are received and filed. (Section 3.4). l l
Response: Nothing additional to repon since last myvo .
l l
- 17. The review team recommends that the State begin documenting all trips to licensee's or
, applicant's facilities when inspecting licensed activities, performing special inspections, or l performing pre-licensing site visits during construction. (Section 3.4).
Response: Nothing additional to report since last response.
l
- 18. The review team recommends that the State management exercise more stringent supervisory review ofinspection reports. (Section 3.4).
l Response: Nothing additional to report since last response.
- 19. The review team suggests that the State complete its revision of the inspection repon forms, l
ensuring that each set of forms covers all key areas for the type oflicensee being inspected, L and that RCP inspectors begin using the standardized form (s). (Section 3.4).
l Response: Nothing additional to repon since last response.
- 20. The review team recommends that the State make onsite, documented investigations of l
incidents, allegations, or mindministrations with potential health and safety effects (i.e.,
source disconnects, possible over exposures, lost sources, contamination, etc. (Section 3.5).
Response: All incidents have been investigated via on-site visits. Thorough documentation has been provided for all investigations via revised incident repon forms.
- 21. The review team recommends that the State create an incident and allegation reponing form that would, at a minimum, identify the person taking the initial report, list the name and telephone number of the reporting pany, provide the details of the incident or allegation as reported, record the State's conversation with the licensee or individual, describe corrective l actions taken by the licensee, describe the investigation conducted by the State and the resuhs, list citations or other regulatory actions, show the date the investigation was closed out and justification for closure, show date(s) incident was reported to the NRC or other
- agencies, and provide spaces for the signatures of the investigator and supervisor. A copy of the form should be maintained in the incident file and in the license file. (Section 3.5).
Response: Nothing additional to report since last response.
i 5 i
I - .. . , , , = = - , _ . . - , . - - - . . - - - . _ -, -
a 0
22.
The review team recommends that the State establish a protocol for making independent investigations and evaluations of the licensee's actions. (Section 3.5).
Response: Nothing additional to report since last response.
- 23. The review team recommends that the State initiate procedures to ensure incidents are followed-up at the next inspection to verify that the licensee's corrective actions have been implemented. (Section 3.5).
Response: Nothing additional to report since last response.
24.
' The review team suggests that when saluating incidents, the State cite appropriate items of deficiencies when applicable. (Section 3.5).
Response: Nothing additional to report since last response.
- 25. The review team recommends that the State: (a) set up a separate incident and allegation file system in the Santa Fe office, keeping all documents and records pertaining to an incident in one location, with the data cross referenced to the license / inspection files there and in the-Albuquerque office, and (b) establish a system to centrally log and track the progress of incidents and allegations. (Section 3.5).
. Response: Nothing additional to report since last response.
- 26. The review team recommends that the State develop and implement written procedures for responding to events involving radioactive material and conduct tnining sessions until all stafTare fully trained and qualified in emergency response. (Section 3.5).
Response: Nothing additional to report since last response.
- 27. The review team suggests that the State keep expanding the allegation procedures to include procedures for notifying the person making the allegation of the results of the investigation and including the allegation in the event reporting fonn, tracking system, and emergency response procedures (Section 3.5).
Response: Nothing additional to report since last response.
6
- _- - - - - . - - . - - - - - . - - - - - - - - - - - - - ' - - ^
1..
28.
The review team recommends that the State expedite promulgation of the compatibility-related regulations now overdue and those which are due within the next 12 months.
(Section 4.1.2).
Response: As of this date all compatibility language changes have been incorporated into the New Mexico Radiation Protection Regulations. A meeting of the New Mexico Radiation Technical Advisory Council (RTAC) will be scheduled in late April for the Council's advise and consent on these changes. Once RTAC's approval is obtained, the changes will be placed on the agenda cf the Environmental Improvement Board (hopefully for the May Board meeting).
- 29. The review team suggests that a file be maintained with the cover letters and ensuring correspondence of all draft or final regulations sent to the NRC. (Section 4.1.2.).
Response: Nothing additional to report since last response.
7
f*
1
! Stanley A.Fitch (SS# 585-70-6011) j 83014th Street,NW #12
] Albuquerque,NM 87114
! Phone (505) 898-4475 l
j .e QUALIFICATIONS
SUMMARY
Mr. Fitch has nine years experience in health physics. F m' years in support of ,
, environmental restoration projecta, and four years in support of operations at Sandia l NationalLaboratories. 1 i
His environmental rertoration assir.-e were re'ated to uranium mill decommissioning and tailings restoration at both' DOE and commercial sites. His taaks provided an excellent health physics basis. Mr. Fitch implemented several hedth physics programs.
Not limited solely to routine health physics survaiH==, his tasks included regulatory compliance and enforcement, environmental monitoring, waste characterization, field correlations, and analytical instrumentation in the laboratory. He successfully devised soil verification protocols for tracking, mapping, and analysis of uranium mill tailings remediation. The waste characterization included identification of mixed waste due to RCRA hazardous constituents. He provided primary support for radiation detection ,
. instrument calibration and repair. He developed protocol and an extensive database for l tracking occupational radiation dose combining external and internal dosimetry. This ;
latter project incorporated the approach referenced in ICRP 26 and ICRP 30, and as implemented in the new (1992) 10 CFR 20. Implementation duties included bioassay and respiratory protection programs He also managed radioactive shipments in compliance with 49 CFR 173. Mr. Fitch performed extensive writing in health physics procedures.
Since 1993 Mr. Fitch has provided support to Sandia National Laboratories (Radiation
- Protection Operations). His duties include health physics surveys, regulatory compliance assistance, and occupational hazard assessments for the Facilities Maintenance and Facilities Construction departments. He has demonstrated successful. implementation of 10CFR835 and DOE Orders 5480.11 and 5400.5.
Prior to entering heahh physics, Mr. Fitch served for 10 years as a land surveyor and civil engineering technician. In the 1970's he served 3 years as a plant operator in an urarium
- 4xide production facility.
- CLEARANCE Active DOE Q-Clearance
- EDUCATION 1987 New Mexico State University A.S. Political Sciences (Additional classes in mathematics, sciences, and computer science) g y' ;
l
1 Stanley A. Fitch (SS# 585-70-6011) J 83014th Street,NW #12 l Albuquerque,NM 87114 Phone (505) 898-4475 l
l 1990-93 I4ad Health Physics Technician Atlantic Richfield Company ARCO BluewaterMill Grants, NM l
l Anisted in health physics surveillance for La menrive uranium mill restoration project (up to 120 construction personnel during some periods). Duties in:luded environmental and occupational sampling and surveys, management of the health physics databases, analytical lab, dosimetry and bionssay programs Reconstructions of environmental and occupational exposures, case and project l histories. Mr. Fitch was also procedure writer, and provided technical advice and l assistance to the site RSO.
Other duties included field and laboratory characterization of soil and wastes, and
. correlation of radiometric data to action hmits to verify restoration criteria.
Devised and implemented a database for mapping and tracking field measurements and sample data for environmental restoration. Devised and implemented a database for tracking and reporting internal and external occupational radiation dosimetry. Radiation detection instrument maintenance and calibration.
Radioactive materials shipping and receiving in compliance with Department of Transportation regulations.
