ML20237H992

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Responds to 870421 Memo Requesting All Regions to Review Draft Insp Procedure 89100, Use of Performance Indicators to Identify Licensees for Enhanced Insp/Attention. Concept of Performance Indicators Supported
ML20237H992
Person / Time
Issue date: 06/11/1987
From: Hind J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Sjoblom G
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20237H486 List:
References
FOIA-87-402 NUDOCS 8708170450
Download: ML20237H992 (2)


Text

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UNITED ' 8TATES

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[ k NUCLEAR REGULATORY COMMISSION l )

" " REOlON til i ig 799 ROOGEVELT RO AD

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GLEN ELLYN, ILLINOtt 60137

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5 MEMORANDUM FOR: Glen L. Sjoblom, Deputy' Director, Division of Fuel Cycle, 1 Medical,. Academic and Commercial Use Safety, MMSS l FROM: Jack A. Hind, Director, Divisen of Radiation Safety and Safeguards, Region III

SUBJECT:

DRAFT INSPECTION PRCCEDURE 89100, 'USE OF PERFORMANCE INDICATORS TO IDENTIFY LICENSEES FOP (NHANCED ' INSPECTION /

ATTENTION" j

This is in response to your memorandur. dated April 21, 1987, requesting all- J regions to review Draft Inspection Procedure 89100. : legion Ill fully supports l I

the conce program copy(ptattached) of performance indicators e - the materials or staff.

inspection " redThe flags" andcfhas purpose that-initiatedj program is to gather da9 u the various indicators and.to determine 1 appropriate thresholds nr which NRC actions are necessary.- Nothing in this program would pre-empt our enforcement policy or practices. The concept would

]y be to identify and correct problems ~before they' lead to' incidents or escalated' -)

enforcement actions.

! With regards to the fuel facility' performance indirators provided by Region II, )

we feel that additional work-is necessary. We suggest that
  • representatives-from each region meet to-discuss the items-proposed by Region 11 and any other I proposals to determine if performance indicators can.be identified that are  ;

less sub$ active.

With regards to the performance indicators for materials licensees, we feel that the items described in the Draft Inspection Procedure are, appropriate but l should be expanded to include the following -

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  • allegations which have been substantiated and have safety significance; j
  • insufficient staffing for licensed program workload;
  • financial instability of licensee; I
  • 1ack of senior management involvement in licensed activities; -l 1

' excessive number of repeat violations; ^

.* excessive number of 10 CFR Part 20 reportable events.

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B708170450 870012 l PDR FDIA POTTERS 7402 - PDR  :

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Glen L. Sjoblom 2 l

In addition to the above we feel that the following items need  !

clarification / incorporation into the Inspection Procedure.

1. The Regional Project Manager is defined in Section 03.03, yet is not i i

mentioned anywhere else in the body of the Inspection Procedure. This persons' responsibilities should be described in greater detail and incorporated into the body as a specific requirement. Also, this concept needs to be incorporated into our budget process. i

! 2. The Inspection Procedure should incorporate measures other than counseling that regions can tcke once a potential problem is fVentified.

This may include, but not be limited to Orders, adding license conditions which may incorporate _ requirements in the license, and requesting licensee comitments to improve perfomance. Thess measures were successful

'i at Region III where it was identified.that licensees were.  !

deficient'in therapy Q.A. programs (Christ Hospital, Henry F6rd Wuspital, j

Washington University).

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We will periodically keep you informed of the progress of our i trial program and notify you of any si~nificant g findings that may arise fram . j the progrrm. d 1

(

ack A. Hind. Director  ;

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Division of Radiation Safety l l and Safeguards

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Attachment:

As stated cc:w/attachmert j

'i R. W. Cooper, Regional Coordinator, EDO T. T. Martin, RI J. P. Stohr, RII L R. L. Eengart, RIV t

! R. A. Scarano, RV li l

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