ML20154L194
| ML20154L194 | |
| Person / Time | |
|---|---|
| Issue date: | 07/10/1998 |
| From: | NRC |
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| ML20154L192 | List: |
| References | |
| NUDOCS 9810190170 | |
| Download: ML20154L194 (28) | |
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I INTEGRATED MATEP.fALS PERFORMANCE EVALUATION PROGRAM FOLLOW-UP REVIEW OF NEW MEXICO AGREEMENT STATE PROGRAM JULY 7-10,1998 l
i FINAL REPORT l
U. S. Nuclear Regulatory Commission i-
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i ENCLOSURE 1 9810190170 981007 I PDR STPR9 E!ONM .0 l . . . -
PDR j
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New Mexico Final Report Page 1
1.0 INTRODUCTION
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 comprised of technical staff members from the Nuclear Regulatory Commission (NRC). Team members are identified in Appendix A. The follow-up review was conducted in accordance with 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 Evaluation Program (IMPEP)." The follow-up review covered the State's response to, and resolution of,29 recommendations and suggestions made during the July 14-18,1997 IMPEP review. The follow up review covered the status of the program since the 1997 review. Preliminary results were discussed with New Mexico management on July 10,1998.
A draft of this report was issued to New Mexico for factual comment on August 6,1998. The State responded in a letter dated August 18,1998 (Attachment 1). The State's factual comments have been incorporated into the final report. The Management Review Board (MRB) met on September 28,1998, to consider the proposed final report. The MRB found the New Mexico radiation control program adequate to protect public health and safety and compatible with NRC's program.
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 Mexico Environment Department Secretary is appointed by and reports to the Governor. Within the Environment 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 included as Appendix B. The New Mexico program regulates approximately 245 specific licenses, including a megacurie pool irradiator, manufacturers, broad academic programs, broad medical programs, nuclear pharmacies and industrial radiographers.
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.
The review team's general approach for conduct of the follow-up review included:
(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 regu!ations; (4) review of quantitative information from the i
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 IMPEP performance criteria for each common and non-common performance indicator and made a preliminary assessment of the radiation control program's performance.
New Mexico Final Report Page 2 2.0 STATUS OF PREVIOUS REVIEW 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 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 performanco 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 final report. At the time of the review, the IMPEP team found the State's performance to be satisfactory for the indicators, Technical Quality of Licensing Actions and Legislation and Regulations Required for Compatibility; satisfactory with recommendations for improvement 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.
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 vear of the IMPEP review, that monthly conference calls take place with New Mexico staff, ana 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 Dirsttors 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.
New Mexico Final Report Page 3 1
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.
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.
l 3.0 COMMON PERFORMANCE INDICATORS The IMPEP process uses five common performance indicators in reviewing both NRC Regional 1 and Agreement State programs. These indicators are: (1) Status of Materials Inspection j 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 Issues identified under " Status of Materials insoection Proaram" 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, i
with respect to this indicator, Status of Materials Inspection Program, was found to be satisfactory with recommendations for improvement during the 1997 review.
l Recommendation The review team recommends that the nuclear pharmacy inspection frequency be modified from 2 years to 1 year.
Current Status The State indicated, in its October 10,1997 response to the draft review report, that the two-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 be current. The frequency was changed to 1 year imn-ediately after identification by the team during the 1997 IMPEP review. IMCs are now centralized in a file maintained by a technical staff person. The review team verified thu the State now inspects nuclear pharmacies on a l one-year inspection frequency. The staff also has access to the NRC inspection manual via the NRC's website. All of New Mexico's inspection frequencies are now at least as frequent as NRC's.
l Based on the follow-up review, the team considers this recommendation to be closed.
l Recommendation 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.
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New Mexico Final Report Page 4 Current Status The review team evaluated the timing of initial inspections for six new licenses issued during the review period. All six were inspected within 6 months of issuance. The Program Manager maintains a tickler file for all new licenses issued by the Program. He personally 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 callin 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 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 i tickler file, all new licenses issued. The Bureau Chief, who s gns 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 companies 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 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 t l maintained of all reciprocity requests with the date of inspection and the inspector's name or, if an inspection was not performed, the reason for the missed opportunity.
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New Mexico Final Report Page 5 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 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 reciprocity inspection.
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 indicator, which were identified as satisfactory ;
during the last review remained adequate and did not show deterioration. These areas include ;
inspection backlog and inspection report timeliness. ;
Based on the team's findings during the follow-up review and the IMPEP evaluation criteria, the review team recomrnends 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 identif6d under " Technical Quality of Inspections" The review team focused on the seven recommendaticas 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 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. j Recommendation The review team recommends that the State inspectors attempt to observe licensee !
operations or demonstrations during all inspections.
Current Status I
New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that Program management has begun more frequent eccompaniments 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 4 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 I
, discuss findings with the Program Manager as inspections are accomplished.
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i New Mexico Final Report Page 6 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 i various activities to observe. The team also verified during staff interviews that all inspectors l have copies of the " Standard Operating Procedures Manual for License inspections" and have l - been instructed in all aspects of the manual.
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 allinspections.
Current Status i
New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that the staff has been advised of the importance of pedorming 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 i each inspector was aware of the importance of performing independent measurements as a .
I 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 consiA.s this recommendation to be closed.
Recommendation The review team recommends that the State increase the rigor of reviewing technical I health physics issues during inspections, and increase the breadth and scope of 1 l inspections.
I Current Status I'
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 i forms and guidance documents.
i The review team found that the depth and scope of technical health physics reviews have l improved since the last review. The inspectors evaluated programs in more detail, reviewing l i
applicable technicalissues related to the type of program, including such areas as surveys, storage and shielding of radioactive material, security, and dosimetry. Staff interviews identified
, that allinspectors 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, i
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New Mexico Final Report Page 7 resulting in more in-depth inspections. The inspection reports have also been revised to l include more technical health physics issues.
Based on the follow-up review, the team considers this recommendation to be closed.
Suoaestion The review team suggests that the State inspectors attempt to interview ancillary workers during inspections.
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.
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 poss;ble as the inspection was at a field site or was a reciprocity inspection, where no ancillary l
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 l 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 allinspections.
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 always contact upper management upon entering a facility. This issue has also been discussed at staff meetings.
l 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.
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i Recommendation The review team recommends that the State develop a formal process for reviewing l licensee responses to deficiency letters and closing open deficiencies.
- Current Status l !
New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that all responses will be tracked using a tickler file; the Program Manager and the Bureau Chief will
, sign off on the adequacy of licensee responses; and requests for additional information are now l
l made in writing, with copies of all correspondence placed in license folders.
The review team found that staff have been made aware of the tickler file and the process for 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.
Sua_ aestion 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 reviewet 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.
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New Mexico Final Report Page 9 Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that each l 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.
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 hetions 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 l applicants' facilities when inspecting licensed activities, performing special inspections, or performing pre-licensing site visits during construction.
Current Status New Mexico responded, in its October 10,1997 response to the draft IMPEP report, that this issue has been discussed with all staff. Allinformation gained through trips to licensed facilities is now documented via rnemoranda to file, which are signed by the Program Manager.
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.
The inspection was documented in the license file. Additionally, the State instituted a telephone log for each license file as needed to document communications with the licensee.
b 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.
Current Status l
l 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 i
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New Mexico Final Report Page 10 l
for adequacy and are signing off on reviews. The Program Manager is signing off on all l documents entered in the files. .
1 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 did not appear to have been reviewed by management. Both were inspections in which no 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 Manager identified 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 resultad in more performance-based inspections.
Based on the follow-up review, the team considers this recommendation to be closed.
Suaaestion 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:
GeneralInspection 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 l response to this suggestion, and considers this suggestion to be closed.
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l New Mexico Final Report Page 11 The primary intent of this follow-up review was to close out programmatic deficiencies identified I 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 l during the last review remained adequate and did not show deterioration. These areas include l
l supervisory accompaniments of inspectors and appropriate regulatory actions resulting from i l Inspection findings. l
\ l Based on the team's findings during the follow-up review and the IMPEP evaluation enteria, 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.
3.3 Status of Pendina Issues identified under " Technical Staffino and Trainina" l I
The review team focused on the three recommendations from the 1997 IMPEP review. New ,
i 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 !
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 i l 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 experience. The program is now fully staffed.
l 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.
l 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 l University of New Mexico Cancer Treatment Center. Refresher training is planned annually at i
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.
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l L New Mexico Final Report Page 12 The NRC-sponsored Teletherapy and Brachytherapy course (H-313) is part of New Mexico's core training prograrn. The Program Manager intends to have staff attend this one-week course or an equally comprehensive alternative training course.
In June 1998, ProTechnics also provided a one-day training course on irradiator safety to the New Mexico staff. Tne training was coordinated with a visit to the Ethicon EndoSurgery pool irradiator in Albuquerque. Staff also attended a Nordion irradiator training course at Ethicon in September 1998.
The Program Manager plans to send one or two staff 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 Nuciear Material Safety and Safeguards Program Area."
Current Status The State developed a " Radiation Protection Licensing 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 journal 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 j 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 l during the last review remained adequate and did not show deterioration.
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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, i Technical Staffing and Training, be upgraded to a finding of satisfactory. l l
3.4 Status of Pendina Issues identified under " Technical Quality of Licensina Actions" The review team focused on the one suggestion from the 1997 IMPEP review. New Mexico's performance with respect to the indicator, Technical Quality of Licensing Actions, was found to be satisfactory during the 1997 review.
The team evaluated casework for 10 licenses, including the following types: pool irradiator, well logging, medical institution, broad scope academic, research and development, industrial l radiography, source manufacturer, and nuclear pharmacy.
Suaaestion The review team suggests that documentation of license reviewers' actions be maintained in license files.
Current Status ,
l The State responded in its monthly progress report, dated January 21,1998, that several of the !
documents that appeared to be missing from the files, were, in fact, present in the Albuquerque office. Since the IMPEP review, all files have been returned to the centralized office in Santa Fe. The importance of documentation for every action taken by staff has been discussed with I 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 additionalinformation from licensees. Additionally, license application evaluation forms are used to review applications and complicated amendments. The evaluation form includes the criteria, any comments by the license reviewer, and what is needed, either from the licensee or 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.
