ML20248E230
| ML20248E230 | |
| Person / Time | |
|---|---|
| Issue date: | 01/06/1998 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20248E220 | List: |
| References | |
| NUDOCS 9806030238 | |
| Download: ML20248E230 (28) | |
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION
'y REGloN I o,
c 475 ALLENDALE ROAD D
,o KING oF PRUSSIA, PENNSYLVANIA 194061415 January 6,1998 MEMORANDUM TO:
Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards FROM:
A. Randolph Blough, Director
.j g/
[A A Division of Nuclear Materials Safety, RI
SUBJECT:
INTEGRATED MATERIALS PERFORMANCE E ALUATI N PROGRAM QUESTIONNAIRE RESPONSE l
In response to your memorandum of November 26,1997 and in preparation for the onsite review during the week of January 26-30,1998, we have completed and enclosed the IMPEP questionnaire. An electronic version of the questionnaire (minus the attachments, is being sent concurrently crith this memorandum. We have also enclosed a current organizational chart for your use. We have made arrangements to provide the team with a dedicated conference room for the duration of their visit and look forward to the review.
Should you or your staff have questions in the interim, please feel free to contact us.
Attachments:
1.
IMPEP Questionnaire for Period March,1996 to January,1998 2.
Organizational Chart for DNMS cc w/ attachments:
l S. Moore, NMSS/IMNS l
CONTACT:
George Pangburn, DNMS (610)337-5283 l
9006030238 990513 PDR ORG NE ED PDR
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Approved by OMB' No. 3150-0183 Expires 4/30/98 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM QUESTIONNAIRE Region i Reporting Period: March 1996, to January 1998 A.
COMMON PERFORMANCE INDICATORS 1.
Status of Materials inspection Proaram 1.
Please prepare a table identifying the licenses with inspections that are overdue by more than 25% of the scheduled frequency set out in NRC Inspection Manual Chapter 2800. The list should include initial inspections that are overdue. is a copy of our most recent monthly report (December,1997) which indicates that we had three overdue core inspections at that time. Those licensees are listed below. In
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addition, although this indicator focuses only on core inspections, we have listed the names of the five overdue nen-core inspections from that report.
Insp. Frequency Licensee Name (Years)
Due Date Months O/D Core Licensees Howard 2
97/02 4
Georgetown 2
97/06 1
2 Estimated burden per response to comply with this voluntary collection request: 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />. Forward comments regarding burden estimate to the Information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0052), Office of Management 1
and Budget, Washington, DC 20503. NRC may not conduct or sponsor, and a person is not
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required to respond to, a collection of information unless it displays a currently valid OMB control number.
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NYState Univ.
2 97/04 2
Non-core Licensees Compu-scan 5
96/08 2
Kepane Lime Co.
5 96/08 2
Frederick R. Harris 5
96/06 4
Vollmer Associates 5
96/07 3
M.aguire Group 5
96/09 1
2.
Do you current!y have an action plan for completing overdue inspections? If so, please describe the plan or provide a written copy with your response to this questionnaire.
DNMS schedules inspections on a quarterly basis, before the beginning of each quarter. All core inspections.are scheduled in this manner, so that if there are no changes to the schedule, there will be no overdue inspections. Any core inspections that become overdue due to a change in the inspection schedule are brought to the attention of the appropriate Branch Chief on a monthly basis and are scheduled, taking into account resources and Division priorities. All overdue core inspections are scheduled to be completed during the first quarter of CY. Overdue non-core inspections will be scheduled and completed coincident with core inspections to maximize efficiency.
l 3.
Please identify individual licensees or groups of licentc r a the State / Region is inspecting more or less frequently than called for in NRC Inspection Manual Chapter 2800 and state the reason for the change.
DNMS inspects its licensees in accordance with the frequencies specified in IMC 2800, subject to the following adjustments: 1) licensees that are the subject of escalated enforcement are inspected on an increased frequency; 2) event response and allegations may result in inspections being done more frequently, depending on the safety significance of the event or allegation; and
- 3) licensee performance may result in changes to the frequency of inspections. Examples of licensees who have been designated for more frequent inspection as a result of one or more of the above factors include: VA-Philadelphia, Community Medical Center, Temple University Hospital, Grandview Hospital, Ambric Engineering, Penn State University, and Atlantic Testing Laboratories. Examples oflicensees whose inspection frequency has been extended based on good performance include: William B.
l Kessler Memorial Hospital, Cardiovascular Imaging, Ciba Specialty I
i l
Chemical Corporation, Rollins Environmental Services, and Applied Geoscience and Engineering. Decisions to modify individual inspection frequencies are made by individual inspectors and approved by the respective branch chief. Documentation of modifications to inspection frequency is placed in the appropriate docket file. A complete list of licensees whose frequencies have been changed on an individual basis is contained in Attachment 2.
