ML20236G410
| ML20236G410 | |
| Person / Time | |
|---|---|
| Issue date: | 10/28/1987 |
| From: | Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sjoblom G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8711020526 | |
| Download: ML20236G410 (8) | |
Text
-
on6
.r r
3 y
i
.00T 2 8 1987 l
I
. MEMORANDUM FOR: Glen L.-Sjoblom, Deputy Director, Division of Industrial j
and Medical Nuclear Safety, NMSS-FROM:
Jack A. Hind, Director, Division of Radiation Safety and
- Safeguards,~ Region III
SUBJECT:
RESULTS OF TRIAL PROGRAM FOR MATERIALS PERFORMANCE INDICATORS-CONDUCTED BY REGION III We have completed the subject trial program as discussed in my June 11, 1987 memorandum and theLresults are presented in Attachment I to this memorandum.
We consider the trial. program a success and' recommend its use by the other regions. The use of. performance indicators should also be incorporated in the materials licensing process since licensing reviewers through their review of-j files, conversations with licensees, and site visits also have an opportunity to identify the potential for degraded performance.
In fact, the reviewers on occasion, may be knowledgeable of potential problems prior to the inspection staff. Region III is currently in the process of developing a list of
' indicators (Attachment 2) which may be used by_ license reviewers. We are also developing a plan'to perform joint inspection and licensing reviews for
. facilities due for renewal utilizing the performance indicator concept.
.If you have any questions, please contact Dr. Bruce Mallett or Mr. Roy Caniano
-j of my staff.
l tk (fi ha.Y
/J ek A. Hind, Director
/ Division Radiation Safety i
and Safeguards Attachments: As stated 1
cc w/ attachments:
R. W._ Cooper, ED0 I
T. T. Martin, RI 8711020526 871028 R. P. Stohr, RII REG 3 LIC30
-R. L. Bangart, RIV PDR.
R. A. Scarano; RV
(
)
i \\l 750 V 1
ATTACHMENT 1 TRIAL PROGRAM FOR MATERIALS PERFORMANCE INDICATORS.
I Objective:
To test the ability to identify a' potential for degraded licensee performance by the use of a set of predetermined performance' indicators.
l II.
Scope:
For the period June 15 through September 30, 1987, each j
materials inspector included a review of the performance I
indicators in his/her routine inspection effort. A total of 98 materials licensees from medical, industrial, and radiographic programs were evaluated by the use of a checklist of performance indicators (copy attached).
Upon completion of each checklist, the appropriate Materials Section Chief reviewed the data, discussed the results with the inspector, if necessary,'and then i
determined any further action to be taken.
III. Result's l
The inspectors identified a total of 23 positive performance indicators
{
or " red flags" encompassing thirteen (13) licensees. The thirteen (13) licensees, identified as having the potential for degraded performance, are listed, along with the " red flags" identified and further action l
taken by Region III.
1.
Licensee: Radiography Facility Indicators Present:
i a.
RSO unable to perform his/her d' uties due to other unrelated l
tasks assigned to him/her.
l b.
Excessive missed surveillance.
c.
Lack of senior management involvement in licensed program, d.
Inadequate consulting services, e.
Numerous 10 CFR Part 20 reportable events.
Regional Action Taken:
a.
Telephone conversation between licensee and Section Chief.
l b.
Management control paragraph added to transmittal letter.
c.
Management meeting held with licensee at Region III.
d.
Reduction in inspection frequency.
2.
Licensee: Medical Facility Indicator Present:
RS0 unable to perform his/her duties due to i
other unrelated tasks assigned to him/her.
)
Regional Action Taken:
Inspector addressed concern to licensee i
management at the conclusion of the inspection.
Subsequently, the licensee sent in an amendment request to Region III requesting l
the addition of more personnel to their program.
i
u.
~
3.
Licensee: Medical Facility.
Indicators Present:
1.
Lack of senior managemmt involvement in licensed activities, i
2.
Inadequate consulting services.
Regional Action Taken:
Inspector addressed-concerns to licensee
~
management at the conclusion of the inspection.
Subsequently the e
licensee sent in an amendment request to Region III requesting the addition.of more personne1 to their program to assist management in oversight of the~ program.