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 recommendations and two suggestions from the 1997
, IMPEP review. New Mexico's performance with respect to the indicator, Response to incidents and Allegations, was found to be satisfactory with recommendations for improvement during the 1997 review.
New Mexico Final Report Page 14 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 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 provadures, 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 fol!ow-up review, the team considers this recommendation to be closed.
l 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 l and telephone number of the reporting party, provide the details of the incident or l 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.
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New Mexico Final Report Page 15 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, the 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.
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 cf 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.
, Suaaestion l
The review team suggests that when evaluating incidents, the State cite appropriate deficiencies when applicable.
l e
New Mexico Final Report Page 16 i 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, l
Recommendation 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.
Current Status l 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 has been established 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, i
Recommendation 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.
l Current Status l
Three newly developed procedures: " Standard Operating Procedure for Response to incidents involving Radioactive Materials,"" incident Investigation Procedures," and " Incident Reporting i System / Abnormal Occurrence Criteria" were found adequate by the NRC after they were l included with the October 10,1997, letter from the State. The team verified that the procedures l were being followed by the investigators. The team also verified during staff interviews that all j
responders had been given copies of the procedures and that they had been instructed in 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.
I
New Mexico Final Report Page 17 Suaaestion 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 tho allegation procedures in the event reporting form, tracking system, and emergency response procedures.
Current Status The team found that the State's allegation procedures have been completely rewritten. There are provisions for notifying the person making the allegation of the results of the investigation.
The procedures have been changed to include allegations in the event tracking system and emergency response procedures.
Based on the follow-up review, the review team notes the actions taken by the State in response to this suggestion, and ccasiders this suggestion to be closed.
l 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 i during the last review remained adequate and did not show deterioration. Those areas include notifications of incidents to NRC and other Agreement States, i
Based on the team's findings during the follow-up review and the IMPEP evaluation criteria, the review team recommends tnat 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 program, Legislation and Program Elements Required for Compatibility 4.1 Status of Pendina issues identified under"Leaislation and Procram 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 l Program Elements Required for Compatibility, was found to be satisfactory during the 1997
! review.
l l Recommendation l
I 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.
l
New Mexico Final Report Page 18 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,"
10 CFR Parts 30,40,70, and 72 amendments (58 FR 39628) that became effective on 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 January 28,1994, and became due on January 28,1997. l a
" 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, i
" 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, l 60 FR 322) that became effective on January 1,1995, and became due on January 1, 1998.
l
" 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.
" Frequency 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.
a
" 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.
l
\
New Mexico Final Report Page 19
" Termination or Transfer of 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 18,1999.
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 effective on June 27,1997, to the current package.
This rule covers all previous Part 34 requirements, some of which were apparently overlooked in previous rule changes.
It is noted that Management Directive 5.9, Handbook, Part V, paragraph (1)(c)(iii), provides that the above regulations should be adopted by the State as expeditiously as possible, but not later than 3 years after the effective date of the new Commission Policy Statement on Adequacy and Compatibility, i.e., September 3,2000.
Until the overdue regulations become effective, the team considers this recommendation to be open.
Suaaestion 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.
Current 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 con.siders 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 deficiencies are being addressed, and program management is providing an appropriate amount of oversight and support.
l The follow-up review team found the State's performance in responding to and resolving 28 of i the 29 recommendations and suggestions to be satisfactory. The only remaining open recommendation concerns the promulgation of regulations required for comoatibility.
New Mexico Final Report Page 20 Funding for the program is still a major issue, especially regarding the training budget.
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.
As discussed earlier in this report, the follow-up review team considers aliof 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 recommended and the MRB concurred, 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 MRB also concurred in the team's recommendation 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 earlierin the report, for consideration by the State.
Recommendation The review team recomrnends 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)
I l
f
a i LIST OF APPENDICES l
Appendix A iMPEP Follow-up Review Team Members l 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
I i
i
APPENDIX A iMPEP FOLLOW-UP REVIEW TEAM MEMBERS Name Areas of Responsibility James Lynch, Rill Team Leader Status of Materials inspection Program Technical Staffing and Training 0 Jack Hornor, 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
M S
t APPENDIX B NEW MEXICO ENVIRONMENT DEPARTMENT ,
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t o-APPENDIX C l
i NEW MEXICO PROGRESS REPORTS JANUARY 21,1998, MARCH 27,1998, AND MAY 29,1998 I'
I l
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-- . .. - . - . - , . .-- - - - . . . . . - . - . - . . - . . - - . . . . ~ . . - . . _ . . _ .
3 State ofNewMexico
.i y ENVIRONMENTDEPARTMENT Hazardous & Radioactive Materials Bureau gx Y
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- P.O. Box 26110 . ;,
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l (505) 827 1557 .
- . CAEYE40RNSON fax (505)82715H MAaKE. WEDLER omsamos sacarra r EDGAs T. F#oJtNroN.m l wurrucarar
- i. January 21,1998 i, .
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! Richard L.Bangart, Director u L
05ce ofState Programs U.S.NuclearRegulatory C+ cMon 33 .1 Washington, DC 20555-0001 *..
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4
DearMr.Bangart:
J 4
i As per Mr. Hugh L. Thompson's request in his letter dated D= ni er 30,1997, to New Mexico L Environ-wnt 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 I appreciate the courtesy and concern expressed by the IMPEP review team and the members ofthe i*
MRB and thank all of you for the advice and recommendations given to improve the new Mexico Radation Control Program. We look forward to working cooperatively 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 Ed Kelley, Director Water and Waste Management Division Benito J. Garcia, Chief -
Hazardous and Radioactive Materials Bureau
. Akom / 3p;
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t .
ACDONS DOCUMENTATION AND PROCEDURES ADOPTED BY NEW MEXICO RCP TO ADDRESS MRB CONCERNS INTRODUCTION:
Below is a amunary list ofsuggestions and reconnnendations identiSed by the IMPEP Review Team as requiring action by the State:
1.
He review ' team recommends that the nuclear pharmacy inspection frequency be m Dom 2 years to I year. (Section 3.1)
P%+s: As Amh I indicates, inspection frequency for nuclear pharmacies has been increased Rom once every 2 years to annually. The two-year inspection frequency being used previously was based on that recommended in out dated copy ofIMC 2800.
2.
The review team recommends that initial inspections oflicensees be performed within 6 months oflicensee's rece.ipt ofmaterial and commencement of operations, consistent with IMC 2800. (Section 3.1)
Response
The Bureau Chief, who signs aD newly issued licenses, has established a hard copy fi for new licenses in his office and will track new license inspections on a six month basis. The RCP Program manager has established a tickler file and will remind inspectors ofinspections coming due during a two-month block at least a month in
=
to be
- 5+2+i within six months AdditionaDy, a standard condition has been added to newly-issued Be instructing licensee to notify RCP within ten days ofreceipt oflicensed material.
- 3. l The review team recommends that the tracking system be revised to allowinitial inspections to be readily identified to staff and management. (Section 3 1) 1
- =
P- v : Computer printouts oflicensees showing hsptions coming due will be generated the last week of every month. A copy of this printout will be given to both management and inspection staE This has been done for the month of October and January 1998, and will continue to be done the last week ofevery month.
4.
The review team recommends that the State increase the number ofrdg4ty inspections to better evaluate the health and safety implications of out-of-state companies working in NewMexico. (Section3.1)
. Response:
When notification is received of an out-of-state licensee's im=ading 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 in 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 between RCP Staff and reciprocal licensee to allow accompanied visit to field site. If staff workload, unavailability of staff or other considerations do not allow for inspections ofreciproc liran=~c in field locations, the RCP Program Manager will indicate on notification form w inspection were not conducted. Master redprocityinspection file will be maintained by RC Manager in Santa Fe. Reciprocal license inspections will be coordinated with routine inspec State li=== whenever possible to maximize use ofin-state travel nmdiaa Program goal willbe to conduct on-site inspections of a minimum of 50% of all Priority I and 2 reciprocal licenses. As ofD-M 1997, eight redprodtyinspections have been accomplished, including seven ofpr 1 and 2 licensees. This amounts to and inspection ratio of 73% of all reciprocallicensees the state.
1 i
5.
The review team recommends that the State maintain the RCP ataffing level to at least the level which existed throughout the review period. (Section 3.2) 4 2 l l
w -
7_.
Response: The two Environmental Spd lid positions vacated ainee 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 arein the process ofreguesting a ro. ranking ofappliant qualifications from State Personnel to better reflect actualqualifications.
l 6.
De review team recommends that the State provide training personnel in the areas ofmedical brachytherapy and irradiator technology. (Section 3.2).
F~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 mannally. There are currently brachytherapy programs at four hospitals i 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 irradiatorsin the State: the one at Ethic on and a 20,000 curie Co-60 model used for instructional and research purposes at the University 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
(+;= 4==, as well as the receipt, assay and radiation monitoring ofincoming radiophar== ear *im1s at las Alamos Medical Center on November 19,1997.
7.
The review team recommends that the State develop a formati=d training program w sreble e to IMC 1246, " Formal Q= hon Pivgiw in the Nuclear Material Safety and Safeguard Program Area"(Section 3.2) 3
P=ge=?.
De State is in the process ofdeveloping a formalized training program comparable toIMC 1246. De States ofTexas, Colorado and Arizona have been contacted about the po ofproviding on-hands training to the New Mexico RCP staff.
8.
The review team suggert: that doarmanwion oflicense reviewer's actions be maintained in beense files. (Section 3.2)
- Rw
- Several dommant< verbally identified by the IMPEP review team as being missing Domlicense files were in fact present in the Albuquerque RCP office. Since the IMPEP revie files have been returned to the centralized Santa Fe RCP office. The Mitance o for every action taken by staffin r.epsee to licensees' requests has been discussed at RCP staff i
meetings. A telephone log sheet has been inserted at the front ofevery license folder for do conversations. All requests for additional material from licensees will henceforth be in writing 9.
The review team reads that the State inspectors attempt to observe licensee operations or demonstrations during all inspections. (Section 3.4)
Response
Program Management has begun more frequent accompaniments ofjunior staff and l
will continue doing so as new staff are hired. A total of15 license inspections have occurred since theIMPEP review where management has accompanied staff. The Standard Operating Proc ,
Manual for License Inspections has been revised, and a copy has been made available to each s mv.-14r. The importance ofperformance based-inspections has been @aM at RCP staffm and inspection forms have been finaliW reflecting performance 4,ased inspections. The iru of interviews with workers, independent measurements, status of previous violations, and th
=>he== of discussions during exit interviews with management are reflected in the newly-r inspection report forms.
