ML20198N977

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Forwards 1998 Integrated Matls Performance Evaluation Program (Impep) List of Action Items
ML20198N977
Person / Time
Issue date: 06/05/1998
From: Knapp M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Thompson H
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20198N952 List:
References
NUDOCS 9901060263
Download: ML20198N977 (16)


Text

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June 5, 1998

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MEMORANDUM TO:

Hugh L. Thompson, Jr.

Deputy Executive Director for g[/a[</ d?g"W

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' Regulatory Programs

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FROM:

Malcolm R.Knapp, Acting Director [0riginal signed by]

Office of Nuclear Material Safety and Safeguards

SUBJECT:

1998 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ACTION ITEMS I

With the recent completion of the Region I and il Integrated Materials Performance J

Evaluation Program (IMPEP) reviews, and the subsequent Management Review Board meetings, NMSS has prepared the attached list of action items. This list includes only those items for which NMSS was tasked with lead. The list includes recommendations and suggestions found in the IMPEP reports, or actions proposed at the MRB meetings. These will be tracked in the responsible Division's internal Operating Plan.

I Attachthent: As stated 4

cc: H.- Miller, RI L. Reyes, Rll i

CONTACT: George Deegan, NMSS/IMNS (301)415-7834 DISTRIBUTION:

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NMSS LIST OF 1998 IMPEP ACTION ITEMS 1A.

"The review team recommends that NMSS and AEOD consider the availability of the

" Finance for Non-Financial Professionals" course and the " Environmental Transport (including Groundwater Transport)" course, and inform the Regions on how these ccurse requirements in IMC.1246 should be met, or relaxed., while the courses are not offered by NRC." (Section 3.3 of RI report).

Lead: Division of Wasto Management Scheduled Completion Date: 12/15/98 1 B.

The Division of Waste Management committed to keep Agreement States informed of any changes in the training requirements regarding the courses listed in item 1 A above (Draft MRB Minutes for RI, dated May 7,1998, page 2).

Lead: Division of Waste Management Scheduled Completion Date: 12/15/98 2.

"The review team recommends that NMSS reexamine IMC 1246 and reconsider the requirements for decommissioning inspectors and decommissioning technical reviewers on non-complex decommissioning cases (e.g., those involving no groundwater contamination, no contamination outside of licensee buildings, and authorized use for enly short half-life materials)." (Section 3.3 of RI report).

i Lead: Division of Waste Management Scheduled Completion Date: 12/15/98 i

I 3.

The MRB (Mr. Kane) asked NMSS to convey to the Office of Human Resources, the comments and concerns related to the need for regions to maintain training records locally, due to the lack of, or inadequacies in, an Agency-wide system. (Draft MRB Minutes for RI, dated May 7,1998, page 2)

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: SDQlE 4.

The MRB asked NMSS and OSP to take another look at the possible overlap of '.he IMPEP allegation review and the regional reviews conducted by Ed Baker of NRR, in order to develop the most resource-effective approach. (Draft MRB Minutes for RI, dated May 7,1998, page 3).

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 9/30/98 i

5.

_"The review team recommends that NMSS complete efforts to add event follow up as a section in the next revision of the irradiator inspection field notes." (Section 2 of Ril

]

report).

1 Lead: Division of Industrial and Medical Nuclear Safety Completion Date: Completed May 7,1998-issued inspection Procedure 87112.

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2 6.

' The review team suggests that NMSS develop guidance for inspection of Sr-90 eye

~ applicators for distribution to the Regions and Agreement States."(Section 3.2 of Ril report)

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 2/26/99. Ril will provide first draft of this guidance. NMSS will develop the guidance, and assure proper distribution.

t 7.

"The review team suggests that NMSS clarify the " Milestone 22" issue by memorandum to the Regions." (Section 3.4 of Rll report)

Lead: Division of Industrial and Medical Nuclear Safety Completion Date: Completed. Memo issued by NMSS on March 23,1998.

8.

"It is suggested that NMSS consider ways in which information technology could be harnessed to improve the accessibility of completed fuel cycle inspection reports to Headquarters and Region-based inspectors." (Section 4.2 of Rll report)

Lead: Division of Fuel Cycle Safety and Safeguards Scheduled Completion Date: 12/31/98 9.

