ML20198P796

Revised Directive & Handbook 5.6, Integrated Matls Performance Evaluation Program

ML20198P796
Person / Time
Issue date:	11/25/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF STATE PROGRAMS (OSP)
To:
Shared Package
ML20198P773	List: ML20198P771 ML20198P796
References
5.6, NUDOCS 9801220254
Download: ML20198P796 (84)

Text

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Integrated Materials 1- Performance Evaluation Program (IMPEP)

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Volume 5, Governmental Relations and Public Affairs

w. Integrated Materials Performance Evaluation Program (IMPEP)

Directive 5.6 Contents Policy................................................................... 1 Obj ec t i ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Organizational Responsibilities and Delegations of Authority............ 2 Deputy Executive Director for Regulatory Programs (DEDR) . . . . . . . . . . . . . . . 2 Director, Office of Nuclear Material S ifety and Safeguards (NMSS) and Director, Office of State Programs (OSP) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 G e n e ral Co u n se l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Director, Office for Analysis and Evaluation of Operational Data (AEOD). . . . . 3 Regional Administ rators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Appli ca b i l i ty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 H a n d boo k . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Re fe re n ces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Approved: September 12,1995 (Revised: November 25,1997) ~ iii

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,, [- , " U. S. Nuclear Regulatory Cownission OSP s% ,,,, Volume: 5 Governmental Relatiera .nd Public Affairs NMSS Integrated Materials Performance Evaluation Program (IMPEP)

Directive 5.6 Policy .

(5.6-01)

It is the policy of the U.S. Nuclear Regulatory Commission to evaluate the NRC regional materials programs and Agreement State radiation control programs in an integrated manner, using common and non common performance indicators, to ensure that public health and safety is being adequately protected.

Objectives (5.6-02) e To establish the process by which the Office of Nuclear Material Safety and Safeguards and th Office of State Programs conduct their periodic assessments to determine the adequacy of their programs in the NRC regions and Agreement States. (021) e To provide NRC and Agreement State management with a systematic and integrated approach to evaluate the strengths and weaknesses of their nuclear material licensing and inspection programs. (022)

• To provide significant input to the management of the regulatory decision-making process, and indicate areas in which NRC and the Agreement States should dedicate more resources or management attention. (023) s Approved: September 12,1995 (Revised: November 25,1997) 1

Volume 5, Governmental Relations and Public Affairs . '~

Integrated Materials Performance Evaluation "rogram (IMPEP) j Directive 5.6 Organizational Responsibilities and Delegations of Authority .

(5.6-03) 1 Deputy Executive Director for Regulatory i l

Programs (DEDR)

(031) e Oversees the integrated materials performance evaluation program (IMPEP). (a) e Chairs management review boards (MRBs). (b)

. Signs final reports issued to each reg:on and Agreement State. (c)

Director, Omce of Nuclear Material Safety and Safeguards (NMSS) and Director, Omce of State Programs (OSP)

(032)

• Implement the IMPEP within NMSS and OSP, Provide staffing support and training for review teams. (a) e Establish a schedule and develop a detailed review regimen for conducting the reviews in each region and Agreement State. (b) e Monitor the IMPEP process; evaluate and develop IMPEP policy, criteria, and methodology, and assess the uniformity and adequacy of the implementation of the program. (c)

• Issue draft reports and prepare final reports for each region and State for consideration by the MRB and signature by the DEDR. (d) e Participate on MRB. (e) e Coordinate with Agreement States to provide appropriate l

representatives for IMPEP reviews and MRB meetings. (f) .

General Counsel l (033) .

Participates on MRBs.

l Approved: September 12,1995 2 (Revised: November 25,1997)

Volume 5, Governmental Relations and Public Affairs

,. Integrated Materials Performance Evaluation Program (IMPEP)

Directive 5.6 Director, Omce for Analysis and Evaluation of Operational Data (AEOD)

(034)

Participates on MRBs.

Regional Administrators (035)

• Implement the IMPEP within their respective regions. (a)

• Provide staffing support for review teams, as needed. (b)

Applicability (5.6-04)

The policy and guidance in this directive and handbook apply to all NRC employees who are responsible for and panicipate in the IMPEP.

Handbook (5.6-05)

Handbook 5.6 describes the performance indicators that will be used, the performance standards against which these indicators will be evaluated, and the frequency and process sequence to be employed.

The " Glossary" to the handbook also defines the most commonly used key terminology.

References (5.6-06)

Code ofFedeml Reg luJons, Title 10 (10 CFR), " Energy."

NRC " Statement of Principle and Policy for the Agreemen* State Program; Policy Statement on Adequacy and Compatibihty of Agreement State Programs," 62 FR 46517, September 3,1997.

NRC Inspection Manual, Chapter 0610, " Inspection Reports."

-, Chapter 1246, " Formal Qualification Programs in the Nuclear Material Safety and Safeguards Program Area."

, Chapter 2600, " Fuel Cycle Facility Operational Safety and Safeguards inspection Program."

Approved: September 12,1995 (Revised: November 25,1997) . 3

Volume 5, Governmental Relations and Public Affairs . .

Integrated M.sterials Performance Evaluation Program (IMPEP) l Directive 5.6 ,

l References l (5.6-06) (continued) ,

, Chapter 2604,"Ucensee Performance Review."

, Chapter 2605," Decommissioning Procedures For Fuel Cycle and Materials Ucensees."

, Chapter 2800," Materials Inspection Program."

, Chapter 2801, " Uranium Mill and 11e.(2) Byproduc'. Material Disposal Site and Facility Inspection Program."

, Inspection Procedure 87104, " Decommissioning Inspection Procedure For Materials Ucensees."

, Inspection Procedure 88104, " Decommissioning Inspection Procedure For Fuel Cycle Facilities."

NRC Management Directive 5.9, " Adequacy and Compatibility of Agreement State Programs."

NRC Office of State Programs Internal Procedure B.7," Compatibility Categories and Health and Safety Identification for NRC Regulations and Other Program Elements" (current revision).

- D.7," Reviewing State Regulations" (current revision).

t Apperved: September 12,1995 4 (Revind: November 25,1997)

Integrated Materials Performance Evaluation

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Program (IMPEP)

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Volume 5, Governmental Relations cod Public Affairs

,. Integrated Materials Performance Evaluation Program (IMPEP)

Handtxxik 5.6 Pg= I - IV Contents Part I Ev a l ua ti on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Evaluation Frequency (A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Evaluation Process Sequence (B) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Part XI Performa nce Indicators . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3

G e m ra l ( A ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4 Commo'n Performance Indicators (B) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Common Performance Indicator 1-Status of Materials Inspection Program ( 1 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Common Performance Indicator 2-Technical Quality of Inspections (2). . . 4 Common Performance Indicator 3-Technical Stdfing and Training (3). . . . 5 Common Performance Indicator ' Technical Qaalitu of Licensing Act:o ns (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Common Performance Indicator 5-Re@onse to Incidents and l Allegations (5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Non. Common Performance Indicators (C) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Non-Common Performance Indicator 1-Legislatior' and Program Elements Required for Compatibility (1) . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Non Common Performance Indicator 2-Sealed Source and Device Evaluation Program (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Non. Common Performance Indicator 3-Low-Level Radioactive Waste Disposal Prngram (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Non-Common Performance Indicator 4-Uranium Recovery Program (4). . 13 Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Progra m (5 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Non-Common Performance Indicator 6-Site Decommissioning Management Plan (SDMP) (6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Part III Evalua tion Cri teria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Common Performance indicator 1-Status of Materials Inspection Program (A ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Approved:- September 12,1995 (Revised: November 25,1997) iii

a Volume 5, Governmental Relations and Pcblic Affairs i Integrated Materials Performance Evaluation Program (IMPEP) . - 1 Handback 5.6 Parts I - IV l Contents (continued)

Part III(continued)

Satisfactory (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Satisfactory With Recommendations for Improvement (2) . . . . . . . . . . . . . . . 24 Unsatisfactory (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Cat egory N (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Common Performance Indicator 2-Technical Quality of Inspections (B) . . . . . . 24 Satisfactory (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Satisfactory With Recommendations for Improvement (2) . . . . . . . . . . . . . . . 25 Unsatisfactoiy (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Cat e go ry N (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 I

Common Performance Indicator 3- Technical Staffing and Training (C). . . . . . . 26 S a tisfact o ry (1 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

)

Satisfactey With Recommendations for Improvement (2) . . . . . . . . . . . . . . . 27' Unsatisfactory (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Cat egory N (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 l

Common Performance Indicator i Technical Quality of I.icensing (D) . . . . . . . 28 l

i S a tisfact o ry ( 1 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Satisfactory With Recommendations for improvement (2) . . . . . . . . . . . . . . . 28 l

l Unsatisfactory (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 i

Cat e go ry N (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 l Common Performance Indicator 5-Response to Incidents and Allegations (E). 29 Satisfacto:y (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Satisfactory With Recommendations for Improvement (2) . . . . . . . . . . . . . . . 29 Unsatisfactory (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Cat ego ry N (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Non-Common Performance Indicator 1-Legislation and Program Elements

! Required for Compatibility (F) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 ,

S atisfact o ry ( 1 ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 l

l Satisfactory With Recommendations for Improvement (2) . . . . . . . . . . . . . . . 31 ,

Unsatisfact ory (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 Catego ry N (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 i

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Approved: September 12,1995 l iv (Revised: Nourrber 25,1997)

Volume 5, Governmental Relations Cnd Public Mfairs

s. Integrated Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Parts I - IV Contents (continued)

Part Ill (continued)

Non-Common Performance Indicator 2--Sealed Source and Device Evaluation Program (G) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 Technical Quality of the Product Evaluation Progr:.m (1) . . . . . . . . . . . . . . . . 33 Technical Staffing and Training (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Evaluation of Defects and Incidents Regarding SS&Ds (3). . . . . . . . . . . . . . . 36 Non. Common Performance Indicator 3-Low-Level Waste Radioactive Waste Disposal Program (H) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Statas of Low Level Radioactive Waste Disposal Inspection (1). . . . . . . . . . . 37 Technical Quality of Inspections (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Technical Staffing and 'Itaining (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 Technical Quality of Licensing Actions (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 Response to Incidents and Allegations (5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 Non-Common Performance Indict. tor i Uranium Recovery Program (1). . 44 Status of Uranium Recovery Inspection Program (1) . . . . . . . . . . . . . . . . . . . . 44 Technical Quality of Inspections (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 Technical StaffSg and Training (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 Technical Quality of Licensing Actions (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 Response to Incidents and Allegations (5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 Status of Fuel CHe Inspection Program (I) . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 Technical Quality of Inspections (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 Technical Staffing and 'Itaining (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57 Response to Incidents and Allegations (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 Non-Common Performance Indicator 6-Site Decommissioning Management Pl an (S D M P) (K) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63 Quality of SDMP Decommissioning Reviews (1). . . . . . . . . . . . . . . . . . . . . . . . 63 Financial Assurance for Decommissioning (2). . . . . . . . . . . . . . . . . . . . . . . . . . 63

'Ibrmination Radiological Surveys (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 Inspe ction s (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66 Staff Qualifications (5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 SDMP Milest ones (6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 Approved: September 12,1995 (Revised: November 25,1997) v

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Volume 5, Governmental Relations and Public Affairs Integrated Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Patts I - IV Contents (continued)

Part IV Prof-am matic As sessmen t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 Ge n eral (A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 j Findings for Agreement State Programs (B) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71 Finding 1-Adequate to Protect Public Health and Safety and Co mpatible (1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71 Finding 2-Adequate to Protect Public Health and Safety and Not Co mp a tible (2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71 Finding 3-Adequate, But Needs Improvement and Compatible (3). . . . . . . 71 Finding i Adequate, But Needs Improvement and Not Compatible (4). . . 72 Finding 5-Inadequate to Protect Public Health and Safety and ' l Co mp atible (5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 Finding 6-Inadequate to Protect Public Health and Safety and Not Co mp ati .c (6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 Findings for NRC Regional Programs (C) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 )

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G lo s sa ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73 l l

Approved: September 12,1995 vi (Revised: November 25,1997)

s. Volume 5, Governmental Relations and Public Affairs

, Integrated Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Part I Part I Evaluation Evaluation Frequency (A)

NRC will review the performance of each region and each Agreement State on a periodic basis. The schedule for conducting each regional or Agreement State visit will be developed by the Office of Nuclear Material Safety and Safeguards (NMSS) and the Office of State Programs (OSP) in coordination with the regions and States.

Approximately 10 to 12 reviews will be scheduled in most years. Under normal conditions, this would allow evaluations of NRC regions every 2 years, and Agreement States every 4 years. However, these frequencies can be adjusted downward on the basis of the findings from the last review, or in light of significant program changes in a particular State or region. In addition, this schedule provides for review of certain NMSS headquarters functions on an as-needed basis.

Evaluation Process Sequence (a)

The typical evaluation process sequence for the integrated materials performance evaluation piogram (IMPEP) reviews is summarized below:

• Develop the review schedule for the year. (1)

• Assemble and train team members. (2)

• Designate a team leader and members for each scheduled review. (3)

• Transmit questionnaires to affected regions and States. (4)

• Provide to team members a copy of questionnaire responses and most current information on the region or Agrement State. (5)

• Assess a sample of inspections at different types of licensett facilities by accompanying inspectors. (6)

Approved: September 12,1995 1

(Revised: November 25,1997)

Volume 5, Governmental Relations and Public Affairs *'

Integrated Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Part 1 Evaluation Process Sequence (B)(continued)

• Conduct the onsite portion of IMPEF, using the criteria specified in .

this handbook and applicable perfonnance review procedures. (7)

• Prepare draft IMPEP report, with recommendation for overall performance evaluation, for office director's signature. (8)

• Issue the draft report to the 7.ppropriate regions or States. (9) e Review and consider written comments received from the regions or Agreement States. (10)

• Prepare proposed final report for consideration by the management review board (MRB). (11) e Conduct MRB meeting. (12)

• Issue final reports; include the written comments received from the regions or Agreement States and any change to the report based on resolution of those comments and a summary of MRB findings. (13)

Approved: September 12,1995

~ (Revised: Nonsber 25,1997)

'- Volume 5, Governmental Relationt and Public /dfairs -

Integrated Materials Performance Evaluation Program (IMPEP) /

Handbook 5.6 Part II Part II Performance Indicators General (A)

A description of the common and non-common performance indic tors to be evaluated, as appropriate, for each region and each Agreement State is given in (B) and (C) of this part. The evaluation criteria (i.e., performance standards) against which these indicators are to be assessed are described in Part III of this handbook. These reviews ensure regional programs provide adequate public health and safety and determine program adequacy and compatibility in the Agreement States. The reviews are instrumental in improving State and NRC regional performance, thus ultimately leading to improved  !

licensee performance. (1)

The performance indicators should be used as a starting point of inquiry. This, in turn, should lead program evaluators to a more careful examinat;on of the underlying conditions, or" root causes" of potential problem areas. Evaluators may find correlations exist between two or more performance indicators. In this situation, the impact ofindisidual performance symptoms could be compounded when combined with others. Conversely, a regulatory program measured as potentially weak against one particular indicator could, nonetheless, be rated as strong overall, if there are sufficient mitigating factors with respect to other indicators. (2)

Certain non-reactor functions that continue to be conducted from NRC headquarters, such as fuel cycle licensing, uranium and thorium milling

. licensing, scaled source and device reviews, and low-level radioactive waste disposal licensing, are excluded from the set of common indicators ty;cause they are not common to the activities of the NRC regions and Agreement States. These functions are incorporated, as appropriate, as non-common indicators contributing to a performance-based evaluation of a program. (3) l i

Approved: September 12,1995 9 (Revised: November 25,1997) 3

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Volume 5, Governmental Relations and Public Affairs .