With the relocation ofall but one inspector to a centralized location, the Program Manager wi be able to discuss inspections face-to-face with inprs 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 of5cc inspector will personally bring all inspection forms to the central ofEce and discuss AnAinge with the Program Manager as inspections are accomplished.
- 10. The review team recommends that the State ia= =*ers conduct independent spesawunents on allla5=+ ions. (Section 3.4)
P&: RCP staffhave been advised of the *ruyvrece of taking independent measurements i
en allinspedane 'Ibe State Lientific laboratory Division (SLD) is working more closely with the RCP in d5 4 bgr-u needs (Quarterly =c+' g: are now being held bet ;w SLD and the RCP to detennine analytical needs ofthe RCP and radic-A :cly capabilities of SLD). Independent measurements have been made on all issgtions since the IMPEP Review.
11.
The 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) i
Response
la5** ion forms and inw=* ion Guidance Dennante have been revised to reflect the imycrece ofin-depth inspections. Monthly staff meetings have been inhiated and will to discuss sevised forms and guidance documents. Minutes ofthese Mage have been kept showing the s of these di=~=< ions.
12.
The review team suggests that the State inspectors attempt to interview ancillary workers duringinspections. (Section 3.4)
Response
RCP staffhave been reminded ofthe importance ofinterviewing ancillary workers duringiaWon. The provisions of Subpart 10, Section 1005, New Mexico Radiation Protection Regulations, which pertain to consuhation with workers during inspections have been discussed during staffma*inge 5
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! 13. The review team recommends that the State inspectors attempt to conduct formal edt l i
meetings with the senior licensee management on all inspections. (Section 3.4)
Fw: 1 Won forms and inspection guidance dommante now indicate that "the closeout conference abould be held with the licensee's highest level of management available," and that I
~@ ors should always contact upper management upon entering a facility." The importance of l co**g upper management as a follow-up, if upper management is unavailable at time of j inspection, has been discussed at staff Mge. Senior Management exit interviews have been held on allinspections conducted since the IMPEP Review.
t l l 14.
- ne review team r= -- = 'e that the State develop a formal process for reviewing licensee responses to deficiency letters and closing open deficiencies. (Section 3.4) l R-ycnse:
All responses will be tracked using ticider file. Both the RCP Pogram 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.
1 15.
- ne 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
l Weekly staff meetings are now being held to discuss the previous week's activities.
RCP Fwgr.is Manager and inspectors discuss infonnation resuhing from previous week's insp efforts. Any need for documentation is satisfied in writing 16.
- ne review team suggests that the St:ae 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. (Section 3.4) s 6
Response
Each Wer will be held responsible for ensuring that au Won files assigned to him or her are complete and that responses to letters ofviolation are received in timely manner.
In accordance with Item 14, adequacy ofresposses is now approved by both Program Manager and Buresa chiet.14tters in reply to licensee responses wiu be signed by Program Manager. Program Manager is reviewing license files each time " circle of coris,yondence"is completed pertaining to Ecensing action, inspection, or incident.
17.
The review team recommends that the State begin documenting all trips to licensees' or applicants' facilities whenr irs ecf-g licensed activities, performing special Wons, or performing pre licensing site visits during construction. (Section 3.4)
P= pas:
The importance of documentation has been dL~s ad at RCP staff Mags. All information gained through trips to licensed facilities is now documented via memoranda to file signed oFon byRCP Program Manager.
- 18. "De review team reco .
--A that the State management exercise more stringent supervisory review ofinspection reports. (Section 3.4)
Response
By relocating all but one of the RCP inspectors to a centrahzed location, inspection reports are no longer being allowed to se==dde witho:st management review in field office. Both Program Manager and the Bureau Chief are revising licensee responses to cited violations for adequacy and are signing off on reviews. Program Marger is signing off on all documents entered in files.
19.
The review team suggests that the State complete its revision of the inspection report form ensuring that each set of forms covers all key areas for the type officensee being inspec and that RCP inspectors begin using the standardized form (s). (Section 3.4)
Response
All inspection report forms are being habad and copies have been distributed to 7
[ .. .
a
=
staft Staffhave been advised as to how
- Won forms are to be completed during staff training snectings.
20.
The review team recommande that the State make onsite, de==amad investigations of incidents, allegations, or =i=d- ' 24.Gons with potatial heahh and safety effects (i.e.,
source f+: -
==pA4 over exposuru, lost mees, contamination, etc.)(Section 3.5)
Re3-:-a; A guidance document has been written omiinia: the standard operating procedures to be followed in response to incidents involving radioactive materials. A copy ofthese documents has been provided to each RCP staff ==t-er. The contents of these incident response guidance damment have been ditme=ad at RCP staff ==9 NRC has indicated satisfaction with current l report forms and the manner that incidents are now being investigated and documented.
21.
The review team r+:+ m.=de that the State create an incident and allegation reycrJsg form that would, at a mini =n=, identify the person taking the initial report, list the name and l telephone number of the reycrdsg party, provide the details of the incident or allegation as reported, ncord 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 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. (S Re;+s; Incident and allegation report forms have been developed by the RCP which incorporate all of the above, Additionally, standard op.Gug procedures have been developed for both incident and allegation investigations and made available to Program Staff.
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) 8
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I RP =: Arws; has been developed for making independent investigations and evaluating l
thelicensee's actions.
23.
The review team recommande that the State initiate procedures to ensure incidents are L
foHowed-up at the next kg=% to verify that the licensee's corrective actions have been implemented. (Section 3.5) i R pra A separate section entitled -rm u-*4eports" has been higreed into inspection i
fonns giving information an types ofincidents that may have occurred since last inspection and to address noti 6 cation reports and corrective actions. The @rtimee of completing this section has been stressed with RCP staff.
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 occurred resulting in a reportable incident. Management interviews are being held to discuss cause efincident, results and corrective actions taken.
- 25. 'Ibe review team me =Ac that the State: (a) set up a separate incident and allegation Se system in the Santa Fe oEce, keeping all documents and records pertaining to an incident in one location, with the data cross-referenced to the license /mspection Ses 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) l
Response
The hxident and allegation Se system has been moved from the Albuquerque osce to the Santa Fe osce. A new Incident / Allegation MM has been developed, as well as a new Incident / Allegation Report Form. The NMED database is being utilized to track all incidents and aDegations and forwarded to NRC. A chronology se (hard copy) will also be kept in the Santa Fe t 9 l
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.s of5ce, and a tickler file has been established to track the progress ofincidents and allegations. .
l 26.
'Ibe review team recommends that the State develop and implement written procedures for
) s,= i% to events involving rad % material and W training sessions until all staff j are fuDy trained and qualified in emergency response. (Section 3.5) i P5== = Written procedures am in place for i yc,rurg to events invoMag radioactive material and staffhas been instructed in their use.
27.
The review team magests that the State keep %= 4% the allegation procedures to include procedures for notifying the person making the allegati:n of the results of the investigation and including the allegation in the event i.yc, ring form, tracking system, and emergency response procedures (Section 3.5)
Response
A guidance document is now in place covering various aspects of allegation procedures, including the notification of the person mMng the allegation. Allegations are being 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. (Sect 4.1.2)
Response
Subpart 3, Section 311. G.4.s through d (pages 3-32 through 3-33) contains the compatibility language for "Deconunissioning Recordmkeep' g and License Termination; Documentation Additions" and was adopted by the New Mexico EIB, April 3,1995, and became etrective May 3,1995.
Language from the Federal Register (61 FR 24669) was approved by the Radation Technical Advisory Council (RTAC) for inclusion under Subpart 3, Section 311.G (page 3-32) NMAC3.1. T RTAC will recommend adoption of these changes by the Environmental Improvement Board.
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Self-Ouarantee as an Additional Finandal MHaai=. "10 CFR Parts 30,40, and 70 pm=6a=*n (58 FR 68726 and 59 FR 1618) that became effective on January 28,1994, and which became due on January 28,1997. hag"= a from the Federal Register (58 FR 68726 and 59 FR i 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 recommend adoption ofthese 1
changes to the Envisc ===u1 Ir-yivw Board.
Work continues on inserting language for the following ==aad=a ** to the New Mexico Radiation Protection Regulations. Once the insertions have been made, the amended regulations will be taken befbre the RTAC for approval prior to submittal to the Envic ==1 Improvement Board. (These will be adopted no later than May 1998):
1.
Timeliness in Decommissioning ofMaterials Facilities, "10CFR Parts 30,40 and 70 amendments.
2.
Preparation, Transfer for Cen-4 Distribution and Use ofByproduct Material for Medical Use, "10 CFR Parts 30,32, and 35 amendments."
3.
Iow-I.evel Waste Shipment Manifest Information and Reporting, "10 CFR parts 20 and 61 emendments."
4.
Frequency ofMedical b= min =+ ions for Use ofRespiratory Protection Equipment, "10 CFR Part 20 amendments."
5.
Radiation Protection ReqG w. Amended Definidons and Criteria, "10 CFR Parts 19 and 20 amendments."
- 6. n Medical Adminie tion ofRadiation and Radioactive Materials,10 CFR Parts 20 and 35 ammadmar*=."
7.
Clarification forDecommissioning Funding Requirements, "10 CFR Parts 30, 40, and 70 mmandments."
8.
Compatibility with the International Atomic Energy Agency, "10 CFR Part 71
, amendment."
9.
Termination or Transfer ofUcensed Activities: Record keeping Requirements,"10 CFR Parts 20 and 30."
11
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- 29.
ne mim team suggests that a Se be mai**i=16 the a h w q ence ofau draR or M regulations sent to the NRC. (Section 4.1.2).
l P e==-:-s:
AU NRW =-- --ywo-dence perta. .mmg to regulation development is @ b 8eParate Se for easy access.