The MRB (Mr. Thompson) asked NMSS to take a deeper look at regional trends in extending or reducing inspection intervals, per Inspection Manual Chapter 2800. (Draft MRB Minutes for Rll, dated May 11,1998, page 2).

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 9/30/98 10.

The MRB suggested that NMSS consider extending the interval for the next Ril IMPEP review beyond two years. (Draft MRB Minutes for Rll, dated May 11,1998, page 4).

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 12/31/98. (Note: This could require Strategic Plan modification.)'

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  • MEMORANDUM TO:

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Deputy Executive Director for

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_ FROM:'

Malcolm R.Knapp, Acting Director [0riginal signed by]

Office of Nuclear Material Safety and Safeguards

SUBJECT:

1998 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ACTION ITEMS With the recent completion of the Region I and 11 Integrated Materials Performance Evaluation Program (IMPEP) reviews, and the subsequent Management Review Board meetings, NMSS has prepared the attached list of action items. This list includes only those items for which NMSS was tasked with lead. The list includes recommendations and suggest:ons found in the IMPEP reports, or actions proposed at the MRB meetings. These will be tracked in the responsible Division's internal Operating Plan.

Attachr'nent: As stated cc: H. Miller, RI L. Reyes, Rll CONTACT: George Deegan, NMSS/IMNS (301) 415-7834 DISTRIBUTION:

NRC Central File IMNS r/f NMSS r/f 1

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"C"= Copy w/o attlenet "E" = Co n w/attlenct"N" = No copy j

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NMSS LIST OF 1998 IMPEP ACTION ITEMS 1 A.

"The review team recommends that NMSS and AEOD consioer the availability of the

' Finance for Non-Financial Professionals" course and the " Environmental Transport (including Groundwater Transport)" course, and inform the Regions on how these course requirements in IMC 1246 should be met, or relaxed, while the courses are not offered by NRC." (Section 3.3 of RI report).

Lead: Division of Waste Management Scheduled Completion Date: 12/15/98 018.~

The Division of Waste Management committed to keep Agreement _ States informed of any changes in the training requirements regarding the courses listed in item 1A above (Draft MRB Minutes for RI, dated May 7,1998, page 2).

e -

Lead: Division of Waste Management Scheduled Completion Date: 12/15/98 2.

"The review team recommends that NMSS reexamine IMC 1246 and reconsider the requirements for decommissioning inspectors and decommissioning technical reviewers on non-complex decommissioning cases (e.g., those involving no groundwater contamination, no contamination outside of licensee buildings, and authorized use for only short half-life materials)." (Section 3.3 of RI report).

Lead: Division of Waste Management Scheduled Completion Date: 12/15/98 3.

The MRB (Mr. Kane) asked NMSS to convey to the Office of Human Resources, the comments and concerns related to the need for regions to maintain training records locally, due to the lack of, or inadequacies in, an Agency-wide system. (Draft MRB Minutes for Rl, dated May 7,1998, page 2)

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 6/30/98 4.

The MRB asked NMSS and OSP to take another look at the possible overlap of the IMPEP allegation review and the regional reviews conducted by Ed Baker of NRR, in order to develop the most resource-effective approach. (Draft MRB Minutes for RI, dated May 7,1998, page 3).

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 9/30/98 5.

"The review team recommends that NMSS complete efforts to add event follow up as a section in the next revision of the irradiator inspection field notes." (Section 2 of Ril report),

Lead: Division of Industrial and Medical Nuclear Safety i

Completion Date: Completed May 7,1998-issued Inspection Procedure 87112.

=

2 6.

"The review team suggests that NMSS develop guidance for inspection of Sr-90 eye

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applicators for distribution to the Regions and Agreement States." (Section 3.2 of Rll report) a Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 2/26/99. Ril will provide first draft of this guidance. NMSS will develop the guidance, and assure proper distribution.

7.

'The review team suggests that NMSS clarify the " Milestone 22" issue by memorandum to the Regions." (Section 3.4 of Ril report)

Lead: Division of Industrial and Medical Nuclear Safety Completion Date: Completed. Memo issued by NMSS on March 23,1998.

8.

"It is suggested that NMSS consider ways in which information technology could be harnessed to improve the accessibility of completed fuel cycle inspection reports to Headquarters and Region-based inspectors." (Section 4.2 of Rll report)

Lead: Division of Fuel Cycle Safety and Safeguards Scheduled Completion Date: 12OJL93 9.

