ML20197C764
| ML20197C764 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1997 |
| From: | Sollenberger D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Aldrich R NEW YORK, STATE OF |
| References | |
| NUDOCS 9712240266 | |
| Download: ML20197C764 (12) | |
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NUCLEAR REGULATORY COMMISSION a
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December 15, 1997 Ms. Rita Aldrich, P-incipal Radiophysicist Radiological Health Unit New York State Department of Labor NYS Office Campus, Bldg.12 Room 457 Albany, NY 12240 Daar Ms. Aldrich:
As you are ervare, NRC is using the integrated Materials Performance Evaluation Program
'(IMPEP) for the evaluation of Agreement State Prograris. Per our discussion, I will be the team leader for the IMPEP review of all four New York programs that make up the Agreement State program for the State of New York. The New Yo* State, Department of Labor, Radiological Health Unit program review is schedul6d for February 23-27,1998. The team includes: Duncan White, Regional State Agreements Officer, NRC Region 1; Douglas Broaddus, Mechanical Engineer, Office of Nuclear Material Safety and Safeguards; Lance Rakovan, Health Physicist, Office of State Programs; and James McNees, Director, Radioactive Materials Compliance, State of Alabama.
Enclosed is the document, " Integrated Materials Performance Evaluation Program m
Questionnaire." The questionnaire is being fumished to you on a computer disk in Wordperfect 6.1 format as well as in printed form. I ask that you send your responses oy interret (DMS4@NRC. GOV) or retum the disk to me by January 21,1998. I am sending the document and disk in advance of the IMPEP review in order to provide time for you to allocate the staif resources necessary to complete and submi'.the document by the due date.
Part A of the questionnaire contains questions on the common performance indicators. Part B contains questions on the non-common performance indicators for Agreement States. Also included with the questionnaire is the document,
- Materials Requested to Be Available for the Onsite Portion of an IMPEP Review." We encourage States to have the items listed prepared prior to the IMPEP t-am's arrival.
I request that you set up an appointment w;th the appropriate management official to discuss the resuus of the IMPEP roview of the New York State Department of Labor, Radiological Health Unit program on February 27,1998. A separate meeting with senior managers from al{
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4 Ms. Rita Aldrich DEC 151907 four New York programs to discuss the findings for the State will be scheduled approximately two wecks following the last program review, According to the cutrent schedule, this meeting would be in mid-April 1998.
If you have questions, please call me at (301) 415 2819.
Sincerely,
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Dennis M. Sollenberger, Team Leader Office of State Programs
Enclosures:
As stated cc w/o oncis: John E. Sweersy, Commissioner of Labor Jack P. Spath, NYGERDA i
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Ms. Rita Aldrich DEC 151997i four New York programs to discuss the findings for the State will be scheduled approximately two weeks following the last program review. According to the current schedule, this r.7eeting would be in mid April 1998.
If you have questions, please call me at (301) 415-2819.
i Sincerely, C;Gn*:16;.6 bj; D.Id. G 2 re q ;r Dennis M. Sollenberger, Team Leader Office of State Programs L
Enclosures:
As stated cc w/o encis: John E. Sweeney, Commissioner of Labor Jack P. Spath, NYSERDA u
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Distribution:
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SDroggitis DWhite,31 KSchneider DBroaddus, NMSS LRakovan JMcNetes, AL New York Labor File FtBlanton, ASPO DOCUMENT NAME: G:\\DMS\\NYllllPEP\\
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NAME DSollenberger:nb PHLo6atls
RL Bangart'l D DATE 121f$97-12/ 2/97 12/Q/97 OSP FILE CODE: SP-AG-20-J
Approved by OMB' No. 3150-0183 Expires 4/30/98 lHIEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Name of State / Regional Program Reporting Period: Month XX, [ YEAR), to Month XX, [VEAR)
A.
COMMON PERFORMANCE INDICATORS 1.
Status of Materials insoection Program 1.
Please prepare a table identifying the licen es with inspections that are overdue by more than 25% of the scheduled frequency set out in NRC Inspection Manual Chapter 2800. The list should include initialinspections that are overdue, insp. Frequency Licensee Name (Years)
Due Date Months O/D 2.