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m State cfNewMexico .
q ENV1RONMENTDEPARTMENT Masardous & Radioactive Materials Bureau gh y l 20H Galisteo I
P.O. Box 26110
\- Santa Fe,New Mexico 87502 (505) 8271557 cm2.JORNSON Fax (505)82715M MAarK vsIDLt.n sovsame ascarra r soc 4a r.ruoax m u. m mamrrancarra r March 27,1998 - so to Richard L.Bangart, Director Office ofState Programs "
Ea U.S. Nuclear Regulatory Commission !-- 9}
~
Washington, D.C.20555-0001 ---
Dear Mr.Bangart:
i 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 j requested bi monthly progress reports addressing the IMPEP Team's suggestions and l recommendations.
l 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 submitted..
t Please call me at (505) 827-1862 should you have any questions.
Sincerely; l
(AuJ.
William M.Floyd L
Program Manager l< cc. Mark E. Weidler, Secretary NMED i
Ed Kelley, Director Water and Waste Management Division Benito J. Garcia, Chief Hazardous and Radioactive Materials Bureau i
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l ACTIONS, DOCUMENTATION AND PROCEDURES ADOPTED PY NEW MEXICO !
RCP TO ADDRESS MRB CONCERNS i INTRODUCTION: Below is a summary list of suggestions and recommendations identified by the IMPEP Review Team as requiring action by the State:
l
- 1. The review team recommends that the nuclear phannacy 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 months oflicensee's receipt of material and commencement of operations, consistent with IMC 2800. (Section 3.1)
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 Avid Engineering 12/97 As of 01/98 City ofAlamogordo 12/97 As of1/29/98 Bizzell Power, hr. 12/97 As of 02/98 Evans Engineering 1/98 As of 02/98 l 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)
Response: Nothing additional to report since last response. l
- 4. 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 companies working in New Mexico. (Section 3.1) l l
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 l which were not inspected were due to insufficient notification time. Following is a l listing of reciprocal licensees which have entered the State:
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_m > _ _ . _ _ - _ _ . . _ . - _ _ _ _ . . _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _
Hama Iygg Date Enterina NM Inspected If not. Reason Westex IR 09/97 09/97 Production Logging - WL 08/97 Insufnotification time.
Transystem Corp. DM 08/97 Insuf. notification time.
BPB Wireline WL 08/97 Insufnotification time.
Gammametrics DM 08/97 Insuf. noti 6cationtime.
Agra, Earth & . .
Environmental ' IR ' 08/97 Insufnotificationtime.
Dakota Geophysics WL 12/97 12/97 ThermNuclean(SoilVolume 08/97 08/97 1 Reduction).
Nucletron(HDRReloading) 10/97 10/97 Amarillo Testing DM- 10/97 10/97 Nordion (PoolIrradiator)) . I1/97 11/97
. Transystems DM - 01/98 01/98 Nucletron(HDRReloading) 01/98 01/98 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
, ; Century Geophysical WL 03/98- 03/98 4
HighlandsEnviron(NORM) 02/98 Insuf.notificationtime.
Agra, Earth, & Env. IR 03/98 Insuf.notificationtime.
BPB Wireline WL 02/98 Insuf. noti 5cationtime.
Speedie Associates DM 03/98 03/98 Welenco WL 01/98 Onlandunderexclusive Federaljurisdiction.
Tru-Tec Division DM 01/98 Insuf.notificationtime.
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) g . Response: The two Environmental Specialist positions vacated since the IMPEP Review were l filled effective February 16,1998. The resumes of the two newly- hired staff l members are attached (See Attachment 1). Both Mr. Garcia and Mr. Fitch are l proving to be excellent employees, being both knowledgeable and highly motivated.
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l 6. The review team recommends that the State provide training personnel in areas ofmedical 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 l
for Protechnics, a Core Laboratorice Company, on April 2,1998, to discuss training for RLRS staff in inspecting pool irradiators, industrial radiogn:phers, gauge operators, and radiation safety for radioactive material laboratory operators. Training l in these areas will be from the regulator's perspective (See Attachment 2 for the course outline of Subs'.nface 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 ofview). In regards to further training options, RLRS staff will be attending a three-day course on A'dvanced 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 traming course in Albuquerque on August 24 and 25 on pool irradiators. Alsc, RLRS staff attended a 5-day EPA sponsored Safety Course on Radiation Safety at Superfund Sites, March 16-20 (Attachment 6).
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- 7. The review team recommends that the State develop a formalized training pror, ram
' 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 training 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.
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. 9. The review team recommends that the State inspectors attempt to observe licensee operations !
or demonstrations during all inspections. (Section 3.4).
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Response: No further action since last response other than the fact that an additional five management-accompanied inspections have been performed.
i 10. The review team recommends that the State inspectors conduct independent measurements i on allinspections. (Section 3.4).
i j R v r: No further action since last response (i.e., independent measurements have been
- conducted at all licensees inspected since the last response).
s 11. The 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. The review team suggests the State inspectors attempt to interview ancillary workers during inspections. (Section 3.4). I Response: When available, ancillary staff have been interviewed during all inspections conducted since the last response. '
- 13. The review team recommends that the State inspectors attempt to conduct formal exit meetings with the senior licensee management on all inspections. (Section 3.4).
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.
- 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: Nothing additional to report since last response.
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- 16. "Ibe 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. (Section 3.4).
R m =: Nothing additional to report since last response.
- 17. He 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 performing pre-licensing site visits during construction. (Section 3.4).
. R p-: Nothing additional to report since last response.
- 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.
l 19. He review team suggests that the State complete its revision of the inspection report forms, ensuring that each set of forms covers all key areas for the type oflicensee being inspected, and that RCP inspectors begin using the standardized form (s). (Section 3.4).
Response: Nothing additional to report since last response.
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- 20. The review team recommends that the State make onsite, documented investigations of incidents, allegt.tions, or misadministrations with potential health and safety effects (i.e.,
source disconnects, possible over exposures, lost sources, contamination, etc. (Section 3.5).
L 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 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. (Section 3.5).
_ Response: Nothing additional to report since last response.
1 22.
He 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. He review team recommends that the State initiate procedures to ensure incidents are followed-up at the next irspcGon to verify that the licensee's corrective actions have been implemented. (Section 3.5).
~ P:g ==: Nothing additional to report since last response.
- 24. He review team suggests that when evaluating incidents, the State cite appropriate items of deficiencies when applicable. (Section 3.5).
Response: Nothing additional to report since last response.
- 25. He 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 training sessions until all staff are fully trained knd 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 form, tracking system, and emergency response procedures (Section 3.5).
Response: Nothing additional to report since last response.
6
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 of the Emironmental 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.
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Stanley A.Fitch (SS# 585-70-6011) 83014th Street,NW #12 Albuquerque,NM 87114 Phone (505) 898-4475
.e QUALIFICATIONS
SUMMARY
Mr. Fitch has nine years experience in health physics. Five years in support of environmental restoration projects, and four years in support of operations at Sandia Nationallaboratories. ,
His environmental restoration assignments were related to uranium mill decommissioning and tailings restoration at both DOE and commercial sites. His tasks provided an i excellent health physics basis. Mr. Fitch implemented several health physics programs. l Not limited solely to routine health physics survdh=, 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 i 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 $480.11 and 5400.5.
Prior to entering heahh physics, Mr. Fitch served for 10 years as a land surveyor and civil engineering technidan. In the 1970's he served 3 years as a plant operator in an uranium
-,exide production facihty.
- CLEARANCE Active DOE Q-Clearance e EDUCATION 1987 New Mexico State University A.S. Political Sciences (Additional classes in mathematics, sciences, and computer science)
Page 1 of 4
.- . . i Stanley A. Fitch (SS# 585-70-6011) 83014th Street,NW #12 Albuquerque,NM 87114 Phone (505) 898-4475 1990-93 lead Health Physics Technician Atlantic Richfield Company ARCO BluewaterMill Grants, NM Assisted in health physics surveillance for an extensive uranium mill restoration ;
project (up to 120 construction personnel during some periods). Duties included l environmental and occupational sampling and surveys, management of the health physics databases, analytical lab, dosimetry and bioassay programs Reconstructions of environmental and occupational exposures, case and project histories. Mr. Fitch was also procedure writer, and provided technical advice and ;
assistance to the site RSO.
Other duties included field and laboratory characterization of soil and wastes, and correlation of radiometric data to action limits to vedfy 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.
D 1989-90 I4ad Health Physics Technician Landmark Reclamation ARCO Bluewater Mill Grants, NM Contractor health physics duties to ARCO at the same Bluewater Mill project
. described above. Duties include occupational monitoring and decommissioning surveys.
1988-89 I4ad Health Physics Technician ChemNuclear Systems,Inc.
(Chemical Waste Management)
Ambrosia Lake Uranium Mill DOE UMTRA Site Coordinated health physics support for field and laboratory work. Database management. Dosimetry and bioassay program implementation, soil and waste Page 3 of4
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l Mark G. Garcia 3331 SchumacherNW i
Albuquerque, New Mexico 87120 (Office)(505) 881-3196
{ (Home)(505) 833-0773 l
l Professional Experience l MDM Lamb May,1997to February,1998 l 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
[ oiBench Scale Testing at the Nevada Test Site for The Plutonium Cleanup Project at Johnston Atoll. The principal health physicist for the development ofsurface gamma scanning techniques, utilized during the characterization of a depleted uranium contaminated 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 (atmospheric 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 radioactive materials to the accessible environment. These computer codes include CAP-88PC, AIRDOS-EPA, GENII, GENII 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, l-Events, and Processes). During this process the outline set forth by BIOMOVS H was utilized. This cutline involves the use of the Rock Engineering System (RES) matrix.
City of Albuquerque Public Works January,1996to November,1996 l Wastewater Utility Division Albuquerque, New Mexico Program Specialist HI / Health Physicist. Devekp and implement Radioactive Discharge Management Program (RDMP) for the City ofAlbuquerque Wastewater Utility Division. Program activities include: establish a permitting, monitoring, and reporting prograng develop a sampling program to obtain data on radioactive material in the regional environment, including soils, river l sedunents, river water and sewage; model environmental exposure scenarios using computer models
! such as GENII and RESRAD to assess potential exposure to the general public and the workers at
! the wastewater utility department; 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.1 4. . /... ,L /
1 Lamb Associates Inc. March,1995 to September,1995 l
Albuquerque, New Mexico l Nuclear Engineer / Junior Health Physicist. Contract work with Sandia National Laboratories Environmental Remediation Field OfHee, 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.