In addition, DNMS implemented a special initiative to inspect all Region i sealed source and device manufacturers during the 4th quarter of CY97. Accordingly, these licensees may have been inspected at a more frequent interval than specified in IMC 2800.
q DNMS has also increased the frequency for inspection of gamma knife licensees from every 3 years as specified in IMC 2800 to annually, in accordance with NMSS direction and has increased the inspection frequency for veterinary programs, primarily those l
Involving treatment of cats with lodine-131, frorn 5 years to 2 years.
l Finally, DNMS performed special follow-up inspections on licensees l
whose licenses were suspended for non-payment of fees.
i 4.
Please complete the following table for licensees granted reciprocity during the reporting period.
j NO. OF LIC. GRANTED l
PRIORITY RECIPROCITY PERMITS NO. OF LIC. INSPECTED Year Total Year Total Service Licensees 1996 2
1996 2
performing teletherapy &
l irradiator source installations or changes 2
4 Program Code 03225 1997 1997 l
1 1996 6
1996 5
l Program Code 03320 (Field Radiography) 1997 7
1997 5
2 1996 0
1996 0
Program Code 03232
=
(Waste Disp-Prepack).
1997 2
1997 2
3
o NO. OF LIC. GRANTED PRIORITY RECIPROCITY PERMITS NO. OF LIC. INSPECTED 3
1996 5
1996 1
Program Code 03225 (Other Services) 1997 6
1997 1
4 1996 0
1996 0
Not Applicable 1997 0
1997 0
OTHER (5) 1996 11 1996 4
Program Code 03121 (Portable Gauges) 1997 9
1997 3
5.
Other than reciprocity licensees, how many field inspections of radiographer were performed?
DNMS performed 25 radiography inspections over the period of 2/96 to 12/97. Of those,14 included field inspections of radiographer.
6.
For NRC Regions, did you establish numerical goals for the number of inspections to be performed during this review period? If so, please describe your goals, the number of inspections actually performed, and the reasons for any differences between the goals and the actual number of inspections performed.
GOAL COMPLETIONS FY96 705 804 FY97 620 813 FY98 545 131 (as of December 1,1997) ll.
Technical Quality of Inspections 7.
What, if any, changes were made to your written inspection procedures during the reporting period?
DNMS conducts its inspection program in accordance with inspection procedures and guidance developed by NMSS, including revisions made during the reporting period. Draft inspection 4
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l procedure 87115 was utilized on a trial basis during the review period. In addition, IMC 0610 has been implemented for those inspections in which inspection reports are written.
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8.
Prepare a table showing the number and types of supervisory l
accomp ilments made during the review period. Include:
Inspector Supervisor License Cat.
Date DNMS lists supervisory accompaniments each month as part ofits monthly report submitted to NMSS. Inspectors are accompanied by their supervisor at least once per fiscal year and in some cases, more frequently. In addition, the Director and Deputy Director conduct selected accompaniments. Copies of relevant portions of the October 1996 and October 1997 reports are included in which list the accompaniments conducted by supervisors during the previous fiscal year.
9.
Describe intemal procedures for conducting supervisory accompaniments of inspectors in the field. If supervisory accompaniments were documented, please provide copies of the documentation for each accompaniment.
Regional Office Instruction 1010.3 continues to govern this activity.
No changes have been made since the previous IMPEP review.
10.
Describe or provide an update on your instrumentation and methods of calibration. Are all instruments properly calibrated at the present time?
Region I is currently sending portable radiation survey instrumentation to RSO, Inc. (MD), for calibration. RSO, Inc. is licensed by the Agreement State of Maryland for providing instrument calibration services. The dates for individual instrument calibration have been staggered so that small groups of instruments require calibration every several months. This assures an adequate supply of calibrated instruments at all times. All instruments available for inspector use are currently calibrated. Region I conducted an onsite audit of the contract with RSO at their MD location.
l The above mentioned activities are proceduralized in the Region i Radiation Survey instrumentation Control Policy. A continuously updated database of calibration status is maintained by the 5
Decommissioning and Laboratory Branch. Records related to the calibration program and inventories are maintained.