' Do you currently have an action plan for compk. ting overdue inspactions? If so, please describe the plan or provide a written copy with your response to this questionnaire.
3.
Please identify individual licensees or groups of licensees the State / Region is inspecting more or less frequently than called for in NRC Inspection Manual Chapter 2800 and state the reason for the change.
3 ' Estimated burden per respora _ to comply with this voluntary collection request: 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />. Forward comments regar@g burden estimate to the Information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0052), Office of Management and Budget, Washington, DC 20503.- NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.
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I 4.
Please complete de following table for licensees granted reciprocity during the raporting period.
Number of Licensees Granted Reciprocity Number of Licensees Priority Permits Each Year inspected Each Year Service Licensees performing YR YR teletherapy and irradiator source YR YR installations or changes YR YR YR YR YR YR 1
YR YR YR YR YR YR YR YR 2
YR YR YR YR YR YR YR YR 3
YR YR YR YR YR YR 4
All Other i
5.
Other than reciprocity licensees, how many field inspections of radiographers were performed?
6.
For NRC Regions, did you establish numerical goals for thu number of inspections to be performed during this review period? If so, please describe your goals, the number of inspections actually performed, and the reasons for any differences between the goals and the actual number of inspections performed.
II.
Technical Quality of Insoections 7.
What, if any, changes were made to your written inspection procedures during the reporting period?
C.
Prepare a table showing the number and types of supervisory accompaniments made during the review period. Include:
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l Insoector Suoervisor License Cat. Dat' 9.
Describe internal procedures for conducting supervisory accompaniments of inspectors in the field. If supervisory accompaniments were documentt.d, please provide copies of the documentation for each accompaniment.
10.
Describe or provide an update on your instrumentation and methods of calibration. Are allinstruments properly calibrated at the present time?
111.
Technical Staffina and TralDlDg 11.
Please provide a staffing plan, or complete a listing using the suggested format below, of the professional (technical) person-years of effort applied to the agreement or radioactive material program by individual. Include the name, position, and, for Agreement States, the fraction of time spent in the following areas: administration, materials licensing & compliance, emergency response, LLW, U-mills, other. If these regulatory responsibilities are divided between offices, the table should be consolidated to include all personnel centributing tc, the radioactive materials program. Include all vacancies and identify all senior personnel assigned to monitor work of junior personnel. If consultants were used to carry out the program's radioactive materials responsibilities, include their efforts. The table heading should be:
NAME POSITION AREA OF EFFORT EIE%
12.
Please provide a listing of all new professional personnel hired since the last review, indicate the degree (s) they received, if applicable, and additional training and years of experience in health physics, or other disciplines, if appropriate.
13.
Please list all professional staff who have not yet met the qualification requirements of license reviewer / materials inspection staff (for NRC, inspection Manual Chapters 1246, for Agreement States, please describe your qualifications requirements for materials license reviewers and inspectors). For etch, list the courses or equivalent training / experience they need to attend and a tentative schedule for completion of these requirements.
14.
Please identify the technical staff who left the RCP/ Regional DNMS program during this period.
15.
List the vacant poshions in each program, the length of time each position has been vacant, and a brief summary of efforts to fill the vacancy.
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l IV.
Technical Quality of Licensina Actions 16.
Please identify any major, unusual, or complex licenses which were issued, received a major amendment, terminuted, decommissioned, bankruptcy notification or renewed in this period. Also identify any new or amended licenses that now require emergency plans.
17.
Discuss any vriances in licensing policies and procedures or exemptions from the regulations granted during the review period.
18.
What, if any, changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) duiing the reporting period?
9 19.
For NRC Regions, identify by licensee name, license number and type, any renewal applications that have been pending for one year or more.
V.
Resoonses to incidents and Allecations 20.