1 Integrated Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Part II_  ;

General (A)(continued)

For Agreement States, the non-common indicators are legislation and program elements required for compatibility, the scaled source and device evaluation program, low level radioactive waste disposal program, and uranium recovery program. (4)

Common Performance Indicators (s)

Common Performance Indicator 1--Status of Materiale Inspection l

Program (1) l l Periodic inspections oflicensed operations are essential to ensure that activities are being conducted in compliance with regulatory l

requirements and consistent with good safety practices. The frequency of inspections is specified in NRC Inspection Manual, Chapter 2800, and is dependent on the amount and kino of material, the type of operation licensed, and the results of previous inspections. There must be a capability for maintaining and retrieving statistical data on the status of the inspection prograra. (a)

Information regarding the number of overdue inspections is a significant measure of the status of an Agreement State's or NRC region's materials inspection program; reviews also should examine specific cases in detail where the inspection frequency has been significantly exceeded (i.e., by more than 50 percent). The terms

" materials inspection" and " overdue inspection" are defined in the Glossary to this handbook. (b)

Common Peitrmance Indicator 2-Technical Quality of inca =*ians (2)

This performa;ce indicator provides the qualitative balance to Performance Indicator 1 above, which looks at the status of the inspection program on a quantitative basis. Review team members will accompany a sample of inspectors at different types of licensed facilities to evaluate the knowledge and capabilities of regional and Agreement State inspectors. These accompaniments will usually occt.;

at a time other than the onsite review of the region or Agreement Stne to afford the review team sufficient time to observe inspectors at .

different types of licensee facilities. These reviews focus on the scope, completeness, and technical accuracy of completed inspectons i and related documentation. Review teams will conduct indysh, onsite reviews of a cross-section of completed inspection report; performed by different inspectors. In addition, review teams vGI verify that Approved: Faptember 12,1995 4 (Revised: November 25,1997)

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Common 1%:fonnance Indicator 2 'Ibchnkal Quality of Inspeedons (2)

(continued) supervisors generally conduct accompaniments of inspectors on an annur1 basis to provide management quality assurance.

C==an 1%:formance Indicator 3-Tbchnical Stamng and 'D31ning (3)

The ability to conduct effective licensing and inspec, tion programs is largely dependent on having a sufficient ntanber of experienced, knowledgeable, well trained technical personnel. Under certain conditions, staff turnover could have an adverse effect on the implementation of these programs, and thus could affect public health and safety. (a)

For this performance indicator, qualitative as well as quantitative measures must be considered. In particular, the reason for apparent trends in staffing must be explored, for exampleM~b)

• Is the rate of turnover and the degree of understaffing symptomatic cf a chrcnic problem oris it merely a short term phenomenon? (i) 4 . Why is turnover high? (ii)

• What steps are being taken to address this? (iii)

. What impact is it having on other performance indicators? (iv)

Review of staffing also requires a consideration and evaluation of the levels of training and qualification of the technical staff. Newly hired employees must be technically qualified. Professional staff should normally have a bachelor's degree or equivalent training in the physical and/or life sciences. Training requirements for NRC license reviewers and inspectors are specified in NRC Inspection Manual, Chapter 1246.

The requirements include a ecmbination of classroom requirements and practical on-the-job training. Some NRC regions impose additional requirements on certain license reviewers or inspectors, depending on their individual responsibilities and the types of licenses they review and/or inspect. (c) 4 Approved: September 12,1995 (Revised: November 25,1997) 5

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Handbook 5.6 Part II Common Performance Indicators (s)(continued)

Common Perfonnana hulicator 3 'Ibchnkal Staf5ng and Tiralnhig(3)

(continued)

In addition, the qualification process for NRC materials progrra inspectors includes demonstration of knowledge of relevant sections of the Code offederalRegulations, completion of a qualifications journal, and appearance before a qualifications board. Al hough Agreement States need not follow NRC Inspection Manual, Chapter 1246, they should have an equivalent program for training and qualification of personnel, and it should be present and adhered to in Agreement State programs. (d)

The evaluation standard measures the overall quality of training available to, and taken by, materials program personne.l. The staff should be afforded opportunities for training that are consistent with the needs of the program, such as attendance at counterpart meetings, university programs, technical workshops, and conventions. (e)

Common Performance Indicator 4-Tbchnical Quality of Licensing Actions (4)

An acceptable program for licensing radioactive material includes:

preparation and use of internal licensing guides and policy memoranda to ensure technical quality in the licensing program (when appropriate, NRC guides may be used); pre licensing inspection of complex facilities; and supenisory review, when appropriate. (a)

This performance indicator evaluates the technical quality of the licensing program, on the basis of an indepth, onsite review of a representative cross-section of licensing actions, including license terminations, decommissioning actions and bankruptcies, and various types of licenses Technical quality includes not only the review of the application and completed acuns, but also an examination of any renewals that have been pending for more than a year because the failure to act on such repests may have health and safety implications.

To the extent possible, the onsite review also should capture a ,

representative cross-section as completed by each of the resiewers in the region or State. (b)

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Handbook 5.6 Part II Common Performance Indicators (s)(continued)

Common Performance Indicator 5-Response to Incidents and Allegations (5)

The quality, thoroughness, and timeliness of a regulator's response to incidents and ahegations of safety concerns can have a direct bearing on public health and safety. A careful assessment of incident response and allegation investigation procedures, actual implementation of these procedures, internal and external coordination, and investigative and followup procedures and actions will be a significant indicator of the overall quality of the program.

Non-Common Performance Indicators (C)

Non Common Performance Indicator 1-Legislation and Program Elements Required for Compatibility (1)

State statutes should authorize the State to establish a program for the regulation of agreement material and provide authority for the assumption of regulatory responsibility under the agreement. The strutes must authorize the State to promulgate regulatory requirements necessary to provide reasonable assurance of protection of public health and safety. The State must be authorized through its legal authority to license, inspect, and enforce legally binding requirements such as regulations and licenses. State statutes should be consistent with Federal statutes, as appropnate. (a)

In accordance with Management Directive 5.9, " Adequacy and Compatibility of Agreement State Programs," and the current revisions of OSP Internal Procedures, D.7, " Reviewing State Regulations," and B.7 (Revision 1), " Compatibility Categories and Health and Safety Identification for NRC Regulations and Other Program Elements," the State shall adopt legally binding require-ments, such as regulations and other necessary program elements consistent with the above guidance. (b)

NRC regulations that should be adopted by an Agreement State for

, purposes of compatibility or health and safety should be adopted in a time frame so that the effective date of the State requirement is not later than 3 years after the effective date of NRC's final rule. (c)

Approved: September 12,1995 (Revised: November 25,1997) . 7

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Handbook 5.6 Part II i Non-Common Performance Indicators (c)(continued)

Non Common Performance Indicator 1-Legislation and Program -

Elements Required for Compatibility (1) (continued)

Other program elements that have been designated as necessary for maintenance of an edequate and compatible program should be adopted and implemented by an Agreement State within 6 months following NRC designation. (d)

Non-Common Performance Indicator 2-Sealed Source and Device Evaluation Program 1 (2)

Adequate technical evaluations of sealed source and device (SS&D) designs are essential to ensure that SS&Ds u:.ed by both licensees and persons exempt from licensing will maintain their integr;iy and that the design features are adequate to protect publ c health and safety. Three sub-clements vrill be evaluated to detennine if the SS&D program is adequate, e Technical Quality of the Product Evaluation Program (a)

The technical quality of the product evaluation program, on the basis of an indepth onsite review of arepresentative cross-section of evaluations performed, includes various types of products and types of actions:(i)

- Product evaluations should be technically accurate and ensure that proper prototype tests or analyses have been performed and passed for the normal and likely accidental conditions of use and that the safety features of the device are adequate to protect public health and safety. (a)

- Completed registration certificates, and the status of obsolete registration certificates and registration certificates for products having defects or involved in incidents, must be clearly and promptly transmitted among various interested parties. (b)

- Vende.rs' ouality assurance and control programs should be evaluated to ensure that products are built to the same 1 Agrectnent States weh authonty for scaled source and device evaluation programs that are not perfc-mmg sS&D reviews are requested to commii m writing to having an SS&D evaluation program in place (as desenbed in Section (C)(2) of this part) before performmg evaluations.

Approved: September 12,1995 8 (Revised: November 25,1997)

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Non Common Performance Indicator 2-Sealed Source and Device Evaluation Program (2)(continued) specification.:; r, those listed on the registration certificate. The commitments made in the registrant's application and referenced in the registration certificate must be enforceable. (c)

To the extent possible, the onsite review also should capture a representative cross section as completed by each of the State reviewers. (ii)

. Technical Staffing and Training (b)

Evaluation of SS&D review staffing and training should be conducted in the same manner and as part of the Common Performance Indicator 3 (Sections (B)(3)(a) and (b) of this part), except with a focus on training commensurate with the conduct of the SS&D reviews. (i)

- A staffing review also requires a consideration and evaluation of the levels of training and qualification of the technical staff.

Newly 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-(ii)

- Understand end interpret, if necessary, appropriate prototype tests that ensure the integrity of the products under normal, and likely accidental conditions of use (a)

Understand and interpret test results (b)

Read and understand blueprints and drawings (c)

- Understand how the device works and how safety features operate (d)

- Understand and apply the appropriate regulations (e)

- Understand the condDions of use (f)

- Understand external dose rates, source activities, and nuclide chemical form (g)

Approved: September 12,1995 (Revised: November 25,1997) 9

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Non Common Performance Indicators (C)(continued)

Non Common Performance Indicator 2-Sealed Source and Device Evaluation Program (2)(continued)

- Understand and utilite basic knowledge of engineering materials and their properties (h) e Evaluation of Defects and Incidents Regarding SS&Ds (c)

Reviews of SS&D incidents should be conducted in the same manner and as pan of the Common Perfoanance Indicator 5 (Section (B)(5) of this part) to detect possible manufacturing defects and the root causes of these incidents. The results should be evaluated to determine if other products may be affected by similar problems. Appropriate action and notifications should take place.

Non-Common IVrformance Indicator 3-Lw Level Radioactive Waste Disposai Program (3)

Five sub-clements will be evaluated to determine if an Agreement State's performance ofitslow-level radioactive waste disposal program is adequate.

• Status of Low-Level Radioactive Waste Disposal Inspection (a)

Periodic inspections of low-level radioactive waste disposal facilities, from the pre-operational through the post-closure phase, are essential to er.sure that activities are being conducted in compliance with regulatory requirements and consistent with good safety practices. (i)

- Inspections during siting and construction phases are essential to ensure the facility is being sited and constructed in accordance with regulatory and license requirements. (a)

- Operational phase inspections are essential for ensuring that disposal activities are being conducted in accordance with license conditions and regulatory requirements. (b)

Closme and post-closure inspections are essential to ensure activities at closure are being conducted in compliance with the regulatory requirements and the facility is performing as expected. (c)

Approved: September 12,1995 10 (Revised: November 25,1997)

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Handbook 5.6 Part II Non-Common Performance Indicators (C)(continued)

Non-Common Performance Indicator 3-ImI.evel Radioactive Was'.e Disposal Program (3)(continued)

The frequency of inspections for operating low-level radioactive waste disposal facilities is specified in NRC Inspection Manual, Chapter 2800, as yearly. Inspection frequencies for non-operational phase inspections should be established. There must be a capability for maintaining and retrieving statistical data on the status of the inspection program for the low-level radioactive waste disposal piogram. (ii) e Technical Quality of Inspections (b)

This sub-clement provides the qualitative balance to sub-element 1 above, which looks at the status of the inspection program on a quantitative basis. Review team members will accompany Agreement State inspectors, including onsite resident inspectors, to evaluate their knowledge and capabilities at low-level radioactive waste disposal facilities during the inspections discussed in sub-element I above. These accompaniments will usually occur at a time other than the onsite review of the region or Agreement State. Reviews in this area focus on the scope, completeness, and techriical accuracy of inspections and related documen'.ation. Review teams will conduct indepth, onsite resiews of completed inspection reports.

. Technical Staffing and Training (c)

Evaluation of staffing and training should be conducted in the same manner and as part of the Common Performance Indicator 3 (Sections (B)(3)(a)-(d) of this part), unless the low-level radioactive waste program is organizationally separate from the materials program. The staffing (which can include contractual support or support from other State agencies) should be sufficient to enable the program to complete review of a new application within 15 months, if practicable, per the Low-Level Radioactive Waste Policy Amendments Act. Professional staff should normally have bachelor's degrees or equivalent training in the physical, life or earth sciences, or engineering. Staff and support contractors qualifications, training, and experience also should include the disciplines of health physics, civil or mechanical engineering, geology, hydrology and other earth sciences, and environmental science.

Approved: September 12,1995 (Revised: November 25,1997) 11

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Non-Common Performance Indicators (c)(continued)

Non Common Performance Indicator 3-Law Level Radioactive Waste Disposal Program (3)(continued) e Technical Quality of Licensing Actions (d)

An acceptable program for licensing low-level radioactive waste disposal facilities ensures that the proposed waste disposal facilities will meet State licensing requirements for waste product and volume, qualifications of personnel, site characterization, performance assessment, facilities and equipment, operating and emergency procedures, financial qualifications and assurances, closure and decommissioning procedures, and institutional arrangements in a manner sufficient to establish a basis for licensing action. This may be accomplished through the preparation and use of internal licensing guides, policy memoranda, or use of NRC equivalent guides. Licensing decisions should be adequately documented through safety evaluation reports, or similar documentation, of the license review and approval process. Opportunities for public hearings are provided in accordance with applicable State administrative procedure laws during the process of licensing a low-level radioactive waste disposal facility. Pre-licensing interactions with the applicant should be conducted to ensure clear communication of the regulatory requirements. (i)

To evaluate the technical quality of the licensing program, a review of a technical aspect of a radioactive waste disposallicensing action (e.g., health physics, hydrology, and structural engineering) will be conducted in addition to an evaluation of the license review process. Technical quality includes not only the review of completed actions, but also an examination of any ongoing requests for licenses or renewals that may have health and safety implications. (ii)

• Response to Incidents and Allegations (e)

Reviews of low-level radioactive waste program incidents and allegations of safety concerns should be conducted in the same manner and as part of Common Performance Indicator 5 (Sections (B)(3)(a)-(d) c this part), unless the low-level radioactive waste program is organizationally separate from the materials program.