The MRB (Mr. Thcmpson) asked NMSS to take a deeper look at regional trends in extending or reducing inspection intervals, per Inspection Manual Chapter 2800. (Draft MRB Minutes for Ril, dated May 11,1998, page 2).

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 9/30/98 10.

The MRB suggested that NMSS consider extending the interval for the next Rll IMPEP review beyond two years. (Draft MRB Minutes for Ril, dated May 11,1998, page 4).

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 12/31/98. (Note: This could require Strategic Plan modification.)

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, RECONSIDER:THE? REQUIREMENTS FOR DECOMMISSIONING Linehan

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, ON NON-COMPLEX-DECOMMISSIONING' CASES..............

'SPECIAL INSTR'UCTIONS OR REMARKS:

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June 5, 1998 1

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MEMORANDUM TO:

Hugh L. Thompson, Jr.

f[/a 6/ d'/ g#/

Deputy Executive Director for

/

Regulatory Programs FROM!

Malcolm R.Knapp, Acting Director [0riginal signed by]

Office of Nuclear Material Safety and Safeguards

SUBJECT:

1998 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM ACTION ITEMS With the recent completion of the Region I and il Integrated Materials Performance Evaluation Program (IMPEP) reviews, and the subsequent Management Review Board meetings, NMSS has prepared the attached list of action items. This list includes only those items for which NMSS was tasked with lead. The list includes recommendations and suggestions found in the IMPEP reports, or actions proposed at the MRB meetings. These will be tracked in the responsible Division's internal Operating Plan.

Attach 51ent: As stated cc: H. Miller, RI L. Reyes, Rif I

CONTACT: George Deegan, NMSS/IMNS (301)415-7834 DISTRIBUTION:

NRC Central File IMNS r/f NMSS r/f KDattilo 84 PDR:YES NO EJBaynard KMcDarby LCamper EQTenEyck E8rd JGreeves DCool FCombs

. SMoore JPiccone JThoma OU "^

rjj DOCUMENT NAME:

G:\\lMPEPACT 98 POM2 gg MI To receive a copy of this document. indicate in the box:

"C"a Copy w/o attlenel "E" = Cosy w/att/enct "N" = No copy OFC OB,

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NMSS LIST OF 1998 IMPEP ACTION ITEMS 1A.

"The review team recommends that NMSS and AEOD consider the availability of the

" Finance for Non-Financial Professionals" course and the " Environmental Transport (including Groundwater Transport)" course, and inform the Regions on how these course requirements in IMC 1246 should be met, or relaxed, while the courses are not offered by NRC."(Section 3.3 of RI report).

Lead: Division of Waste Management Scheduled Completion Date: 12/15/98 1 B.

The Division ~ of Waste Management committed to keep Agreement States informed of any changes in the training requirements regarding the courses listed in Item 1 A above (Draft MRB Minutes for RI, dated May 7,1998, page 2).

1:

Lead: Division of Waste Management Scheduled Completion Date: 12/15/98 M23 The review team recommends that NMSSsraexamma E1246 and reconsider the requirements for decommissioning inspectors and decommissioning technical reviewers on non-complex decommissioning cases (e.g., those involving no groundwater contamination, no contamination outside of licensee buildings, and authorized use for only short half-life materials)." (Section 3.3 of RI report).

Lead: Division of Waste Management Scheduled Completion Date: 12/15/98 3.

The MRB (Mr. Kane) asked NMSS to convey to the Office of Human Resources, the comments and concerns related to the need for regions to maintain training records locally, due to the lack of, or inadequacies in, an Agency-wide system. (Draft MRB Minutes for RI, dated May 7,1998, page 2)

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 6/30/98 4.

The MRB asked NMSS and OSP to take another look at the possible overlap of the IMPEP allegation review and the regional reviews conducted by Ed Baker of NRR, in 4

order to develop the most resource-effective approach. (Draft MRB Minutes for RI, dated May 7,1998, page 3).

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 9/30/98 1

- S.

"The review team recommends that NMSS complete efforts to add event follow up as a section in the next revision of the irradiator inspection field notes." (Section 2 of Rll

. report),

Lead: Division of industrial and Medical Nuclear Safety Completion Date:. Completed May 7,1998-issued Inspection Procedure 87112.

4,

2 6.

