ML20198D027

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Forwards Summary Analysis Re Mgt Directive 5.6 of State of Oh,For Use in Making Determination as to Qualification to Perform Sealed Source & Device Safety Evaluations
ML20198D027
Person / Time
Issue date: 12/18/1998
From: Camper L
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Suppes R
OHIO, STATE OF
References
SSD, NUDOCS 9812220243
Download: ML20198D027 (12)


Text

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December 18, 1998

-- Roger L. Suppes I

Chief Bureau of Radiation Protection Ohio Department of Health PO Box 118 Columbus, Ohio 43266-0188 )

Dear Mr Suppes:

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, l l This is in response to our phone conversation on December 14,1998, regarding Messrs. Karl ,

Von Ahn's and George Cicotte's "on-the-job" training conducted at the NRC office in l Rockville, MD. As discussed, your staff members reviewed casework that afforded them an I opportunity to address the 9 elements for staff training denoted in Management Directive 5.6. In l addition, they worked on a significant number of diverse cases resulting in a meaningful OJT l experience. Enclosed is a summary analysis for your use in making the determination as to their qualification to perform sealed source and device safety evaluations..

I met with Karl Von Ahn and George Cicotte to ascertain their perspectives on their training and their related confidence to proceed with casework. Both of them ensured me that their l experience had been positive and they believe they are prepared to process cases. I made them aware that we are available to answer questions, etc.

Should you have further questions, please feel free to contact me.

Sincerely, 1 (orig, signed by C. Raddatz, for)

Larry W. Camper, Chief Materials Safety Branch l Division of Industrial and l Medical Nuclear Safety Office of Nuclear Material Safety  ;

and Safeguards j

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DISTRIBUTION:

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          • [ December 18, 1998 Rcger L. Suppes Chief Bureau of Radiation Protection Ohio Department of Health PO Box 118.

.. Columbus, Ohio 43266-0188 ~

Dear Mr Suppes:

u This is in response to our phone conversation on December 14,1998, regarding Messrs. Kari

,1 . Von Ahn's and George Cicotte's "on-the-job" training conducted at the NRC office in l Rockville, MD. As discussed, your staff members reviewed casework that afforded them an opportunity to address the 9 elements for staff training denoted in Management Directive 5.6. In addition, they worked on a significant number of diverse cases resulting in a meaningful OJT

experience; Enclosed is a summary analysis for your use in making the determination as to their qualification to perform sealed source and device safety evaluations..

I met with Karl Von Ahn and George Cicotte to ascertain their perspectives on their training and their related confidence to proceed with casework. Both of them ensured me that their experience had been positive and they believe they are prepared to process cases. I made

them' aware that we are available to answer questions, etc.

Should you have further questions, please feel free to contact me.

Sincerely, Larry W. Camper, Chief h

Materials Safety Branch Division of Industrial and - ,

Medical Nuclear Safety I Office of Nuclear Material Safety and Safeguards  ;

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Enclosure 1 1

Management Directive 5.6 -- ANALYSIS STATE OF OHIO

l. " New hired employees need to be technically qualified. Professional staff should have a bachelor's degree or equivalent training in the physical and/or life sciences.

Both initial and concurrence reviewers should be able to:

Karl Von Ahn -- B.S. in Biomedical Engineering from Case Western Reserve University (Cleveland, Ohio) in May 1997, with a technical sequence in biomaterials.

George Cicotte -- B.S. in Physics, Lebanon Valley College,1985, with additional graduate course-work in Environmentai Science at Washington State University from 1991 to 1994 and in Industrial Hygiene at Tulane Univert:,;ty from 1994 to 1996.

II. . Understand and interpret, if necessary, appropriate prototype tests that ensure the integrity of the products under normal, and likely accidental conditions of use.

Karl Von Ahn -- Understanding and interpreting test results is a part of routine training in the engineering and scier.ce course work to attain an engineering degree.