Ill.
Technical Staffino and Trainina 11.
Please provide a staffing plan, or complete a listing using the suggested format below, of the professional (technical) person-years of effort applied to the agreement or radioactive material program by individual. Include the name, position, and, for Agreement States, the fraction of time spent in the following areas: administration, materials licensing & compliance, emergency response, LLW, U-mills, other. If these regulatory responsibilities are divided between offices, the table should be consolidated to include all personnel contributing to the radioactive materials program. Include all vacancies and identify all senior personnel assigned to monitor work ofjunior personnel. If consultants were used to carry out the program's radioactive materials responsibilities, include their efforts. The table heading should be:
NAME POSITION AREA OF EFFORT FTE% contains a current (FY98) staffing plan for DNMS.
Since the last IMPEP review the Division has assumed regional responsibility for the inspection programs at power reactors undergoing decommissioning. The resources attendant to this responsibility are provided by NRR and are identified in the staffing plan.
12.
Please provide a listing of all new professional personnel hired since the last review, indicate the degree (s) they received, if applicable, and additional training and years of experience in health physics, or other disciplines,if appropriate.
Since the last IMPEP review, DNMS has hired only one new professional staff member. Mr. John Wray was hired in April 1997 into the Decommissioning and Laboratory Branch. He has degrees in Nuclear Engineering and Environmental Engineering, and many years of health physics experience. His outside work experience includes 5 years as a radiat'on protection engineer for Stone &
Webster,3 years as a corpo rate health physicist at Southern California Edison, and 10 years at Salem / Hope Creek as Radiation Protection Manager and corporate health physicist. He also has previous NRC experience as a senior radiation specialist in Region 11 6
for 5 years, and is a certified health physicist and registered professional engineer.
As stated above, DNMS was assigned the responsibility for mar. aging the inspection program for decommissioning of power reactors effective November 1997. Although not new hires, technical staff added to this effort include Craig Gordon, Joseph Nick, William Raymond, and Richard Rasmussen. Mr. Gordon was the regional state agreements officer and has also been a health physicist in NMSS. Mr. Nick was a radiation specialist in the Division of Reactor Safety and the lead radiation specialist for the decommissioning of the Yankee Rowe plant. Messrs. Raymond and Rasmussen are the senior resident inspectors at Haddam Neck and Maine Yankee, respectively.
13.
Please list all professional staff who have not yet met the qualification requirements of license reviewer / materials inspecti.on staff (for NRC, inspection Manual Chapters 1246; for Agreement States, please describe your qualf.ications requirements for materials license reviewers and inspectors). For each, list the courses or equivalent training / experience they need to attend and a tentative schedule for completion of these requirements. contains a summary, by Branch, of the status of qualification (both licensing and inspection) of the DNMS staff.
DNMS is unique among the Regions in that the technical staff of l
each branch of the organization conducts both licensing and inspection functions. The number of staff having full signature authority for licensing has increased from 12 at the time of the last l
lMPEP review to 14. Limited signature authority is possessed by 12 l
l additional staff. In addition, the number of fully qualified inspectors l
has increased from 28 to 33 since the time of the last IMPEP review i
(not including 3 fully qualified reactor inspectors).
1 l
The changes to IMC 1246 qualification requirements have been most pronounced in the area of required training for decommissioning inspectors. DNMS has arranged for Division of Waste Management staff to conduct onsite training for all technical staffin the
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decommissioning handbook in February 1998. Other courses of importance to meeting the qualification requirements for decommissioning inspectors v ithin the 3 year time frame of IMC i
1246 include Environmental Transport and Finance for Non-Financial professionals.
o 14.
Please identify the technical staff who left the RCP/ Regional DNMS program during this period.
During the review period the following individuals left NRC: Mark Bouwens, Mary Cahill, and JoAnn Stambaugh. Two other individuals-Jack McFadden and Kathy Modes-transferred out of the Division to other positions within the Region.
15.
List the vacant positions in each program, the length of time each position has been vacant, and a brief summary of efforts to fill the vacancy.
DNMS has no vacant positions at this time.
IV.
Technical Quality of Licensina Actions
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16.
Please identify any major, unusual, or complex licenses which were issued, received a major amendment, terminated, decommissioned, bankruptcy notification or renewed in this period. Also identify any new or l
amended licenses that now require emergency plans.