Approved: September 12, ;: 95 12 (Revised: November 25,1997)

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Handbook 5.6 Part II Non-Common Performance Indicators (C)(continued)

Non-Comum Perfonnance Indkator 4-Uranium Resery Pmgram (4)

Five sub-elements, as appropriate, will be evaluated to determine if the performance of the Region IV or an Agreement State's uranium recovery program is adequate.

. Status of Uranium Recovery Inspection Program (a)

Periodic inspections of licensed uranium recovery operations are essentia' to ensure that activities are being conducted in

, compliance with regulatory requirements and consistent with good safety practices. The frequency of inspections is specified in the NRC Inspection Manual, Chapter 2600, for insitu leach mining facilities,. and in Chapter 2801 for conventional uranium and thorium mills. Uranium recovery facihties that are on standby or under decommissioning also should be inspected at that frequency.

Inspections should occur more frequently if significant regulatory concerns develop, before major changes are made to operations, or if generic problems are identified. There must be a capability for maintaining and retrieving statistical data on the status of the inspection program for the uranium and thorium program.

• Technical Quality of Inspections (b)

This sub-clement provides the qualitative balance to sub-clement I above, which looks at the status of the inspection program on a quantitative basis. Review team members will accompany the region and Agreement State inspectors to evaluate their knowledge and capabilities at uranium recovery facilities. These accompaniments will usually occur at a time other than the onsite review of the region or Agreement State. An acceptable program for conducting inspections for radioactive ma.erial licenses includes preparation and use of internal inspection guides and policy memoranda to ensure technical quality in the inspection program (when appropriate, NRC guidance may be used). Reviews of this sub-clement focus on the scope, completeness, and technical l accuracy of completed inspections and related documentation.

! Review teams will conduct indepth, onsite reviews of completed inspection reports. In addition, review teams will verify that supervisors generally conduct accompaniments ofinspectors on an l annual basis to provide management quality assurance.

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Handbook 5.6 Part II J Non-Common Performance Indicators (c)(continued)

Non-Common Performance Indicator 4-Uranium Remvery Program (4)

(continued)

• Technical Staffing and Training (c)

Evaluation of staffing and training should be conducted in the same manner and as part of Common Performance Indicator 3 (Sections (B)(3)(a)-(d) of this part), unless the uranium recovery program is organizationally separate from the materials program.

Professional staff normally should have bachelor's degrees or equivalent training in the physical sciences, life or earth sciences, or

. engineering. Staff and support contractors qualifications, training, and experience should include the disciplines of health physics; civil or mechanical engineering; geology, hydrology and other earth sciences; and environmental science.

e Technical Quality of Licensing Actions (d)

An acceptable program for licensing uranium recovery actisities ensures that essential elements of NRC licensing requirements for radiation protection, qualifications of personnel, facilities and equipment, operating and emergency procedures, financial qualification and assurance, closure and decommissioning procedures, and institutional arrangements are met in a manner sufficient to establish a basis for licensing action. This may be accomplished through the preparation and use ofinternal licensing guides, policy memoranda or use of NRC equivalent guides to ensure technical quality in the licensing program. Pre-licensing inspection of complex facilities are conducted, when appropriate. (i)

To evaluate the technical quality of the Agreement State licensing program, an indepth review of an aspect of the uranium recovery license (e.g., radiation protection, hydrology, or geotechnical engineering) will be conducted. Technical quality includes not only the review of completed actions, but also an examination of any F ongoing requests and license renewals that may have health and

• safety implications. Technical quality includes review of the State's compliance with the statutory requirements or prohibitions in Section 274 of the Atomic Energy Act, as amended. (ii)

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Handbook 5.6 Part II Non-Common Performance Indicators (C)(continued)

Non.co,==an Performance Indicator 4-Uranium Recovery Program (4)

(continued)

• Response to Incidents and Allegations (c)

Reviews of uranium recovery program incidents and allegations of safety concerns should be conducted in the same manner and as part of Commcn Performance Indicator 5 (Sections (B)(3)(a)-(d) of this part), unless the uranium recovery program is organizationally separate from the materials program.

Non Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (5)

Five sub-elements, as appropriate, will be evaluated to determine if the performance of the regional fuel cycle inspection program is adequate.

• Status of Fuel Cycle Inspection Program (a)

Periodic inspections of licensed operations are essential to ensure that activities are being conducted in compliance with regulatory requirements and license commitments, and in an overall safe and adequate manner. (i)

The appropriate frequencies of inspections for established procedures are discussed in NRC Inspection Manual, Chapter 2600. NRC Inspection Manual, Chapter 2600-04.02, provides the responsible headquarters and regional offices flexibility to adjust the frequencies, focus, and intensiveness of inspections for different functional areas at a licensed facility, taking into account the complexity, risk level, and previous operating history of the facility. These adjustments are generally determined by consensus of headquarters and regional management during the licensee performance review (LPR) process, or in response to significant facility events or conditions between LPRs. (ii)

The level of resources provided for an inspection also may be adjusted. Unexpected external influences (e.g., turnover of key l staff, diversion of staff for augmented inspection team (AIT),

I incident investigation teams, or other inspections in response to l incidents, accretion of new regulatory responsibilities without timely provision of additional resources) may occasionally aff :t the frequencies with dich routine inspections can be conducted, Approved: September 12,1995 i (Revis-d: November 25,1997) 15 l -

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Non Common 1%rformanceIndicator5-RegionalFuelCycleInspection Pro 6 ram (5)(continued) or the level of resources available for routine inspections. These influences should be documented and reviewed on a regular basis and integrated into each facility's portion of the fuel cycle master inspection plan. The master inspection plan also should inclrde scheduling of LPRs according to the frequencies specified in NRC Inspection Manual, Chapter 2604. (iii)

Inspection scheduling and planning should consider the resource requirements for both routine and reactive inspection efforts, preparation for and documentation of inspections, and participation in other programmatic duties (e.g., training, licensee performance reviews, licensing support, or participation in or support for enforcement conferences). This planning should permit adequate time for inspectors to complete inspection repons so that the reports can be issued in accordance with the timeliness i requirements contained in NRCInspection Manual, Chapter 0610.

Other planning and scheduling factors include concern for unusual impacts on licensees and exchanges of inspection resources between different regions. The established fuel cycle inspection schedule for the region should reflect these considerations. (iv)

Regional management should monitor the region's inspection program to determine that the current program is being implemented in accordance with the requirements of the fuel facility inspection program described in NRC Inspection Manual, Chapter 2600, the documented inspection plan for each facility, and overall regional objectives. There should be a capability for maintaining and readily retrieving (without additional analytical effort) the necessary informatian for demonstrating the extent to which established inspection program objectives are being met. (v)

There should be a means for maintaining and readily retrieving regional performance information for each facility. This information may reside in inspection reports, correspondence files, the inspection followup system, or the nuclear materials events database (NMED). Where there are several different inspectors inspecting each facility, the region may find it more practical to maintain its own summary information files (e.g., site issues matrices, incident analysis summaries, enforcement histories), to Approved: September 12,1995 16 (Revised: November 25,1997)

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Handbook 5.6 Part II Non-Common Performance Indicators (C)(continied)

Non-CommonPerforme ceIndicator5-RegionalFuelCycleInspection Program (S)(continued) assemble the kind of information needed to support the fuel cycle licensee performance review program and to justify any changes in the inspection program for a facility as they occur. (This would prevent the loss of summary information valuable to the LPR, which is normally provided by the inspectors, if they are not available at the time the LPR is conducted.) Such programmatic changes should be documented at the time they are made. LPRs should be conducted in cooperation with headquarters according to the schedule included in the fuel cycle master inspection plan. (si)

The reviewer should exa:nine specific instances in which established inspection program objectives appear not to be met, and determine if mitigating circumstances may have been documented to offer justification for departures from the established plans. (vii) e Technical Quality of Inspections (b)

This sub-clement provides the qualitative balance to the sub-clement 1 above, which looks at the status of the inspection program on a quantitative basis. (i)

Reviews of programs under this sub-clement focus on the scope, completeness, and techt ical accuracy of completed inspectiens and related documentation. The reviewer will conduct indepth, onsite reviews of a cross-section of completed Npection reports, selecting from among ; hose perfonned by different inspectors, if applicable.

The reviewer also may interview the respective in:,pectors, if cvailable. (ii)

Tiie reviewer will verify that supenisors accompany inspectors on an annual basis to provide management quality assurance. (iii)

Inspection effoits should focus on the :icensee's performance in ensuring the safety and safeguarding of operations. Inspection reports should reflect this focus by addressing licensee performance issues regarding plant operations posing the greatest safety or safeguards risks and where previous perfonnance issues have been identified as requiring greater attention, consistent with the inspection program previously documented for the facility. (iv)

Approved: September 12,1995 (Revised: November 25,1997) 17

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Non-Common Performance Indicators (C)(continued)

Non-Common Perfor nance Indicator 5--Regional Fuel Cycle Inspection Program (5)(continued)

Conversely the results of inspections should be summarized and appropriately documented for later reference (e.g., for support of the licensee performance review program). (v)

Only qualified NRC inspectors are to conduct inspections on their own. When inspector trainees or contractors are included in an inspection visit, at least one qualified NRC inspector should be designated to lead the inspection. In these cases, the qualified

. inspector should provide guidance to such personnel trainees or contractors to ensure that their activities are appropriate to an NRC inspection. (si) e Technical Staffing and Training (c)

The ability to conduct effective inspection programs is largely dependent on having a sufficient number of experienced, knowledgeable, well-trained technical personnel. Fuel cycle inspectors generally require extensive training in specialized technical areas, in addition to meeting academic requirements.

This often results in significant time delays before newly hired inspectors can become cenified as qualified NRC fuel cycle inspectors. Under cenain conditions, staff turnover could have an adverse effect on the implementation of a region's fuel cycle inspection program, and thus could affect public health and safety.

For small programs, their viability may depend upon the continued availability of a single individual with skills and experience that vmuld be difficult to replace with another individual. (i) l Plans should be in place to replace the functional capabilities required for each aspect of the program (perhaps by contributions I from several different individuals), in case a key inspector becomes unavailable (e.g., cross-training of other staff in the same organization, identification of individuals with required skills and qualifications in other NRC organizations, dentification of possible outside contr.netors with suitable experience or expertise to -

augment specified types of inspections, if needed). (ii)

Qualitative aswell as quantitative measures must be considered; in particular, the reason for apparent trends in staffing must be '

explored: (iii)

Approved: September 12,1995

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Handbook 5.6 Part II Non-Common Performance Indicators (c)(continued)

Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (5)(continued)

- Is the rate of turnover or the degree of under staffing symptomatic of a chronic problem, or is it merely a short term phenomenon? (a)

- Why is turrover high? 'b)

- Are inspectors being overburdened? (c)

- Is high turnover related to a morale problem? (d)

- What steps are being taken to address the basic problem? (e)

What impact is high tumover having on other performance indicator sub-elements? (f)

Review of staffing also requires a consideration and evaluation of the levels of training and qualification of the technical staff and management. New hires need to be technically qualified.

Professional staff normally should have bachelor's degrees or equivalent training in the physical and/or life sciences, or related engineering fields. Training requirements for NRC fuel facility specialist inspectors are specificd in NRC Inspection Manual, Chapter 1246. The requirements include a combination of classroom requirements and practical on-the-job training. In addition, the qualification process includes demonstration of kr.,Medge of relevant sections of the U.S. Code of Fedemt negulations, completion of a qualifications journal, and satisfactory review before a qualifications board. There also are refresher training and retraining requirements, including taking new fuel cycle courses as they are developed. (iv)

The small number of fuel cycle facility inspectors who may need training at any one particular time pose unique challenges to

_ arranging for the proper training of these individuals on a cost effective basis. The region may have to seek outside training opportunities to provide inspectors with specific safety knowledge needed for unique aspects of their facilities (e.g., heavy duty overhead cranes). (v) l Approved: September 12,1995

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Handbook 5.6 Part II 3 Non-Common Performance Indicators (c)(continued)

Non Common Performance Indicator 5-Regional Fuel Cycle laspection Program (5)(continued)

After an inspector is trained and imtially qualified to perform inspections in a specific technical area, providing additional cross-training opportunities for inspectors willincrease the ability of the inspection organizatbn to better respond to facility incidents, unexpected staff turnover, or other unusual situations. (vi)

• Response to Incidents and Allegations (d) t .

l The quality, thoroughness, and timeliness of a regulator's response

to incidents and allegations can have a direct bearing on public health and safety. (i)

Significant indicators of the overall quality of the fuel cycle facility inspection program will ine'.ude detailed written procedures for incident response and the maintenance of records and reports of actual incidents, focusing on internal and external coordination, and analytical, investigative, and followup procedures. (ii)

The region should exhibit a reudiness to respond, in conjunction with Headquarters, to major incidents that may arise at a facility.

This will include a review of preparations in place at the region's incident response center (e.g., identification of individuals with recaired skills, facility data for use during emergencies, detailed preparations for responding to the highest risk types of incidents postulated for the facility, on the basis of known facility processes and source terms, etc.).- (iii)

The region, possibly in coordination with headm arters, should conduct, or participate in, documented followup setf-assessments of drills and responses to any maje' incidents that involved activation of the region's incident respc..se center. (iv)

The region's responses to any allegations invoMng fuel cycle .

facilities should be grounded in established inspection procedures and good technical and regulatory analysis to determine if regulations were followed or may be deficient and in need of revision with regard to a significant safety issue brought to light by the allegation. (v)

Approved: September 12,1995 20 (kevised: November 25,1997)

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Non-Common Performance Indicators (C)(continued)  !

l Non Ccamon Performance Indicator 6-Site Decommissioning Management Plan (SDMP)(6)

Six sub-clements, as appropriate, will be evaluated to determine if the l performance of the regional site decommissioning management plan i (SDMP)is adequate.

• Quality of SDMP Decommissioning Reviews (a) l NRC staff reviews and approves planned, significant decommissioning actions at facilities that are listed on the SDMP in advance of decommissioning. Decommissioning plan reviews are conducted in accordance with NRC Inspection Manual, ,

Chapter 2605, current NRC policies, standard review procedures, l and other regulatory guidance. Reviews are documented as outlined in Chapter 2605, using environmental assessments, emironmental impact statements, safety evaluation reports, checklists, interrogatories, and other written correspondence, as appropriate.