!t Albuquerque Medical Physic: December,1994 to March,1995 Albuquerque, New Mexico Assistant Medical / Health Physicist. Assisted in all areas ofhospital health physics which include nuclear medicine audits, dose calculations for patient and fetus, equipment calibrations and shielding design.
, 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: radiopharmaceutical preparation, quality control, and injection; patient handling and imaging; quality control on all instrumeots used in a clinical nuclear medicine department.
Education j 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 emphasis 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.
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. September 1990. l The National Certification Agency For Medical Personnel Certified Clinical Laboratory Scientist. August 1989.
American Society of Clinical Pathologist. Certified Medical Technologist. September 1989. ;
Publications 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.
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FEB-24-1998 08:45 PROTEO NICS INT'L 261679 9Er76 P.01 l
FAX TRANSMISSION PROTECHNICS ENVIRONMENTAL e so DAmr AsHrono, src 444 HOUSTON,1TXAS 77070 (as i s 40e-3734 hx: tas1 e70-es7e To: BILL FLOYD Date: February 23,1998 Fax #: (505) 827-1544 Pages: 4, including this cover i From: LARRY J. STEPHENSON
Subject:
TRACER.IRAINING COURSE COMMENTS:
1 Bill:
Attached is the outline for the upcoming training course. I added information about performing an inspection of a tracer operation. We can change any or all of this outline to fullfill your specific needs.
Call me after your review. We also need to set the dates for the course.
Larry J. Stephenson i
l,.
ProTechnics Environmental
.ow.m e m ,w.
L %"rm"e Phone. 301)aB M 72 Fat M IM7 H S75 SUBSURFACE TRACER OPERATIONS FOR STATE REGULATORY PERSONNEL i INTRODUCTION 11 HISTORY OF TRACER OPERATIONS
! lll CURRENT METHODS OF TRACER INJECTION (HIGH PRESSURE / LOW PRESSURE)
- 1. AREAS OF POTENTIAL CONTAMINATION
- 2. TYPES OF INCIDENTS THAT CAN OCCUR L IV MANUFACTURER OF TRACER MARRIAL r
A. SOUD TRACERS B. GAS TRACERS C. UQUID TRACERS '
V RADIOACTIVE MATERIAL UCENSE REQUIREMENTS A. ISOTOPES' l B. QUANTITY UMITATIONS C. LICENSED USES D. FORMS OF MATERIAL E. UCENSE CONDITIONS VI OPERATING AND EMERGENCY PROCEDURES A. ORGANIZATION AND RESPONSIBluTIES B. FACluTY LAYOtJTS C. RADIATION SAFETY PROGRAM D. EMERGENCY PROCEDURES E. TRAINING FOR TRACER PERSONNEL F. RADIOACTIVE TRACER HANDLING PROCEDURES G. TRACER WATER FLOOD PROCEDURES H. BIOASSAY PROCEDURES
..FEB-24-1998 08846 PROTECW ICS INT'L 281679 9ET?6 P.03
- 1. RADIOACTIVE WASTE DISPOSAL J. RECElVING AND MONITORING RADIOACTIVE TRACERS K. TRANSPORTATION OF RADIOACTIVE MATERIAL L COLLAR MARKER PROCEDURES Vil STATE REGULATIONS FOR TRACER OPERATIONS Vill D.O.T. REQUIREMENTS FOR TRANSPORTATION OF TRACER MATERIAL IX RADIATION INSTRUMENTATION FOR TRACER OPERATIONS X REGUthTORY INSPECTION OF TRACER OPERATIONS A. PREPARATION FOR INSPECTION
. . . 1. UCENSE REVIEW .
l 2. OPERATING AND EMERGENCY PROCEDURE REVIEW l .
- 3. REGULATION REVIEW l 4. PREVIOUS VIOLATIONS NOTED B. MANAGEMENT ENTRANCE INTERVIEW C. INSPECTION TOUR
- D. CONFIRMATORY MEASUREMENTS E. FOU.OW UP ON ITEMS OF NONCOMPLIANCE F. FOLLOW UP ON REPORTS SUBMITTED TO THE AGENCY
\
- G. ORGANIZATION H. LICENSEE AUDITS
- 1. TRAINING PROGRAMS J. RADIATION PROTECTION PROGRAM K RADIATION SAFETY EQUIPMENT AND INSTRUMENTATION
- 1. INTERNAL EXPOSURE PROTECTIVE EQUIPMENT
- 2. EXTERNAL EXPOSURE PROTECTIVE EQUIPMENT L RECEIPT, TRANSFER AND DISPOSAL ProTechnics Environmental om. % ofcoe.Labove w es. k
-. .. . ...- ., .- . . _ _ = . . . - . . . . - . . . . . . ~ - _ - . . - . . . . . . _ - . - - . . . - - . . . . .. . - - . .
,, Ft"B-24-1998 98846 PROTEONICS INT'L 281679 9Er?6 P.04 i
M. TRANSPORTATION PROGRAM N. POSTING OF NOTICES / PROCEDURES /UCENSE. ETC.
Q. ENVIRONMENTAL MONITORING PROGRAM P. EMERGENCY PLANS Q. MANAGEMENT EXIT INTERVIEW l
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'Ib: 3iI/ F/qL r,om: Margie A. Dronen Location: Location: 345 Hills, Rm 171 Phone: Phone: (509) 376-8226 Fax: 5715- /27- /E7/# yax: (509) 376-2364 Verify: Verify: (509) 376-8226 Number of Pages Including Cover Message: A I)7V1 070- If 544n S h A l moric Aowce, ,
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7 James H. Portsmouth, Manager Waste Management Federal Services, Inc.
Transportation Iegistics Nothwest Operations (509)376 7164 P.O. Box 650, MSIN H1 14 Fax:(509)376 2364 Rlehland, Washington 99352-0700 1
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CONFIRMATION NOT CE .
AdvancedRadioacdve Material hausportation NationalIVaxsportanon Progran Dates: Tuesday, March 31,1998 -Thursda g, Apri!2,1998 Time: 8.00 a.m. - 5:00 p.m. each day l Imcation: Energy Training Center (ETC) 1 Kirtland AirForceBase 1401 Maxwell St.
Albuquerque,NM 87118 Phone:(505) 845 5402 Fax: (505) 845-5262 Per Diem: 370 Lodging / $34 Meals .
l Badges: Students tell guard at gate you are DOE and attending a class at the
! Energy Training Center (ETC). -
~
Required Calculator j Material: .
4 14dging: For your convenience, a block of sleeping rooms have been reserved at the following hotel undst the group name " Department ofEnergy "(DOE). Reservations ale your responsibility. The cut off date to make your hotel reservation is February 23,1998.
When checking in iand out, be sure that your room rate is within government per diem.
WinrockInn
, 18 Wierock Center,N.E.
I Albuquerque,Newyexico 87110 (505) 883-5252 . Fax:(505)889-3206 (800) 866-5252 i Directions: From Albueuercue International Airoort to Winrock Inn-Please see attached map. .
From Winrock inn to Kirtland Air Force Base-Please see attached map. Allow 20. minutes travel time in case of heavy morning traf5c. l T
f 1
i
Energy Trainiing Complex, ETC Y '
1401 Maxwell St. KAFB West, Albuquerque,NMJ 87118 .
Phone (505)'845-5402 FAX (505)845-5262 .
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- C2 23.C33*of10AMILAr4L N13-FlVC 3SO6S8beeJJ a Los Alamo?., screaucrds scien o ~4 Tcchncingy, NIS-5
. National Laboratory FAX Transmittal Cover Sheet
- Informal Correspondence Date 2/26/98 Time 9:02 43 AM O fax s.nt Number of pages 7 Date _2/26/98 (including this page)j Sender Ay .
1mmmmmmum FROM: TO: O mA Correspone.ne.
Sendino Station Receivine Station l N me Anene M. Mersyo l Name: _Wriem Floyd Signature -
F1 / did p Company:
f-Campany Safeguards Science and Technology (NIS 5)
Los Alamos National Laborstory P. O. Box 1663 MS E540 Phone Number:
Les Alamos, NM 87545 USA Phone No. 505/667-5258 FAX Number:
127-1544 FAX No. 505/665-5055 Confirm Number:
C:afirm No. 505/667 5258
Subject:
Message l Find attached information regarding our training courses (reguested by Joe Wachter). Thanks.
Distribution l
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. o,_n........o e m a-r m i so==a s s LANUDOL .,ahguards Tcchnelsgy Trainin, rograin
, * .- Los Alamos National Lab:ratory
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W Ims Alamos / DOE Safeguards TM. bg Training program was begun in 1973 with a single, week-long trainmg course on the Fumismenfals o[NOMdestrNefiW Assey o[Nudeaf Malerial.
i I 1he program has grown over the succeeding 18 years to four courses that serve the full DOE complex, '
NRC, the domestic nuclear facilities and intamational safeguards practitioners. The courses offered a
by Les Alamos Nudear safeguards staff are a unique resource for the support of US nuclear matenals ,
accounting and safeguards and US Non-proliferation pohcaes. The courses are taught by the sesearch staff and involve actual hando on sneasurement expenence with real nuclear material samples and with instrumentation currently available for 6 eld and in-plant measurements. It is anticipated that i j dennand for these laboratory NDA courses will expand,in view of the increased emphasis by the '
Department of Energy on Materials A - e4 and sedmical suppor'. of US Nonprohfaration j initiatives. ..
The Ims Alamos Safeguards training resource has also extended beyond the DOE eponsored courses to become an integral part of the IAEA L WW Trammg Program and the US Nudear Non-Ptohferation Act (NNFA). Mandated Safeguards Training for developmg countnes. As sudi, the DOE
{
Safeguards Research and Development Program and its associated Technology Training Program l provide widespread practical trammg an nondestructive assay tedmiques for appliation in nuclear i
j materials accountmg, process ccatrol, nudear and citicality safety, and nuclear safeguards.
- Presented below are brief syrwapees of the cunat.-r ;.L. af courses offered through the i
1.ANI /DOESafeguardsTWo.d sy Training Prognun. Formoreinforenatioru ContactJanetSander .