George Cicotte -- Formal training in quality control and quality assurance by U.S. Navy-designated as a quality controlinspector and analysis quality control reviewer. Also, courses in metallurgy, thermodynamics, physics, nuclear processes, thermal stresses, optics, and in assessment procedures as part of USN training and degree programs for a BS in physics and MS in environmental science / industrial hygiene. Approximately five years experience conducting various field and laboratory tests for corrosion, exposure, chemical content, and physical properties. See report (bibliographic reference Attachment 1 PNNL-11905.

Ill. Understand and interpret test results Karl Von Ahn - Understanding and interpreting test results is a part of routine training in completing engineering and science course work to attain an engineering degree. Karl Von Ahn has work experience in evaluating results of tests for radionuclide assays from radiation surveys, surveys and audits of laboratories, and also working in research laboratories for 7-8 years.

George Cicotte -- While in the U.S. Navy, designated as a quality control inspector and analysis quality control reviewer. Approximately five years experience conducting various field and laboratory tests for corrosion, exposure, chemical content, and physical properties.

Three years as a U.S. NRC inspector in facilities radiological protection, during which I conducted numerous assessments of test results, including radiation and other measuring instrument functions, transportation and shipping package integrity, sealed source integrity

2 during field use, processing system functions, and quality control of NIOSH approved devices. In several of these assessments, I was responsible for discovery of defects in  !

assembly, construction, component quality and configuration, metallurgical defects, and of testing deficiencies.

IV. Read and understand blueprints and drawings Karl Von Ahn - One semester course in Engineering Graphics as part of his engineering core curriculum. While at CWRU's Radiation Safety Office, he was involved in the construction of an interim and low level radioactive waste facility, and also in the development and construction of oversight for the entire departments (staff of 20) move to a new building location. Significant experience was gained in reading and interpreting blueprints from air handling equipment, waste shredder, compactor, survey meter, fire suppression, gas detection and security alarm systems in support of the daily operations of the safety office.

George Cicotte -- Over 20 years experience in work requiring regular reference to blueprints, schematics, assemb!y detail drawings, etc., for the purpose of assessing access, work hazards, component integrity, environmental conditions to which equipment was subject, and material construction. This included assessment of suitability of materials, physical challenges to function, etc.

V. Understand how the device works and how safety features operate Karl Von Ahn -- Included in the duties as an Assistant Radiation Safety Officer was performing safety evaluations of university facilities and equipment which requires a basic understanding of how equipment and devices work and their safety features operate. Part of the inspections included x-ray diffraction units, van degraff generators, a hospital cyclotron, in addition to facility equipment and layout.

George Cicotte -- Over 20 years experience which included assessing access, work hazards, component integrity, environmental conditions to which equipment was subject, and material construction. This included assessment of suitability of materials,, physical challenges to function, etc. Equipment evaluated included respiratory protective devices, radiographic handling equipment, instrumentation for detection of numerous temperature, pressure, radiation, and chemical property sensors, interlocks, fire protection equipment for susceptibility to damage, malfunction, or misuse. Also, long experience in repair of mechanical devices such as automotive equipment, residential construction.

VI. Understand and apply appropriate regulations Karl Von Ahn -- Over 5 years as Case Western Reserve University's Assistant Radiation Safety Officer (as listed on all NRC licenses) which required routinely reviewing, understanding and applying appropriate regulations. He has also attended the NRC's Sealed Source and Device Workshop in August 1998, and the NRC's Licensing Practices and Procedures Course" in September 1998.

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George Cicotte -- Three years as a USNRC inspector, five years as a research engineer l during which I performed numerous formal assessments of regulatory cc,mpliance for NRC l and DOE, and internal assessments for several major DOE contractors, and two years as a health physicist with the State of Ohio as a license reviewer and inspector, for a total of approximately 10 years conducting compliance assessments. Included in the time as a i research engineer were a number of publications (see Attachment 1) related to regulatory compliance, and assistance to DOE in development of numerous implementation guides (similar to NRC regulatory guides), technical manuals for safety during activities involving various materials and processes, and in impact assessments related to the revised 10 CFR 20 and 10 CFR 835. See also attached list of training courses related to regulatory enforcement.