• Financial Assurance for Decommisrioning (b)

Adequate financial assurance for the decommissioning c,1 SDMP sites has been established in accordance with regulatory requirements and applicable guidance. Financial assurance is provided for estimated costs for an independent, third party to

( perform decommissioning with the objective of releasing the site, I unless alternative arrangements have been approved by the regulator. Financial assurance mechanisms are reviewed and maintained to ensure that they would be executable and proside sufficient funding for decommissioning in the event that the licensee liquidates or is otherwise unable to pay for I

decommissioning.

e Termination Radiological Surveys (c)

Surficient radiological surveys are required before license

, termination and site release, as outlined in NRC Inspection Manual, Chapter 2605, to ensure that residual radioactivity levels comply with release criteria. Licensee survey results are validated through a closcout inspection or confirmatory survey, also outlined l in Chapter 2605, given the extent and significance of any residual l contamination.

1 Approved: September 12,1995 (Revised: November 25,1997) 21 l

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Handbook 5.6 Part II 3 Non-Common Performance Indicators (C)(continued)

Non Common Performance Indicator 6-Site Decommissioning Management Plan (SDMP) (6) (continued)

• Inspections (d)

Decommissioning projects are inspected in accordance with established frequencies and with written inspection procedures to confirm the safety of decommissioning procedures. Inspections are documented and carried out in accordance with NRC Inspection Procedures 87104 and 88104. Inspections focus on safety oflicensee procedures, release of effluents to the emironment, public and

. worker exposure, and suitability of decontaminated areas and structures for release.

Staff Qualifications (e)

License reviewers and inspectors are qualified through trsining and exnerience to review the safety of decommissioning. Qualifications for license reviewers and inspectors are established and reviewed.

Staff members are qualified to perform licensing reviews and inspections related to decommissioning through training and documented work experience. Nonqualified staff members are subject to the direct supervision of qualified managers; this supervision is evidenced by concurrence on inspection reports and licensing documentation.

• SDMP Milestones (f)

The decommissioning milestones summarized in the SDMP are being met. If not, delays are identified and there is a mechanism in place to ensure that any appropriate corrective actions are taken.

Policy issues affecting the decommissioning of SDMP sites are being identified. Staff is updating the SDMP database in a timely manner.

s Approved: September 12,1995 22- (Revised: November 25,1997)

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Part III Evaluation Criteria NRC regions and Agreement States will be evaluated in their ability to conduct effective licensing and inspection programs using the common and non-common performance indicators, described in

. Part II of this handbook, as appropriate. The evaluation criteria for each performance indicator .tre given below. These criteria do not represent an exhaustive list of the factors that may be relevant in determining performance. In some cases, there may be additional considerations not listed here that are indicative of a program's performance in a particular area.

Common Performance Indicator 1 Status of Materials Inspection Program (A)

. Satisfactory (1) l

• Core licensees (those with inspection frequencies of 3 years or less) are inspected at regular intervals in accordance with frequencies prescribed in NRC Inspection Manual, Chapter 2800. (a) e Deviations from these schedules are normally coordinated between working staff and management. Deviations are generally the result of joint decisions that consider the risk of licensee operation, past t licensee performance, and the need to temporarily defer the inspection (s) to address more urgent or more critical priorities. (b)

• There is a plan tc, reschedule any missed or deferred inspections or a basis established for not rescheduling. (c) e Inspections of new licensees are geuerally conducted within 6 months oflicense appmval, or in accordance with NRC Inspection

, Manual, Chapter 2800 Section 04-03, for those new licensees not possessing licensed material. (d) l

• A large majority of the inspection findings are conununicated to i

licensees in a timely manner (30 calendar days as specified in NRC Inspection Manual, Chapter 0610-10). (e)

,, Approved: September 12,1995 (Revised: November 25,1997) 23 L-

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Common Performance Indicator 1-Status of Materials Inspection Program (A)(antinued)

Satisfactory With Recortmendations for Improvement (2) e More than 10 percent of the core licensees are inspected at intervals that exceed the NRC Inspection Manual, Chapter 2800, frequencies by more than 25 percent. (a)

• Inspections of new licensees are frequently not conducted within 6 months oflicense approval. (b) e Many of the inspection findings are delayed, or not communicated to licensees within 30 days. (c)

Unsatisfactory (3)

• More than 25 percent of the core licensees are inspected at intervals that exceed the NRC Inspection Manual, Chapter 2800, frequencies by more than 25 percent. (a)

• Inspections of new licensees are frequently delayed, as are the inspection findings. (b)

Category N (4)

Special conditions exist that provide adequate justification for withholding a rating. For example, an unforeseen event or emergency with significant health and safety consequences may have required a temporary diversion of resources from the core inspection program.

However, these programmatic adjustments are well-thought out, and properly coordinated with Office of Nuclear Material Safety and Safe s ds ar (NMSS) or Agreement State management.

Common Performance Indicator 2-Technical Quality ofInspections (B)

Satisfactory (1) e Review team members accompanying inspectors combined with an onsite review of a representative cross-section of completed inspection reports indicates inspection findings are usually well-founded and well-documented throughout the assessment. (a)

. A review of inspector field notes or completed reports indicates that most inspections are complete and reviewed prcmptly by supe: visors or management. (b)

Approved: September 12,1995 24 (Revised: November 25,1997)

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Satisfactory (1)(continued)

• Procedures are in place and normally used to help identify root .

causes and poor licensee performance. (c)

• In most instances, followup Inspections address previously identified open items and/or past violations. (d)

• Inspection findings generally lead to appropriate and prompt regulatory action. (e)

• Supervisors accompany nearly allinspectors on an annual basis. (f)

Satisfactory With Recommendations for Improvement (2)

• Rev'ew indicates that some inspections do not address potentially important health and safety concerns or it indicates periodic problems with respect to completeness, adherence to procedures, management review, thoroughness, technical quality. and consistency. (a)

• Review indicates that findings in inspection reports and inspection files are, on occasion, not well founded or well-documented. (b) e Review does not demonstrate an appropriate level of management review. (c) e Accompanim:nt of intpectors by supenisors is performed non systematically. (d) e Followup actions to inspection findings are often not timely. (c)

Unsatisfactory (3) e Review indicates that inspections frequently fail to address potentially important health and safety concerns or it indicates chronic proMems exist with respect to completeness, adherence to procNrr. , management review, thoroughness, technical quality and consistency. (a)

• Supenisors infrequently accompany inspectors. (b)

• Followup actions to inspection findings are often not timely and appropriate. (c)

Approved: September 12,1995 (Revised: November 25,1997) 25

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Category N (4)

Not aprUcable.

Common Performance Indicator 3-Technical Staffing and Training (c) '

Satisfactory (1)

. Review indicate: implementation of a well conceived and balan ed stdfing strategy throughout the assessment period, and demonstrates the qualifications of the technical staff. This is indicated by the presence of most of the following fe tures:

. There is a balance in staffing the licensing and inspection programs. (a) e There are few, if any, vacancies, especially at the senior level positions. (b) e There is prompt management attention and review, such as development of a corrective action plan to address problems in high rates of attrition or positions being vacant for extended periods. (c) e Quali5 cation criteria fer hiring new technical staff are established and are being followed. (Staff would normally be expected to havs, bachelor's degtces or equivalent training in the physical and/or life sciences. Senior personnel should have additional training and experience in radiation protection commensurate with the types of licenses they issue or inspect.) (d)

• License reviewers and inspectors are trained and qualified in a reasot.aW time r:riod.1 (e) e Management comulitment to training is clearly evident. (f) 1For the regions, tHs eneans there has been, and continues to be, a clear effort to adhere to the requirements -

and condmons specified in NRClaspction Manual, Chapter 1246, and the a beable qualificationsjournals, or r equ nt training elsewhere. For the Agreement states, eyn at requirernents should be in Approved: September 12,1995 26 (Revised: November 25,1997)

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Handbook 5.6 Part III Common Performance Indicator 3 -Technical Staffing and 'IYaining (c)(continued)

Satisfactory With Recommendations for Improvement (2)

Review determines the presence of some of the following conditions:

• Some staff turnover that could adversely upset the balance in staffing the licensing and inspection programs. (a) e Some vacant positions not readily filled. (b) e Some evidence oflack of management attention or actions to deal

. with staffing problems. (c) e Some of the licensing and inspection personnel not making prompt progress in completing all of the training and qualification requirements. (d) e The training and qualification standards include areas needing improvement. (e) e Some of the new staff is hired with little education or experience in physical and/or life sciences, or materials licensing and inspection. (f)

Unsatisfactorj (3)

Review determines the presence of chronic or acute problems related to some of the following conditions, which cause concems about their likely effects on other performance indicators:

• There is significant staff turnover relative to the size of the program. (a)

• Most vacant positions are not filled for extended periods. (b) e There is little evidence of management attention or actions to deal with staffing problems. (c) e Most of the licensing and inspection personnel are not promptly completing all of the training and qualification requirements. (d) e New staff members are hired without having scientific or technical backgrounds that would equip them to receive technical training. (e)

Approved: September 12,1995 (Revised: November 25,1997) 27

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Common Performance Indicator 3-Technical Staffing and 'IYaining (c)(continued) .

Category N (4)

Special conditions exist that provide justification for withholding a rating. For example, there has been a substantial management effort to deal with staffing problems. NMSS or 03P has been kept informed of the situation, and aiscernable recent progress is evident.

Common Performance Indicator 4-Technical Quality of Licensing (D)

Satisfactory (1) e Review of completed licenses and a representative sample of licensing dies indicates that license reviews are generally thorough, complete, consistent, and of ac eptable technical quality. (a) e Health and safety issues are properly addressed. (b)

• License reviewers have the pmper signature authority for the cases they review independently. (c) e Speciallicense tie-down conditions are usually stated clearly and are inspectable. (d) e Deficiency letters clearly state regulatory positions and are used at the proper time. (c) e Reviews of renewal applications demonstrate thorough analysis of a licensee's inspection and enforcement history. (f) e AppHeable guidance documents are available to reviewers and are followed. (g)

Satisfactory -Vith Recommendations for Improvement (2)

Review indicates that some licensing actions do not fully address health and safety concerns or indicates repeated examples of problems with ,

respect to thoroughness, completeness, consistency, clarity, tecimical quality, and adherence to existing guidance in licensing actions.

Approved: September 12,1995

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Handbook 5.6 Part III Common Performance Indicator 4-Technical

. Quality of Licensing (D)(continued)

Unsatisfactory (3)

Review indicates that licensing actions frequently fail to address important health and safety concerns or 11dicates chronic problems with respect to thoroughness, completeness, consistency, clarity, technical quality, and adherence to existing guidance in licensing actions.

Category N (4)

Not applicable.

Common Performance Indicator 5-Response to Incidents and Allegations (s) 1 Satisfactory (1) e Incident response and allegation procedures are in place and followed in nearly all cases. (a) e Actions taken are appropriate, well coordinated, and timely in most instances. (b) e Level of effort is usually commensurate with potential health and safety significance of an incident. (c) e Inve.tigative procedures are appropriate for an incident. (d) e Corrective (enforcement or other) actions are adequately identified to licensees promptly and appropriate followup measures are taken to ensure prompt compliance. (c) e Followup inspections are scheduled and completed, if necessary. (f) e Notification to NMSS, the Office for Analyris and Evaluation of Operational Data (AEOD), or OSP, and othen; as may be appropriate, is usually performed in a timely fashion. ; g)

Satisfactory With Recommendations for Improvement (2)

• Incident response and allegation procedures are in place but occasicnally not practiced in a detailed fashion. (a)

Approved: September 12,1995 (Revised: November 25,1997) .29

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Handbook 5.6 Part III i Common Performance Indicator 5-Response to Incidents and Allegations (E)(continued) -

Satisfactory With Recommendations forImprovement ('l)(continued) e Performance is marginal in terms of resolving potential public health and safety issues, but not as well coordinated, complete or timely as would be required under the "S tisfactory" performance standard. (b) e Infrequent failure to notify NMSS, AEOD, or OSP, and others, as appropriate, of incidents. (c)

Unsatirfactory (3)

• Review indicates frequent examples of response to incidents or allegations to be incomplete, inappropriate, poorly coordinated, or not timely. As a result, potential health and safety problems persist. (a) e Failure to notify NMSS, AEOD, or OSP, and others, as appropriate, ofincidents. (5)

Category N (4)

Not applicable.

Non-Common Performance Indicator 1-I2gislation and Program Elements Required for Compatibliity (F) satisfactory (1) e State statutes authorize the State to establish a program for the regulation of agreement material and provide authority for the assumption of regulatory responsibility under the agreement. (a)

• The statutes authorize the State to promulgate regulatory requirements necessary to provide reasonable assurance of protection of public health and safety. (b) e The State is authorizad through its legal authority to license, -

inspect, and enforce legally binding requirements such as regulations and licenses. (c) e State statutes are consistent with Federal statutes, as appropriate. (d)

Approved: September 12,1995 30 (Revised: November 25,1997)

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Handbook 5.6 Part III Non-Common Performance Indicator 1-Iegislation and Program Elements Required for Compatibility (F)(mntinued)

Satisfactory (1)(continued) e The State has existing legally enfomeable measures such as generally applicable rules, license provisions, or other appropriate measures, necessary to allow the State to ensure adequate protection of public health and safety in the regulation of agreement material. (e)

• The St te has adopted legal binding requirements, regulations, and other program elements in accordance with Management Directive (MD) 5.9," Adequacy and Compatibility of Agreement State Programs," and the current revisions of OSP Internal Procedures D.7, " Reviewing State Regulations," and B.7,

" Compatibility Categories and Health and Safety Identification for NRC Regulations and Other Program Elements," with only minor discrepancies. (f)

• NRCregulations, that should be adopted by an Agreement State for purposes of compatibility or health and safety, are adopted in a time frame so that the effective date of the State requirement is not later than 3 years after the effective date of NRC's final rule. (g)

• Other program elements that have been designated as necessary for maintenance of an adequate and compatible program should be adopted and implemented by an Agreement State within 6 months of such designation by NRC. (h)

Satisfactory With Recommendations for Improvement (2)

• The State has adopted legal binding requirements, regulations, and other program elements in accordance with MD 5.9 and the cu .cnt revisions of OSP Intemal Procedures D.7 and B.7 but there are compatibility or health and safety discrepancies that need to be addressed. (a)

• Several NRC regulations that should be adopted by an Agreement State are adopted in a time frame such that the effective date of the State requirement is greater than 3 years after the effective date of NRC's final rule. (b)

Approved: September 12,1995 (Revised; November 25,1997) 31

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Non-Common Performance Indicator 1-Legislation and Program Elements Required for Compatibility (F)(continued) .