1989-90 lead Health Physics Technician Landmark Reclamation ARCO BluewaterMill Grants,NM Contractor health physics duties to ARCO at the same Bluewater Mill project described above. Duties include occup.Jonal monitoring and decommissioning surveys.
i 1988-89 I4ad Health Physics Technician ChemNuclear Systems,Inc.
1 (Chemical Waste Management) i Ambrosia Lake Uranium Mill DOE UMTRA Site l
Coordinated health physics support for field and laboratory work. Database management. Dosimetry and bioassay program implementation, soil and waste Page 3 of4
m _ _ _ _ _ _
=
Mark G. Garcia 3331 SchumacherNW Albuquerque,New Mexico 87120 (Oflice)(505) 881-3196 (Home)(505) 833-0773 Professional Experience MDM Lamb May,1997 to February,1998 Albuquerque, New Mexico ;
Health Physicist. Lead author for health physics related issues during the preparation of the Environmental Assessment ofJohnston Atoll Pilot-Scale Technology Demonstrations and the Transport andDisposal of Contaminated Rubble and Soil. Data collection and reduction in support of Bench-Scale Testing at the Nevada Test Site for The Plutonium Cleanup Project at Johnston Atoll. The principal health physicist for the development of surface gamma scannmg techniques, utilized during the characterization of a depleted uranium contminted site. The technique involved the integration of a gamma field survey instruments to a Global Positioning System (GPS).
Science Applications International Corporation December,1996 to May,1997 Las Vegas, Nevada Health Physicist. Lead investigator for preclosure (atmospher:c dispersion) and postclosure (Groundwater leaching) biosphere modeling at the Yucca mountain project. Working knowledge of several computer codes used for risk assessment associated with the release of radicactive materials to the accessible environment. These computer codes include CAP-88PC, AIRDOS-EPA, GENU, GENU S, RESRAD, and XoQDoQ. Have reviewed and assessed the implication of numerous Regulatory Guides to the project, specifically Reg. Guide 1.109,1.111,1.23,1.3,1.4, and 1.145. I have worked with the biosphere working group to develop site specific FEP's (Feature, Events, and Processes). During this process the outline set fonh by BIOMOVS U was utilized. This outline involves the use of the Rock Engineering System (RES) matrix.
City of Albuquerque Public Works January,1996 to November,1996 Wastewater Utility Division Albuquerque, New Mexico Program Specialist IU / Health Physicist. Develop and implement Radioactive Discharge Management Program (RDMP) for the City of Albuquerque Wastewater Utility Division. Program activities include: establish a permitting, monitoring, and reporting program; develop a sampling program to obtain data on radioactive material in the regional environment, including soils, river sedunents, river water and sewage; model environmental exposure scenarios using computer models such as GENU and RESRAD to assess potential exposure to the general public and the workers at the wastewater utility depanment; collect and update information regarding radioactive discharges to sewers from licensees; develop a cooperative working relationship with potential dischargers to ensure compatibility between regulatory requirements and community concems.
A./A /. . . ,l- /
Lamb Associates Iac. March,1995 to September,1995 Albuquerque, New Mexico Nuclear Engineer / Junior Health Physicist. Contract work with Sandia Natioral Laboratories Environmental Remediation Field Office, participation in all aspects of ER scoping sampling (both surface and subsurface), while following all OSHA standards listed in 1910.120 that apply to
' environmental sampling, waste storage, and handling. Worked on various occupational and environmental health physics projects. Developed and maintained radiation protection manuals for nuclear medicine and diagnostic radiology for local hospitals.
Albuquerque MedicalPhysics December,1994 to March,1995 Albuquerque, New Mexico Assistant Medical / Health Physicist. Assisted in all areas of hospital health physics which include nuclear medicine audits, dose calculations for patient and fetus, equipment calibrations and shielding d=i:m.
Presbyterian Hospital November,1990 to December,1994
. Albuquerque,New Mexico Nuclear Medicine Technologist. Performed all duties required to run a nuclear medicine department. This includes: radiophannaceutical preparation, quality control, and injection; patient
, handling and imaging; quality control on all instruments used in a clinical nuclear medicine department.
Education i University of New Mexico 1991 to 1994 Albuquerque, New Mexico Masters of Science in Nuclear Engineering. Completed graduate program in occupational and environmental health physics / radiation protection engineering. Extensive training with radiation detection systems and nuclear measurement techniques with special emphneis on selection of !
sampling techniques and instrumentation for measuring low levels ofradiation in air, soil, and water.
University of New Mexico 1985 to 1990 Albuquerque,New Mexico ,
Bachelors of Science in Medical Technology / Nuclear Medicine Technology. Completed undergraduate programs that included extensive training at local hospitals. Experience with clinical laboratory and nuclear medicine department equipment.
.. _ . , - -. -. . - . .-. - -- . . _ . = .-
4 Certifications American Board of Health Physics. Eligible for ABHP board examination in 1996.
American Registry of Radiologic Technologists. Registered Technologist in Nuclear Medicine Technology. Certificatenumber242326. August 1990.
Nuclear Medicine Technology Certification Board. Registered Nuclear Medicine Technologist.
Certificate Number 012774. Septemher1990.
The National Certification Agency For Medical Personnel Certified Clinical Laboratory Scientist. August 1989.
American Society of Clinical Pathologist. Certified Medical Technologist. September 1989.
e Publications I
M.L. Miller, C.R. Bowman and M.G. Garcia; Roy F. Weston, Inc. and City of Albuquerque Wastewater Utility Division. " Avoiding Potential Problems from Accumulation of Radionuclides in Municipal Wastewater Sludge", Presented at Health Physics Society 41st Annual Meeting, ,
Seattle, Washington, July,1996. '
i 4
1 l
-.. _ ..-._-.~-... __-._ .--.~. . -
.' FEB-24-1998 08:45 PROTEOt41CS INT'L 281679 9ErP6 P.01 FAX TRANSMISSION PROTECHNICS ENVIRONMENTAL i so omer wwono. sn:u4 HOUSTON. TEXA$ 77079 (2843400-3734 m:cae n e7o-oeve To: BILL FLOYD Date: February 23,1998 Fax #: (505) 827-1544 Pages: 4, including this cover From: LARRY J. STEPHENSON
Subject:
TRACER.IRAINING COURSE COMMENTS:
Bill:
Attached is the outline for the upcoming training course. I added information about performing an inspection of a tracer operation. We cen change any or all of this outline to fultfill your speelfic needs.
Call me after your review. We also need to set the dates for the course.
Larry J. Stephenson 6
.g -- _. .
r .
W ProTechnics Environmental a DMeion of core I.aboratories,Inc.
O"mm?"
em. es5Is'E l l
SUBSURFACE TRACER OPERATIONS l FOR STATE REGULATORY PERSONNEL I INTRODUCTION 11 HISTORY OF TRACER OPERATIONS
~
Ill CURRENT METHODS OF TRACER INJECTION (NIGH PRESSURE / LOW PRESSURE)
- 1. AREAS OF POTENTIAL CONTAMINATION
- 2. TYPES OF INCIDENTS THAT CAN OCCUR IV MANUFACTURER OF TRACER MATERIAL A. SOUD TRACERS B. GAS TRACERS C. UOUlD TRACERS l
V RADIOACTIVE MATERIAL UCENSE REQUIREMENTS A. ISOTOPES B. QUANTITY UMITATIONS C. LICENSED USES D. FORMS OF MATERIAL E. UCENSE CONDITIONS ,
VI OPERATING AND EMERGENCY PROCEDURES A. ORGANIZATION AND RESPONSIBILITIES B. FACIUTY LAYOUTS C. RADIATION SAFETY PROGRAM i D. EMERGENCY PROCEDURES E.