Vil Understand the conditions of use Karl Von Ahn -- Over five years as Case Western Reserve University's Assistant Radiation Safety Officer which required understanding and interpreting license conditions (included five NRC licenses, a State of Ohio radioactive materials program and a State of Ohio Radiation Producing Equipment (X-ray) program) and applying them to Authorized Users.

George Cicotte -- Over 20 years, regular use of field and laboratory equipment for assessment of form, function, durability, environmental conditions, suitability for purpose, and other considerations, for materials and equipment used in production, utilization, nuclear medicine, radiation protection, calibration, independent measurements, dosimetric and calorimetric evaluations. Additionally, responsible for assessment of conditions of use to determine compatibility of use with standards of performance, for various detection and process equipment used for purposes of environmental remediation, personnel safety, compliance assessment, performance evaluations, and development of mechanical defects.

Vill Understand external dose rates, source activities, and nuclide chemical form, and Karl Von Ahn - NRRPT certification which requires passing a Health Physics certification exam to be registered as a Radiation Protection Technologist. His formal health physics training includes Health Physics Technician (1989) and Advanced Health Physics Training (1997). As CWRU's Assistant Radiation Safety Officer, he was responsible for understanding and making safety recommendations based on dose rates, source activities and nuclide chemical forms.

George Cicotte -- Over 20 years as a health physicist, including technician-level work at Three Mile Island Unit-2 post-accident and during kinetic expansions project at Unit 1, and at Peach Bottom Atomic Power Station during recirculation system piping replacement to correct intergranular stress corrosion cracking, professional-level work in training

! development as the technical resource for industrial hygiene and radiation safety, as Radiation Safety Officer for an environmental remediation project, as a U.S. NRC inspector for numerous utilization facilities, as a research engineer conducting assessments of safety, functionality, and applications (see publications list attached), and two years performing assessments, primarily with respect to use of small radioactive sources.

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l IX Understand and utilize basic knowledge of engineering materials and their l

properties."

l Karl Von Ahn's - Understanding and utilizing basic knowledge of engineering materials and their properties include three semesters of physics, two semesters of chemistry, two semesters of organic chemistry, two semesters of physical chemistry, one semester of polymers, and three semesters of metallurgy in addition to one semester of engineering j mechanics.

George Cicotte's - B.S. in Physics, with additional graduate course-work in Environmental l Science and in Industrial Hygiene. Performed numerous assessments of industrial and l mechanical failure analyses, programmatic risk assessments, and the environmental and occupational hazards associated with various failure modes. Assessments involved nuclear criticality, nonproliferation, emergency preparedness, compensatory measures, probabilities and modalities of failures, assessment of failures or misuses of generally and specifically licensed sealed sources, industrial processes which posed a challenge to the integrity and the chemical and physical properties of materials, such as fire involving sealed sources or contained radioactive materials. Major projects included kinetic expansion (explosive cold- .

roll of high-density steel alloys), seismic qualification of effluent processing equipment (assessment of configuration control, and fit such as thread engagement, materials compatibility, etc.), assessments of gaseous diffusion facilities (environmental conditions and challenge to materials), risk assessment of sealed sources (see Attachment 1).

On the Job Trainina Both Karl Von Ahn and George Cicotte spent two weeks (November 30 - December 11,1998) at the Nuclear Regulatory Commission Headquarters for "on-the-job" training regarding sealed source and device safety evaluations. Because both gentleman had recently completed the Sealed Source and Device Workshop, " on-the-job" training consisted mainly l of casework review, analysis and documenting the evaluations. Below is an agenda of the two weeks. Both the gentleman re- took the SSD Workshop exam, Karl Scored an 80% and l George Scored and 86%.

AGENDA 11/30/98

! General Orientation and Introductions Review of NUREG 1556 Vol 3, ANSI standards (source, device, irradiators) I Discussion of casework l j Discussion of objective of the two weeks OJT and expectations of Karl and George. l l Daily summary meeting to discuss status, issues, questions.

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5 12/1/98 Case work review Discussion of Vendors located in Ohio and estimated level of effort required for support in the SSD area.

10:30 Meeting with Brian Smith to discuss NMED data and tracking system for generic issues and how the Generic Assessment Panel Operates.