Satisfactory With Recommendations for Improvement (2)(continued)

• Several program ciements that have been designated as necessary for maintenance of an adequate and compatible program have been adopted and implemented by the Agreement State in a time frame greater than 6 months of such designation by NRC. (c)

Unsatl4 factory (3) e State no longer has statutes that authorize the State to establish a program for the regulation of agreement material and provide authority for the assumption of regulatory responsibility under the agreement. (a) e The State is not authorized through its legal authority to licence, inspect, and enforce legally binding requirements such as regulations and licenses. (b) e State statutes are in conflict with, or do not sufficiently reflect, scope of Federal statutes. (c)

• The State does not have existing legally enforceable measures such as generally applicable rules, license provisions, or other appropriate measures, necessary to allow the Sate to ensure adequate protection of public health and safety in the regulation of agreement material. (d)

• The State has not adopted significant legal binding requirements, regulations. and other program elements in accordance with MD 5.9 and the current revisions of OSP Internal Procedures D.7 and B.7. (c)

• Most NRC regulations that should be adopted by an Agreement State are consistently adopted in a time frame so that the effective date of the State requirement is significantly greater (many months oryears) than 3 years after the effective date of NRC's final rule. (f)

• Most program elements that have been designated "as necessary" for maintenance of an adequate and compatible program have been adopted and implemented by the Agreement States in a time -

frame significantly greater (many months oryears) than 6 months of such designation by NRC. (g)

Approved: Septemter 12,1995 32 (Revised: November 25,1997)

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Non-Common Performance Indicator 1-Iegislation and Program Elements Required for Compatibility (F)(continued)

Category N (4)

Not applicable.

Non-Common Performance Indicator 2-Sealed Source and Device Evaluation Program (c)

Technical Quality of the Product Evaluation Program (1)

Satisfactory (a)

-

• Review of a representative sample of SS&D evaluations completed during the review period indicates that product evaluations are thorough, complete, consistent, of acceptable technical quality, and adequately address the integrity of the products in use and likely accidents. (i) e Health and safety issues are properly addressed. (ii)

• All initial and concurrence reviews 2 are performed by persons l having adequate training. (iii) l

• All registrations clearly summarize the product evaluation and  !

provide license reviewers with adequate information to license possession and use of the product. (iv) e Deficiency letters clearly state regulatory positions and are used at the proper time. (v) e An independerst technical review of the application and proposed certificate of registration is performed by a second indisidual and supports the finding that the product is acceptable for licensing purposes. (It is important to keep in mind that the independent technical miewer must concur with the initial review.) (si)

• Applicable guidance documents are followed, unless approval to use alternate procedures is obtained from management. (vii) iA concurrm review indudes an indeptadent technaal review of the materials submitted by the apphcant and the documents generated by the initi ; reviewer. TE concurrence tenew indudes evaluauon of each area addressed during the initial rewew (e.g construction of the product,labehng, and prototyp testing), but the conurrence rewew is not to the same leveW # sl as the initial renew (l.c it is not necessary to renew every page of the apphcant's submittal). The concu. .w renew must be focused on ensuring that the product meets aD apphenble regulations, that the product would not pose any health or safety concerns, and that the registration certification provides an adequate basis for hcensing. This concurrence review by a second quahf24 renewer is necessary in view of the potential health and safety imphcation resulting from the widespread distribution of sealed sources and devices.

. Approved: September 12,1995 (Revised: November 25,1997) 33

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Non-Common Performance Indicator 2-Sealed Source and Device Evaluation Program (c)(continued) -

Tbehnical Quality of the Product Evaluation Program (1)(continued)

• Completed registration certificates, and the status of obsolete registration certificates, are clear and are promptly transmitted to interested parties. (viii) e Reviewers ensure that registrants have developed and implemented adequate quality assurance and control programs. (ix) e There is a means for enforcing commitments made by registrants in their applications and referenced in the registration certificates by the program. (x)

Satisfactory With Recommendations for Improvement (b) e Resiew indicates that some SS&D evaluations do not fully address important health and safety concerns or indicates repeated examples of problems with respect to thoroughness, completeness, consistency, clarity, technical quality, adherence to existing guidance in product evaluations, and addressing the integrity of the products. (i)

• Not all registrations clearly summarize the product evaluation and not all provide license reviewers with adequate information to license possession and use of the product. (ii) e Reviewers do not follow all appropriate guidance documents. (iii) t

• The initial and concurrence reviews are not always performed by persons having adequate training. (iv)

• Completed registration certificates, and the status of obsolete registration certificates, are not always clear or are not always promptly transmitted to interested parties. (v)

• Not all product evaluations include an evaluation of proposed quality assurance and control programs. (si) e Commitments made by registrants in their applications, and referenced in the registration certificates, cannot be enforced for all registrations. (vii)

Approved: September 12,1995 34 (Revised: November 25,1997)

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• • IntegrateJ Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Part III i

Non Common Performance Indicator 2-Sealed Source and Device Evaluation Program (a)(continued)

Technical Quality of the Product Evaluation Program (1)(continued)

Unsatisfactory (c) ,

e Review indicates that SS&D evaluations frequently fail to address important health and safety concerns orindicates chronic problems with respect to thoroughness, completeness, consistency, clarity, technical quality, adherence to existing guidance in product evaluations, and adequately addressing the integrity of the products. (i)

• Registrations often do not clearly surranarize the product evaluation and do not provide license reviewers with adequate mformation to license possession and use of the product. (ii) .

• Revi:wers often do not follow appropriate guidance documents. (iii)

• The initial and concurrence reviews are often not performed by pensons having adequate training. (iv)

• Corapleted registration certificates, and the status of obsolete registration certificates, are unclear and are not promptly transroitted to interested parties. (v)

• Product evaluations often do not include an evaluation of proposed ouality assurance and control programs. (si) e Commitments made by registrants in their applications, and referenced in the registration certificates, often cannot be eniorced. (vii)

• The review has identified potentially significant health and safety issues linked to a specific product evaluation. (viii)

Category N (d)

Not applicable.

Approved: September 12,1995 (Revised: November 25,1997) 35

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Non-Common Performance Indicator 2-Sealed  !

Source and Device Evaluation Program (o)(conti .ied) l Technical Stamng and Training (2)

Satisfactory (a)

The technical review and audit are performed by staff having proper training and qualifications.

Satisfactory with Recommendations for Imprmement (b)

Some reviewers do not have the proper qualifications and training.

Unsatisfactory (c)

Technical review of the reviewer's evaluation is either not performed or l

r;ot perfonned by managemem or staff having proper qualifications l

and training.

Category N (d)

Not applicable.

Evaluation of Defects and Incidents Regarding SS&Ds (3)

Satisfactory (a)

The SS&D evaluation program routinely evaluates the root caus.es of defects and incidents invohing SS&D evaluations and takes approprir.te actions, including modifications of SS&D sheets and notification of affected parties and other regulatory authorities.

Satisfactory With Recommendations for Improvement (b)

The SS&D evaluation program dcies not fully evalunte the root causes of all defects and incidents invohing SS&D evalactions, or when performed, the programs do not always take appropriate actions, .

including notification ofinterested parties.

Approved: September 12,1995 36 -(Revised: November 25,1997)

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Handbook 5.6 Part III i

Non-Common Performance Indienf or 2-Sealed Source and Device Evaluation P.ogio 1 (o)(continued)

Evaluation of Defer *.s and Incid(nts Regarding SS&Ds (3)(continued)

I Unsatisfactory (c)

The SS&D evaluation program does not ensure evaluation of the root causes of defects and incidents involving SS&D evaluations, or if performed, does not ensure appropriate actions are taken, including notification ofinterested parties, i

. Category N (d)

Not applicable.

Non-Common Performance Indicator 3-Low-Level Waste Radioactive Waste Disposal Program (H)

Status of LoweLevel Rrdloactive Waste Disposal Inspection (1)

Satisfactory (a) e Low-level radioactive waste disposal licensees are inspected at regular intervals in accordance with frequencies prescribed in NRC Inspection Manual, Chapter 2800. (i) e Deviations fr om these schedules are normally coordinated betwecn working staff and management. (ii) e The inspection findings are communicated to licensees in a timely manner (30 calendar days es specified in NRC Inspection Manual, Chapter 0610-10). (iii) e All nenoperational phas: inspections are conducted at the State's prescribed frequency. (iv)

Satisfactory with Recommendations forImprovement (b)

. The licensee is inspected at intervals that exceed the NRC Inspection Manual, Chapter 2800, frequency by more than 25 percent. (i)

Approved: September 12,1995 (Revised: November 25,1997) 37

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status of ImLevel Radioactive Waste Disposal Inspection (1)

(continued) e All nonoperational phase inspections are conducted at intervals that exceed the State frequencies by more than 25 percent. (ii)

• Some of the inspection findings are delayed, or not communicated to lixnsees within 30 days. (iii)

Unsatisfactory (c) e The licensee is inspected at intervals that exceed the NRC Inspection Manual, Chapter 2800, frequency by more than 100 percent. (i) e Nonoperationa! phase inspections are conducted at intervals that exceed the State fIequencies by more than 100 percent. (ii)

. Inspection findings are frequently delayeA (iii)

Category N (d)

Not applicable.

Technical Quality of Inspections (2)

Satisfactory (a) e Review team member accompanying inspectors combined with r.n onsite aview of completcd inspection files indicate inspection findings are usually well founded and well-documented throughout the assersment period. (i)

• A review of inspector field notes or completed reports, as appropriate, indicates that most inspections are complete and reviewed promptly by supervisors or management. (ii)

• Procedures are in place and normally used to help identify root causes and poor licensee performance. (iii) ,

e In most inr.ances, followup inspections address previously identified open items and/or past violations. (iv)

Approved: September 12,1995 38 (Revised: November 25,1997)

Volume 5, Governmental Relations and Public Affairs Integrated Materfuls Performance Evaluation Program (IMPEP)

Handbook 5.6 Part IIJ Non> Common Performance Indicator 3-Low-Level "laste Radioactive Waste Disposal Program (H)(continued)

Technical Quality ofInspections satisfactory (2)(continued) e Inspection findingt generally lead to appropriate and prompt regulatory action. (v) e Supenisors accompany nearly all inspectors on an annual basis. (vi) satisfactory With Recommendations forImprovement (b)

. e Review indicates that low level radioactive was- t aposal inspections do rest fully address potentially important health and safety concems or it indicates periodic problems with respect to completeress, adherence to procedures, maaagemen6 review, thoroughness, technical quality, and consistency. (i) e Review indicates that findings in inspection reports and inspection files are, op occasion, not well founded or well-documented. (ii) e The review does not demonstrate an appropriate level of management review. (iii)

. Accompaniments of inspectors by supenisors are performed non systematically. (iv) e Followup actions to inspection findings are often not timely. (v)

Unsatisfactory (c)

• Review indicates that inspections (including construction phase and closure / monitoring phase) frequently fail to address potentially important health and safety concerns or it indicates chrcerac problems exist with respect to completeness, adherence to procedures, management review, thoroughness, technical quality and consistency. (i)

• Accompaniments of inspectors are infrequently performed. (ii) e Followup actions to inspection findings are often not timely and appropriate. (iii)

Approved: September 12,1995

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Non Common Performance Indicator 3-Low-Level Waste Radioactive Waste Disposal Program (n)(continued) .

Technical Quality ofInspections Satisfactory (2) (continued)

Category N (d)

Not applicable.

Technical Staffing and Training (3)

Satisfactory (a) e Review indicates that the qualifications of the technical staff are commensurate with expertise ider.tified as neccLary to regulate a low level radioactive waste disposal facility. (i)

• The managenaent has developed and implemented a training program for staff. (ii) e Staffing trends that could have an adverse impact on the quality of the program are tracked, analyzed, and addressed. (iii)

Satisfactory With Recommendations forImprovement (b) e There is some staff turnover that could adversely impact the low level radioactive waste disposal program. (i) e Some vacant positions are not readily filled. (ii) e There is some evidence oflack of management attention or action to deal with staffing problems. (iii)

• Some of the licensing :md inspection personnel in the low level radioactive waste disposal program are not making prompt progress in completing all of the training and qualification requirements (iv)

• The training and qualification standards include areas that could be improved. (v) -

• Some of the nee staff is hired with little education or experience in physical and/or life sciences; materials licensing and inspection; -

civil or mechanical engineering; geology, Sydrology and other eat th sciences; and emironmental science. (si)

Approved: September 12,1995 40 (!tevised: . November 25,1997)

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Handbook 5.6 Part III Non-Common Performance Indicator 3-Low Level

, Waste Radioactive Waste Disposal Program (H)(continued)

Techwical Stamng and ' Raining (3) (continued)

Unsatisfactory (c) e There is significar.t staff turnover relative to the size of the program. (i)

• Most vacant positions are not filled for extended periods. (ii) ,

• Tilere is little evidence of management attention or actions to deal with staffing problems. (iii)

• Most of the licensing and inspection personnel are not making prompt progress in completing all of the training and qualification requirements. (iv) e New staff members are hired without having education or experience in physical and/or life sciences; materials licensing and inspection; civil or mechanical engineering; geology, hydrology and other earth sciences; and environmental science. (v)

Category N (d)

Not applicable.

Technical Qutlity of Licensing Actions (4)

Satisfactory (a) e Prelicensing interactions with the applicant are occurring on a regular basis. (i) e Special license tie-down conditions are usually stated clearly and are inspectable. (ii)

• Deficiency letters clearly state regulatory positions and are used at the proper time. (iii)

- e Reviews of amendments and renewal applications demonstrate thorough analysis of a licensee's inspection and enforcement history,if applicable. (iv)

• Applicable guidance documents are available to reviewers in most cases, and are generally followed. (v) 4 Approved: September 12,1995 (Revised: Novembr.r 25,1997) 41

Volume 5, Governmental Relations and Public Affairs '*

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Handbook 5.6 Part III ,

Non-Common Performance Indicator 3-Low-Level Waste Radioactive Waste Disposal Program (H)(continued) .

