ML20155H093
| ML20155H093 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1988 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20155H081 | List: |
| References | |
| FOIA-88-422 NUDOCS 8810180262 | |
| Download: ML20155H093 (11) | |
Text
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UNITED STATES 1p NUCLEAR REGULATORY COMMISSION I
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NRC INSPECTION MANUAL sMss TEMPORARY INSTRUCTION 2800/15 ESTABLISHMENT OF REGIONAL TRIAL PROGRAM FOR EARLY IDENTIFICATION OF MATERIAL LICENSEES NEEDING MORE NRC ATTENTION 2800/15-01 PURPOSE The purpose of this procedure is to establish, in each Region, a one-year program to identify, early, licensees with the potential for degraded safety pei formance.
NRC Regional management can take appropriate action with the identified licensees to adjust the situation before significant degradation occurs.
If successful, this program will result in improved overall performance of licensees, reduction in violation of NRC require-ments, and reduction in the attendant need for enforcement action.
This one-year program will emphasize the use of performance symptoms or per-fomance evaluation criteria in assessing licensee perfomance.
2800/15-02 BACKGROUND An NRC license to possess nuclear materials is issued on the premise that the licensee managetrent will diligently ensure that requirements of NRC regulations and license conditions are met.
This premise is necessary because NRC representatives cannot visit facilities frequently.
The most important factor in ensuring proper control of licensed material for most categories of materials licensees is that licensee ctaff follow or perfom procedures properly.
However, there are some categories of mate-rials licensees, such as irradiators and fuel facilities, where control equipment performs certain safety functions, e.g.,
interlocks, automati-cally.
Basically, good licensee management perforrance is the Je to goed k
perfomance, through efforts to ensure adequate pncedures, well designed and maintained equipment, sufficient numbers of qualified and trained per-sonnel, adequate management audits and reviews, and correction of causes of identified deficiencies.
We have observed the ability of experienced reviewers and inspectors to detect signs of slipping management performance before trouble occurs.
We are now seeking to have all inspectors systema-tically look for these sprly signs of degraded perfomance so that Regional management can initiate corrective actions before serious problems develop.
2800/15-03 PROGRAM GUIDANCE The ability of the NRC to pronote high quality licensee perfomance, and, conversely, to prevent deterioration of that perforrance, requires coordi-nated licensing and inspection efforts.
Before granting a license, NRC ino2pm2 **22 8\\
Issue Date:
CC/30/85 FELTON88-422 PDR
1 2800/15-06 TRACKING 0F LICENSEE FERFORMANCE L
j Each Region should assign responsibilities to enhance its ability to track l
the performance of licensees and categories of licensees.
One way to accorplish this is to assign Regional project officers to keep abreast of licensing and inspection information on each category of licensees and to keep management aware of problems and need for action.
2800/15-07 REPORT ON ONE-YEAR USE OF PERFORMANCE FACTORS 3
Each R6gion is to conduct an assessment, after one year, of its use of degraded perfomance criteria and symptoms and its Regional action with licensees. idar.tifying the usefulness, difficulties, ideas for improvement that are institutGd or planned, and innovations that are particularly useful.
A report should be submitted in May 1989.
NMSS will convene a meeting with the Regions to discuss lessons learned and future program guidance.
J 2800/15-08 EXP! RATION This Temporary Instruction will remain in effect until June 30, 1989.
2800/15-05 STATISTICAL DATA REPORTING l
Budgeting for FTE's has already been implemented.
The time should be I
charged to NRC Inspection Procedure 87100, i
I END Exhibit I
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2800/15 Issue Date: 06/30/6f i
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PERFORMANCE EVALUATION FACTORS Enforcement History - Point system depending on the number and types of violations.
Points Exangles (may be added to by each Region, as appropriate).
25 a.
Failure of Isotope Consnittee (or certain key members there-of) to meet or discuss meaningful issues for a Broad Scope type license.
25 b.
RSO too bus with other assignments (RSO spending less than 25% of time.
15 c.
Excessive customer complaints from major manufacturers or distributors.
50 d.
Excessive allegations which have been substantiated.
15 e.
Significant number of diagnostic misadministrations (greater than 10'3 per procedure).
20 f.
High man-rem levels (greater than 50% of workers requiring NRC Form 4).
20 g.
Frequent or excessive contamination within the restricted area (greater than 10 x NMSS guidance for release to unre-stricted areas).
15 h.
Excessive missed surveillances (leak testing, inventory.
surveys, etc. greater than 50% per year).
50 1.
Financial instability of licensee (shoe string operations, one or two-man operation such that cost of cleanup is signi-ficant to continued operations of the facility).