Daily summary meeting to discuss status, issues, questions.

12/2/98 Case work review Daily summary meeting to discuss status, issces, questions.

12/3/98 Case work review Discussion of case work issues, status Daily summary meeting to discuss status, issues, questions.

12/4/98 Casework review Daily summary meeting to discuss status, issues, questions.

12/7/98 through 12/11/98 Casework review Daily summary meeting to discuss status, issues, questions.

12/8/98 Discussion of prototype testing and its applicability conditions of use.

Discussion of generallicensing criteria of 10 CFR 32.51 and 31.5 12/11/98 Discussion of items completed. Worked, and experience gained

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, Casework KarlVon Ahn >

Hauni Richmond - Beta Density Gauge use in the tobacco industry to measure density. The company requested an amendment to the device to incorporate some design changes in the housing and in how the source are held in place. The device will be use by specific licensees only.

Ohmart - Basic design criteria for several industrial density and level gauges, The l company requested approval of the design criteria that is the same for all of its model devices, including its quality control program. The devise will be use by both general and specific licensees.

Ohmart - Gamma Density and Level Gauges used in a wide range of industrial applications. The company requested registration of 3 SR series models for use by both general and specific licensees.

Ohmart - Gamma Density and Level Gauges used in a wide range of industrial application. The company requested registration of a series of nine source housings model numbers SHLM-B, - C, -CP , for use by specific licensees only.

l Ohmart - Gamma Density and Level Gauges used in a wide range of industrial application. The company requested registration of a series of eight source housings model numbers SHLM-BR series and - CR series, for use by specific licensees only.

Grasbey Dynamics - Chemical Agent detector using a weak beta emitter for application involving hazardous chemical detection. The foreign company requested guidance on registration of the product for use by generallicensees and for persons exempt from the requirements of a license.

George Cicotte TWA - Associated equipment for use in radiography operations. The company l requested registration of a custom rigid guide tube to be used in radiographic operations involving aircraft engines. The produce would only be used by TWA and required a exemption to certain sections of 10 CFR part 34.

l Ohmart - Basic design criteria for several industrial density and level gauges. The company requested approval of the design criteria that is the same for all of its model l-devices, including its quality control program. The devise will be use by both general l and specific licensees.

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7 Ohmart - Gamma Density and Level Gauges used in a wide range of industrial application. The company requested registration of a series of 3 source housings model numbers SHLG -1. -2, and -3 for use by specific or generallicensees.

Ohmart - Gamma Density and Level Gauges used in a wide range of industrial application. The company requested registration of a series of 2 source housings model numbers SH and SH-F series for use by specific or generallicensees.

Sony Chemical Corocration - Bremsstrahlung Web thickness gauge used in a specific hiaustrial application. The foreign company requested registration of the custom device deign for use in its Pennsylvania plant.

Nvcomed Amersham - Gamma source used in medical applications. The company requested registration of a source design approved for use by an Agreement State but the distributor is located in NRC jurisdiction.

Gamma Med USA - High dose rate afterloader used in medical applications. The company requested reactivation of a certificate of registration they made inactive several years ago.

Ohmart - Gamma Density and Level Gauges used in a wide range of industrial application. The company requested registration of a series of 2 source housings model numbers SHLM BR/CR series for use by specific or generallicensees.

Ohma_rj - Gamma Density and Level Gauges used in a wide range of industrial application. The company requested registration of a series of 2 source housings model numbers SHRM B and BW for use by specific or general licensees.

GE Medical Systems - Gamma thickness gauge used in medical application The company requested registration of device use on SPECT cameras for use by specific licensees only.

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GEORGE CICOTTE'S PUBLICATIONS & PRESENTATIONS Enclosure 2 George Cicotte , G.R., and G.A. Stoetzel,1993. Task 5: Clean-uo Standards for Rocky Flats Plant D&D Projects. PNL-8788. August 1993. U.S. Department of Energy Rocky Flats Office (DOE-RF), Golden, Colorado.

Hickey, C.C.. G.A. Stoetzel, D.J. Strom, G.R. Cicotte, C.M. Wiblin, and S.A. McGuire.1993.