Technical Quality of Licensing Actions (4)(continued) e Public hearings in accordance to the State administrative laws have occurred. (vi)

• Review of certain technical aspects of the low-level radioactive waste license files indicates that aspect of the license review is generally thorough, complete, consistent, and of acceptable technical quality. (vii)

- e Health and safety issues are properly addressed. (viii) e An evaluation of the license review process indicates that the process is thorough and consistent. (ix)

Satisfactory With Recommendations for Improvement (b) e Review indicates that some technical aspects of licensing do not -

fully address health and safety concerns or indicates problems with respect to thoroughness, completeness, consistency, clarity, technical quality, and adherence to existing guidance in licensing actions. (i) e Some aspects of the public hearings are not consistent with State administrative law or do not address some aspects of the licensing of a low level radioactive waste disposal facility. (ii)

Unsatisfactory (c)

• Review indicates that technical aspects of the licensing actions frequently fail to address important health and safety concerns or indicates chronic problems with respect to thoroughness, completeness, consistency, clarity, technical quality, and adherence to existing guidance in licensing actions. (i)

• Public hearings are not consistent with State administrative law or fail to address aspects of the licensing of a low level radioactive .

waste disposal facility. (ii)

Approved: September 12,1995 42 (Revised: November 25,1997)

1 Volume 5, Governmental Relations and Public Affairs Integrated Materials Perfonnance Evaluation Program (IMPEP)

Handbook 5.6 Part III Non-Common Performance Indicator 3-Low-Level Waste Radioactive Waste Disposal Program (H)(continued)

Technical Quality of Licensing Actions (4)(continued)

Category N (d)

Not applicable Response to incidents and Allegations (5)

Satisfactory (a)

Meets " Satisfactory" performance for common performance indicator criteria, Section (E)(1) of this part, as applied to the response to incidents and allegations sub-clement for the low-level radioactive waste disposal program.

Satisfactory W'th Recommendations for Improvement (b)

Meets " Satisfactory With Recommendations for Improvement" performance for common performance indicator criteria, Section (E)(2) of this part, as applied to the response to incidents and allegations sub-clement for the low level radioactive waste disposal program.

Unsatisfactory (c)

Meets " Unsatisfactory" performance for common performance indicator criteria; Section (E)(3) of this part, as applied to the response to incidents and allegations sub-clement for the low-level radioactive waste disposal program.

Category N (d)

Not applicable.

Approved: September 12,1995 (Revised: November 25,1997) 43

Volume 5, Governmental Relations and Public Affairs ,,'

Integrated Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Part III i Non-Common Performance Indicator 4-Uranium Recovery Program (I) ,

Status of Uranium Recovery Inspection Program (1)

Satisfactory (a)

• Uranium recovery licensees are inspected at regular intervals in accordance with frequencies prescribed in NRC Inspection Manual, Chapters 2801 and 2600. (i) e Deviations are' generally the result of decisions that consider the risk oflicensee operation, past licensee performance, and the need to temporarily defer she inspection (s) to address more urgent or more critical priorities. (ii)

• There is a plan to reschedule any missed or deferred inspections or a basis established for not rescheduling. (iii)

• Inspection findings are communicated to licensees at the exit briefings and confirmed fonnally in writing in a timely manner (30 calendar days as specified in NRC Inspection Manual, Chapter 0610-10). (iv) .

Satisfactory With Recommendations for Improvement (b)

• The licensees are inspected at intervals that exceed the NRC ,

Inspection Manual, Chapter 2801, frequencies for conventional uranium mills or the NRC Inspection Manual, Chapter 2600, frequencies for insitu leach facilities by more than 25 percent. (i) e So.ne of the inspection findings are delayed, or not communicated to licensees within 30 days. (ii) l Unsatisfactory (c)

• The licensees are inspected at intervals that exceed the NRC Inspection Manual, Chapter 2801, frequencies for conventional uranium mills or NRC Inspection Manual, Chapter 2600, frequencies for insitu leach facilities by more than 100 percent. (i)

L e Inspections findings are frequently delayed. (ii)

Category N (d) -

Not appliccble.

L Approved: September 12,1995 44 (Revised: November 25,1997)

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T chnical Quality ofInspe:tions (2)

Satisfactory (a) e Review team members accompanying inspectors combined with an onsite review of a repesentative cross-section of completed inspection files indicate inspection findings are usually well fouaded and well-documented throughout the assessment period. (i) e Licensing history and status are incorporated into the inspection program as demc.nstrated through accompaniments and pract dures in place. (ii) e A review of inspector field notes ar completed reports indicates that most inspections as e comp.ete and reviewed promptly by supervisors or management, (iii) e Procedures are in place. and normally used to help identify root causes and poor licensee performance. (iv)

. In most in.tances, followup inspections address previously identified open items and/or past violations. (v)

• Inspection findings generally lead to appiopriate and prompt regulatory action. (iv) e Supervisors accompe.ny nearly all inspr nors on an annual basis. (vii)

Satisfactory With Recommendations for Improvement (b) e Review indicates that uranium recovery inspections occasionally do not address potentially important health, safety, and emironmental concerns or it indicates periodic problems with respect to completeness, adherence to procedures, management review,

. thoroughness, technical quality, and consistency. (i) e Review indicates that findings in inspection reports and inspection files are, on occasion, not well founded or well-documented, and the review does not demonstrate an appropriate level of management resiew. (ii) l l

Approved

Geptember 12,1995 l (Revised:- Nwember 25,1997) 45 i

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Handbook 5.6 Part III ,

Non-Common Performance Indicator 4-Uranium Recovery Program (1)(continued) -

Technical Quality of Inspections (2) (continued)

. Accompaniment of inspectors by supervisors is performed non systematically. (iii) e Followup actions to inspection findings are often not timely. (iv)

Unsatisfactory (c)

• Review indicates that uranium recovery inspections frequently fail

. to address potentially important health, safety, and environmental concerns or it indicates chronic problems exist with respect to completeness, adherence to procedures, management review, thoroughness, technical quality and consistency. (i)

. Accompaniments ofinspectors are infrequently performed. (ii)

• Followup actions to inspection findings are often not timely and appropriate. (iii)

Category N (d)

Not applicable.

Technical Stamng and Th.Ining (3)

Satisfactory (a) e Review indicates that the qualifications of the technical staff are commensurate with expertise identified as necessary to regulate uranium recovery facilities. (i) e The managemcnt has developed and implemented a training program for staff. (ii)

• Staffing trends that could have an adverse impact on the quality of the program are tracked, analyzed, and addressed. (iii) .

Approved:' September 12,1995 46 (Revised: November 25,1997)

Volume 5, Governmental Relations and Public Affairs Integrated Materials Performance Evaluation Program (IMPEP) 1 Handbook 5.6 Part III Non-Common Performance Indicator 4-Uranium Recovery Program (1)(continued) hchnical Staffing and Walning (3) (corlinued)

Satisfactory With Recommendations for Improvement (b)

• There is some staff turnover, which adversely impacts the uranium recovery program. (i)

• Some vacant positions, necessary for continued program effectiveness, are not readily filled. (ii)

.

• There is some evidence of lack of management attention or action to deal with staffing problems. (iii)

• Some of the uranium recovery licensing and inspection personnel are not making prompt progress in completing all of the training and qualification requirements. (iv)

• The training and qualification standards include areas that could be improved. (v) e Some of the new staff are hired with little education or experience in physical and/or life sciences; materials licensing and inspection; civil or mechanical engineering; geology, hydrology and other earth sciences; and environmental science. (vi)

Unsatisfactory (c)

• There i significant staff turnover relative to the size of the program. (i) e Most vacant positions are not filled for extended periods. (ii)

• There is little evidence of management attention or action to deal with staffing problems. (iii)

• Training program is not i . place. (iv)

• Most of the licensing and inspection per:.onnel are not making prompt progress in completing all of the training and qualification requirements. (v) l

!- Approved: Septernber 12,1995 (Revised: November 25,1997) 47

Volume 5, Governmental Relations and Public Affairs ..

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Handbook 5.6 Part III i Non-Common Performance Indicator 4-Uranium Recovery Program (I)(continued) -

Technical Stemng and Walning (3) (continued) e New staff members are hired without having education or experience in physical and/or life sciences; materials licensing and inspection; civil or mechanical engineering; geology, hydrology and other carth sciences; and environmental science. (vi)

Category N (d)

Not applicable.

hchnical Quality of Licensing Actions (4)

Satisfactory (a)

• Review of completed licenses and a representative sample of licensing files indicates that license reviews are generally thorough, ,

complete, consistent, and of acceptable technical quality. (i) e Health, safety, and environmental issues are properly addressed. (ii) e Ucense reviewers almost always have the proper signature authority for the cases they review. (iii) e Special license tie-down conditions are usually stated clearly and are inspectable. (iv) e Deficiency letters clearly state regulatory positions and are used at the proper time. (v) e Reviews of renewal applications demonstrate thorough anaiysis of a licensee's inspection and enforcement history. (vi)

. Applicable guidance documents are available to reviewers in most cases, and are generally followed. (vii)

Approved: September 12,1995 48 /, Revised: November 25,1997)

( Volume 5, Governmental Relations cod Public Affairs

• . Integrated Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Part III D

Non-Cominnn Performance Indicator 4-Uranium Recovery Pm ram (I)(continued)

Technical Quality of Licensing Actions (4) (continued) ,

Satisfactory With Recommendations for Improvement (b)

Review indicates that some licensing actions do not fully address health, safety, and environmental concerns or indicates repeated examples of problems with respect to thoroughness, completeness, consistency, clarity, technical quality and adherence to existing guidance in licensing actions.

~

Unsatisfactory (c)

Review indicates that licensing actions frequently fail to address important health, safety, and em'ironmental concerns or indicates chronic problems with respe:t to thoroughness, completeness, consistency, clarity, technical quality and adherence to existing guidance in licensing actions.

Category N (d)

Not applicable. .

Response to Incidents and Allegations (5)

Satisfactory (a)

Meets " Satisfactory" performance for common performance indicator criteria, Section (E)(1) of this part, as applied to the response to incidents and ellegations sub-clement for the uranium recovery program.

Satisfactory With Recommendations for Improvement (b)

Meets " Satisfactory with Recommendations for Improvement"

< performance for common performance indicator criteria, Section (E)(2) of this part, as applied to the response to incidents and allegations sub-clement for the uranium recovery program.

Approved: September 12,1995 (Revised: November 25,1997) 49

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_ Handbook 5.6 Part III 3 Non-Common Performance Indicator 4-Uranium Recovery Program (I)(continued) .

Respon=e toIncidents and Allegations;(5)(continued)

Unsatisfactory (c)

Meets " Unsatisfactory" performance for common performance indicator criteria. Section (E)(3) of this part, as applied to the response to incidents and allegations sub-clement for the uranium recovery program.

Cate::ory N (d)

Not applicable.

Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)

Status of Fuel Cycle Inspection Program (1)

Satisfactory (a) e Licensee facilitics are inspected at regular intervals in accordance with frequencies prescribed in NRC Inspection Manual, Chapter 2600,with appropriate documented adjustments to reflect licensee performance and the inherent risk of !!censee operations. (i)

- The schedules for facility inspections are appropdately updated and maintair.ed in the fuel cycle master inspection plan. (a)

- The inspections scheduled for each fccility are consistent with the requirements of NRC Inspection Manual, Chapter 2600, with appropriate adjustments. (b)

- There are few differences between the inspections planned and

^

scheduled for the current fiscal year, and the inspection program currently intended for each facility for the fiscal year. (c)

- Changes in the fuel cycle master inspection plan are documented when they occur and generally are the result of joint decisions between management and staff in the regions and headquarters. (d) t

, Approved: September 12,1995 50 (Revised: November 25,1997)

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l Volume 5, Governrnental Relations and Public Affairs Integrated Materials Performance Evaluation Program (IMPEP)

Handboek 5.6 Part III Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued)

Status of Fuel Cycle Inspection Program (1)(continued)

Changes in the region's inspection program for each facility are well-documented and primarily based on the inherent risks of licensee operation, past licensee performance, and the need to address more urgent or more critical priorities or deal with unforeseen resource limitations. (e)

• There is evidence that regional management periodically ascertaint the status of the inspection program and, when necessary, acts swiftly to resolve problems affecting performance.

Management is confident that th existing inspection schedule adequately reflects the region's stated objectives for each facility's inspection program. Management also is aware of the comparison betwecn planned inspections and actual performance of inspections, and is confident that the objectives for each facility's inspection program are being met. (ii) e There is clear evidence of an ongoing process to reschedule reiy missed or deferred inspections, and to optimize the ability to meet the stated objectives. (iii)

. The scheduling and performance of inspections optimizes the utilization ofinspection resources so that inspectors are permitted sufficient time to prepare for and document inspections. The percentage of time inspectors spend on routine inspections, reactive inspections, preparation and documentation, and other programmatic activities, is close to that originally planned in accordance with stated objectives. Significant departures from what was originally planned, and the reasons for their occurrence, are documented as they become apparent. (iv) e Inspection findings are communicated to licensees in a timely manner (normally within 30 calendar days, or 45 days for team inspections, as specified in NRC Inspection Manual, Chapter 0610-10, unless there are legitimate documented reasons for delays). (v)

• The region udequately maintains documentation of licensee c performance in support of the licensee performance resiew program.- (vi)

Approved: September 12,1995 (Revisedt November 25.1997). 51 ,

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Non-Comnr n Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued) -

Status of Fuel Cycle Inspection Program (1) (continued)

Satisfactory With Recommendations for Improvement (b) e IJcensees are inspected at greater intervals than specified in NRC Inspection Manual, Chapter 2600, absent timely written documentation of the intention to do so. (i)

- Objectives for the inspection of some of the region's facilities are not documented in an inspection plan for each facility, or they are not in sufficient detail to adequately express the inspection requirements for each facility in terms of licensee performance or inherent facility risk. (a)

- The ins:mjons scheduled in the fuel cycle master inspection plan for a facility do not correspond to the objectives previously documented for the facility's inspection program, and the reasons for the discrepancies have not been documented adequately. (b)

- The inspections scheduled in the fuel cycle master inspection plan for one or more facilities do not reflect the requirements contained in NRC Inspection Manual, Chapter 2600, and no timely documentation exists to justify the discrepancies. (c) e Reliable documentation regarding the conduct of the region's inspection program cannot be readily produced, and the region cannot confirm within a reasonable time that the inspection program rnects the requirements of NRC Inspection Manual, Chapter 2600, or the objectives previously documented for each facility's inspection program. (ii) e Regional management is slow to react to problems affecting performan::e of planned inspections, with the result that the inspections contained in the fuel cycle master inspection program no longer correspond to the inspection direction needed to focus on changes in licensee performance. (iii) e Some inspectors are under-utilized or ovet-utilized for routine inspections to the extent that their onsite inspection hours do not correspond to the region's stated objectives for utilization of inspection resources, with no adequate documentation tojustify the discrepancies. (iv)

Approved: September 12,1995 52 (Revised: November 25,1997)

Volume 5, Governmental Relations and Public Affairs Integ.sted Materials Performance Evaluation Program (IMPEP)

, Handbook 5.6 Part III Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued)

Status of Fuel Cyc!c Inspxtion Program (1) (continued)

• Son.e of the inspection findings are delayed, or not communicated to licensees within 30 days (45 days for team inspections), without adequate documentation of justification or legitimate reasons for such delays or deletions (as in the case of pen.iing escalated i6 enforcensent). (v)

• Documentation in support of the observations required to be

, formulated for the licensee performance review program do not exist, or are not easily located. (vi)

Unsatisfac^ory (c)

• Licemees ate inspected at intervals that frqu:htly exceed the NRC hspection Manual, Chapter 26G3, frequencies, irrespective of licensee performance or facility risk, without adequate documentation orjustification for such departures. (i) e Objectives for each facility's inspection program have not been documented, or do not adequately consider NRC Inspection Manual, Chapter 2600, requirements, licensee performance, or the inherent risk oflicence operations. (ii)

• Management cannot readily demonstrate that the existing regional fuel cycle inspection sch dule, in combination with the recent history oicompLted inspections, support the inspection objectives described in the inspection programs for each facility. (iii) e Inspections of licensees or communications of the inspection findings are frequently delayed, without adequate documentation or justification. (iv)

. he region does not adequately maintain documentation necessary to document licensee performance in support o. the licensee performance review program. (v)-

• Observations }3ovided to support the licensee performance review program cannot be supported by existing documentation. (si)

Apprc,ved: September 12,1995 (Revise & November 25,1997) 53-m, . -

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Handbook 5.6 Part III _

Non-Common Performance Indicator 5-Regional

, Fuel Cycle Inspection Program (J)(continued) .