Please provide a list of the reportable incidents (i.e., medical misadministration, overexposures, lost and abanconed sources, incidents requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less notification, etc. See Handbook on Nuclear Material Event Reporting in Agreement States for adCitional guidance.) that occurred in the Region / State during the review period. For Agreement States, information included in previous sub nittals to NRC need not be repeated (i.e., those submitted under OMB 3150-0178). The list should be in the following format:
LICENSEE NAME LICENSE #
DATE OF INCIDENT / REPORT TYPE OF INCIDENT 21.
During this review period, did any incidents occur that involved equipment or source failure or approvad operating procedures that were deficient? If so, how and when were other State /NRC licensees who might be affected notified? For States, was timely notificatic.i made to NRC7 For Regions, was an appropriata and timely PN generated?
22.
For incidents involvir.g failure of equipment or sources, was information on the incident provided to the agency responsible for evaluation of the device for an assessment of possible generic det!gn deficiency? Please provide details for each case.
23.
In the period covered by this review, were there any cases involving possible wrongdoing that were reviewed or are presently undergoing rcview? If so, please describe the circumstances for each case.
24.
Identify any changes to your procedtires for handling allegations that occurred during the period of this review.
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a.
For Agreement States, please identify any allegations referred to your program by the NRC that have not been closed.
VI.
General
- 25. Please prepare a summary of the status of the State's or Region's actions taken in responte to the comments and recommendations following the last review.
- 26. Provide a brief description of your program's strengths and wea.knesses. These strengths and weaknesses should be supported by examples of successes, problems or difficulties which occurred during this review period.
B. NON-COMMON PERFORMANCE INDICATORS l.
Lecislation and Proaram Elements Reauired for Comcatibility
- 27. Please list all currently effective legislation that affects the radiation control program (RCP).
- 28. Are your regulations subject to a " Sunset" or equivalent law? If so, explain and include the next expiration date for your regulations.
- 29. Please complete the enclosed table based on NRC chronology of amendments. Identify those that have not been adopted by the State, explein why they were not adopted, and discuss any actions being taken to adopt them. Identify the regulations tnat the State has adopted through legally binding requirements other than regulations.
- 30. If you have not adopted all amendments within three years from the date of NRC rule promulgation, briefly describe your State's procedures for amending regulations in order to maintain compatibility with the NRC, shruing the normallength of time anticipated to complete each step.
II.
Sealed Source and Device ProQIam
- 31. Prepare a table listing new and revised SS&D registrations of sealed sources and devices issued during the review period. The table heading should be:
SS&D Manufacturer.
Type of Registry Distributor or Device Date
. Number Custom User or Source issued 32.
What guidec, standards and procedures are used to evaluate registry applications?
33.
Please include information on the following questions in Section A, as they apply to the Sested Source arJ Device Program:
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Technical Staffing and Training - A.lli.11 15 Technical Quality of Licensing Actions - A.IV.1618 Responses to incidents and Allegations - A.V.20-23 Ill.
Low-Level Waste Prearam 34.
Please include information on the following questions in Section A, as they apply to the Low-level Waste Program:
Status of Materials inspection Program - A.I.1-3, A.I.6 Technbl Quality of Inspections - A.ll.710 Technical Staffing and Training - A.lli.11-15 Technical Quality of Licensing Actions A.IV.16-18 Responses to incidents and Allegations A.V.20-23 IV.
Uranium Mill Procram 35.
Please include information on the fo! lowing questions in Section A, as they apply to the Uranium Mill Program:
Status of Materials Inspection Program - A.I.13, A.I.6 Technical Quality of Inspections - A.ll.7-10 Technical Staffing and Training - A.llt.11-15 Technical Quality of Licensing Actions - A.IV.16-18 Responses to incidents and Allegations - A.V.20-23 6
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TABLE FOR QUESTION 29.
DATE DATE 10 CFR RULE DUE ADOPTED CURREK EXPECTED STATUS ADOPTION Any amendment due prior to 1991. Identify each regulabon (refer to the Chronology of A.T# ients) '
Deconmssioning; 7/27/91 Parts 30,40,70 Emergency N -4.f,.