[505467 5258, FAX 505465-5055 ] Ies Alamos National Imboratory, Safeguards Technology Trauung
{ Psogram, P.O. Box 1663, Mall Stop E540, Ims Alamos, NM 87545.
i 1
Course
Title:
Nondestructive Assay Techniquesfor Safeguards Practitioners -MCA-241 . April 6-10,1998
} - Designed for: Expenenced practitioners in the area of nuclear material assays for material j .
j mce4 and proarss control. The course is open to DOE contractor and NRC licznsee employees who manage or perform nuclear material assays for thesepurposes. Employees of other organizations are 4 accepted on a space-available basis.
{ Hours: 36 (4.5 days) Course is offered approximately annually.
j
Description:
This course is an introduction to the nondestructive assay (NDA) of nuclear materials j
j using both gamma rey and neutran measurement techniques. Topics include gamma-ray and neutron j
interactions with matter, detectors, uranium ennchment measurement, transmissichm..c.J
- gamma-ray assays, neutron singles countmg, and both active and passive neutron comcidence countin6-(
Both uranium and plutonium bearing materials are rneasured. Curriculum involves plenary lectures i
to introduce the topics, followed by hand on laboratory measurements to illustrate the concepts.
1 Activities involve the use of radioactive matenals. Attendance is limited to 32 students.
Goals of the course:
j To provide the student with Arst-hand snessurement experience with neutron snethods 7 and esy assay To acquaint the student with the NDA instrumentation available for needed sneasurements To provide the student with the knowledge to apply appropnate measurement tedudgues to i
various NDA problems j y ds.cs with nuclear radiation measurement .py Prerequisites: Some sc .t is desirable, as is j familiarity with nuclear radiation and assooated mathematics. Although not required, successful completion of the CTA course MCA 140is recommended.
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LANUDOE Saftguards Techno1cgyTraining Program !
, Los Alamos National Laboratory Course
Title:
Gamma-Ray Spectroscopyfor Nuclear Materials Accounting-MCA-343 (not offeredin 1998)
Designed fon Expenanced practitiorwrs in the area of nuclear material assays for material
==~eing and process cuntrol. The course is open to DOE contractor and NRC licensee employees who l
ananage or perform nuclear material anssys for these purposes. Employees of other organizations are accepted on a space evallable basis.
. Hours: 36 (4.5 days) Course is offered .yy.m .ately annu' ally.
Description:
- Ihis course covers the use of high resolution gamma-esy spectroscopy to measure various uranhan and phrtcmium matemals. Topia include uranium and plutonium isotopics measurements, transmission-corrected assay techniques inchading the segmented gamma scan procedure, absarption-edge densitornetry, and x ray Suorescence. Bench-top apparatus and measurements are used to j illustrate basic ansay pnnciples and also to demonstrate complete automated systems for in-plant use.
Activities involve the use of radacactive mate. rials. Attendance is limited to 24 students-Goals of thecourse .
To provide the student with first-hand measurement expenence with advanced, high-reschrtion gamma-ray asasy methods {
i e .
To acquaint the student with the advanced NDA instrumentation available for needed snessurements To provide the student with the knowledge of measurement physics and data analysis techniques for application to various NDA problems Preregalsites: Although not required, successful completion of the CTA course MCA440is recommended. Also recommended are previous experience with nuclear radiation measurement equipment and familiarity with nuclear radiation and assomated mathematics.
Course
Title:
Materials Accountingfor Nuclear Safeguards - MCA-111 March 9-13,1998 Designed for: 4-.M Nuclear Safeguards practitioners who operate, manage, or evaluate materials accounting systems.
Hous: 36 (41/2 days)
Description:
The course covers methods for desi 6 nin5 and implementmg conventional and near-real-tLw accounting systems for safeguarding nuclear material Incture topics include Basic Materials Accountmg Concepss,7he St ucture of Safeguards Systems, Measurement Technology, h-.c.t Control Statistical Basis of Materials Aczounting, Nudaar Material Holdup, Materials Accounting at speafic types of facilities, MC&A system decision analysis and detection sensitivities, and International Safeguards. Short workshops are conducted an topics such as NDA measurement technology, measurement statistics, simulation of matenals accounting, measurement controt and error propagetion.
Goals of the couroc Upon sw-=ful cosnpletion of this course, attendees will be famihar with the basic concepts of nuclear materials w.Lig systems and the roles of the associated technologies and techruques to operate such a system.
Prerequisites: Although not requued, prior completion of the CTA course MCA 101 is I,w r..w.ded.
DOE Docs Zap / General School Dom /SG Tech Trrig.
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- .. i LANI/ DOE Safeguards Technology Training Program Los Alamos Nationallaboratory Cousse TIGe: Nondestructive Assay Inspector Tr'aining Course February 3--13,1998 .
Designed for: IAEA inspectoes with less than 1 year's expenance who perform safeguards mspections in nuclear facilities worldwide.
Bours: 68 (81/2 days). Tuesday mornmg through the following Priday noon.
Descdytton: This carree provides broad and in depth expenance with both neutron and gamma-ray NDA techniques for quantitative measumnet of SNMitems. Topics include basic neutron detector and gamma-ray detector designs, active and passive neutron colnddence measurements, and gamma-ray anansurements of uranium asM . ant, plutoniumisotopic e -',Wtion, and spent-fuel ds.J aics.The course concludes with a team-onented performance test in which unknown SNM inventory items are ciWM and quantified to establish an inventory. Attendance is Itmited to 12 students.
Goals of the course:Upon successful completion of this course, attedoes willbe thoroughly famihar with the appropdate mondestructive assay instruments and techniques ava!!able for needed snensurements.
F erequisites: Previous experience with nuclear r=<hatirm measurement eq4.. ant is se =w.ded.
Famiharity with nuclear radiation and assoanted mathematics is assumed.
Course Tine: Nondestructive Assay of Special Nuclear Materials Holdup
- MCA-243 . April 27-Mayla1998 Designed for: E-g;aacsd practitioness in the area of nuclear material assays for material
' eccmmtin6 and process control. The course is open to DOE contractor and NRC licensee employees who manage or perform nuclearmaterial assays for these p ys.es. Employees of other organizations are accepted on a space evallable basis.
~
- Hours: 36 (4.5 days) Courseis offer d approxirnately annually.
Description:
This course covers the apphcation of basic nondestructive assay techniques and field-portable instrumentation to the measurement of nuclear material holdup deposits in process
.q4.s.t and ductwork.1.e'.~..uy exercises will emphasize procedures for calibration and measurement of uranium and plutonium holdup, using mainly gamma. ray instrumentatica and a generahzed-p y approach. Measurements w!D be performed on simulated deposits using SNM standards inserted within equipment (pipes, ducts, tanks, pumps, etc.) that represents process equ2pment hardware. Equipment attenuaticm'and self attenuation effects will be considered.
1.a~..W experzanents will be supplemented with lectures on topics related to holdup measurements.
students. Activities involve the use of radioactive materials. Attedance is limited to 24 Goals of the course:
To provide the student with first-hand sneasumnentre,c es with portable nondestructive assay equipment under in plant conditions .
To acquaint the student with measurement stategies and todmiques that mirdmize sneasurusnent uncertanties To provide the student with the knowledge of the generalized-geometry approach to calibration and data analysis for the varied measurement geometries ecountered in holdup uneasurement campaigns . .
Frerequisites: "Ihe foDowmg are recommended: Experience with nuclear radiation measumnent equipment, practical e,c, Jam with nuclear radiation and = =winted snathematica, and successful completion of the CTA course MCA-140.
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LANUDOE Saftguards Technology Training Program ;
Les Alamos National Laboratory '
l Course
Title:
International Training Course on State Systems of Accountingfor and Control ofNuclearMaterials (SSAC) '
May 3-21,1999 Designed for. Nuclear tedmologssts in developing countries that have aespdred or are about to acquire nuclear ;.d.c.k,.y.
Hours: 3 weeks. Two weeks in Santa Fe on general SSAC pnndples and m uss. One weekin a model fadlity to illustrate application of a SSAC.
Description:
This course is mandated by the US Nonprolderation Act of 1978 and prevides in<iepth inforznation on how to design a State System of Accountmg for and Control of Nudear Material that will allow full-scope IAEA safeguards of that state's nudear facilities. System attributes are discussed for :nany possible facahties, and examples of SSACs in place worldwide are described. The course fmishes with a workshop in which a SSAC is designed for a model facility.
l Goals of the cmurse:Upon successfulwkthi of this course, attendees will be thoroughly 8-ihe with the requisite attrbutee of 6 SSAC and with the requirements for appropriate interaction with the IAEA.
Frurequisites: Fam!harity with the rnaclear fuel cycle and experience in state nuclear programs is 1 assumed in those students invited to attend. !
l Ad-Hoc Training for International Safeguards Practitioners:
Designed for: Nudear facility operators and intemational inspectors who must verify the effectiveness of materials accounting systems or perform nonproliferation-motivated inspections.
Hours: Has varied from 2 days to one week. Trammg has been offered cm request to intemational .
inspection teams, and state facility S..e1.
Description:
This training has provided lecture materials and hands <m rerEMai on in. field nudear 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-field conditions, with real samples of special nudear materials that replicate sample attrbutes
-y-Gd in real field exercises.
Goals of the course: Upon sue-eful completion of this course, attendees w!Il be famIhar with in-field inspection techniques involving nudear measurements and associated data evaluation.
Prerequisites: Fanuharity with the nuclear measurements, instrumentation, and associated mathematics, as well as experience in nuclear fuel cycle fadlities and programs.
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i Waste and Residue NDA Measurements
~
/f19' Days required for course: approximately 4.5 !
Course topics 1
- Waste certification regulatory requirements e Safeguards.quirements
- Neutron NDA 'erhniques o Gamma NDA techniques l .
Segmented and Tomographic gamma-ray scanning Differential Dicaway and Combined Therrial-Epithermal Neutron Interrogation
- 1 Neutron Coincidence Counting, Add-a Source, and Californium Shuffler techniques Attendance Limit: 24 Students 1
Course objectives e
First-hand measurement experience with advanced neutron and gamma. ray
[ instruments e
Understanding of how existing NDA equipment applies to waste characterization and l safeguards issues Demonstrate the use of NDA radiation measurement techniques and equipment to assay TRU and low level contact handled waste Experience with nuclear radiation measurement equipment is desirable, as isfamiliarity with nuclear radiation andassociatedmathematics. Although not required completion of CTA course MCA-HOis recommended.