Status of Fuel Cycle Inspection Program (1) (continued)

Category N (d)

Special couditions exist that provide adequate justification for withholding a rating. For example, an unforeseen event or emergency with significant imith and safety consequences may have required a temporary dit::rsion of resources from the core inspection program.

} However, these programmatic adjustments are well founded and properly coordinated with NMSS managemert.

Technical Quality of Inspections (2)

Satisfactory (a)

}.,; e An onsite review of a representative cross-section of completed r i inspection files indicates inspection finding,s are usually l2 well-founded and well-documented throughout the assessment t period. (i)

• A review of completed inspection reports indicates that most inspections are complete, consistent with the requirements cf NRC Inspection Manual, Chapter 0610, and reviewed promptly by supervisors or managemer.t. (ii)

• Inspection efforts focus on the safety or safegrards significance of licensee performance, while maintaining alertness te possible trends and patterns of poor licensee performance. Plant operations addressed and performance areas emphasized correspond closely to the objectives documented for the region's inspection program for the facility. (iii) e N most instances, followup inspections addiess previously identified open items and/or past violations. (iv) e Inspection f5 dings generally lead to prompt and appropriate regulatory action. (v)

• A inspections are conducted or led by qualified NRCinspectors Contractors and inspector trainees, augmenting inspections, are provided proper guidance by the inspection leader during onsite inspections, resulting in good ir'.egration of the efforts of these personnel with those of the oth r qualified in pectors. (vi) 1 Approved: September 12,1995 54 (Revised: November 25,1997)

. Volume 5, Governmental Relations and Public Affaira Integrated Materials Performance Evaluation Program (IMPEP)

Handbook 5.6 Part III Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued)

Techvilcal Quality 6 Inspections (2)(continued)

• Supervisors accompany all inspectors on at least an annual basis, with greater emphasis on the less-experienced inspectors. (vii)

Satisfactory With Recommendations for Improvement (b) e Review indicates that findings in inspection reports and inspection

'iles are, on occasion, not well-founded or well-documented, or the review demonstrates an inappropriate icvel of management review. (i) e Review indicates that scme inspections do not address potentially important health and safety concerns, or indicates recurring problems with respect to completeness, adherence to procedures, management review, thoroughness, technica' quality, or consistency, relative to the requirements specified in NRC Inspection Manual, Chapter 0610. (ii) e Inspection efforts do not always focus on the safety or safeguards significance of licensee performance. Inspection reports do not attempt to address possible trends or patterns of poor licensee performance. Plant operations addressed and performance arcar emphasized do not always correspond closely to the objectives documented in the region's inspection program for the facility. (iii)

• An instance occurs in which a contractor or inspector trainee, augmenting an inspection, is not provided proper guidance by the

inspection leader during an onsite inspection, resulting in inappropriate activity by the contractor that is not immediately corrected when discovered. (iv) e Supervisors do not sy;tematically accompany all inspectors to ensure at least annual frequency, but the more recently hirca, inexperienced inspectors are accompanied at least annually. (v)

, e Followup actions to inspection findings ofter are not timely, or not appropriate. (vi)

,' 7' Approved: September 12,1995 (Revised: November 25,1997) 55

.e Volume 5, Governmental Relations and Public Affairs ,,' ,

Integrated Materials Performance Evaluation Program (IMPEP) l Handbook 5.6 Part III i Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued)

Technical Quality ofInspections (2) (continued)

Unsatisfactory (c)

• Review indicates that inspections frequently fail to address potentially importe.nt health and safety concerns, or indicates that chronic problems exir.t with respe::t to completeness, adherence to procedures, management review, thoroughness, technical quality and consistency, relative to the requirements specified in NRC Inspection Manual, Chapter 0610. (i)

• Inspection efforts typically do not focus on the safety or safeguards significance of licensee performance. Inspection reports do not attempt to address possible trends or patterns of poor licensee performance. Plant operations addressed :md performance areas of emphasis typically bear little correspondence to the objectives documented in the region's inspection program for the f acility, or such documentation does not exist. (ii)

• More than one instance occurs in which a contractor, augmenting an inspection, is not provided proper guidance by the inspection leader during an onsite inspection, resulting in inappropriate activity by the contractor that is not immediately corrected when discovered. (iii)

• An inspection is conducted solely by an individual who is not a qualified NRC inspector, or is led by an individual who is not a qualified NRCinspector. (iv) e Supervisors infrequently accompany inspectors, and accompaniments that are performed fail to involve the more recently hired, less experienced inspectors. (v) e Followup actions to inspection findings are often not timely or appropriate. (vi)

Category N (d)

Not applicable.

Approved: September 12,1995 56 (Revised: November 25,1997)

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Non-Common Performanc^ Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued) -

Technical Stamng and 'IYalning (3)

Satisfactoy L)

Review indicates implementation of a well-conceived and balanced staffing strategy throughout the assessment period, and demonstrates the qualifications of the technical staff. This is indicated by the presence of most of the icllowing features:

e Prompt management attention and review to recognize staffing or training problems (e.g., high rates of attrition, positions being vacant foi enended period:. tack of adequate training cpportunities), and to develop appropriate corrective action plans. (i) e Qualification criteria for hiring new technical staff have been established and are being followed. Staff woulc; normally be expected to have bachelor's degrees or equivalent training in tne physical and/or life sciences. Senior personnel should have additional training and experience beyond their original area of specialization to reflect the broader area of responsibility in their organization. (ii e Inspectors are trained and qualified in a reasonable time period, despite difficulties that may be encountered in the availability of training opportunities provided by NRC, or of alternative outside training opportunities determined by the Division of Fuel Cycle Safety and Safeguards (FCSS) to meet requirements specified in NRC Inspection Manual, Chapter 1246. Training plans and schedules for qualification are established, maintained, and personally reviewed by the inspector and management. (iii)3

• Management ensures that inspectors avail themselves of ,

apportunities for required training mfrequently provided by NRC, oridentifies to FCSS alternative outside training opportunities that can be determined by FCSS to meet NRC Inspection Manual, Chapter 1246, requirements, resulting in trainees reaching qualification without undue delays. (iv) 3For the regions, this means there has been and continues to be. a clear effort to adhere to the requirements and conditions specified in NRCinspection Manual, Chapter 1246, and the applicable quahfications journals, of to receive equivalent training thewhere.

i Approved

September 12,1995

-(Revised: November 25,1997) 57

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Handbook 5.6 Part III _ i Non-Common Performance Indicator 5 -Regional Fuel Cycle Inspection Program (J)(continued)

Technical Staffing and Training (3)(continued) e Management commitment to training is clearly evident. (v) e Inspectors ne provided cross-training opportunities to develop skills necessary to substitute for or assist other inspectors in functional areas outside their normal assignments. (si) e Inspectors are current with regard to required retraining and refresher training. (vii) e Records are kept to track of how training requirements are satisfied for those requiring training, to provide reminders of when refresher training is due, and to provide reliable and accurate statistics on the status of the training program. (viii)

Satisfactory With Recommendatioas for Improvement (b) e Some unanticipated staff tumover has occurred, that could adversely affect the ability of remaining staff to conduct the inspection program, and management has not taken immediate steps to adjust inspection planning accordingly, or begin the process of replacement. (i)

• Some vacant positions hwe not been readily filled. (ii)

. Some evidence of management attention or actions to deal wiQ staffing problems that may have arisen, but problem still persists. (iii)

• Some of the inspection personnel are not making reasonable I progress in completing the training (or retraining) and qualification

requirements, despM allowing for difficulties in arranging for NRC

! Inspection Manual, Chapter 1246, required courses infrequently l

provided by NRC. (iv) e Management permits several instances to occur, in which inspectors do not avail themselves of opportunities for required training infrequently provided by NRC, resulting in extensions of the time necaed for trainees to reach qualification. (v) e The region's tre.ining and qualification standards do not completely correspond to functicral requirements for inspections. (vi)

Approved: September 12,1995 38: (Revised: November 25,1997)

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Handbook 5.6 Part III Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued)

Technical Stamng and 'haining (3) (continued) '

• Minor difficulties arix when attempting to recurately determine the status of training, retraining, and refresher training requirements and accomplishments for those requiring such training. (vii) e Some of those requi-ing retraining or refresher training are not current. There is an effort to track and schedule the required training, but there is no documentation to explain why the necessary training has not been provided. (viii)

Unsatisfactory (c)

Review determines the presence of chronic or acute problems related to some of the following conditions, which cause concerns about their

[ likely impacts on other sub-elements of this performance indicator:

• Significant unanticipated staff turnover relative to the size of the program, the causes of which cannot all be attributed to normal attrition. (i)

• Many vacant positions remain unfilled for extended periods. (ii) e Little evidence is exhibited of management attention or actions to Sal with staffing problems found to exist. (iii) e Many of the inspection personnel have not met their schedules for qualification, or met refresher training requirements, falling short of written plans and schedule:: to do s. (iv) e Some opportunities for taking NRC Inspection Manual, Chapter 1246, required training courses infrequently provided by NRC, or alternative outside training opportunities identified by FCSS as meeting such requirements, were not attended by inspectors needing such courses for qualification, contributing to failure of inspector trainees to meet established schedules for qualification. (v)

• New staff members are hired without having adequate scientific or technical backgrounds. (vi)

Approved: September 12,1995 (Revised: November 25,1997) 59

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Handbook 5.6 Part III >

Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued)

Technical Stamng and 'Itaining (3) (continued)

• Management is unable to determine within a reasonable time the status of training, retraining, and refresher training for those requiring such training. (vii) e Inadequate or no tracking or scheduling for those requiring retraining or refresher training. (viii)

• Newly hired inspector trainees are not provided sufficient onsite

- training experience, or they are not provided proper guidance by inspection leaders or supervisors while directly contributing to inspections. (ix) e Management consistently withdraws inspection personnel from required training activities to participate in other activities, with the result that established schedules for qualification of inspection personnel are not met. (x)

Category N (d)

Special conditions exist that provide jus +ification for withholding a rating. For example, there has been a substantial management effort to deal with staffing problems, or the mission of the organization has changed too rapidly for training programs to adjust. NMSS has been kept informed of the situation, and discernable recent progress is evident.

Response to Incidents and Allegations (4)

Satisfactory (a) e Incident response and allegation procedures are in place. (i)

• Incident response and allegation procedures are appropriately followed in nearly all cases. Actions taken are well-coordinated with headquarters, as appropriate, and timely in most instances.

Level of effort investigating incidents is usually commensurate with potential health and safety significance ofincident. (ii) .

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Handbook 5.6 Part III Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program g)(continued)

Response to Incidents and Allegations (4)(continued) e Corrective (enforcement or other) actions are adequately iomdfied to licensees promptly, and appropriate followup measures are taken, in coordination with headquarters, as appropriate, to ensure prompt compliance and protection of public health and safety. (iii)

• Followup inspections are scheduled, if necessay, and completed within a reasonable time. Notification to NMSS, AEOD, and others, as may be appropriate, are usually provided in a timely fashion. (iv) e Preparations for the region's portion of the response to major incidents are appropriate to the types ofincidenis '. hat may occur at the region's facilities. Sufficient documentation exists to identify

, individuals viiiiequired skills and experience to be summoned to respond in an emergency, and potential regional participants have been trained to respond to worst-case-scenario incidents. (v) e Procedures are in place to periodically check for completeness of materials needed for emergency response and to occasionally gdate these materials when circumstances change (e.g., staff turnover, completion of training requirements by staff who would respond, change in processes conducted at facilities, or addition or e de'etion of a facility). (vi) e The region's portion of self-assessment activities following a drill or actual event are comprehensive in recognizing problems that arose during the subject activity. Recommendations for improvement arising in self-assessment studies are tracked to ensure further study or implementation. (vii)

• Inspection activity conducted as follow up to rexipt of allegations is technically sound and successful in determining the siety implications of the allegations, as appropriate. (viii)

Satisinctory With Recommendations for Improvement (b)

• The regional portions of incident response and allegation procedures are m place, but occasionally are not adhered to in detail. (i)

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Non-Common Performance Indicator 5-Regional Fuel Cycle Inspection Program (J)(continued)

Response to Incidents and Allegailons (4)(continued) e Resolution of potential public health and safety issues is marginal, with problems in coordination, or timeliness. (ii)

• Preparations for the regional portions of emergency response lag behind changes in circumstances (as described above). Some lapses in training, background, or experience needed to deal with identified types of incidents requiring response, or some types of incidents have been analyzed at the segion's facilities but are not recognized in the region's portion of emergency response plans. (iii)

• The region's portion of self assessment activities following a drill or actual event are shallow in some areas, in not recognizing or funher analyzing problems that arose during the subject activity. Some recommendations for improvement in self-assessment studies are not tracked to ensure further study or implementation. (iv)

• The regional portion of inspection activity conducted as fobow up to receipt of allegations fails to completely address the safety implications of the allegations. (v)

Unsstisfactory (c) e Review indicates frequent examples of the regional portion of response to incidents or allegations to be incomplete, inappropriate, poorly coordinated, or not timely. As a result, the identified potential health ant'. safety problems persist. (i)

• Through regional direction, excessive effort is allocated to the investigation of relatively minor safety issues to the detriment of addressing more significant ones. (ii)

• The region has failed to adequately prepare for significant incidents that could occur at its facilities, despite existing documentation or analyses that indicate those incidents could occur. (iii)

• Inspection activity is not conducted as a follow up to receipt of an -

allegation, though there was a clear need to investigate the safety implications of the allegations. (iv)

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Respoase to Incidents and Allegations (4)(continned)

Category N (d)

Not applicable.