NIH (license renewal, including removal of authorization for
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incineration of RAM and decommissioning ofincinerators
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University of Pittsburgh (amendment to add a second gamma 1
knife unit)
Novartis (combination of two licenses)
Allegheny University (splitting out and rearranging of i
programs)
Branch Radiography (radiography equipment exemption request)
US Army-Fort Detrick (disposal of waste treatment plant l
sludge)
Permagrain (pool water conductivity)
Safety Light (updates of sealed source device registry sheets)
Smith Environmental Technologies Corporation (bankruptcy l
notice) i Pitt-DeMoines (radiography equipment exemption request )
Electric Boat (radiography equipment exemption request)
RTl (terminated and removed from the Site Decommissioning Management Plan [SDMP])
Aberdeen Proving Grounds (renewed and removed froin the
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SDMP)
Texas instruments (terminated and removed from the SDMP)
Westinghouse Waltz Mill (renewed and remains on the SDMP) 8 j
o Watertown Arsenal (terminated and removed from the SDMP, other parts of the site remain on the SDMP)
In addition, application of new broad scope licensing guidance to renewals of long-standing programs (Harvard, Rutgers, MIT, Penn State, and Allegheny University) required significant reviewer and supervisory time issuance of licenses for veterinary use of lodine-131 (Cardiopet and Radiocat) was also complex since we had to carefully consider the licensee's estimates of doses to the public and the appropriate policy on use of dose calibrators.
There were no changes in terms of licenses that require emergency plans except that two former DNMS licenses in Massachusetts that were required to have emergency plans (du Pont and du Pont Merck) are now the responsibility of the Commonwealth under the Agreement.
17.
Discuss any variances in licensing policies and procedures or exemptions from the regulations granted during the review period.
DNMS conducts licensing in very close accord with NMSS-estabilched licensing policies and procedures. Requests for exemp+ ions are cleared with HQ pursuant to the guidance contained in Policy and Guidan' ce Directive 1-26. Licensing reviewers consult with their Branch Chief for any unusual situations or cases requiring substantial interpretation of licensing policies.
18.
What, if any, changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) during the reporting period?
Beyond routine changes to licensing practices to reflect NMSS program direction, DNMS instituted a new policy directive in October 1997 to more clearly define the scope of administrative review necessary before final issuance of completed licensing actions. We are also working to convert existing licensing macros from WP 5.1 to WP 6.1.
19.
For NRC Regions, identify by licensee name, license number and type, any renewal applications that have been pending for one year or more.
A complete list of renewals pending for one year or more is contained in Attachment 1. Progress and anticipated future actions on these cases is discussed monthly as part of DNMS' management 9
i review of the licensing and inspection program and is provided to NMSS. In recognition of the direction provided by the Operating Plan to eliminate all such cases, DNMS is placing additional licensing emphasis on older cases during FY98.
V.
Responses to incidents and Allegations
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20.
Please provide a list of the reportable incidents (i.e., medical misadministration, overexposure, lost and abandoned sources, incidents requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less notification, etc. See Handbook on Nuclear Material Event Reporting in Agreement States for additional guidance.)
that occurred in the Region / State during the review period. For Agreement States, information included in previous submittals to NRC.need not be repeated (i.e., those submitted under OMB 3150-0178). The list should be in the following format:
The following is a list of reported incidents involving NRC licencees for which Preliminary Notifications (PN's) were issued during the review period. The complete PN's are available for review in DNMS for all these incidents LICENSEE NAME LICENSE #
DATE TYPE OF INCIDENT Nuclear Metals SMB-179 02/21/96 Fire Syncor inti.
37-18467-01MD 08/10/95 Contamination Lane Const.
06-06284-02 03/08/96 Stolen Gauge Allegheny Gen.
37-01317-04 03/08/96 Missing 1-125 seed Hosp.
DuPont Merck 20-28598-01 03/19/96 Contam. pkg.
Mallinkrodt 24-04205-16MD 03/26/96 Internal Contam.
Knight Consulting 44-19115-02 04/03/96 Damaged port.
gauge St. Francis Hosp. 06-00854-03 04/04/96 Ther. misadmin.
Pharmalogic 37-30219-01MD 04/18/96 Package dose j
rates J
Private Residence N/A 04/29/96 Uranium Vialin
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house Brigham &
20-17131-01 05/01/96 Ther. misadmin.
I Womens Hosp.
Berkshire Med.
