ML20196E820
| ML20196E820 | |
| Person / Time | |
|---|---|
| Issue date: | 07/21/1988 |
| From: | Nussbaumer D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20150E008 | List:
|
| References | |
| FOIA-88-514 NUDOCS 8812120091 | |
| Download: ML20196E820 (1) | |
Text
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N01. Ad 1989
. Ref- SA/JOL
- ALL AGREEMENT STATES MATERIAL LICENSEE SAFETY PERFORMANCE EVALVATION FACTORS Enclosed is in advance copy of a temporary NRC Inspection Procedure on safety perfonnance evaluation factors for materials licensees (TI 2800/15). The purpose of this procedure is to establish a program to identify licensees having the potential for degraded safety perfomance. Early identification of such licensees by a radiation control program can enable the program to take appropriate actions to adjust the situation and prevent development of a "problem licensee."
NRC Regions will implement this temporary procedure for a one year period. We believe that this procedure could be a significant factor in improving our ability to ensure that licensed radioactive material is esed safely and in compliance with radiation safety requirements. We reconsnend each Agreement State develop a plan to implement it and to evaluate its effectiveness.
We are interested in learning of the results of your effects. We plan to include in our reviews and visits to your programs discussions of your licensee safety perfomance evaluations but will be glad to discuss this with you at any time.
Oris' M '188'A D D. Eussbauses' M '
Donald A. Nussbaumer Assistant Director for State Agreements Program State. Local and !ndian Tribe Programs
Enclosure:
As stated Distribution:
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FELTON88-514 PDR f
JUL 1 553 MEMOMNDUM FOR: Glen L. Sjoblom, Acting Director Division of Radiation Safety and Safeguards, RI J. Philip Stohr Director Division of Radiation Safety and Safeguards, RI!
Charles E. Morelius, Director Division of Radiation Safety and Safeguards, RIII Richard L. Bangart, Director ,'
Division of Radiation Safety and Safeguards, RIY ,,
Ross A. Scarano, Director Division of Radiation Safety and Safeguards, RV FRDM: Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety. W.SS
SUBJECT:
TEMPORARYINSTRUCTION(TI) 2800/15 SAFiiY PERFORMNCE EVALUATION FACTORS We have enclosed an advanced copy of the final TI on safety performance evaluation factors. The NRC inspection manual version has gone to print and will be forthcoming soon. Coments that were provided by the Regions on the draf t TI dated May 6,1988, have been taken into account.
As you know, the Comission is very interested in performa6ce evaluation, and .
NMSS will be closely ronitoring this effort. Therefore, we would appreciate'it if you could provide us with a description of your plans to implement the TI within 60 days.
Signed by Ramon Hall for Richard C. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
As stated cc: John Kinneman, R!
John Glenn, RI John White, RI John Potter, R!!
Darryl Wiedeman, RIII Don Srenawski, RIII Dale Powers, RIV Bob Thomas, RV DISTRIBUTION:
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- CHANGE NOTICE 88-l SUPERSEDED: TRANSMITTED:
M Date Number M ,
TI 1800/15 RDMRKS: Temporary Instruction 2800/15 is being issued to inspect mate-rials licensees in inspection Priorities I !!. and III. -
against performances evaluation factors. The use of performance factors will assist the Regional inspectors to identify items
, that may if not corrected, result in violations.
DISTRIBUTION: Standard and all Regionally based State Agreement Officers.
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Issue Date:
l NMSS TEMPORARY INSTRUCTION 2800/15 ESTABLISHMENT OF REGIONAL TRIAL PROGRAM FOR EARLY IDENTIFICATION "
OF MTERIAL LICENSEES NEEDING MORE NRC ATTENTION 2800/15 01 PURPOSE The purpose of this procedure is to establish, in each Region, a one-year l program to identify, early, licensees with the potential for degraded
! safety performance. MRC Regional management can take appropriate action 1
with the identified licensees to adjust the situation before significant
- degradation occurs. If successful, this program will result in taproved overall performance of licensees, reduction in violation of NRC require-1 ments, and reduction in the attendant need for enforcement action. This one-year program will emphasize the use of performance symptoms or per-formance evaluation.:riteria in assessing licensee performance.
2800/15 02 BACKGROUND An NRC license to cossess nuclear materials is issued on the premise that the Itcensee ranagement will diligently ensure that requirements of NRC regulations and license conditions are met. This premise is necessary because ARC representatives cannot visit facilitie) frequently. The most important factor in ensuring proper control of licensed material for most categories of materials licensees is that licensee staff follow or perform 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 performance is the ghe to good performance, through efforts to ensure adequate procedures, well designed and maintained equ' paent, sufficient aus6ers of qualified and trained per-sonnel, adequate management audits and reviews, and correction of causes of identified deficiencies. We have obcerved the ability of experienced reviewers and inspectors to detect signs el slipping management performance before trouble occurs. We are now seeking to have all inspectors systema-tically look for these early signs of degraded performance so that Regional management can initiate corrective actions before serious problems develop.