4.
Licensee: Medical Facility -
Indicators Present:
- a.. RSO unable to perform his/her duties due to other nonrelated i
tasks assigned to him/her.
b.
Licensee does not have sufficient technologist, authorized user,_
or radiation staffing for licensed program workload.
Regional Action Taken:
a.
Area of concern paragraph added to transmittal letter.
- b.. Reduction in inspection frequency.
5.
Licensee: Medical Facility Indicators Present:
a.
Lack of senior management involvement in licensed activities.
b.
Inadequate consulting services.
Regional Action Taken:
a.
Telephone conversation between licensee and Section Chief.
4 b.
Area of_ concern paragraph added to transmittal letter.
i c.
Reduction in inspection frequency.
6.
Licensee: Medical Facility Indicators Present:
a.
RSO unable to perform his/her duties due to other unrelated tasks assigned to him/her.
b.
Lack of senior management involvement in licensed activities.
Regional Action Taken:
a.
Area of concern paragraph added to transmittal letter.
b.
Reduction in inspection frequency.
i 7.
Licensee:
Industrial Facility Indicator Present:
Financial instability of licensee.
Regional Action Taken: Reduction in inspection frequency.
y dt g
- j.
-g
,,5",
8.
Licensee:' Industrial Facility ~
~
In'dicators Present:
a.
RSO unable.to perform his/her duties due to other unrelated.
. tasks assigned-to him/her.
b Licensee does not'have. sufficient technologist / authorized user / radiation staffing for. licensed program workload..
i
-. Regional' Action Taken: -Inspector addressed concern to licensee -
management at the conclusion of the' inspection.
Subsequently, the licensee sent in.an amendment request to Region III requesting.
the addition of more personnel to their. program.:
9.-
Licensee:
Industrial Facility Indicator Present:' RS0 unable to perform his/her duties due to other unrelated; tasks assigned to him/her.
~
Regional' Action Taken: Area of concern a$ dressed to licensee which resulted in-an amendment request being submitted to Region III. requesting the addition of more personnel to their -
program.
10.- Licensee: ~ Industrial Facility Indicator Present:
Lack of senior management involvement in licensed activities.
- Regional Action Taken
a.
Area'of concern addressed to licensee.
-b.
' Reduction in inspection frequency.
.]
ll. Licensee: _ Industrial Facility 1
' Indicators Present:
1 a.
Licensee-does not have sufficient technologists / authorized users / radiation staffing.for licensed program workload.
b.
Financial instability of licensee.
Regional-Action Taken:
a.
Area of concern addressed to licensee.
- b.. Reduction in inspection frequency.
- 12. Licensee:
Industrial Facili.ty Indicator Present: Lack of ' senior management involvement in
. licensed activities.
o 4
' Regional Action Taken:
a.
Area of concern addressed to licensee.
b.
Reduction in' inspection frequency.
- 13. Licensee: Industrial Facility Indicator Present: RSO unable to perform his/her duties due to other work-related tasks assigned to him/her.
1 Regional Action Taken:
a '. Management control paragraph added to transmittal letter to licensee.
j b.
Reduction in inspection frequency.
f f.
~.( '
~l? ?
g;
, 4,1_
e yIV.
Conclusion:
The performance' indicators /were valui6le in' determining the.
,N
. potential for degraded licensee performance. Thef Aave;anabled Region.III to' correct' situations that could have led to healthiand safety problems-at
' thirteen (13) licensees. The future performance of,the 13 lic<nsees will be followed closely. The performance indicators used in the tria1 program t
are a: good starting point to utilize in developing a formal' procedure for 1'-
the materials staff.. '
s 1
9 i
t t
6
,)
I J
.)
'I
,e It
'I J
Ii g
l t
,j e
ll
,l cv
-)
/
\\
t i
l Y
I.
i l
._ k '
. _ - -,,a
[ :2]. f, A h' n ;
p-r,7 3
'b
{.f Ly)
_ js, aqr
{ *,
5_.
y
- yp v'
tr:
_ #, ; Q' ?
?
e '
A J/
r o,
PossiMe Perfonnance Indicators for License Reviewers 1.