"The review team suggests that NMSS develop guidance for inspe : lion of Sr-90 eye applicators for distribution to the Regions and Agreement States." (Section 32 of Ril report)

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: 2/26/99 Ril will provide first draft of this guidance. NMSS will develop the guidance, and assure proper distribution.

7.

"The review team suggests that NMSS clarify the " Milestone 22" issue by memorandum to the Regions." (Section 3.4 of Ril report)

Lead: Division of Industrial and Medical Nuclear Safety Completion Date: Completed.~ Memo issued by NMSS on March 23,1998.

8.

"It is suggested that NMSS consider ways in which information technology could be harnessed to improve the accessibility of completed fuel cycle inspection reports to Headquarters and Region-based inspectors." (Section 4.2 of Rll report)

Lead: Division of Fuel Cycle Safety and Safeguards Scheduled Completion Date: 12/31/98 9.-

The MRB (Mr. Thompson) asked NMSS to take a deeper look at regional trends in extending or reducing inspection intervals, per Inspection Manual Chapter 2800. (Draft MRB Minutes for Rll, dated May 11,1998, page 2).

Lead: Division of Industrial and Medical Nuclear Safety Scheduled Completion Date: JL3D193 10.

The MRB suggested that NMSS consider extending the interval for the next Ril IMPEP review beyond two years. (Draft MRB Minutes for Ril, dated May 11,1998, page 4).

Lead: Division of Industrial and Medical (Juclear Safety Scheduled Completion Date: 12/31/98. (Note: This could require Strategic Plan modification.)

)

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SECTION VII TRAINING REQUIREMENTS FOR FUEL CYCLE LICENSE REVIEWER A.

APPLICABILITY The training described below is required for all fuel cycle license reviewers assigned to perform safety reviews of fuel cycle license applications.

B.

TRAINING 1.

Reouired Initial Trainina a.

Self Study and on-the.iob Trainina (1)

NRC Orientation (2) Code of Federal Regulations (3) Office Instructions (4)

Regulatory Guidance (5)

Fuel Cycle Licensing Branch Manual

~

(6)

Industry Codes and Standards L

(7)

NRC Management Directives (8)

Review of significant events at fuel cycle licensees (9)

Directed Review of Selected Licensing Case Work b.

Core Trainina.

These courses establish minimum formal classroom training requirements.

Refer to Section 1246-11 for exceptions to these requirements.

(1) RoottCause/ Incident Investigation' Workshop.(G-205)

(2) OSHA; Indoctrination' Course (G-111)

(3) Site' Access Training (H-100)

(4) General" Health" Physics Practices 1for' Fuel Facilities Directed Self-StudyiCourse (F-1025).or equivalent;

~(5) fuel Cyclc Tcchnology Course (I-200) Fuel: - Cycle 1 Processes Directed Self-Study; Course (F-201S)

(6)

Integrated Safety Analysis _ Course ~(F-103)

Issue Date:

XX/XX/XX VII-1 1246. APPENDIX A a,

c.

Soecialized Trainina.

Depending on the fuel cycle license 4

reviewer's previous work experience and planned reviewer activities.

I additional courses may be required in order to gain knowledge necessary for specialized licensing activities. Headquarters branch management will make this determination on an individual basis. For example, if a license reviewer is assigned activities in one of the J

areas listed below then that reviewer should attend the ap)ropriate l

training course or have equivalent experience as determinec by their management.

(1) Nuclear Criticality Safety Directed,Self-Study Course (F-101S)

(2) Air Sampling for Radioactive Material Course (H-119)

(3) Site Access Training Course (H-100)

(4) Transportation of Radioactive Materials Course (H-308) l l

(5) Environmental Monitoring for Radioactivity (H-111) l (6) Fire Protection for Fuel Cycle Facilities Directed Self-Study Course (F-206S) l 2.

Suoolemental Trainina.

Additional training beyond that identified as Core Training.

This training will be determined by the individual's supervisor and will depend on the individual's previous work experience and planned inspection or licensing activities in specific areas.

3.

Refresher Trainina.

Refresher training will be conducted every three years following initial certification.

Refresher training will be 1

determined by management on a case-by-case basis.

END l

l I

I

)

l 1246, APPENDIX-A VII-2 Issue Date:

XX/XX/XX

SECTION VIII TRAINING REQUIREMENTS FOR DIVISION OF WASTE MANAGEMENT INSPECTORS AND LICENSE REVIEWERS A.