4C193 Parts 30,40. 70 Standards for Protechon Against Radiabon; 1/1/9#
Part 20 Safety Requwements for Radiographic 1/10/94 Equipment; Part 34 '
Notification ofinodents, 10/15/94 Pats 20,30,31,34,39,40,70 Quality Management Progrc.n and 1/27/95 Misadministrabons: Part 35 Licensing and Radrabon Safety Requwements 7/1/96 for Irradiators; Part 36 Definshon of Land Drspo al.
7/22/96
_and Waste Site QA Program: Part 61 Decomreissioning Recordkeeping Docu-10/25/96 rentation Addebons; Parts 30,40. 70 Self-Guarantee as an Additional Financial 1/28/97
_ Mechanism; Parts 30,40. 70 Urarwom Mill Tailings: Conformmg to EPA 7/1/97 Standards: Part 40 Timehness in Decommissioning 8/15/97 Parts 30,40,70 Preparation. Transfer for Cw...wM Dis-1/1/98 inbu%n, and Use of Byp > duct Material for Medical Use; Parts 30,32,35 7
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OR DATE DA1E CURRENT EXDECTED 10 CFR RULE DUE ADOPTED STATUS ADOP1X)N Frequency of Medcal Exa%iations for Use of 3/13.98 Residratory Protedicr. Equivii. ora Low-LevelWaste Stupment Manifest 3/1/98 infuar+R-3 and Repwi;Og I
Performance Requirements for Radography 6/30/98 W--Tent Radiation Protechon Requrernents: Amended 8/14PJ3 Definitions and Criteria Clanfication of Decommissioning Funding 11/24/98 Requirements 10 CFR Part 71: Compatibility with the 4/1/99 Intemational Atomic Ersgy Agorcf Medical Administration of Radiation and 10/20/98 f
R+R+:tive Materials.
Tennenation or Transfer of Licensed Actrvities 6/16/99 Recordkeeping Requirements.
Resolution of Dual Regulation of Airbome 1/9/00 Effluents of Radioactive Materials; Clean Air Act Fissile Material S;-Jy, cis and Exo.. v; ions 2itO!DO Recognition of Agreement State Ucenses in 2/27/00 Areas Under Exclusive Federal Jurisdiction Within an Agreement State Criteria for the Release of Indmduals 5/29/00 Administered R=*nar+ive Material Licenses for Industrial Radiography a,nd 6/27.00 Radiation Safety Requirements for industrial Radiography Operations: Final Rule fla RR-82 Criteria for U. + i.e Termination 8/20/00 I
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MATERIALS : REQUESTED TO BE AVAILABLE FOR e
THE ONSITE PORTION OF AN IMPEP REVIEW.
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ORGANIZATION CHARTS -
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Closn, sized 8% X 1 i" including names and positions i'
- a : One showing positions from Govemor down to Radiation Control Program Director (RCPD) -
o - One showing po itions of current radiation control program with RCPD as Head i-
- 01 Equivalent charts for LLRW and mills programs, if applicable
- LICENSE L!STS'-
O Printouts of current licenses, showing total, as follows:
Name License #.
Location License Type Priority l Last inspection Due Date l
< Sort siphabetically i
- Also, sort by due date and by priority (if possible).
THE FOLLOWING LISTS' L
l o. List of open license cows, with date of original request, and dates of follow up actions a List oflicenses terminated during review period.
o Copy of current log or other document used to track licensing actions
- o J Copy of current log or other document used to track inspections o List of Inspection frequency by license type 4
o Listing or log of all incidents and allegations occurring during the review period. Show whether incident i+
is open or closed and whether it was reported to the NRC 4
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- THE FOLLOWING DOCUMENTS i --
0 All State regulations <
a Records of results of supervisory -
'o Statutes affecting the regulatory authority of accompaniments ofinsrectors l;
the state program o Emergency plan and communications list j
o - Standard license conditions a Procedures for investigating allegations o Technical procedures for licensing, model a Enforcement procedures, including -
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-licenses, review guides procedures for escalated enforcement,D
- a SS&D review procedures severity levels, civil penalties (as applicable)
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- o Instrument calibration records a Cope of job descriptions o n inspection procedures and guides'
- o. Inspection report forms.
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