Air Samolina in the Workolace, NUREG-1400. September 1993. U.S. Nuclear Regulatory Commission, Washington, D.C.

Strom, D.J., R.L. Hills, J.S. Dukelow, and G.R. Cicotte.1993. Probabilistic Descriptions of Human Interactions with Radiation Sources Based on Historical Accidents. PNL-SA-22651, presented at the Society for Risk Analysis Annual Meeting December 5,1993. Society for Risk Analysis, Atlanta, Georgia.

Cicotte, G.R., and R. D. Mogle.1995. Mitiaation Factors Determination at Department of Enerav Sites for Safeauards and Security Purposes. February 1995. Presented at the DOE Office of Safeguards and Security Issues Annual Meeting. February 7,1995, Albuquerque, ,

New Mexico.

l Strom, D.J., R.L. Hill, J.S. Dukelow, and G. R. Cicotte.1994. TECHNICAL LETTER REPORT: TASK 7. FINAL REVIEW OF THE 1987 REPORT BY OAK RIDGE ASSOCIATED UNIVERSITIES. "lMPROPER TRANSFER / DISPOSAL SCENARIOS FOR GENERALLY LICENSED DEVICES. PNNL - 19905." June 1994. U.S. Nuclear Regulatory Commission, Washington, D.C.

GEORGE CICOTTE's TRAINING COURSES RELATED TO REGULATORY ENFORCEMENT Course No. Course Name Acoroximate Date (if applicable)

DOT Transportation of Radioactive Materials 3/97 CERCLA Site Hazardous Waste Operations 8/97 Refresher (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />)

BRP-006 Radiation Worker Training for Emergency Responders 4/97 BRP-005 Radiological Incident Response Program 2/98 in-Place Filter Testing Workshop [ Harvard School of Public Health) 6/89 NEC 3356 Engineering Laboratory Technician 8/76 NEC 3355 Nuclear Mechanical Operator 4/76 l HAZWOPER Hazardous Waste Site Operations (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />) 2/91 WSU CEUs Health Physics Certification Preparation 3/91 Nuclear Criticality Safety [ DOE Hanford] 8/92 G-108 Fundamental of Inspection 3/88 l

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9 G-109 Licensing Practices and Procedures 9/97 Licensing Practices and Procedures OJT [NRC R-Ill) 10/98 Sealed Source and Device Review Workshop [NRC-HQ) 8/98 (PENDING) Sealed Source and Device Review OJT [NRC-HQ) 12/98 H-111 Radiological Monitoring, Sampling and Analysis at 9/87

- Nuclear Facilities H-120 Radiological Surveys in Support of Decommissioning ~ 11/96

' H-201 Health Physics Technology (advanced topics) 12/89

- H-308 Transportation of Radioactive Materials 12/87 H-312 Internal Dosimetry and Whole Body Counting 2/88 H-314 Safety Aspects of Well-Logging 11/98 R106P Pressurized Water ReactorTechnology 10/87 R104B Boiling Water Reactor Technology - 9/87 Respiratory Protection at Nuclear Power Plants (R-Ill] 8/88 Probabilistic Risk Assessment Overview [NRC R-V) 4/88 Effective Communications for NRC Inspectors [NRC RV) 4/88

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L ' Ohio Vendors Enclosure 3 l

ABB Process Automation, Inc. 5 active certificates of registration Advanced Medical Systems, Inc. 3 active . certificates of registration Advanz Measurements and C v::ol 1 active certificates of registration Bicron was Solon Tech and Harshaw. 2 active certificates of registration Frontier Technology 2 active certificates of registration l

Industrial and Research Measurement Systems, Inc.1 active certificates of regis*ation Ohmart 2 Ohio sheets,1 NRC and 12 KY sheets. certificates of registration Overhoff Technology 1 active certificates of registration Picker International (was Ohio Imaging) 2 active certificates of registration Qual-X 1 active certificates of registration Stock Equipment Company 1 Ohio Sheet,1 active certificates of registration Technicare Corp 2 Ohio sheets cert.1icates of registration Thorn Automated Systems - Edistribution remains with NRC.

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