APPLICABILITY The training described below is required for all insoectors assigned to perform Division of Waste Management (DWM) inspections and 'license reviews.

B.

TRAINING 1.

Reauired Initial Trainina a.

Self Study and on the Job Trainina (1) NRC Orientation (2) Code of Federal Regulations (3) Office Instructions (4) Regulatory Guidance (5) NRC Inspection Manual (6)

Industry Codes and Standards (7)

Inspection Accompaniments (8) NRC Management Directives (9) Review of significant events involving either licensees or sites for which DWM has regulatory responsibility (10) Directed Review of Selected Licensing Case Work l

b.

Core Trainina These courses establish minimum formal classroom training requirements.

Refer to Section 1246-11 for exceptions to I

these requirements.

(1) Fundamentals of Inspection Course (G-101) or Inspection Procedures Course (G-108)

(2) Root Cause/ Incident Investigation Workshop (G-205)

(3)

Inspecting for Performance Course - Materials Version (G-304)

Issue Date:

XX/XX/XX VIII-1 1246, APPENDIX A

(4)

Effective Communications for NRC Inspectors (0P)

(5) OSHA Indoctrination Course (G-111)

(6) NMSS Radiation Worker Training (H-102) or Site Access Training (H-100)

(7)

Introduction to Health Physics Course (H-117) or Health Physics Technology Course (H-201)

(8) Licensing Practices and Procedures Course (G-109)

(9) NRC Inspection Team Leader Workshop (OP)

(10) The Regulatory Process Course (0P)

(11) Confident Public Speaking c.

Soecialized Trainino.

Depending on the employee's previous work experience and planned activities, additional courses may be required in order to gain knowledge necessary for specialized inspection or licensing activities.

Management will make this determination on an individual basis.

Hiah Level Waste (HLW):

(1) Leading NRC Work Teams (2) Lead Auditor Training (3) General Underground Training (GUT) including First Aid and CPR (4) General Employee Radiological Training (GERT)

(5) General Employee Training (GET)

Uranium Recoverv:

(1) Uranium Program Policy and Guidance Directives Decommissionina:

l (1) Environmental Transport (including groundwater transport) (368 trainirig, specific course to be determined by supervisor)

(2) Radiological Lurveys in Support of Decommissioning (ll-120) Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) Course (H-121)

(3) Environmental Monitoring for Radioactivity (H-111)

(4) Workshop on Financial Assurance for Decommissioning (DWM) 1246. APPENDIX A VIII-2 Issue Date:

XX/XX/XX

2.

Sucolemental Trainina Mditional training beyond that identified as Core Training.

This-training will be datermined by the supervisor and will depend on. the individual's previous work experience and planned inspection or licensing activities in specific. areas.

3.

Refresher Training Refresher training will be conducted every three years following initial certification.

Refresher training will include the following courses and other courses as determined by management:

(0 Fundameritals of i,1spection Refresher Course (G-102)

END 1

i, 3

i 4

)

4 4

A k-t Issue Date:

XX/XX/XX VIII-3 1246, APPENDIX A

,'I 3

SECTION IX TRAINING REQUIREMENTS FOR DECOMMISSIONING INSPECTORS A.

APPLICABILITY The training described below is required for all decommissioning inspectors 4

assigned' to perform radiological safety inspection activities at material decommissioning facilities.

1 B.

' TRAINING 1.

Reauired Initial Trainina a.

Self Study and On-the-Job Trainina

-(1) NRC Oric ntation (2) Code of Federal Regulations (3) - Office Instruct 1ons/ Regional Procedures I

(4) Regulatory Guidance (5) NRC Inspection Manual (6)

Industry Codes and Standards (7). Inspection Accompaniments (8) NRC Management Directives (9) Review of significant events at facilities being decommissioned (10) Directed Review of Selected Inspection Case Work i

b.

Core Trainina. These courses establish minimum formal classroom training requirements.

Refer to Section 1246-11 for exceptions to-these requirements.

(1) Fundamentals of Inspection Course (G-101) or Inspection Procedures Course (G-108) l l

(2) Root Cause/ Incident Investigation Workshop (G-205)

(3)'~ -Inspecting for Performance Course - Materials Version (G-304)

(4) ' Effective Communications for NRC Inspectors (0P)

(5) OSHA Indoctrination Course (G-111) j Issue Date:

XX/XX/XX IX-1 1246,. APPENDIX A F

L

o-(6)' NMSS Radiation Worker Training (H-102) or Site Access Training l

(H-100)-

1 (7) Radiological Survcys in suggu, m vsmummissioning Course j

v.