4 TRAINING FOR TRACER PERSONNEL F. RADIOACTIVE TRACER HANDLING PROCEDURES G. TRACER WATER FLOOD PROCEDURES H. BIOASSAY PROCEDURES 4
- - - . . - .-e ,- -- -
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.. . FEB-24-1998 98:46 PROTEC>NICS INT'L 2B1679 SEf?6 P.83 I l. RADIOACTIVE WASTE DISPOSAL
!- J. RECElVING AND MONITORING RADIOACTIVE TRACERS K TRANSPORTATION OF RADIOACTIVE MATERIAL L COLLAR MARKER PROCEDURES vil STATE REGULATIONS FOR TRACER OPERATIONS i
j Vill D.O.T. REQUIREMENTS FOR TRANSPORTATION OF TRACER MATERIAL J
j IX RADIATION INSTRUMENTATION FOR TRACER OPERATIONS i
- X REGUL'ATORY INSPECTION OF TRACER OPERATIONS l A. PREPARATION FOR INSPECTION 4 . . . 1. UCENSE REVIEW .
- 2. OPERATING AND EMERGENCY PROCEDURE REVIEW
- 3. REGULATION REVIEW
- 4. PREVIOUS VIOLATIONS NOTED B. MANAGEMENT ENTRANCE INTERVIEW f
- C. INSPECTION TOUR 1
l D. CONFIRMATORY MEASUREMENTS I E. FOLLOW UP ON ITEMS OF NONCOMPLIANCE
- F. FOLLOW UP ON REPORTS SUBMITTED TO THE AGENCY 1 G. ORGANIZATION l H. LICENSEE AUDITS ,
! 1. TRAINING PROGRAMS j J. RADIATION PROTECTION PROGRAM j- K RADIATION SAFETY EOUIPMENT AND INSTRUMENTATION
- 1. INTERNAL EXPOSURE PROTECTIVE EQUIPMEffT
- 2. EXTERNAL EXPOSURE PROTECTIVE EQUIPMENT
- L RECEIPT, TRANSFER AND DISPOSAL L $
ProTechnics Environmental i
} s>vwon e em Laborskwies. ine.
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- PEB-24-1998 98146 PROTEONICS INT'L 281 679 9876 P.04
- M. TRANSPORTATION PROGRAM N. POSTING OF NOTICES / PROCEDURES /UCENSE, ETC.
Q. ENVIRONMENTAL MONITORING PROGRAM P. EMERGENCY PLANS Q. MANAGEMENT EXIT INTERVIEW r
i ProTechnics Enytronmental Dwision of Com Laboratones. M TOTAL P.04
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Tb: 3il/' F/ow L r,om: Margie A. Dronen Location: Location: 345 Hills, Rm 171 Phone: Phone: (509)376-8226 Fax: 606- [N7- /dM[ Fax: (509) 376 2364 Verity: Verify: (509)'376-8226 Number of Pages Including Cover b uessage: AonEruv,+ier &<: -
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,. l CONFIRMATION NOT"CE Advanced Radioactive Material Transportation l
National hansportanon Program i i l Dates: Tuesday, March 31,1998 - Thursda y, April 2,1998 l Time: 8.00 a.m. - 5:00 p.m. each day l l
Location: Energy Training Center (ETC)
Kirtland AirForceBase 1401 Maxwell St.
Albuquerque,NM 87118 Phone: (505) 845-5402 Fax: (505) 845-5262 Per Diem: 370 Lodging / $34 Meals f.
1 Badges: Students tell guard at gate you are DOE and attending a class at the l Energy Training Center (ETC). - l Required Calculator j l Material:
4 Lodging: For your convenience, a block of sleeping rooms have been rese:ved at the following hotel undar the group name " Department ofEnergy"(DOE). Reservations ale your responsibility. The cut off date to make your hotel reservation is February 23,1998.
t When checking-in and out, be sure that your room rate is within govemment per diem.
Winrock Inn 18 Winrock Center,N.E.
Albuque*que, New giexico 87110 (505) 883 5252 Fax: (505)889-3206 3
(800) 866-5252 Directions: From Albucuercue International Airoort to Winrock Inn:
Please see attached map. .
Frern Winrock inn to Kirtland Air Force Base:
'Please see attached map. Allow 20 minutes travel time in case of heavy morning traffic. I T
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1401 Maxwell St. KAFB West, Albuquerque,NM. 87118 Phone (505)'845-5402 FAX (505)845-5262 [
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,'- National Laboratory FAX Transmittal Cover Sheet
- Informal Correspondence Date 2/26/98 Time 9:02 43 AM C FAX Sent Number of pages Date 2/26/98 (includlag this page)j 7 Sender gy
- ummummin FROM: TO: oroA corr. pondence pendinn Dtation Receivine Station Neme Artene M. Meray Name: WIiam Flovd Signature A #1 /)dd/s p Company:
f-C:mpany Safeguards Science and Technology (NIS 5)
Los Alamos National Laboratory P. O. Box 1663 MS E540 Phone Number:
Les Alamos, NM 37545 ,
USA Phone No. 505/661-5258 FAX Number:
_B27-1544 FAX No. 505/665-5055 Confirm Number:
C nfirm No. 505/667 5258 subject:
Message l Find attached information reganiing our training courses (reguested by Joe Wachter). Thanks.
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LANI/ DOL,af: guards Technology Trainin, rogram s
Los Alamos N:tional Labtr:tary
%e Ims Alamos / DOE Safeguards TM. cgyTranung program was begun in 1973 with a single, week lang trainmg course on the Fundamentals of Nandestructive Assay of Nuclear Materist
)
j j
he progrum has grown over the succeeding 18 years to four courses that serve the fuH DOE complex,
' NRC, the domestic nuclear faciuties and intemational safeguards practitioners. The courses offered ,
by Les Alamos Nuclear safeguards staff are a unique resource for the support of US nuclear materials accounting and safeguards and US Non-proEferation policies. Se courses are taught by the ressan:h j
staff and involve actual hands on snaasurement experience with real nuclear material samples and i
with instrumentation currently available for 6 eld and in-plant measurements. It is anticipated that
{ demand for these laboratory NDA courses will expand,in view of the increased emphasis by the 4
Cry ^ .er.t of Energy an Matsnals W=tng and todmical support of US Nonprohferation l initiatives. .
he Los Alamos Safeguards training resource has also extended beycmd the DOE-sponsored courses to become an integral part of the 1AEA hyam Trammg Program and the US Nuclear Non-Probieration Act (NNPA)-Mandated Safeguards Trainmg for developing countnes. As such, the DOE '
i Safeguards Research and Development Program and its associated Tedmology Training "i.p provide widespresd practaesi trainmg on nondestructive assay techniques for application in nuclear l materials accounting, process ccmtrol, nuclear and criticality safety, and nuclear safeguards.