RSO unable to perform his oEher duties due to other unrelated tasks assigned to him or her.
<u
' 2.
Licenseefdoes'not have sufficient technologist / authorized users / radiation staffing lforycensedprogramworkload.
3.
Numerousf safety rvlated allegations which have Men subs [antiated.
4.
.S gnificant numb'er of misadministration reported.
e 5.
ENcessive number of repeat. violations.
6.
Numerous 10 CFR Part 20 reportable events.
7.
' Excessive turnover of licensee sddff, increased number of amendment requests, or frequent changes in licensee ownership.,
If it is: determined during a: lice _nse review that any of the above indicators n
an present, the following actionKmay be taken.
1..
Addition of speciaf conditions.
2.
Performance of a special inspection.
3.
Reduction in inspection frequency.
4.
Address concerns with. licensee management.
5.
Removal of Broad Scope authority..
6.
Denialordelayj!,suanceofthelicense, r
g t
i h
I 1
m
.c e
1 l
kkg i?
l G '.
.\\
- \\
I. : O l
e l:.I i
3,
v
y, "f O
(,l[(
n V$l';
l W
A l
., 3 Q
<1 1
Trial Program for Materials Performance Indicators (Effec;1ve from June.15 - September 30, 1987) y,
.;3 Failure of Radiation Safety.Connittee (or certain key {se 1.
or discuss meaningful issues.
( ) M 3( PM
) NfQ j
l q
-[I 2.
RSO unable to perform his or her dutifs, due to other, unrelatedta'sks assigned to hini or her.
(
)Yes
( )g
(
)tg@
~
q Licenstis dces not have sufficient technologist /adh'orized user / radiation 3.
1 staffing for -licensed program workload.
(
) Leg ; ( 1) M
(
) N/A s
e
't 4
,J
[2
, u/'l.,
humerois customer corplaints reaardina manufcciurers or distributors l
(19) {q
(
) No
(
) N/A Numeroussafety-relatedallegationswhichhavepee]nsEbstantiated.
5.
.( ) Yes
( )g g(
)N/A I
Significant 0mberofdiagnosticmisadministratins 6.
3
(
)Yes
(
),P /
(
)N/A 3
7.
F.adiation exposures approaching 10 CFR Part 20 limits. "(
)_Yes
(
) ~No. '1'
(
)NjA
/ 4, B.
Frequentorexcessivecontaminationwithinrestrictedareas(greattNtkan
~
10 x NF.SS guidance for release to unrestricted areas).
(
).N/A
(
)Yes
([)No i
s
?
9.
Excentve ohised surveillance (leak testing, inventories, survey 4 etc.,
- greatdr,tMn 50% per year).
(
)_Yes
(
)g' -(N1) sg l '
y r
+
k 5
s,
- 10. ;[inanc sal instability of licensee (shoe-string cperation' ' or.e in two-men operation psuch that cost of cleanup is significant to coatinued~ operations
/ofthefacility).
(
). _Yes
(
) M
'(
)N/A
~,i 1Y.: Lack of senior managemeSt involvement in licensed activities.
(
)_Yes
(
) do_
(
)N/A 4
12.
Inade does]quateconsultinoservices(consultantnot,ffodingsproblemsbutNRC
.j )(,J.)Yes ( )M
(
)N/A p/-
)~
,_ n 13.. Pediation Safety Comittee give " rubber star.yuepprovals" to users and/or uscs of licenst:d materials a issues! permits for indefinite periods of time.
(
) Y335,
(
) pg 1,(
)N/A i
j
(,"4
/
,7 s
1 p
\\
l
-~
3 2
l l
l
- 14. Excessive number of repeat violations (three or more).
(- ) Yes
\\
l
(
)No
(
)N/A
- 15. Numerous 10 CFR 20.402, 20.403, and 20.405 reportable events.
(
)_Yes
(
) Eo
(.) N/A Inspector (s) Concents / Suggestions:
l l
l l
)
Inspector (s) Signature:
Date:
Action Required as deemed'by Region 111 management (telephone contact, licensee management meeting, reduced inspection frequency):
j i
I Action Taken:
l 1
I Section Chief Signature:
Date:
2 4
)
- - - - - _-