20-12009-03 05/09/96 Ther, misadmin.
Ctr.
Med Coll of PA 37-00467-34 05/09/96 Missing 1-125 source 10
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h Nuclear Metals SMB-179 05/14/96 Ruptured wastewater pipe Mallinkrodt 24-04206-14 05/16/96 Contam. pckg.
Abington Hosp.
37-00432-02 05/15/96 Cs-137 source Bayley-Ellard HS 29-13030-01 05/16/96 Term irradiator lic Mallinkrodt 24-04205-1MD 05/20196 Contam. pckg.
Permagrain 37-17860-02 05/20/96 Hot cell fan malfunct.
Motorex 37-28461-01 06/20/96 Gen. Lic. gauge theft Medi-Physics 20-30176-01MD 06/20/96 Contam pckg.
Macklin Engin 37-20533-01 06/24/96 Damaged port.
gauge US Engineering 29-30107-01 06/27/96 Damaged port.
gauge Equimed 37-30086 41 12/31195 Possible ther.
1 misadmin.
Mount Holyoke 20-01677 4 2 08/05/96 Co-60 College contamination Yale-New Haven 06 00819-03 08/06/96 Lost 1-131 seeds Hospital U. of CT Health 06-13022-05 08/07/96 Ther. misadmin.
CW.
1 Technicut N/A 08/27/96 Loss of static elim.
l Dept of the Army 08-01317-02 08130/96 Missing RAM ABI Laboratories 37-30215-01 09/12/96 Stolen Port Gauge i
VA-Boston 20 00671-02 09/23/96 Pkg. dose rates Medi-Physics 37-27830-02MD 09/24/96 Shipping containers l
INS Corporation 20-03529-01 09/30/96 Nuc. Laundry l
Flood l
l EMR Photo-29-08636-02 10/17/96 Missing neutron Elec.
gen.
B&W Parks Twp. SNM-145 10/24/96 Contaminated equip.
Bayonne Hospital 29-12253-01 11/13/96 Potential HDR Misadm.
Mass Gen Hosp 20-03814-80 11/15/96 Fire in Res. Bldg.
Mercy Cath Med 37 00993-05 11/27/96 Contam package Ctr.
DuPont Merck 20-28598-01 12/02/96 Mo/ Tech Spill Amersham 20-12836-01 12/11/96 Missing Ir-192 shipment 11
a Lower Bucks SNM-1800 12/11/96 Lost pacemaker Hospital CIS-US 20-20973-01 12/18/96 Highway accident Amersham 20-12836-01 12/20/96 Missing Ir-192 l
source l
NIH 19-00296-10 12/23/96 Fire in laboratory EdgewaterApts 99990001 12/26/96 Stolen H-3 exit signs Altoona Hospital 37-11826 01 01/09/97 Poss.1-131 Misadms.
Geomechanics 37-17332-01 01/11/97 Damaged port.
gauge Hillis Carnes Engr 19-30304-01 01/14/97 Stolen Troxler gauge Centre Comm.
37-13681-01 01/15/97 HDR 'misadmin l
Hospital NIMCO Shredding 99990001 01/21/97 RAM in scrap t
NIH 19-00296-10 01/22/97 Lost 1-125 package i
Dept of the Army SUB-348 02/11/97 Missing DU ammo Monsour Med Ctr 37-14870-01 02/14/97 l-131 misadmin NIH 19-00296-10 02/19/97 l-131 misadmin Univ. of 37-00245-02 02/24/97 Damaged package Pittsburgh Doverspike Coal 37-28449-01 03/12/97 Cs-137 gauge Company found Frank Barker 29-28783-01 03/17/97 Package dose Assoc rates Hewlett Packard 07-28762-01 04/07/97 Loss of RAM Merck and Co.
29-00117-06 04/10/97 Loss ofI-131 Overlook Hospital 29-03308-01 05/06/97 l-131 misadm Private Residence 99990001 05/10/97 H-3 uptake from exit sign VA-Buffalo 31 00786-02 05/14/97 l-131 misadmin Larchmont 29-23540-01 05/15/97 Contaminated imaging package Mallinkrodt 24-04206-13MD 05/29/97 Contaminated package St. Elizabeth 29-04333-01 06/05/97 l-131 capsule in Hosp.
waste Washington 08-03604-01 06/06/97 Xenon release Hosp.
l DuPont 99990001 06/19/97 Missing RAM l
Abington Mem.