Presented below are brief synopees of the current s.r.a,L, of courses offered through the ,
IANL/ DOE Safeguanis TM-icavsy 'haining Program. For more informatiore Contact }anet Sander j
[50H67 5258, FAX 505 665-5055 ] Los Alamos National Laboratory, Safeguards Technology Trauung
) Program, P.O. Box 3663, Mail Stop ES40, I.ms Alamos, NM 87545.
s Course
Title:
Nondestructive Assay Techniquesfor Safeguards 1
Practitioners -MCA-241 . April 6-10,1998
- Designed for: Experienced practitioners in the area of nuclear material assays for material l
accountmg and process control. he course is open to DOE contractor and NRCliensee employees who i
manage or perform nuclear material assays for these purposes. Employees of other organizations are i accepted on a space-available basis.
1 Hours: 36 (4.5 days) Course is offered approxanately armually.
Description:
His course is an introduction to the nondestructive assay (NDA) of nuclear materials using both gamma ray and neutrem measurement techniques. Topics include gamma-ray and neutron i
interactions with matter, detectors, uranium enrichment measurement, transmission,.m..ca
} gamma-ray assays, neutron smgles countmg, and b oth active and passive neutron comeidence countin6-Both uranium and plutonium bearing materials air measured. Currieu!um involves plenary lectures I
to introduce the topics, foHowed by hand-on laboratory measurements to illustrate the concepts.
j Activities involve the use of radioactive materiah Attendance is limited to 32 students.
Genisof thecourse:
To provide the student with Brst-hand measurement experience with neutron and yrsy assay methods
}
To acquaint the student with the NDA instrumentation available for needed measurements To provide the student with the knowlectge to apply appmpnate measurement ted niques to
, various NDA problems Prerequisites: Some arysiier.a with nuclear radiation measurement equipment is desirable, as is i
familiarity with nuclear radi.: ion and assooate 1 mathematics. Although not required, successful
! counpletion of the CTA course MCA-140 is recomnwrwied.
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- f. LANUDOE Saftguards Tedmolcgy Training Program Los Alamos National Laboratory Course
Title:
Gamma-Ray Spectroscopyfor Nuclear Materials Accounting-MCA-343 (not offeredin 1998)
Designed fon Experienced practitioners in Gw area of nuclear material assays for mateds!
--@g and process control. The course is open to DOE cxmtractor and NRC limnase employees who manage or perform nuclear material assays for these purposes. Employees of other .-.; i.icas are accepted on a spaos4vailable basis.
. Hours: 36 (43 days) Course is cliced syy.vedy annually.
Description:
This course covers the use of high resolution gamma-ray spectroscopy to measure various uranium and phrtonium maimala Topics include uranium and plutonium isotopics measurements, transmission-corrected assay techniques including the segmented gamma scan prowdure, absorphan-edge densitometry, and x eay Suorescence. Bench-top apparatus and measurements are used to Blustrate basic assay pnndples and also to demonstrate complete automated systems for in plant use.
Activities involve the use of radioactive materials. Attendance is Innited to 24 students.
Goalsof thecourse To provide the student with Aret hand mer moment expenance with advanced,
- high-resohrtion gamma-ray assay method .
To acquaint the student with the advance NDA instrumentation available for needed maarnements To provide the student vl$ the knowledge of measurement physics and data analysis eschniques for application to various NDA problems Prerequisites: Althoughnotrequired,successfulcompletionof theCTAcourseMCA440is recommended. Also muu a.ded are previous experience with nuclear radiation measurement
%a.s.t and fanuharity with nuclear radiation and associated mathematics.
Cousse
Title:
Materials Accountingfor Nuclear Safeguards - MCA-111 March 9-13,1998 Designed fon Ly hsd Nuclear Safeguards practitioners who operate, manage, or evaluate materials accounting systems.
Hours: 36 (4 1/2 days)
Description:
The course covers methods for designing and implementmg conventional and men-real-time accountmg systems for safeguardmg nuclear material. Imeture topics include Basic Mate (als Accountmg Concepts, The Structure of Safeguards Systems, Mea.m .wa Technology, Measurement Controt Statistical Basis of Materials Accounting, Nuclear Material Holdup, Materials Accounting at specifie types of facilities, MCdcA system decision analysis and detection sensitivities, and Intemational Safeguards. Short wcr *. shops are conducted on topics such as NDA measurement technology, measurement statistic,, almulation of materials accounting, aneasurement controt and error propagation.
Goals of the course Upon s====41 completion of this course, attendees will be familiar with the basic myi. of nuclear materials wi..g systems and the roles of the assadated technologies and techmques to operate such a system.
Prerequisites: Although not required, prior completion of the CTA course MCA 101 is ;-.cr.ded.
l DOE Docs Zip / General School Docs /5G Tech Trng.
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l: LANIlDOE Safeguards Technology Training Program
, [7 Los Alamos National Imboratory i
l Course
Title:
Nondestructive Assay Inspector Tr'aining Course
, February 3-13,1998 i
j Designed fon IAEA hW with less than 1 year's experience who perform safeguards mspections in nuclear facilities worldwide.
i 1
Houw. 66 (61/2 days). Tuesday morning through the following Priday noord Desalption: This carree provides broad and in depth expenance with both neutron and gamma-ray NDA techniques for quantitative measumnant of SNM items. Topks include basic neutron detector
! and gamma-ray detector designs, active and passive neutron coincidenar measurements, and gamma-my snessumnants of urenlum enrichment, plutonium isotopic composihon, and spent-fuel
{ d.a tks. The course concludes with a team-oriented performance test in which unknown SNM i
inventory items are characterized and quantified to establish an inventory. Attendance is Itmited to u students.
Goals of the course: Upon successful completion of this course, attendees willbe thoroughly familiar with the appropriate nondestructive assay instruments and techniques available for needed i mens =ments.
F erequisites: Previous experience with nuclearradiaticm measurement equipmerd is recommended.
] Familiarity with nuclear radiation and assoanted mathematics is assumed.
! Course
Title:
Nondestructive Assay of Special Nuclear Materials Holdup
- MCA-243 l l April 27-May 1,1998 :
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Designed fon E@.csd practitioners in the area of nuclear material assays for material
( accountin6 and process control The course is open to DOE contractor and NRC licensee employees who j
manage or perform nuclear material assays for these purposes. Employees of other organizations are
- accepted on a space available basis.
i
' Hours: 36 (4.5 days) Course is offered approximately annually.
Description:
This course covers the application of basic nondestructive assay techniques and field-portable instrumentation to the measurement of nuclear material holdup deposits in process
.qdp..mt and ductwork. L 6 6 exercises 7 will emphasize procedures for calibration and j measurement of uranium and plutardum holdup, using mainly gamma-ray instrumentation and a generalized-W.aq approads Measurements wG1 be performed on simulated deposits using SNM i standards inserted within equipment (pipes, ducts, tanks, pumps, etc.) that represents process i equipment hardware. Equipment attenuation ~and self attenuation effects wDI be considered.
l Laboratory experzments will be supplemented with lectures on topics related to holdup
! measurements. Activities involve the use of radioactive anaterials. Attendance is limited to 24 students. .
! Goals of the course:
i e To provide the student with first-hand measumnent expenence with portable mondestructive j assay equipment under in plant conditions i e To acquaint the student with measurement strategies and todmiques that minimize measumnent uncertamties i e j To provide the student with the knowledge of the generalized-geometry approach to calibration and data analysis for the varied snessurement geometries encountered in holdup 1 awasurement compaigns .
l Prerequisites: The IoDowmg are recommended: Experience with nuclear radiation measurement j equipment, practical experience with nuclear radiation and assaanted mathematics, and successful
, completion of the CTA course MCA440.