Non-Common Performance Indicator 6-4ite Decommissioning Management Plan (SDMP) (K)

Quality of SDMP Decommissioning Reviews (1)

Satisfactory (a)

Nearly all decommissioning plans are reviewed and the resiews are documented in accordance with NRC Inspection Mariual, Chapter 2605.

Satisfactory With Recommendations for Improvement (b)

Most decommissioning plans are reviewed and the reviews are documented in accordance with NRC Inspection Manual, Chapter 2605.

Unsatisfactory (c)

Decommissioning plans are not being consistently reviewed or documented in accordance with NRC Inspection Manual, Chapter 2605.

Category N (d) ,

Special conditions exist that provide justification for withholding a rating for one or more evaluation criteria.

Financial Assurance for Decommissioning (2)

Satisfactory (a) e For nearly all sites, financial assurance is provided for the estimated costs for an independent, third party to perform d: commissioning with the objective of releasing the site. (i)

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Financial Assurance for Decommitsionine (2)(continued) e For sites where financial assurance has not been prosided, alternative arrangements have been approved by the applicacle regulators. (ii) e Financial assurance mechanisms are reviewed and maintained to ensure that they are executable and prcside sufficient funding for decommissioning in the event that the licensee liquidates or is othemise unable to pay for decommissioning. (iii)

Satisfhetory With Recommendationc for Improvement (b) e For most sites, fmancial assurance is provided for the estilaated costs for an independent, third party to perform decommissioning with the objective of releasing the site. (i) .

• For most sites where financial assurance has not been provided, alternative arrangements have been approved by the applicable regulators. (ii) e For most sites, financial assurance mechanisms are resiewed and maintained to ensure trat they are executable and provide sufficient funding for decommissioning in the event that the licensee liquidates or is otherwise unable to pay for decommissioning. (iii)

Unsatisfactory (c) e Fir ncial assurance is not consistently provided for the estimated cc: for an independent, third party to perform decommissioning with the objective of re!eesing the site. (i) e For sites where financial assurance has not been provided, alternative arrangements have not been always approved by the applicable regulators. (ii) e - Financial - assurance mechanisms are not being consistently reviewed and maintained to ensure that they would be executable and provide sufficient funding for decommissioning in the event -

that the licensee liquidates or is otherwise unable to pay for decommissioning. tili)

Approved: September 12,1995

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Financial Assurance for Decommissioning (2)( ontinued)

Category N (d)

Special conditions exist that provide justification for withholding a

, rating for one or more evaluation criteria.

I Termination Radiological Surveys (3)

Satisfactory (a)

• For nearly all SDMP sites, sufficient radiological surveys are being

{ performed before license termination and site release, as outlined in NRC Inspection Manual, Chapter 2605, to ensure that residual radioactivity levels comply with release criteria. (i) e Licensee survey results are routmely validated through a closecut inspection or confirmatory survey, as outlined in NRC Inspection Manual, Chapter 205, given the extent and significance of any residual contamination. (ii) s Satisfactory With Recommendations for Improvement (b)

'. e For mon SDMP sites, Lufficient radiological surveys are being performed before license tennination and site release, as outlined in NRC Inspection Manual, Chapter 2605, to ensure that residual radioactivity levels comply with release criteria. (i)

• License survey results are usually validated through a closecut inspection or confirmatory survey, as outlined in NRC Inspection Manual, Chapter 2605, given the extent and significance of any residual contamination. (ii)

Unsatisfactx; (c)

Sufficient radiological surveys are not consistently being performed before license termination and site release, as outlined in NRC

. Inspection Manual, Chapter 2605,to ensure that residual radioactivity levels ::omply with release criteua. Also, survey results are not normally validated through a closcout inspection or confirmatory survey, given the extent and significance of any residual c<mtamination, as outlined in NRC Inspection Manual, Chapter 2605.

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Termination Radiological Surveys (3) (continued)

Categon N (d)

Cpecial conditions exist that provide jusufication for withholding a rating for one or more evaluation :riteria.

Inspections (4)

Satisfactory (a)

• At nearly all SDMP sites, inspections are carried out in accordance with established frequencies. (i) e SDMP sites are inspected at least once during decommissioning, and at all significant milestones in the decommissioning process,in addition to the closeout mspection before license termination. (ii) e Inspections are documented and carried out in accordance with NRC Inspection Procedures 87104 and 88104. (iii)

Satisfactory With Recommendations for Improvement (b)

• At most SDMP sites, inspections are carried out in accordance with

stablished frequencies. (i)

• SDMP sites are inspected at least once during decommissioning and at most signi5 cant milestones, in addition to the clos' '

inspection before license termination. (ii)

• At most SDMP sites, inspections are documented and carried out in accordance with NRC Inspection Procedures 87104 and S8104. (iii)

Unsatisfactory (c)

• Inspections are not consistently being carried out in accordance with established frequencies. (i) e SDMP sites are not inspected at least once during decommissioning or e.t significant milestones, in addition to the cMseout inspection before license termination. (ii)

• Inspections are not consistently being documented and carried out in accordance with NRC Inspection Procedures 87104 and 88104. (iii) 1 Approvea: September 12,1995 66 (Revised: November 25,1997)

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Category N (d) i Special conditions exist that provide justification for withholding a i rating for one or more evaluation criteria.

Staff Qualifications (5)

Satisfactory (a)  ;

e Qualifications for license reviewers and inspectors are established and reviewed annually. (i)  !

• Nearly all staff men.bers are qualified to perform licensing reviews i and inspections related to decommissioning through training and i documented work experience. (ii) l e Nonqualified staff are subject to the direct supervision of qualified l managers; this supervision is evidenced by concurrence on inspation reports and licensing documentation. (iii) i Satisfactory With Recommendations for Improvement (b) e Qualifications for license reviewers and inspectors are established and reviewed every 2 to 3 years. (i)

• Most staff members are qualified to perform Iicensing reviews and inspections related to decommissioning through training and documented work experience. (ii) e Nonqualified staff are usually subject to the direct supervision of qualified managers; this supervision is evidenced by concurrence on inspection reports and licensing documentation. (iii)

Unr.atisfactory (c) e Qualifications for license reviewers and inspectors are not established or if established, these qualifications are not reviewed. (i) e The majority of staff is not qualified to perform licensing reviews and inspections related to decournissicning through training and documented work experience. (ii)

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Staff Qualifications (5) (continued) e Nonqualified staff a e not typically subject to direct supervision of qualified managers. (iii)

Category N (d) e Special conditions exist that provide justification for withholding a rating for one or more of the evaluation criteria.

SDMP Milestones (6)

Satisfactory (a)

• At nearly all SDMP sites, the decommissioning milestones summarized in the SDMP are being met or delays are identified and a mechanism is in place to ensure that any appropriate corrective actions are taken. (i) e Policy issues affecting decommissioning of SDMP sites are being identified. (ii) e Staff is updating the SDMP database in a timely manner. (iii)

Satisfcciory With Recommendations for Improvement (b) e For most SDMP sites, the decommissioning milestones summanzed in the SDMP are being met or delays are identhied and a mechanism is in place to ensure that any appropriate corrective actions are taken. (i) e Staff routinely identify policy issues affecting the decommissioning of SDMP sites in a timely manner. (ii) e Staff are updating the SDMP database for ruost sites in a timely manner. (iii)

Unsatisfactory (c)_

e The decommissioning milestones summarized in the SDMP are not routinely being met or delays are not being identified and a mechanism is not in place to ensure that any appropriate corrective actions are taken. (i)

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SDMP Milestones (6)(continued)

• Policy issues affecting the decommissioning of SDMP sites are not typically being identified in a timely maler. (ii) e Staff are not routinely updating the SDMP database in a timely manner. (iii)

Category N (d)

Special conditions exist that provide justification for withholding a rating for one or more evaluation criteria.

s i Approved: Septe.mber 12,1995

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Handbook 5.6 Part IV Part IV Programmatic Assessment General (A)

A management review board (MRB) will make the overall assessment of each NRC region's or Agreement State's progract, on the basis of the proposed final report and recommendations prepsred by the team that conducted the review of that region or State, including any unique circumstances. (1)

The MRB will consist of a group of senior NRC managers, or their designees, to include-(2)

• Deputy Executive Director for Regulatory Programs (a)

• Director, Office of Nuclear Material Safety and Safeguards (b)

• Director, Office of State Programs (c)

• Director, Office for Analysis and Evaluation of Operational Data (d)

General Counsel (e)

The Agreement States also will be invited to nominate a representative to participate in MRB meetings, as a non-voting Agreement State liaison. In this capacity, the State representative would have full authority to receive applicable documentation and engage in all MRB discussions except for any that might involve the Agreement State liaison's own State. The Agreement State liaison would not have voting authority; this function is reserved solely to NRC. (3)

For an NRC region, the MRB will only assess the adequacy of the program *o protect public health and safety. The nature of NRC findings regarding NRC's Agreement State review process is described below. (4)

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, 4 Findings for Agreement State Programs (s)

Finding 1-Adequate to Protect Public Health and Safety and Compatible (1) e If NRC finds that a State program has met all the Agreement State program review criteria or that only minor deficiencies exist, the Commission will find that the State's program is adequate to protect public health and safety. (a)

• If the NRC determines that a State program does not create conflicts, gaps, or disruptive duplication in the collective national effort to regulate Atomic Energy Act materials, the program would

. be found compatible. (b)

Finding 2-Adequate to Protect Public Health anc. Safety and Not Compatible (2) e If NRC finds that a State program has met all the Agreement State program ieview criteria or that only minor deficiencies edst, the Commission will find that the State's program is adequate to protect public health and safety. (a) 5

• If NRC determines that a State program creates unnecessary gaps, conflicts, or disruptive duplication in the collective national effort to regulate Atomic Energy Act mate;ials, the program would be found not compatible. (b)

Finding 3-Adequate, But Needs Improvement and Compatible (3) e If NRC finds that a State program protects public health and safety, but is deficient in meeting some of the review criteria, NRC may find that the State's program is adequate, but needs improvement.

NRC would consider, in its determination, which deficiencies the State has to address that were noted during the review. (a) e In cases where less significam State deficiencies previously identified have been uncorrected for a significant period of time, NRC also may find that the program is adequate, but needs improvement. (b) >

e If the NRC determines that a State program does not create conflicts, gaps, o- disruptive duplication in the collective national effort to regulate Atomic Energy Act materials, the program would be found compatible. (c)

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i Findings for Agreement State Programs (B)(continued)

Finding 4-Adequate, But Needs Improvement and Not Compatible (4)

• If NRC finds that a State program protects public health and safety, but is deficient in meeting some of the review criteria, NRC may find that the State's program is adequate, but needs improvement.

NRC would consider, in its determination, which deficiencies noted during the review that the State has to address. (a)

C e In cases where less significant State deficiencies pre iously identified have been uncorrected for a syificant period of time, NRC also may find that the program is adequate but in need of improvemeat. (b)

. If NRC determines that a State progtam creates unnecessary gaps, conflicts, or disruptive duplication in the collective national effort to regulate Atomic Energy Act materials, the program would be found not compatible. (c)

Finding 5-Inadequate to Protect Public Health and Safety and i Compatible (5)

• If NRC finos that a State program is significantly deficient in some or all the review criteria, NRCwould find that the State's program is inadequaic to protect public ht h and safety. (a)

. If the NRC determines that a State program does not create conflicts, gaps, or disn.ptive duplication in the collective national effort to regulate Atomic Energy Act materials, the program would be hund compt.tible. (b)

Finding 6-Inadequate to Protect Public Health and Safety and Not Compatible (6) e If NRC finds that a State program is significantly deficient in some or all the review criteria, NRC would find that the State's program is inadequate to protect public health and safety. (a) e if NRC determines that P. State program creates unnecessary gaps, conflicts, or disrupti ve duplication in the collective national effort to regulate Atomb Energy Act materials, the program would be found not compatible. (b) .

Findings for NRC Regional Programs (C)

The MRB fmdina,s for regional programs will be the same as those listed above for Agreement States with the exclusion of the findings for compatibility.  !

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Handbook 5<6 Glossary l

1 Glossary It is necessary to note that some Agreement States or NRC regions may not define these terms identically. In such cases, the review team will >

highlight any differences in its review, but draw its conclusions and make its assessments based on the definitions used by that State or region at the time of the review.

Allegation. A declaration, statement, or assertion of impropriety or inadequacy associated with regulated activities, the validity of which has not l'ecc established. This term includes all concerns identified by doe a such as the media, individuals, or organizations, and e.dmical audit efforts from Federal, State, or lo:al governnwm offices regarding activities at a licensee's site.

Excluded from this definition are matters being handled by more formal processes such as 10 CFR 2.206 petitions, hearing boards, appeal boards, and so forth.

Fuel Cycle Inspections. The definition of " Inspections" in 10 CFR 170.3 should be used to determine what constitutes a fuel cycle inspection. The term includes both reatinely scheduled and reactive inspections.

Incident. An event or condition that has the possibility of affecting public health and safety such as described in 10 CFR 20.2201 through 20.2204, 30.50, 34.25, 34.30, 35.33, 36.83, 39.77, 40.60, 70.50,71.97, or the equivalent State regulations.

Materials Inspection. The definitions in 10 CFR 170.3, and in NRC Inspection Manual, Chapter 2800, Sections 03.03 and 07.01, should be used to determine what constitutes an inspection. In addition, Agreement State hand-delivery of new licenses may constitute initial inspections. The term includes both routinely scheduled and reactive inspections.

Materials Licensing Action. Reviews of applications for new byproduct materials licenses, license amendments, renewals, and license terminations.

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[ Glossary (continued) l Overdue Inspections. Currently, NRC defines this term based on guidance in NRC Inspection Manual, Chapter 2800, especially Sections 04.03 (a), and 05.01 through 05.04. Many States use different definitions. For purposes of this directive, a materials license will be considered overdue for inspection in the following cases:

• A new licensee that possesses licensed material has not been inspected within 6 full months of receipt of licensed material, within 6 months of beginning licensed activities, or within 12 months of license issuance, whichever comes first.

• An existing core license is more than 25 percent beyond the interval defined in NRC Inspection Manual, Chapter 2800, Enclosure 1. An existing non core license is rnore than 1 year beyond the interval. (An inspection will not be considered overdue if the inspection frequency has been extended in accoraance with NRC Inspection Manual, Chapter 2800, Section 05.01, based on good licensee performance.)

e Overdue inspections will not be determined on the basis of any inspection frequencies established by States or regions that are more stringent than those contained in NRC Inspection Manual, Chapter 2800. The frequencies provided in NRC Inspection Manual, Chapter 2800, will generaJy be used as the yardstick for determining if an inspection is overdue.

Approved: September 12,1995 74 1 (Revised: November 25,1997)

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