(!!-120) Multi-Agency Radiation' Survey andl Site: Investigation

~

Manuaif(MARSSIM) CourseL(H-121)

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(8) ' Health Physics. Technology Course (H-201)

(9): Transportation of Radioactive Materials Course (H-308)

(10) Environmental Monitoring for Radioactivity Course (H-111) 1 (11) Environmcatal Transacrt (including groundwater transport) (form 053) l (12) Financc for Nonfirincial Professional (0P)

Workshop 11on Financial Assurance;fotDecommissioning (DWM) c.

Soecialized Trainina.

Depending on the inspector's previous work experience and planned inspection activities, additional courses may be required in order to gain knowledge necessary for specializea inspection activities.

Management will make this determination-on an individual basis.

(1) Environmental Transport (including groundwater _ transport) (368 training. specif.ic course to be determined by supervisor) 2.

Sunolemental Trainina.

Additional training beyond that identified as Core Training.

This training will be determined by the individual's

.i supervisor and will depend on the individual's orevious work experience r'

and planned inspection activities in specific areas.

i 3.

Refresher Trainina.

Refresher training will be conducted every three

-years. following initial certification.

Refresher training will include 3

the following:

i (1) Fundamentals of Inspection Refresher Course (G-102)

)

(2) Health Physics Topical Review Course (H-401)

END 4

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h L1246, APPENDIX A IX-2 Issue Date:

XX/XX/XX

i 4

a 1 3 i

-SECTION X.

. TRAINING REQUIREMENTS FOR DECOMMISSIONING PROJECT MANAGERS AND

. TECHNICAL-REVIEWERS I.

fAPPLICABILITY l

A u

s The' training described below is required for all decommissioning:-project managers and technical-reviewers.

3

.B.

TRAINING

'1.

Reauired Initial Trainina-a.

Self-Study and On-the-Job Trainina (1) NRC Orientation

-(2)' Code.of Federal Regulations

(3) Office Instructions.

1

-(4) Regulatory Guidance l

(5) NRC Inspection Manual (6)

Inspection Accompaniments l

o i

(7) NRC' Management Directives (8). Directed Review of Selected Licensing Case Work

.b.

Core Tsininc. These courses establish minimum formal classroom training requirements.

Refer to Section 1246-11 for exceptions to

these requirements..

~

(1) Fundamentals of Inspection Course (G-101)

(2) OSH, Indoctrination Course (G-111)

(3) The Regulatory Process (0P)

(4), Corifident Public Speaking (OP).

(5) Finance 'for Nonfinancial Professionals (0P) Workshop T on I

financiaKAssuranceiforiDecommissioning;(DWM)

' ' ~

(6)- NMSS' Radiation Worker Training. (H-102) or Site Access Training (H-100) gIssuelDate:

XX/XXiXXc ~

X-1

-1246. APPENDIX A u

6 4

j i

f(7)IntroductiontoHealthPhysicsCourse(H-117) 5 3

or Health Physics-Technology Course.(H-201)

(8). Licensing Practices:and Procedures Course (G-109) b, m?N,yv, E,'$2[agggrt (including groundwater 55 e

u ov m vuu, c

(9) Radiological Surveys in Support of Decomissioning (ll-120)

Mul ti 2 AgencyJ Radi ati on 4 Survey lland 3 Si te EInvesti gati oniManua1

(MARSSIM); Course (H-121)

(10) Environmental Monitoring for.. Radioactivity-(H-111)

(11) Root Cause/ Incident Investigation Workshop (G-205) c.

Soecialized Trainina.

. Depending on the decommissioning project' manager's or technical reviewer's previous work experience and planned-activities, additional courses may be required in order to R

gain knowledge necessary -for specialized activities.

Management j

will make this determination on an individual basis.

(1) Environmental Transport (including groundwater: transport):(368 training,jspecific course to be; determined by;supervi'sor) 2.

Sijoolemental Irainins. Additional training beyond that identified as Core Trai n'.ng.

This training will be determined by the individual's and planned.activiti. depend on the individual's previous work experience supervisor'and will es in specific. areas.

l 3.