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LANUDOE Safcguards Tcchnology Training Program i
Los Alamos National Laboratory
- Cousse
Title:
International Training Course on State Systems of Accountingfor and Control ofNuclearMaterials (SSAC)
May 3-21,1999 i
Designed for: Nuclear technologwts in developmg countries that have acqsdred or an about to acquin nuclear tedinology.
] Hours: 3 weeks. Two weeks in Santa Fe on general SSAC pnnciples and experience. One week in a 2
model facility to illustrate apphcation of a SSAC.
i Description This course is mandated by the US Nonptdiferation Act of 1978 and pnmdes irwiepth information on how to design a State System of Accountmg for and Control of Nuclear Material that i
will allow full-scope IAEA safeguards of that state's nuclear facilities. System attributes am 4
' discussed for snany possible facahties, and examples of SSACs in place worldwide are described. The course finishes with a workshop in whids a SSAC is designed for a model facility.
Goals of the course: Upon successful amnpletion of this course, attendees will be thoroughly f=miliar with the requisite attributes of a SSAC and with the requi. wa. for appropriate interaction with i the IAEA.
[ Psvrequisites: Famiharity with the nuclear fuel cycle and exponence in state nuclear programs is i
A assumed in those students invited to attend.
j Ad-Hoc Training for International Safeguards Practitioners:
i Designed for: Nuclear facility operators and intemational insg;or. who must verify the effectiveness of materials accounting systems or perform nonproliferation-motivated !==p+2-x Hours: Has varied from 2 days to one week. Tranung has been offered on request to intemational inspection teams, and state facility -r.L. .el.
Description:
This training has provided lectun materials ad hands cm eice;e.ci on in-field nuclear i
measurements, search / survey techniques, and data evaluation and interpretation in the context of
- materials accounting and nonproliferation goals. Measurements are made in simulated in-plant or in-Seld conditions, with real samples of spedal nuclear materials that replicate sample attributes j -y.c d in real field exercises.
Goals of the course: Upon successful completion of this course, attendees will be fandhar with in-field j
inspection techniques involving nuclear measurements and associated data evaluation.
j Parequisites: Fanuharity with the nuclear znessumments, instrumentation, and associated i
mathematics, as well as experience in nuclear fuel-cycle facilities and programs i
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Waste and Residue NDA Measurements
~
/f17 Days required for course: approxirnately 4.5 Course topics
. Waste certification regulatory requirements e Safeguards requisements
. . Neutron NDA techniques ,
e Gamma NDA techniques e
Segmented and Tomographie gamma-ray scanning Differentia! Disaway and Combme.d Thernial-Epithermal Neutron Intermgation e
Neutron Coincidence Counting, Add-a Source, and Californium Shuffler techniques Attendance Limit: 24 Students Course objectives e
First-hand measumment ex; iks with advanced neutron and gamma-my instmments e
Understanding of how existing NDA equipment applies to waste characterization and safeguards issues -
Demonstrate the use of NDA radiation measurement techniques and equipment to assay TRU and low level contact bandled waste Experience with nuclear radiation measurement equipment is desirable, as isfamiliarity with nuclear radiation and associatedmathematics. Although not required compierion of CTA course MCA 140is recommended.
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Waste and Residue Nondestructive Assay (NDA) Measurements Training School
Description:
This course will provide plenary lectures on waste assay requirements for safeguards. waste character ration requirements to meet waste acceptance criteria, and neutron and gamma ray based waste and resulue NDA techniques. Three major course inodules will pro ide hands-on training with actualinstruments used to assay radioactive isotopes in 55 gal. drums: (1) the Segmenied Gamma-ray Scanner t5G5 and the Tomographie Gamma ray Scanner (TGS):(2) Neutron Coincidence Counting with Add a Source. and the Californium Shuffler; (3) the Differential Diesway Technique. Combined Thermal Epithermal Neutron interrogation. Each module will cover topics such as calibration procedures and use of standard teference materials: matrix effects, limitations. corrections: response variation due to radioectiw material distnbution within the waste drum; sensitivity; lump effects (gamma)/ self shielding (neutron) cornetions: isotope identification / ratios (gamma) and their importance for neutron assey: acope of the techniques mith respect to waste forms and limitations. The course will conclude with a workshop session between instruetors and students on the parucular waste problems of most interest to the students.
Goals:
Upon succeuful completion of this course, anendees will have gained the following:
- An understanding of current DOE safeguards and da .zation issues assoeisted with waste and residue measurements.
Hands-on training in the operation and use of major waste and residue NDA systems.
- Knowledge needed to apply appropnate snemurement nachniques to the waste and residue materials present in their facilities.
Designed Fer: -
Esprienced radioactive measurement technicians who operate waste assay instruments and their technical supervisors. Also, auditors and regulators who musijudge the resuhs of the waste measurements and make declarations on the hazardous material documents. The course is open to DOE contractor and NRC licensee employees: employees of other orgarutations are accepted on a space available basis. (Attendance is hmited to 24 students.)
Prerequisites:
Some experience with nuclear radiation measurement equipment and techniques is desirable. Attendees should.hase a knowledge of gamma-ray spectroscopy and neutron counting. but these topics will be reviewed. Although not required, successful completion of MCA 140. (" Basics of MCAA Measuremeni")
is recommended.
Location:
The course will be conducted at Los Aterr.os.o - < Mesico.
Duration: 4 5 days Time Frame: .
., The first offering of the school will be June 3 through June 7.1996.
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Training for Radioactive Materials & Licensing Program Classes offered by Sandia National Laboratory No. of Staff Course Course Attending Cost Total Field Instrumentation 5 $162.00 $810.00 Laboratory Spill Cleanup 5 $163.00 $815.00 Radiological Worker I Training / 5 $152.00 $760.00 Radiological Worker 11 Training ., 5 $176.00 $880.00 Portable Survey Instrument Training 5 $127.00 $635.00 TOTAL $3900.00 k ALGAf
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, AGENDA RADIATION SAFETY AT SUPERFUND SITES (165.11)
City, State Date Course Director: Name of Course Director instructors: Name ofInstructor
- Name ofInstructor Technician
- Name et Tectmician Day and Time Subject Speaker Monday l 12:30 - 2:00 p.m. Orientation and introduction 2:10 - 3:00 p.m. Atomic Structure and Radioactive Decay 3:10 - 4:00 p.m. Interaction of Radiation with Matter
~
4:10 - 5:00 p.m. Radiation Exposure and Biological Effects 5:10 - 6:00 p.m. Radiation Exposure Umits and Methods to Control Exposure
. . Tuesday 8:00 - 8:30 a.m. Basic Concepts in Radiation Detection and Measurements 8:40 - 9:30 a.m. Radiation Detection Instruments
- 9
- 40 - 10:30 a.m. Surveying for Radioactive Materlats 10:40 - 12:30 p.m. Exercise: Ra(sation Survey Meters
- 1. Exposure Rats Meters / Dosimeters
- 2. Count Rate Meters
- 3. Bench Counters 12:30 - 1:30 p.m. Lunch 1:30 - 5:00 p.m. Exercise: Radiation Survey Meters (cont.)