1 I
20 j.
Lack of involvement of senior management to oversee RSO -
perfonnance (management unaware of operations).
20 k.
Inadequate consultant service (consultant not finding any problems but NRC does),
t 15 1.
Radiagion Safety Consnittee (Broad Scope) gives "rubber I
l stamp approvals to users and/or issues user permits for indefinite periods of time.
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20 m.
Insufficient technologist / authorized user / radiation safety j
staffing for licensed program workload.
1 7_5 n.
Excessive numbers of repeat violations (three or more).
5 25 o.
Frequent internal uptakes greater than 125 mrems, whole body equivalent but less than 520 MPC/hr limits.
Exhibit 1. 2800/15 El-1 Issue Date:
06/30/85
p.
PERFORMANCE-BASED EVALUATION FACTORS FOR THE NRC REGION I MATERIALS PROGRAM CRITERIA P051TIVE_ NEEATIVE REMARK 5:
A.
MANAGEMENT OVERSIGHT AND CONTROL INDICATORS
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1.
Is there evidence that there is senior level management support for the radiation safety aspects of the licensed program?
- YES NO ATTRIBUTES TO CONSIDER
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Senior management attends entrance / exit
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meetings.
The radiation safety officer reports to a senior management representative.
Senior management is knowledgeable of the radiation safety program.
Radiation safety policy and procedures are reviewed and approved by senior management.
The performance appraisal of the responsible senior manaser contains elements directed towarc successful implementation of the radiation safety
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program.
m M
M M
e 4
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PERFORMANCE BASED EVALVATION FACTORS PAGE 2 CRITERIA
_P051TIVE_ MEGATIVE _ REMARK 5-2.
Do the minutes of Radiation Safety Comittee meetings indicate that the
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comittee is a ressive in establishing, plementing and maintaining po cies and procedures affecting radiation safety?
- YES NO ATTRIBUTES TO CONSIDER 1
The substance of the meeting is not pro forma, but involves discussion and decision making on real health and safety matters.
Critical review and discussion is evident.
Sanctions for noncompliance are imposed.
l The meetings are held when scheduled, and -
the croper attendees are present.
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3.
Are periodic documented audits / reviews
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j performed of the licensed program?
YES NO 4.
Is the licensee able to readily retrieve records and documentation
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pertaining to licensed activities?
YES NO 5.
Is there formalized structure and 1
definition of the licensee's organization such that responsibilities and authorities are identifiable?
- YES NO i
ATTRIBUTES TO CONSIDER
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A clear reporting structure is evident.
3 l
Individuals involved in the program are cognizant of their respective J
responsibilities and authorities.
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4 PERFORMANCE-BASED EVAL.VATION FACTORS PAGE 3 CRIHRIA J051TIVE_ NEEATIVE _ RENARK5--
6.
Is the Radiation Safety Officer
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separated from responsibility for
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j production activities?
YES NO 7.
Has the company been subject to a name
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change, developed into a subsidiary,
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or transferred since the last
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inspection?
_ NO YES ATTRIBUTE TO CONSIDER A license amendment request has been
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filed in a timely manner.
B.
Quality of Operation Indicators 1.
Is radioactive waste managed such that
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waste disposition occurs at the same rate as generation?
YES NO
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2.
Does the licensee inventory
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radioactive materials, including radioactive wastes and contamination,
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in terms of quantity and location in the facility?
- YES NO 1
3.
Does the licensee appear to have the resources necessary to decontaminate i
and release the facility sufficient for unrestricted use?
- YES NO
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4.
Does the licensee appear to have an
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effective housekeeping program?
YES NO 5.
Is there evidence that key personnel frequently resign or leave the
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i licensee's organization?
- NO YES 6.
Is the licensee able to perform all
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required surveys on time?
- YES NO i
7.
Have there been any unplanned or
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abnormally high personnel exposures 4
since the last routine inspection or substantial increase in aanrem for the
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same effort?
NO YES i
8.
Have there been any reportable events
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or alsadministrations since the last
- NO YES l
inspection?
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PERFORMANCE BASED EVALVATION FACTORS PAGE 4 CRTTUTA
_r0 6 TIVE _ RHARK5-~
9.
Are the licensee's reports to the NRC j
complete and candid?
- YES NO
- 10. Has the licensee been late in responding to NRC correspondence relative to inspection or licensing activities?
NO YES 11.
Does the licensee report as required by the regulations?
YES NO 12.
Arere[ortsreheqistefotheintentt utred b regulations comple e and a
- YES NO
- 13. Does the licensee perform preventative maintenance on equipment and instruments that are used in licensed activities?