2800/15-03 PROGRAM GUIDANCE The ability of the NRC to promote high quality Itcensee performance, and, conversely, to prevent deterioration of that performance, requires coordi-nated licensing and inspection efforts. Before granting a license, NRC Issue Date:
1
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- licensing officials tr to detersine if the licensee understands his responsibilities, is fufly qualified, understands what kind of performance NRC expects, and what actions NRC will take if violations occur. Once the license is granted, there are periodic inspections to identify violations of regulatory requirements, and also to identify early indications of
. degraded performance. Based on these inspections, Regional management determines when particular licensees show the kind of symptoms that indicate that NRC should pay closer attention to them. ,
NRC Regional management should judge what the appropriate action is for each individual situation. However, there is a range of actions that can be considered, including: telephone contacts; meetings with licensee man-apements special inspections tailored to emphasize certain aspects; addi-t< onal management comments in letters forwarding inspection reports; or Confirmatory Action Letters. A follow-up inspection in such situations is -
also warranted. The purpose of these additional actions is to focus on licensee management and assure that he understands any concerns NRC may i i
have about the symptoms and potential for degraded performance and that he takes action to correct underlying causes. I Each Region should develop and use a list of "performance factors' that may indicate the potential degraded performance. The term ' performance evaluation factors' is being used in relation to the nuclear materials pro- i gram, to differentiate this effort from the reactor program, where the ters is "performance indicators." Although the objective of the reactor program !
is also to assist in improving performance, the type of information avail-able in the materials area is not trend information on performance and not data-intensive information on equipment. Rather, the kinds of information available are the primary early subjective warnings or precursors of degraded performance of the licensee operations. ...
l 2800/2-04 RELATIONSHIP TO ' PROBLEM" LICENSEES l
Licensees whose performance has already degraded to the extent that serious !
incidents have occurred, or escalated enforcement actions have become s necessary, are, by definition, problem licensees. There should be fewer of l these than those for whom their performance symptoms indicate a need for l increased NRC and licensee management attention. ' Problem" licensees '
demand extensive impediate attention. Licensees with symptoms of degraded ;
performance uma in the future become "probles" licensees, unless actions j are taken to Taprove performance.
2800/2-05 FACTORS OF DEGRADED PERFORMANCE f
The specific performance each Region uses should be patterned after the attached enclosure, and added to as necessary by each Region. However, the factors that the Regions use should cover the areas of: licensee man- ,
agement oversight and control; quality of procedures and operations; ade- ,
quacy of personnel staffing and training; and audits and feedback l mechanisms to correct causes af defit;iencies. ,
I Issue Date:, 2800/15
2800/2-06 TRACKING OF LICENSEE PERFORMANCE Each Region should assign responsibilities to enhance its ability to track the performance of licensees and categories of Ifcensees. One way to accomplish 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 PEAFORMANCE FACTORS Each Region is to conduct an assessment, after one year, of its use of degraded performance criteria and symptoms and its Regional action with lice.nsees, identifying the usefulness, difficulties, ideas for improvement tht.t are instituted or planned, and innovations that are particularly uteful. A report should be submitted in May 1989. INSS will convene a FAeting with the Regions to discuss lessons learned and future program guidance.
i 2800/15-08 EXPIRATION This Temporary Instruction will remain in effect until June 30, 1989.
2800/15-09 STATISTICAL DATA REPORTING i
Budgeting for FTE's has already been implemented; The time should be charged to NRC Inspection Procedure 87100. ...
END
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Enclosure:
As stated l
2800/15 Issue Date:
.- Enclosure PERFORMANCE EVALUATION FACTORS Enforcement Histcry - Point system depending on the number and types of violations.
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points Examples (may be added to by each Region, as appropriate).
Failure of Isotope Committee (or certain key imembers there-E a.
of) to meet or discuss meaningful issues for a Broad Scope type license, y b. R50 too busy with other assignments (RS0 spending less than l 25%oftime).
M c. Excessive customer complaints from anjor manufacturers or
) ,
distributors.
E d. Excessive allegations which have been acostantiated.
E e. Significant number of diagnostic misadministrations (greater than 10~8 per procedure). !
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! 3 f. Hi h man-rem levels (greater than 50% of workers requiring j NR Form 4).
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20 g. Frequent or excessive contamination within the restricted ,
l area (greater than 10 x 255 guidance for release to unre'-
strictedareas).
15, 5 h. Excessive utssed surveillances (leak testing, inventory. .
- surveys, etc., greater than 50t per year). !
E 1. Financial instability of licensee (shoe string operations, !
one or two-man operation such that cost of cleanup is signi- i l
ficant to continued operations of the facility). !
, J R j. Lack of involvement of senior management to oversee RSO 1 l performance (management unaware of operations).
i R k. Inadequate consultant service (consultant not finding any problems but NRC does). [
(
E 1. Radiation safety Committee (Broad scope) gives
- rubber t stamp" approvals to users and/or issues user permits for i indefinite periods of time.
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R u. Insufficient technologist /authortred user / radiation safety ;
staffing for licensed program workload 3 n. Excessive numbers of repeat violations (three or more).
M o. Frequent internal uptakes greater than 125 areas, whole body equivalent but less than 520 MPC/hr limits.
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