- 1. Exposure Rate Meters / Dosimeters
- 2. Count Rate Meters
- 3. Bench Counters Wednesday f ._
8:00 - 8:15 a.m. Dosimeter Calibration Check j ,-
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t l 3:20 - 9:50 a.m. Exercise: Characterisdcs of Unknown l Sources / Dose Assessment i 10:00 - 10:50 a.m. Radiadon Signs and Labels
- 1
~
. 11:00 - 12:00 p.m. Contaminadon Comrol -
1 l
12:00 - 1:00 p.m. Lunch 1:00 - 1:50 p.m. Athri a.i..ation Clothing and Respiratory Protection Devices 2:00 - 2:50 p.m. Radiological Control Area Demonstradon l 3:00 - 3:50 p.m. Decontamination l 4:00 - 5:00 p.m. Problem Session: Decontamination l
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! - 8:00 - 8:50 a.m. Radioactive Material Packaging, !
Labeling, and, Shipping !
9:00 - 9:50 a.m. Ra(soactive Soil and Water Sampling i 10:00 - 12:00 p.m. Exercise:- Site Work Day i
- 1. Initial Entry and Count Room
- 2. Contamination Survey Station l- , 3. Simple Soil and Water Sampling l Protocol 12:00 - 1:00 p.m. Lunch 1:00 - 5:00 p.m. Exercise: Site Work Day (cont.)
1.
Initial Entry and Count Room l 2. Contamination Survey Station i 3. Simple Soil and Water Sampling N
l Priday 8:00 8:50 a.m. Regulations and Guidance on Radioacdve Wasts Disposa!
9:00 - 9:50 a.m. Ramedal and Disposal Opdons 10:00 - 10:20 a.m. Course Closing l 10:30 - 11:30 a.m. Course Exam
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State ofNew Mexico a
y ENVIRONMENTDEPARTMENT Hasardous & Radioactive Materials Bureau gx Y
}C y 20H Galisteo l l 5 P.O. Box 26110 w Santa Fe, New Mexico 87502 (505) 827 1557 GARYE. JOHNSON fax (505)82715M blAaKZ. WEWLER eovssNon SECsErMr
, EDGAR T. rRoRNroN.B1 asrurrsacssta r
. March 30,1998
Subject:
RLRS Licensing and Inspection Training Policy This document states the policy for training and qualification of personnel involved in radiological licensing and inspecticns for the New Mexico Environment Department, Hazardous and Radioactive Materials Bureau, Radiation Licensing and Registration Section (RLRS).
RLRS personnel must understand the facilities, equipment. processes, and activities of the ,
programs they inspect or license, as well as the enteria, techniques, and mechanics ofinspection and licensing. The qualification process will provide inspectors and license reviewers with sufficient information to conduct inspections and license reviews that are technically correct and in accordance with NRC regulations, policies and procedures.
J To provide standardized training protocol for licensing and inspections as set forth in NRC Inspection Manual Chapter 1246, this document mandates formation of the HRMB-RLRS Radiation Protection Licensing and Inspection Training Procedure.
~
Personnel assigned as inspectors or license reviewers in the RLRS program must successfully i
. complete requirements for inspection and/or licensing as detailed in individual Qualification Journals. Inspectors and license reviewers have 2 years to complete the Qualification Joumals,
- and are required to complete refresher training at intervals not to exceed 3 years. Until qualification is complete, the RLRS Program Manager may, at his/her discretion, assign personnel to inspection and licensing activities for which they have demonstrated adequate competency based on NRC criteria.
/A/Noii> ?k A5c.J William M. Floyd - Managfer N Radiation Licensing and Registration Section i
e l
MASTER TRAININGMATRIX l
nh a aret Waner M ;
Training Categories Lopez Medina Moore Fitch Garcia
~
SELF STUDY j NRC Orentation / / l CFRs / /
Regulatory Guides / /
. NRC inspection Manunt / /
I Industry Codes and Standards / /
- Licensinatinspection Site Wsits / /
NRC Manacement Duettves / /
Review of Sionificant Events / /
. Directed Review of Se!ected Licensino and inspection Casework / /
BASIC TRAINING and OJ.T.
Overali proaram onentation / / (
Review of State Regutations / /
Review of location of Rea Guides and reference matenal / /
Essentra!s ofinspection / Opt Essentials of Ucensina Opt /
Essentia's of Transpo tation / Oct 3
COURSE TRAINING Effective Communications for NRC inspectors (09) C Inspection Fundamenta!s and Procedures (G 101 or G 106) C S Licensino Practices and Procedures (G-109) C OSHA Indoctnnation (G-111) C Root Causellncident investigation Workshop (G-205) C I
inspecting for Perfo mance Materia!s Version (G-304) C NMSS Radiation Worker (H 102) or Site Access (H-100) C i Environmental Monitonna for Radioactivity (H 111) S S Air Samplina for Radioactive Material (H 119) S S Radiolooical Surveys in Support of Decommissionina (H-120) S HeaMh Physics Technology (H-201) C C Dinanostic and Therapeutic Nuclear Medicine (H 304) C C Safety Aspects of industnat Radiography (H 305) C C 4
Transportation of Radioactive Material (H-308) C C i Respiratory Protection (H-311) S i intemal Dosimetry and Whole Body Countina (H-312) S S Teletherapy and Brachytherapy Course (H-313) C C
! Safety Aspects of Well Locaina (H-314) S S i irradiator Technolooy (H-315) S S 1 REFRESHER TRAINING (Recuired eserv heos durim teksher rainim ofomertourses )
Fundamenta!s of Inspection Refresher (G-102) /
l / /
l Hea'th Physics Topica' Review (H-401)
\
SUPPLEMENTAL TRAINING 4
l i4 i
i i inspection /UcenSing Codes: / = Required C = Core S = Specialized I
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~ %g ENVIRONMENTDEPARTMENT gN a .
$ I l Hazardous & Radioactive Materials Bureau 20H Galisteo \
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so- P.O. Box 26110 Santa Fe, New Mexico 87502 (605) 827 1557 GARYE JORNSON -
"" Fax (605)82715H u a rs.wstat.an u carr a r EDGART.THoRNroN,M May 29,1998 auvrvsscur4 r l
1 i
Richard L.Bangart, Director Office ofState Progranu U. S. Nuclear Regulatory Cornmission Washington. D.C. 20555-0001 l
Dear Mr. Bangan:
As per Mr. Hugh L. Thompson's request in his letter dated December 30,1997, to New Mexico Environment Department Secretary Mark E. Weidler, I am submitting the third of the req monthly progress reports addressing the IMPEP Team's suggestions and recommendations. J Please note that for the suggestions and recommendations identified by the IMPEP Resiew T r quiring action by the State, those with responses reading "no further action required" indicate they were addressed in the first or second bi-monthly progress report, and that either no addit action was requh4 or that there have b%n no changes to the material previously subadtted, Please call me at (505)327-1862 should you have any ouestions.