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S2*aS-oa81os90AMit.At& NIS*F4VC 38o308 4433 e 7. ?
Waste and Residue Nondestructive Assay (NDA) Measurements Training School Deseeiption:
This course will provide plenary lectures on waste assay requirements for safeFuards. waste charactenration mquirements to meet waste acceptance criteria.and neutron and gamma ray based maste and residue NDA techniques. Three major course tradules will provide hands-on training with actualinstruments used sci assay radioactin isotopes in 55 gal. drums: (1) the Segmented Gamma-ray Scanner tSGS I and the
- Tomographie Gamma. ray Scanner (TGS):(2) Neutron Coincidence Counting with Add-a-Source.and the Californium Shuffler: (3) the Differential Dienway Technique. Combined Thermal Epithermal Neutron interrogation. Each module will cover topics such as calibration procedures and use of standard teference maierials: matria efleets, limitations, cometions: response variation due to radioactiw material distnbution .
within the maste drum: sensitivity; lump effects (gamma) / oelf. shielding (neutron) cometions: isotope identification / ratios (gamma) and their importance for neutron assay: acope of the techniques with respect to mete forms and limitations. The course will conclude with a workshop session hetween instructors and students on the particular waste problems of most interest to the students.
Goals:
Upon successful completion of this course, anendees will have gained the following:
. An understanding of cunent DOE safeguards and characterization issues assoeisted with saste and residue measurements.
Hands-on training in the operation and use of major waste and residue NDA systems.
Knowledge needed to apply appropnate measurement techniques to the waste and residue masenals present in their facilities.
Designed For: .
Esprienced radioactive measurement technicians who operate asste assay instruments and their technical supervisors. Also, auditors and regulators who mustjudge the results 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 organizations are accepted on a space.available basis. (Attendance is limited to 24. students.) '
Prerequisites:
Some experience with nuclear radiation measurement equipment and techniques is desirt.ble. Attendees should.hase a knowledge of gamma-ray spectroscopy and neutron counting. but these topies will be reviem ed. Although not required, successful completion of MCA 140, (-Basics of MC&A Measurement")
is recommended.
Location:
The course will be conducted at 1.os Alamos. New Mexico.
Duration: 4.5 days
. t Time Frame ,
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, 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 1
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No. of Staff Course Course Attending Cost Total j Field Instnunentation 5 5162.00 $810.00 Laboratory Spill Cleanup 5 $163.00 5815.00 Radiological WorkerI Training / 5 5152.00 $760.00 l
Radiological Worker 11 Training .< 5 $176.00 $880.00 Portable Suney Instnunent Training 5 $127.00 $635.00 l TOTAL $3900.00
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AGENDA RADIATION SAFETY AT SUPERFUND SITES (185.11)
City, State Date Course Director: Name of Course Director I Instructors: Name ofInstructor Name ofInstructor Techniden: -
Name of Tarhaletan i
Day and Time Subject Speaker Monday 12:30 - 2:00 p.m. Orientation and imroduction 2:10 - 3:00 p.m. Atomic Structure and Radioactive Decay 3:10 - 4:00 p.m. Interaction of Radiation with Matter l 4:10 - 5:00 p.m. Radiation Exposure and Biological Effects 5:10 - 6:00 p.m. Radiation Exposure Umits and Methods I 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 0:40 - 10:30 a.m. Surveying for Radioactive Materials 10:40 - 12:30 p.m. Exercise: Radiation Survey Meters
- 1. Exposure Rate 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
.. 8:00 - 8:15 s.m. Dosimeter Calibration Check
~-
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7-i A Day and Time Subleet Sparkar
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Wednesday (contJ 8:20 - 9:50 a.m. Exercise: Characteristics of Unknown Sources / Dose Assessment 10:00 - 10:50 a.m. Radiation Signs and bbels
- 11:00 - 12:00 p.m. Contamination Control -
12:00 - 1:00 p.m. Lunch 1:00 - 1:50 p.m. Anti-Contamination Clothing and Respiratory 7. e Devices i
2:00 - 2:50 p.m. . Radiological Comrol Area Demonstration 3:00 -3:50 p.m. Decontamination 4:00 - 5:00 p.m. Problem Session: Decontamination Thursday 8:00 - 8:50 a.m. Radioactive Material Packaging, Labeling, and, Shipping 9:00 - 9:50 a.m. Radioactive Soll and Water Sampling l 10:00 - 12:00 p.m. Exercise: Site Work Day-
- 1. Inida! Entry and Count Room
- 2. )
Contamination Survey Station l
. 3. Simple Soil and Water Sampring !
Protocol .
12:00 - 1:00 p.m. Lunch !
i 1:00 - 5:00 p.m. Exercise: Site Work Day (cont.)
. 1. Initial Entry and Count Room
- 2. Contamination Survey Station
- 3. Simple Soll and Water Sampling Protocol Friday 8:00 - 8:50 a.m. Regulations and Guidance on Radioactive Wasta Disposal 9:00 - 9:50 a.m. Reme(sal and Disposal Optiont 10:00 10:20 a.m. Course Closing 10:30 - 11:30 a.m. Course Exam ..
g 8/97
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State ofNew Mexico q_ ENVIRONMENTDEPARTMENT gx
\ }L Hasardous & Radioactive Materials Bureau qqqV 20H Galisteo P.O.-Box 26110 me- Santa Fe, New Mexico 87502 (505) 827-1557 GMtYE,rchM3oN fax (505)82715M MAaKE. WEDUR 80VEENot ssestrnY EDGAR r. THoaNTON,M 1 worrucatrar 1 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 inspections 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 actisities 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 acco: dance with NRC regulations, policies and procedures.
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 complete requirements for inspection and/or licensing as detailed in individual Qualification Joumals. Inspectors and license reviewers have 2 years to complete the Qualification Journals, 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 criterit.
/AN&S h William M. Floyd - Mana(er N
! Radiation Licensing and Registration Section l
i
},* MASTER TRAININGMATRIX
" d f 3
{ Stanley Fitch Mark Garcia Margaret Lopez Walter Medina Jerrie Moore
) SELF STUDY 4 NRC Orentation / 7
} CFRs / /~
j ReQutatory Guides / /
! NRC inspection Manual / /
l industry Codes and Standards / /
i Limnsing/tnspection Site Visits / /
i NRC Management Directives / /
j Reviewof Sionificant Events / /
j Directed Review of Selected Licensino and inspection Casework / /
j BASIC TRAINING and O.J.T.
i Overall program onentation / /
j Reviewof State Reaulations / /
l Review oflocation of Rec Guides and reference matenal / /
j Essentia!s of Inspection / Opt i 8 Essentials of Licensina opt /
Essentia's of Transportation / opt l
l COURSE TRAINING j Effective Communications for NRC inspectors (OP) C Inspection Fundamenta!s and Procedures (G-101 or G-108) C S I Licensing Practices and Procedures (G 109) C OSHA Indoctnnation (G-111) C Root Causelineident investication Workshop (G-205) C k
Inspecting for Performance - Materia!s Version (G-304) C
- NMSS Radiation Worker (H-102) or Site Access (H-100) C j Environmental Monitonno for Radioactivity (H-111) S S Air Sampling for Radioactive Material (H-119) S S l
l Rad.olooical Surveys in Support of Decommissionina (H 120) S Heatth Physics Technology (H-201) C C l
5 Diagnostic and Therapeutic Nuclear Medicine (H 304) C C Safety Aspects of industrial Radicaraphy (H-305) C C Transportation of Radioactive Materia!(H-308) C C Respiratory Protection (H 311) S Intema! Dosimetry and Whole Body Counting (H 312) S S Teletherapy and Brachytharapy Course (H-313) C C Safety Aspects of Well Logging (H-314) S S j lirad:stor Technolooy (H 315) S S j REFRESHER TRAlNING (Re7uimiewy 3 was durim renesher ruinine ofoverenes 1 4 sundamentats of inspe: tion Refresher (G-102) /
Hes'th Physi:s Topica! Review fH-401) / / i
! SUPPLEMENTAL TRAINING l I
1
(
1 I
Ir i
e Inspection / Licensing Codes: / = Required C = Core S = Specialized i
d4,V-
0b82I1544 State ofNewMexico
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- ^? g a ENVIRONMENTDEPARTMENT
@k Hazardous & Radioactive Materials Bureau 208 Galisteo -
g&
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h a- P.O. Box 26110 Santa Fe. New Mexico 87502
\ \
(505) 827 1557 GARYEJOHNStW c.o m sos Fax (605)82715H kaxt. wtwr.za sscstrar KDGM T. THOMTON.IR May 29,1998 D2!UrYstcktrAs y Richard L. Bangan, Director Oflice ofState Programs U. S. Nuclear Regulatory Commission Washington. D.C. 20555-0001
DearMr.Bangart:
As per Mr. Hugh L. Thompson's request in his letter dated December 30,1997, to New Mexic Environment Department Secretary Mark E. Weidler, I am submitting the third of the re monthly progress reports addressing the IMPEP Team's suggestions and recommendations.
Please note that for the suggestions and recommendations identified by the IMPEP Resi r: quiring action by the State, those with responses reading "no further action required" ind they were addressed in the first or second bi-monthly progress report, and that either no action was required, or that there have ba.cn no changes to the material previously submit Please chIl me at (505)S27-1862 should you have any cuestions.
Sincerely, h/hb Wi!!iam M. Floyd, Piegram Man ger
(
Hazardous and Radioactive Materials Bureau cc:
Mark E. Weidler, Secretag, New Mexico Environment Depamnent Ed Kelley, Director, Water and Waste Management Division Benito J. Garcia, Chiet Hr.rardous and Radioactive Materials Bureau dUu G io'Ob h - DPP-
, MAY-29-98FR112:31 ilAZ/ RAD MAT BUR FAX N0. 5058271544 P.03 s' .
ACTIONS, DOCUMENTATION AND PROCEDURES ADOPTED BY NEW ME }
l RCP TO ADDRESS MRB CONCERNS I INTRODUCTION:
' Below is a summary list ofr_ggestions and recommendations iden IMPEP Review Team as requiring action by the State:
1.
The review team recotumends that the nuclear pharmacy inspection freque 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 months oflicensee's receipt ofmaterial and commencement of operations, consiste!