Refresher Trainina, Refresher training will be conducted every three j

years following. initial ' certification. Refresher training will be determined by management on a case by case basis.

-]

END E

i I

D 1246, APPENDIX Ai X-2 Issue Date:

XX/XX/XX

F

  • 4 l u, ) A TICKET DATE RECEIVED: 06/17/98 ORIGINAL DUE DT 12/15/98 CONTROL NO: 9800302 DIVISION DATE: 12/10/98 DOC DT: 06/05/98 FRON:

TIME COMP DT

/ /

Knapp/Deegan NMSS/IMNS TO:

Thompson FOR SIGNATURE OF

    • BLUE **

SECY NO:

ASSIGNED TO:

CONTACT:

DWM DESCs ROUTING:

1998 IMPEP PROGRAM ACTION ITEMS - 1A.

THE REVIEW Knapp TEAM RECOMMENDS THAT NMSS & AEOD CONS! DER THE Cool AVAILABILITY OF THE " FINANCE FOR NON-FINANCIAL Linehan PROFESS 10NAIS" COURSE & THE " ENVIRONMENTAL Poland TRANSPORT COURSE, & INFORM THE REGIONS ON HOW..

SPECIAL INSTRUCTIONS OR REMARKS:

Due to NMSS:

12/10/98 Due to be completed: 12/15/98

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TICKET DATE RECEIVED: 06/17/93 OAIGINAL DUE DT 12/15/98 CONTROL NOf 9800304 DIVISION DATE: 12/10/98 DOC DT 06/05/98 FROM:

TIME:

COMP DT:

/ /

Knapp/Deegan NMSS/IMNS TO:

i Thompson FOR SIGNATURE O

    • BLUE *
  • SECY NO:

Knapp ASSIGNED TO:

CONTACT:

DWM l

ROUTING:

DESC:

1998 IMPEP PROGRAM ACTION ITEMS THE REVIEW Knapp TEAM RECOMME!!DS THAT NMSS REEXAMINE IMC 1246 AND Cool PECONSIDER THE REQUIREMENTS FOR DECOMMISSIONING Linehan INSPECTORS & DECOMMISSIONING TECHNICAL REVIEWERS Poland ON NON-COMPLEX DECOMMISSIONING CASES..

SPECIAL INSTRUCTIONS OR REMARKS:

Due to NMSS:

12/10/98 Due to be completed: 12/15/98 kOTCt h 0> $.

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~n December 14, 1998 C. J. Paperiello o DWM and ITD have reviewed the requirements for inspectors and license reviewers of non-complex decommissioning cases. The primary differences between complex and non-complex sites are extent and !ocation of contamination, particularly in ground water. TfD has made changes in training related to ground water and environmental transport of contamination (See Response to NMSS Ticket 9800302 above). Further changes in the training requirements would not result in cost effective use of personnel, because of the potential for a site to be re-categorized after decommissioning begins. For example, if during remediation activities, a site was detennined to have more extensive contamination than originally believed, under a dual qualification scheme a new inspector and license reviewer with the additional training would have to be assigned. This could cause unacceptable delays in time and cost in the decommissioning effort. Further, a dual qualification scheme would limit the range of assignments ofindividuals and may have unfavorable impacts on organizational structure. Therefore. NMSS does not consider there to be justification for two classes ofinspector and reviewers.

TICKETS: N-9800302-4 (3 #cN6b )

DISTRilllITION:

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C. J. Paperiello -,

o DWM and TfD have reviewed the requirements for inspectors and license reviewers of non-com' plex deenmmissioning cases.. The primary differences between complex and g

- non-complex sites are extent and location of contamination, particularly in ground water, 1TD has made changes in training related to ground

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j-water and envirosigental transport of contamination (See Respeme to NMSS Ticket I

9800302 above). Fyher changes in the training requirements would not result in cost ~

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effective use of perso 1, because of the potential for a site to be re-categorized after

' decommissioning begi That is, if during remediation activities, a site was determined a

. to have more extensive c tamination than oiiginally believed, ender a dual quali6 cation L

schema a new inspector an-icense reviewer with the additional training would have to be assigned. This could cause nacceptable delays in time and cott in the decommissioning elTort. Furthe ' a dual quali0 cation schema would limit the range of l

assignments ofindividuals and m have unfavorable impacts on organizational structure. Therefore, NMSS will no implement two classes ofinspector and reviewers.

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