Sincerely, h/hb
' William M. Floyd, Pmgram M ger Hazardous and Radioactive Materials Bureau
.cc:
Mark E. Weidler, Secretag, New Mexico Environment Department
~ Ed Kelley, Director, Water and Waste Management Division Benito J. Garcia, Chiet Harardous and Radioactive Materials Bureau
>s now
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MAY-29-98 FR1 12:31 HAZ/ RAD MAT BUR FAX N0. 5058271544 P.03 a
p, ACTIONS, DOCUMENTATION AND PROCEDURES ADOPTED BY NEW MEX RCP TO ADDRESS MRB CONCERNS DfTRODUCTION:
~ Below is a smnmary list of suggestions and recommendations ide
]MPEP Review Team as requiring action by the State:
! 1
. The review team recommends that the nuclear pharmacy inspection frequ from 2 years to 1 year. (Section 3.1)
Response
Nothing additional to report since last response.
2.
The review team recommends that initial inspections oflicensees be performedj months oflicensee's receipt of matedal and commencement of operations, consistent '
IMC 2800. (Section 3.1) i Response:
All radioactive matedallicenses issued since the IMPEP Review have been or will be inspected, within six months ofissuance. (i.e.,
Phase One Molecular Issued:
04/97 IaW: No material.
p 09/97 Avid Engincedng 12/97
!- 05/06/98 City ofAlamogordo 12/97 05/05/98 Bizzell Power, Inc. 12/97 04/27/98 Evans Engincedag 1/98 04/01/98 Wyfand X-Ray Service 03/98 Terracon,Inc. 05/98 As of 02/98).
W.W. Construction As of 05/28/98 04/98 l Trace, Incorporated As of 04/28/98 03/30/98 l As of 04/15/98
- l. 3.
The review team rwuwends that the tracking system be revised to allow initial to be readily identiSed to staff and management. (Section 3.1)
L
- Response:
Nothing additional to report since last response.
! 4.
. The review team recommends that the State increase the number of reciproc to better evaluate the health and safety implications of out-of-state companies New Mexico. (Section 3.1)
Response
Since August 1997, a total of28 reciprocallicensees have entered New Mexico. Of these, sixteen have been inspected on-site. The majority of the reciproca11icensee which were not inspected were due to insufficient notification time. Following i listing of reciprocal licensees which have entered the State since the previous submitted on April 1,1998.
i i
4.
i
.- . ~
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4 MAY-29-98 FH1 lbu HAu RAD MAT BUR FAX N0. 5058271644 P.04 l
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Name
. Type Date Entering NM inspElgd If not. Reason VectorEngineering IR 05/98 Tm-Tec Services, Inc.DM 05/12/98 05/98 Tru-Tag WL Insuf. Noti 5 cation time.
05/98 Insuttime to send anyone from Sants Fe To inspect.
5.
level which existed throughout the review period. (Se Response: !
As previously noted, the two Environmental Specialist positions vacatedl IMPEP Review were filled effective February 16,1998.
6.
The review team recommends that the State provide training personnel in brachytherapy and irradiator technology. (Section 3.2) 1
Response
Radiation Licening and Registration Section staff attended a one-day on XRF sponsored by Niton on April 20,1998.
training session on the use ofdensity/ moisture gauges on April 17
. Five RLRS staffmembers attended the 30th annur,! National Conference on Radiation C Mesa, Anzona.May 16-20, 1998.
Larry Stephenson, Director of Environmental Compliance for ProTechn Laboratories Company, will provide a week-long traming session for Radia Licensing and Registration Section staff the week ofJune 22 -26,1998.
the training outline is enclosed. A contract has been signed by the Depar ProTechnics to provide for this training.
7.
The review team recommends that the State develop a formahzed traini comparable to IMC 1246, " Formal Quahfication Programs in the Nuclear M Safeguard Program Area." (Section 3.2)
Response
A RLRS Training Policy Statement has been completed, as well as a Matrix. Qualification Journals for all RLRS staff have been completed.
8.
The review team suggest that documentation oflicense reviewer's actions be license files. (Section 3.2).
R sponse:
No further action sic e last response.
2
~
.'8 ,. "fiAN998'FRI12i32 ifAI/RAIOiAI~ BUR 7 AXIO 30iB2715dd [ 05 l
- 9. .
or demonstrations during a!! inspections.ra ons (Section 3 '
Reg-3n=: -
Nothing additional to report since last response.
' 10.
on allinspections. (Section 3.4).Ibe review team recommend
Response
No further action since last response (i.e., independent measurem
. conducted at all licensees inspected since the last response).
11.
physics issues during inspections, and increa 3.4).
Response
d No .further action since last response.
12.
inspections. (Section 3.4).The review team suggests the State '
Response
When since available, thelast response. anci!!ary staff have been interviewed during all inspe 13.
, The review team recommends that the State mspectors attempt to co meetings with the senior licensee inanagement on all inspections. (Sectio Response.
No further action since last response.
14 The review team isnecds that the State develop a forrnal process fo responses to de6ciency let* rs and closing open deSciencies. l
Response
Nothing additional to report since last response.
15.
, The review team suggests that the State develop a formal process for in s-t reviewers to document and transmit pertinent information to each o (Section 3.4).
4
Response
Nothing additional to report since last response.
'I 4
1
. 3 ]
i
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~
I HAY-20-98'FR1 12:33 ' AZdADflAEBk FAINO.50iB27b P[06
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16.
, The review team suggests that the State develop a process for ensun are complete, that all appropriate State documents are prepared and filed responses are received and Sed. (Section 3.4).
Response
Nothing additional to report since last response.
' 17.
The review team recommends that the State begin documenting a
- ' applicant's facilities when inspecting licensed activities, performing spe ;
! performing pre-licensing site visits during construction. (Section 3.4). ,
! Response:
+
Nothing additional to report since last response.
i 18.
i nyiew ofinspection repons. (Section 3.4).The review team Response: ,
Nothing additional to report since last response.
i 19.
The myiew team suggests that the State complete its revision of the inspec ensuring that each set offorms covers all key areas for the type oflicense) i and that RCP inspectors begin using the standardized forrn(s). (Section 3.4). ! ,
- Response
- j i
Nothing additional to report since last response, 20.
l The review team recommends that the State make onsite, documented i i
incidents, allegations, or misadnnnistrations with potential health a . . ,
source disconnects, possible over exposures, lost sources, contaminat
- ~
Response
Allincidents have been investigated via on-site visits. Thorough documen been provided for all investigations via revised incident report forms.
. 21.
The review team recommends that the State create an incident and alle
.! that would, at a minimum, identify the person taldng the initial report, list the n
! telephone number of the reporting party, provide the details of the incident j reported, record the State's conversation with the licensee or individual, describ
" actions taken by the licensee, describe the investigation conducted by the S results, list citations or other regulatory actions, show the date the investigatio out and justification for closure, show date(s) incident was reported to the NRC o of the form should be tn.intained in the incident f
Response
Nothing additional to report since last response. i 4
6_ _ - -- _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
].- - - MAY-29-98 FR1 12:33 HAZ/ RAD MAT BUR FAX NO. 5058271544 P.07
,. o 22.
investigations and evaluadons of the licensee's ac
Response
Nothing additional to report since last response.
23.
\
followed-up at the next inspection to vedfy tha implemented. (Section 3.5).
- Response
_ Nothing additional to report since last response.
24.
de5ciencies when applicable. (Section 3.5).The review t
Response
Nothing additional to repon since last response.
25.
The review team recuusuends that the State: (a) set up a separate sustom in the Santa Fe ofBee, keeping all documents and records pe one location, with the data cross-referenced to the licensermspectio Mbuquerque incidents and allegations. ofEce, (Section and3.5). (b) esablish a system to centrally log and Response: !