37-00432-02 06/24/97 Contaminated i
Hosp.
package 12
B&W-ParksTwp 06/26/97 Personnel Contam l
Ambric Engrg.
37-20968-01 07/10/97 Lost portable l
gauge source RSA Laboratories 06-30007-01 07/22/97 RAM in public domain Jeannette Mun.
99990008 08/08/97 Contaminated Auth.
municipal waste Koch Engr.
07-28386-01 08/28/97 Sealed sources at FedEx Defense Logistics 37-00062-01 08/28/97 Missing H-3 sources Royal Green N/A 09/02/97 Ruptured Am-241 Recycling source Allegheny Gen.
.09/18/97 Lost pacemaker Hosp.
Apgeo-Berthold 37-21226-01 09/15/97 Loss of RAM in gauge Temple University 37-00697-31 09/25/97.
Contam incident ALP Lighting 99990001 09/23/97 Missing RAM Geocore Environ. 29-30411-01 10/18/97 Stolen portable gauge Cabot Corp.
SMB-920 10/27/97 Leaking transport containers Arthur Brisbane 99990001 10/30/97 Broken H-3 exit sign US Customs Svc. 08-17447-01 11/06/97 Potential overexposure MQS inspection 12-00622-07 12/08/97 Radiography source disconnect Canberra ind.
06-15099-01 12/11/97 Sealed source in shipper's vehicle Sikorsky Aircraft 99990001 12/18/97 Lost or stolen RAM 21.
During this review period, did any incidents occur that involved equipment or source failure or approved ope ating procedures that were deficient? If so, how and when were other State /NRC licensees who might be affected notified? For States, was timely notification made to NRC? For Regions, was an appropriate and tirnely PN generated?
Ambric Engr.
37-20968-01 7/10/97 Lost source broken from Troxler gauge 13 i
Apgee Berthold 37-21226-01 9/15/97 Co40 source fell out of gauge when bolts failed to secure end plate Koch Engr.
07-28386-01 8/28197 Cs-137 sources lostin transit recovered at FedEx facility; damaged or inadequate DOT
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package l
MQS Inspection 12-00622 07 12/8/97 Source disconnect at temp jobsite in Rl; connector broken off guide wire l
St. Michael's Med. 29-06759-01 06/05/97 Deficient Ctr.
procedure for administration of l
1-131 capsules US Engineering 29-301007-01 6/27/96 Shielding damaged on Troxler gauge; run over by truck at work site.
In all above cases, notification was accomplished through DNMS development of PN.
t 22.
For incidents involving failure of equipment or sources, was information on f
the incident provided to the agency responsible for evaluation of the i
device for an assessment of possible generic design deficiency? Please provide details for each case.
NMSS and vendors were notified in each applicable case listed in the response to Question 21.
23.
In the period covered by this review, were there any cases involving possible wrongdoing that were reviewed or are presently undergoing review? If so, please desenbe the circumstances for each case.
DNMS routinely refers cases involving potential wrongdoing to the Office of Investigations (01) for resolution. Approximately 29 l
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materials cases were opened during the review period by the Office of Investigations Field Office in Region i during the review period.
DNMS will be pleased to discuss the specifics of any particular case with the IMPEP team during the onsite review, upon request.
24.
Identify any changes to your procedures for handling allegations that occurred during the period of this review.
a.
For Agreement States, please identify any allegations referred to your program by the NRC that have not been closed.
DNMS handles allegations in accordance with the direction contained in Management Directive 8.8 and Regional Office Instruction 1210, which was revised in September,1996 to comport with MD 8.8. During the review period DNMS provided additional resources to the Regional Administrator's office to assure timely closure of allegations. As a result, we made substantial progress in reducing the number of pending allegations and in improving our timeliness in closure of allegations. DNMS staff also received additional training in handling of allegations, which included sensitivity to allegers and granting of confidentiality. DNMS also instituted a self-assessment program in which Division management reviews two closed allegations per month to assure timely closeout of allegations in accordance with the documented Allegation Panel decisions.
VI.
General 25.
Please prepare a summary of the status of the State's or Region's actions taken in response to the comments and recommendations following the last review.
Region I responded to the three recommendations of the final 1996 IMPEP review in a memorandum of July 30,1996 from Thomas T.