- YES NO
- 14. Are equipent and instruments used in
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licensed activities checked periodically to verify correct operation?
- YES NO
- 15. Does the Itcensee pursue enhancements to effect radiological safety by engineering -
design features as opposed to reliance on -
administrative controls?
- YES NO C
Personnel Training and Qualification In3Teators 1.
Does the licensee provide training to individuals prior to authorizing them to use licensed materials?
YES NO 2.
Is there periodic retraining of authorized users?
YES NO 3.
Is personnel training documented?
YES NO
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'ERFORMANCE BASED EVALUATION FACTORS PAGE 5 t
CRITERTA
_r05TTIVE NEGATIvt _ RERAIO T ~
4.
Are shere sufficient numbers of qualified -
personnel to carry on Itcensed activities -
without constraint?
YES NO 5.
Does the licensee estabitsh minimum qualifications for positions in the licensed program?
- YES NO 6.
Does the Itcensee periodically assess the performance of personnel training?
YES NO l
0.
Previously identified items Indicators 1.
Have violations been identified that i
are similar in nature to items J
previously identified during the last inspection?
- NO YES 2.
Has the licensee been subject to i
allegations or O! referrals since the
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1ast routine inspection?
NO YES 3.
Has the licensee been the subject of i
escalated enforcement action since or as a result of the last routine inspection?
- NO YES 4.
Does the Itcensee effectively correct self identified deficiencies promptly?
YES NO
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5.
Have corrective actions for ked?reviously identified items been comple YES NO
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J i
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t PERFORMANCE EVALUAT1,0N FACTOR $
ticensee:
License No,t Date of Inspection:
Inspector (s);
i i
1.
Does the Radiation Safety Comittee appear to be functioning adequately to i
successfully implement the licensee's radiation safety program? (e.g.,15 membership ar.d attendance at meetings adequate? Art adequate reviews of users and/or facilities being conducted? Are meaningful issues being discussed at the meetings?)
(
) Yes
(
) No
(
)h/A 2.
15 the Radiation Safety Officer (RS0) able to perform his or her duties adequately without being burdened by other duties?
+
j
(
)its
(
) No
(
) N/A i
3.
15 su'ficiert staffing avat1Atle te rtragt the licerset pro;ra worticat:
(
)les
(
) No
(
) h/A 4
Octs licersee rer. age ent providt suprert for the radiatice si tty aspects f
of th< litersed prograr?
(
)Yes
(
) No
(
) h/A 5.
Does the licer.see have the resources te operate the facilit,s safely and support decerta-ir.ation of the f acility if riecessar)?
(
) Yes
(
) ho
(
)h/t 6.
Is it esident thet the licensee is capable of respordirt to a radielogicel ev e r.t ?
(
) Yes
(
) ho
(
) h/A I
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7.
Are periodic audits conducted of the radiation safety program by the licensee and/or a contractor and do the audits appear adequate?
(
)Yes
(
)No
(
)N/A 8.
Are licensee's radiation exposures in accordance with ALARA?
(
)Yes
(
)No
(
)N/A 9.
Are reportable events (10 CFR 20.402, 20.403, 20.405) kept to a level comensurate with the licensee's workload?
(
)Yes
(
) No
(
)N/A
- 10. Are the number of repeat violations kept to a minimum and has the licensee successfully implemented corrective actions on previous violations?
(
)Yes
(
) No
(
)N/A
- 11. Are safety related allegations kept to a minimum level? Does the licensee have an adequate system to fcilow up on complaints?
(
) Yes
(
) No
(
)N/A
- 12. Are licensee's reports and responses to violations complete, candid and tinely?
(
)Yes
(
) No
(
) N/A
- 13. Art risad-ir.istratiets (cia;eostic cr thera;ewtic) kept tc. a leu' Cerrtriurait with the liter set's work 1 cad?
(
) ies
(
) Ac
(
)h/A Ic. Dres tbt lictrset base sufficiert instrurentation to safely matait the i
proprar and art these instruments properly reinteired?
(e.g., l5 there a pre.er.tise reintarance/qualit) assurante progrer.?)
(
) tes
(
) ho
(
) h/A
! !.. Oces the litersee have an adecuate prograr in place to store rac'cactive weste safely?
(e.g., Art raterials prcperly labeled and irstr.tcried?
15 exposure tc tre elements controlled?)
(
) its
(
) he
(
)N/A 2
Inspector's Convents:
(Required for any factor given a negative response)
Action Required: '( As deemed by Region !!! management, i.e., telephone centact. licer.see manageM nt meeting, increased inspection effort, etc.)
A tier 1#Len:
l Se: tion Chief Sigeature:
Date:
3