Nothing additional to report sinca k,t response.
26.
The review team recommends that the State develop and implemen responding to events involving radioactive matedal and are fully trained and qualiSed in emergency response. conduct training sessions u (Se tion 3.5). i
Response
Nothing additional to report since last response.
27.
The review team suggests that the State kee, mpanding the allegatio procedures for notifying the person making ti.e allegation of the result and including the allegation in the event reporting form, tracking s raponse procedures (Section 3.5).
Raponse:
Nothing additional to report since last response.
5
.- MAY-29-98 FR1 12:34 HAZ/ RAD MAT BUR FAX N0. 5058271544 P.08
.=
O 28.
The review team recommends that the State expedite promulgation of -
\
related 4.1.2). regulations now overdue and those which are due within the nex
Response
A meeting of the New Mexico Radiation Technical Advisory Council w Friday , June 26.1998 to consider the compatibility revisions to the N Radiation Protection Regulations. Following their consideration and consent, the amended regulations will be placed on the agenda ofthe ne (hopefully for the July meeting). meeting of the New Mexi 29.
The review team suggests that a file be maintained with the cove conespondence of all draft or final regulations sent to the NRC. (Section 4.1.2
Response
Notidng additional to report since last response.
6
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1 i INDUSTRIAL RADIOGRAPHY '
FOR STATE REGULATORY PERSONNEL l 1 INTRODUCTION 11 HISTORY OF INDUSTRIAL RADIOGRAPHY OPERATIONS i A.
INCIDENTS CASEHISTORIES B.
DEVELOPMENT OF RADIOGRAPHY EQUIPMENT Ill i SPECIFICATIONS FOR RADIOGRAPHY EQUIPMENT
- 1. CONTROL CABLES I
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RADIOACTIVE MATERIAL LICENSE REQUIREMENTS A.- ISOTOPES B. QUANTITY UMITATIONS C. LICENSED USES D. LICENSE CONDITIONS VI OPERATING AND EMERGENCY PROCEDURES A.
ORGANIZATION AND RESPONS!BILITIES B. PACILfTY LAYOUTS C. RADIATION SAFETY PROGRAM D. EMERGENCY PROCEDURES 1,
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DEVICES REQUIREMENTS FOR TRANSPORTATION OF RADIOGRAPH '
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PREPARATION FOR INSPECTION 1
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- 3. OPERATING AND EMERGENCY PROCEDURE REYlEW REGULATION REVIEW 4.
PREVIOUS VIOLATIONS NOTED B. I MANAGEMENT ENTRANCEINTERVIEW C. INSPECTION TOUR D.
CONFIRMATORY MEASUREMENTS E.
FOLLOW UP ON ITEMS OF NONCOMPLIANCE F.
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RADIATION SAFETY FOR BRACHYTHERAPY SOURCES
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RADIATION INSTRUMENTATION FOR NUCLEAR MEDICINE OPERATIONS VI REGULATORY INSPCCTION or.NUCLEAn MEDICINE OPERATIONS A. PREPARATION FOR INSPECTION
- 1. LICENSE REVIEW 2.
- 3. OPERATING AND EMERGENCY PROCEDURE REVIEW REGULATION REVIEW
- 4. PREVIOUS VIOLATIONS NOTED B. MANAGEMENT ENTRANCE INTERVIEW C. INSPECTION TOUR D. CONFIRMATORY MEASUREMENTS E.
FOLLOW UP DN ITEMS OF NONCOMPLIANCE F.
FOLLOW UP ON REPORTS SUBMITTED TO THE AGENCY G. ORGAN!ZAT10N i
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- 1. TRAINING PROGRAMS i
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STEP TWO DETERMINING THE PROPER SHIPPING NAME O.
STEP THREE SELECTING THE PROPER PACKAGE D. j STEP FOUR - DETERMINING THE PACKAGE MARKING REQUIREMENTS E.
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G. NOTIFICATIONS AND REPORTS TO INDIVIDUALS PRESENCE OF REPRESENTATIVES OF UCENSEE AND WORKERS DURING INSPECTIONS H.
I. CONSULTATION WITH WORKERS DURING INSPECTIONS 4
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Santa Fe, New Mexico 87502 (505) 827 1557 GARYE. JOHNSON fax (505)8271544 gob 1RN02 MBEE. WEmLER BECRETARY zoaARt.THORNToN,m DEPUTYSECRETARY August 18,1998 Richard L. Bangart, Director OfBee of State Programs U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Dear Mr. Bangart:
Thank you for your letter of August 6,1998, which documents the results of the Agreement State follow-up review held in Santa Fe July 7-10,1998.
We were pleased to learn that the State has responded to and resolved 28 of the 29 recommendations and suggestions from the 1997 review. The only remaining open recommendation, the promulgation of regulations required for compatibility, is in the process of resolution. The follow-up review team's recommendation to the Management Review Board (MRB) that for each of the five common indicators and the one non-common indicator reviewed, New Mexico's performance be found satisfactory and that the program as a whole be considered adequate to protect public health and safety and compatible with NRC's regulatory program is most encouraging to myself and staff. Depending on the scheduling of the MRB, I and Bill Floyd, of my staff, will plan on appearing before the MRB to discuss the review team's findings.
Once again, I appreciate the courtesy and assistance offered by the IMPEP review team and thank all of you for the advise and recommendations given to improve the New Mexico Radiation Control Program. We look forward to working cooperatively with the NRC in the future.
Sincerely, t.o Ed Kelley, Ph.D., Director Water and Waste Management Division E
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S-ATTACHMENT 1 W0llY '
- G Aaenda for Manaaement Review Board Meetina Mondav. September 28.1998 . 2:30 - 4:30 p.m.. TWFN. 2-B-5
- 1. Convention. MRB Chair convenes meeting (H. Thompson)
- 2. New Business - Consideration of New Mexico Follow-up IMPEP Report A. Introduction of New Mexico IMPEP Team Members (J. Lynch)
B. Introduction of New Mexico representatives and other State representatives participating through teleconference.
C. Findings regarding New Mexico Program (IMPEP Team)
Status of Materials inspection Program Technical Quality of Inspections Technical Staffing and Training Technical Quality of Licensing Actions Response to incidents and Allegations Legislation and Program Elements Required for Compatibility D. Questions. (MRB Members)
E. Comments from State of New Mexico F. MRB Consultation / Comments en issuance of Report (H. Thompson)
Recommendation for next IMPEP review
- 3. Old Business - Approval of the MRB minutes
- 4. Status of Upcoming Reviews
- 5. Adjournment (H. Thompson) f Attendees: Hugh Thompson, MRB Chair, EDO Richard Bangart, MRB Member, OSP Karen Cyr, MRB Member, OGC Carl Paperiello, MRB Member, NMSS Thomas Martin, MRB Member, AEOD Richard Ratliff, OAS Liaison to MRB Ed Kelley, Director, NM Water and Waste Management Division William Floyd, NM Water and Waste Management Division James Lynch, IMPEP Team Leader, Rlll Jack Hornor, IMPEP Team Member, RIV/WCFO Linda McLean, IMPEP Team Member, RIV Torre Taylor, IMPEP Team Member, NMSS Paul Lohaus, OSP
' ATTACHMENT 2
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