Martin, Regional Administrator to Hugh L Thompson, Jr., Deputy Executive Director for Nuclear Materials Safety, Safeguards and Operations Support. Attachment 5 is a copy of that response. We conducted audits in late 1996 and 1997 on the follow up actions from the review and the status of those actions is listed below:
- 1. Initial inspections (which are treated as core inspections) are now scheduled and completed in accordance with the requirements of IMC 2800.
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- 2. Inspection field notes available in the docket room and on the LAN are up-to-date.
- 3. Documentation of reciprocity inspections is maintained in the Region.
26.
Provide a brief description of your program's strengths and weaknesses.
These strengths and weaknesses should be supported by examples of successes. problems or difficulties which occurred during this review period.
The nuclear materials safety program remains an exceptional area of overall strength in Region 1. Foremost among the Divisjon's strengths is its stable, talented, conscientious, and experienced staff, which has outstanding knowledge of the overall nuclear materials areas and excellent working relationships with the program offices. Sharing in those characteristics are our outstanding Branch Chiefs, who also bring strong lerdership and management skills and
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a positive "can do" approach to the routine functioning of DNMS.
The division has developed highly effective management information systems that are reviewed regularly by the division managers to ensure that programs are on target and that operating plan goals are being achieved. This has resulted in major reductions in the pending and backlog of licensing actions over the past several years, a minimal number of overdue inspections, and several sites being removed from the Site Decommissioning Management Plan.
DNMS inspections and licensing activities have led to significant benefits to nuclear safety. Our staff has often identified significant issues that had not been recognized by the licensee and which led to escalated enforcement. In addition, DNMS staff and management have been energetic in following up on issues to ensure that licensees effected appropriate corrective actions and performance improvements. Numerous examples of DNMS' impact are evident in the quarterly summary of significant accomplishments contained in NRC Region l Management information Status Report.
DNMS has also taken a leadership role in providing support to the program offices: in providing senior staff and management to the numerous guidance consolidation projects; in staffing the Part 35 and risk re-evaluation projects; and in providing experienced Branch Chiefs to the pilot program on external evaluation of the Department of Energy and to the review of candidates for the resident inspector candidate development program. DNMS also took the lead in 16
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developing the Lost Source Exercise, in concert with the Environmental Protection Agency. This multi-agency, multi-state exercise, in addition to being one of the few materials exercises conducted by NRC, was the first exercise designed to test the abilities of Federal agencies to operate under the Federal Radiological Emergency Response Plan.
Most importantly are the successes that DNMS has had in timely response to incidents and the proper handling of these health and safety matters. This has included NIH, MIT, the broken exit signs in New Jersey on two occasions, numerous misadministration, potential overexposure, and radiography incidents.
In addition, DNMS has a particularly robust program of self-assessments. In addition to reviews of completed licensing actions and inspections, the Division undertook self-assessments in the areas of allegations, financial assurance instruments, and license terminations. Copies of these assessments will be available to the l
lMPEP team upon request.
DNMS will continue to be challenged to provide promotional and growth opportunities to the staff. Even though most of the staff are highly qualified and have many years of experience in Region I, the availability of long-and short-term opportunities is limited, especially in light of current and projected FTE reductions.
Rotational assignments and involvement in program office provide some opportunities forjob enrichment, but only in the short-term.
Assumption of the reactor decommissioning inspection program is viewed as a welcome addition to the Division and could provide growth opportunities for the staff. Notwithstanding these factors, morale within the Division continues to be good and in large measure is reflective of the strong safety orientation, quality work, and sense of accomplishment among the staff.
B.
NON-COMMON PERFORMANCE INDICATORS 1.
Fuel Cvele inspections Status of Inspection Procram i
1.
List in chronological order the fuel cycle inspections (or assessments, in the case of non-licensee facilities) performed during the reporting period by facility and type (i.e. U= unannounced routine inspections, R = reactive 17 t
inspections, D= decommissioning inspections, etc.). Please include the inspection procedure number (e.g., IP 88020). A sample format is shown below.
Licensee Dates / Procedures Tyng Although there are no operating fuel facilities in Region I, DNMS continuallyinteracts with the Division of Fuel Cycle Safety and Safeguards (FCSS) through conference calls and counterpart meetings, and is aware of the inspection planning process. DNMS has three facilities that are of interest to FCSS; these are West Valley, Babcock & Wilcox, and Combustion Engineering. These do not fit the fuel cycle inspection procedures, but are nortetheless included here for completeness.