IMC 2800. (Section 3.1)
Response
All mdioactive material licenses issued since the IMPEP Review have bee or will be inspected, within six momhs ofissuance. (i.e.,
Issued: Inspected:
Phase One Molecular No material:
^
04/97 09/97 Avid Engineering 12/97 05/06/98 City of Alamogordo 12/97 05/05/98 Bizzell Power, Inc. 12/97 04/27/98 Evans Engineering 1/98 04/01/98 Wy!and X-Ray Service 03/98 Terracon,Inc. 05/98 As of 02/98).
W.W. Construction As of 05/28/98 04/98 Trace, Incorporated As of 04/28/98 03/30/98
. As of 04/15/98 3.
The review team recommends that the tracking system be revised to allow ini to be readily identified to staff and management. (Section 3.1)
Response
Nothing additional to report since last response.
4.
The review team recommends that the State increase the number tf reciproch to better evaluate the health and safety implications of out-of-state cornpanies NewMexico. (Section 3.1)
Response
Since August 1997, a total of28 reciprocallicensees have entered New Mexico. O these, sixteen have been inspected on-site. The majority of the reciprocal licensee which wue not inspected were due to insufficient notification time. Following is
.submitted listing ofonreciprocal April 1,1998.
licensees which have entered the State since the previo 4
i 1
a
' ~
^ ^
i.f~HAi-2'9-98FRi12i32- HAZ/ RAD' HAT Bl1R ~ ~ ~ ~ FAfN0"50'58271544 P. 0 i
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F.AOC hag Date Entering NM Insp.ggard i if not. Reason
' VectorEngineering IR 05/98 Tru-Tec Services, Inc.DM 05/12/98
[ 05/98 Tru-Tag WL i 05/98 Insuf. Notification time.
i Insuttime to send '
i anyone from Santa Fe To inspect.
! 5.
i i level which existed throughout the review period. (S
! Response:
I As previously noted, the two Environmental Specialist positions vacat IMPEP Review were filled effective February 16,1998.
i 6.
- The review team recommends that the State provide training personne
! brachytherapy and irradiator technology. (Section 3.2)
- Response
- Radiation Licensing and Registration Section staffattended a one-d on XRF sponsored byNiton on April 20,1998.
i
- trainmg session on the use ofdensity/ moistureFive .
gauges RLRS on April 17 i
staffmembers attended the 30th annual National Confere Mesa, Anzona, May 16-20,1998.
, Larry Stephenson, Director ofEnvironmental Compliance for ProTech i Laboratories Company, will provide a week-long training session for Ra 1 Licensing and Registration Section staff the week ofJune 22 -26,1998.
j the training outline is enc ~.,ed. A contract has been signed by the De 1 ProTechnics to provide for this training.
i 7.
The review team recommends that the State develop a formahzed tra Safeguard Program Area." (Section 3.2) comparable to IMC 12
Response
A RLRS Training Policy Statement has been completed, as well a Matrix. Qualification Journals for all RLRS staff have been completed.
8.
The review team suggest that documentation oflicense reviewer's action license files. (Section 3.2).
Response
No further action since last response.
2
~
) HAY-29-98FRI12:32 HAZ/ RAD MAT BUR FAX NO.' 5058271544 P. 05 1
- 9. -
or demonstrations during a!! inspections. (Section perations Pg-==:
Nothing additional to report since last response.
10.
The review team recommends that the State inspectors on allinspections. (Section 3.4). ments conduct in
Response
No further action s' ace last response (i.e., independent meas!
conducted at all licensees inspected since the last response).
11.
physics issues dudng inspeedons, and incre 3.4).
Resper e:
No further iction since last response. ..
12.
inspections. (Section 3.4).The review team suggests the Stat
Response
since thelast response.When available, ancillary staffhave beei 13.
I meetings with the seniorlicensee managemen Response.
No further action since last response.
14 The review team wieueuds that the State develop a formal proce responses to de6ciency leuers and closing open de5ciencies.
Response: !
Nothing additional to report since last response. 1
- 15. l The review team suggests that the State develop a formal e process reviewers to document and transmit pertinent information to ea (Section 3.4). .
Response
Nothing additional to report since last response.
t t
3 3
i
( - .- . _ .
-. .~. - . . - . - . _ . - . . - . - . - _ - . - - - . - - - - - - . - - . . - . -
- flay-29-98FRI12:33 HAZ/ RAD MT BUR FAX WO. 5058271544 P.06
- 16. I The rewcw team suggests thst the State develop a process for ensu are complete, that all appropriate State documents are prepared and file responses are received and filed. (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 performing pre-licensing site visits during construction. (Section 3.4).
Response
Nothing additional to report since last response.
18.
i review ofinspection reports. (Section 3.4).De review team
Response
Nothing additional to repon since last response.
19.
The review team su8 gests that the State complete its revision of the insp ,
and that RCP inspectors begin using the standard
Response
Nothing additional to report since last response.
20.
! The review team recommends that the State make onsite, documented incidents, allegations, or misadministrations with potential health . . ,
source disconnects, possible over exposures, lost sources, contamin L Response:
Allincidents have been investigated via on-site visits. Thorough documen been provided for all investigations via revised incident report fonus.
1 ;21.
The review ~ team recommends that the State create an incident and '
that would, at a minimum, identify the person taking the initial report, list th telephone number of the reporting party, provide the details of the incide reponed, record the State's conversation with the licensee or individual, desc
! actions taken by the licensee, describe the investigation conducted by the i results, list citations or other regulatory actions, show the date the investigat
! out and justification for closure, show date(s) incident was reponed to the NRC of the form should be maimained in the incident
Response
Nothing additional to report since last response.
I
!- 4 1 - .. . - . . - - .-
3~ flay-29-98 FR1 12:33. _ _MZ/ RAD fiat BUR FAX N0. 5058271544 P.07 1
- 1 l
.~..
22 investigations and evaluations of the licensee's Pv==: Nothing additional to repon since last response.
23.
\
followed-up at the next inspection to venfy implemented. (Section 3.5).
r een thi j
1
Response
Nothing additional to report sincelast response.
~24 defidencies when applicable. (Section 3.5).The review!
Response: !
Nothing additional to repon since last response.
- 25. j system in the Santa Fe of!!ce, keeping all d one location, with the data cross-referenced to the license /msp Mbuquerque office, incidents and allegations. (Sectionand3.5).
(b) establish a system to centrally log
Response
Nothing additional to report since last response.
26.
The review team recommends that the State develop responding to events involving radioactive material and ures for and impleme are fully trained and qualified in emergency response. conduct training sessions u (Section 3.5).
Response
Nothing additional to repon since last response.
27.
De review team suggests that the State keep expanding the alle and including the allegation in the event rep response procedures (Section 3.5).
Response
Nothing additional to repon since last response.
5
c ' flay-29-98FRI12:34 HAZ/ RAD flat BUR FAX N0. 5058271544 P.08 I
\
l i 28. l The review team recommends that the State expedite promulgation l
l related 4.1.2). regulations now overdue and those which are due within the n .
1
! Response:
1 A meeting oftbc New Medeo Radiation Technical Advisory Council
! Radiation Protection Regulations. Following consent, the amended regulations will be placed on the agenda ofthe (hopefully for the July meeting). meeting of the New Mex 29.
The review team suggests that a file be maintained with the co correspondence of all draft or final regulations sent to the NRC. (Section 4 l
Response: j Nothing additional to report sinee last response. l 1
I l
6
- - - - - - * ' ' ^ ~ ~ ' " ~ ^ ^ ~ ^ ^ ' ' ~ '" ~ '
[7tiAYh9-98FRIh2:35
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- 1. CONTROL CABLES
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RADIOACTIVE MATERIAL LICENSE REQUIREMENTS A. ISOTOPES B. QUANTITY LIMITATIONS C. LICENSED USES D. LICENSE CONDITIONS VI OPERATING AND EMERGENCY PROCEDURES A.
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DEVICES REQUIREMENTS FOR TRANSPORTATION OF RADIOGRA IX RADIATION INSTRUMENTATlON FOR RADIOGRAPHY OPERATION X
REGULATORY INSPECTION OF RADIOGRAPHY OPERATIONS A.
PREPARATION FOR INSPECTION
- 1. LICENSE REVIEW 2.
- 3. OPERATINGREVIEW REGULATION AND EMERGENCY PROCEDURE REVIEW 4.
PREVIOUS VIOLATIONS NOTED B.
MANAGEMENT ENTRANCEINTERVIEW C. INSPECTION TOUR D.
CONFlRMATORY MEASUREMENTS E.
FOLLOW UP ON ITEMS OF NONCOMPLIANCE F.
FOLLOW UP ON REPORTS SUBMITTED TO THE AGENCY G. ORGANIZATION H .
LICENSEE AUDITS 1.
TRAINING PROGRAMS J .
RADIATION PROTECTION PROGRAM K .
RADIATION SAFETY EOUIPMENT AND INSTRUMENTATION
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DEVELOPMENT OF IRRADIATOR EQUIPMENT 111 SPECIFICATIONS FOR 1RRADIATOR EQUIPMENT IV MANUFACTURER OFIRRADIATOR SOURCES V
RADIOACTIVE MATERIAL LICENSE REQUIREMENTS A. ISOTOPES B. QUANTITY LIMITATIONS C. LICENSED USES D. LICENSE CONDmONS E. SOURCE INSTALLATION
- 1. BY MANUFACTURER
- 2. BY LICENSEE VI OPERATING AND EMERGENCY PROCEDURES A. ORGANIZATION AND RESPONSIBILmES B. FACILITY LAYOUTS C. RADIATION SAFETY PROGRAM -
D. EMERGENCY PROCEDURES E. TRAINING FOR PERSONNEL F. OPERATING PROCEDURES G. CELL ENTRY PROCEDURES G. SOURCE INSTALLATION PROCEDURES
- 1. INSTALLATION SURVEY
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" sunsz wzar.za sacasrAsy socAsr.ruonNwn.m ururrascastaar August 18,1998 Richard L. Bangart, Director Office ofState Programs U.S. NuclearRegulatory Commission Washington, D.C. 20555-0001
Dear Mr.Bangart:
Thank you for your letter of Augun 6,1998, which documents the results of the Agreement State i 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 Managunent 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, e
Ed Kelley, Ph.D., Director Water and Waste. Management Division 55
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