Babcock & Wilcox Date Tvoe/ Procedure December 1995-Jan Parks,SLDA: routine, announced inspection for 1996 decommissioning (84750)
AQ June 24-28,1996 Parks, SLDA: routine, announced inspection for j
independent measurements / confirmatory surveys (87100). Confirmatory surveys perfonned of a building licensee wanted to release for unrestricted use.
AQ August 5-6,1996 Parks: routine, announced inspection to collect samples, make independent measurements, and monitor activities by licensee to clean up contamination on riverbank (87100). Confirmatory survey of bank, including split samples.
AD October 21-25,1996 Parks: routine, announced inspection for decommissioning (87104). Collected additional riverbank samples and split with licensee.
AQ March 17-21,1997 Parks: routine, unannounced inspection for decommissioning (87104).
UD 18 r
1 1
Babcock & Wilcox July 9-11,1997 Parks: reactive, announced inspection to follow up on personnel contamination event (87103)
B i
December 8-12,1997 Parks: routine, unannounced inspection for decommissioning (87104) 1 g
West Valley November 18-22,1996 Routine announced monitoring visit (no procedure)
January 6-10,1997 Routine announced monitoring visit (no procedure)
March 3-7,1997 Routine announced monitoring visit (no procedure)
May 12-16,1997 Routine announced monitoring visit (no procedure)
June 30 July 2,1997 Routine announced monitoring visit (no procedure) l November 3-7,1997 Routine announced monitoring visit (no procedure) i Combustion Engineering May 6-9,1996 Routine, announced inspection of decontamination and decommissioning activities (83822,88035) l November 18-21,1996 Routine, announced inspection of decontamination l
and decommissioning activities (83822,88035)
April 14-17,1997 Announced confirmatory survey of Building 21 (88104)
November 18-20,1997 Routine, announced inspection of waste storage activities (83822,84900) 2.
Please identify any individual licensees with planned inspection frequencies different from the normal frequencies listed in Table 1 of the 19 I
Appendix to inspection Manual Chapter 2600, and indicate the inspection procedure (s) so affected.
Based on the response to Question 1, this question is not applicable to DNMS.
Technical Quality of Inspections 3.
With reference to the inspections described in item 1 above, please indicate the supervisory accompaniments made during the review period, and by whom. Also, briefly describe the way the accompaniments were conducted and documented.
The Chief, Decommissioning and Laboratory Branch, Ronald Bellamy, accompanied James Kottan to Combustion Engineering in April 1997 and Todd Jackson to B&W Parks Township in January 1996. As noted above, these accompaniments ivere conducted in accordance with Regional Office Instruction 1010.3.
Technical Staffina and Trainino 4.
Please list the professional (technical) personnel assigned to perform inspections in the fuel cycle facilities inspection program, and the fractional amount of person-years of effort to which they are normally committed in the program. Also, include the generalinspection areas of responsibility (e.g., E= environmental protection, N= nuclear criticality, O=
operations, P= physical security, R= radiation protection, T= other). For those who joined the program since the last review, and any others who have not yet met the qualification requirements of fuel cycle facility inspection staff, please indicate when they joined the staff, the degrees they received, the years of experience in the general areas they inspect (e.g., health physics, engineering, etc.), and the extent to which they are qualified as NRC inspectors. A sample format is shown below.
The project manager and inspector for Combustion Engineering remains Mr. Kottan. The project manager and inspector for West Valley and Babcock & Wilcox is Mr. Todd Jackson. The inspection qualification criteria for fuel cycle inspectors do not apply to them.
Mr. Kottan generally performs 2 inspections a year at Combustion Engineering. Mr. Jackson performs 3 monitoring visits a year to West Valley and 4 inspections a year at Babcock & Wilcox.
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r a
I 5.
Please identify any professional or technical staff who left the fuel facility inspection program during the review period, and if possible, describe the reasons for their departures.
Describe what plans and procedures are in place to assure full coverage of the specified fuel cycle inspection procedures, as specified in Inspection Manual Chapter 2600, in view of the possible impacts of retirements and other tumover on a small inspection staff. Also, please describe the extent to which current fuel cycle inspection program goals have been achieved, and the reasons for any differences between the goals and the actual implementation of your program as the result of such personnel issues.
Mr. Joseph Furia no longer does monitoring visits at West Valley; l
however, he remains in Region I as a radiation specialist in the Division of Reactor Safety.
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11.
SDMP Proaram 1
6.
What is the status of meeting the milestones in SECY-96-207 for the SDMP listed sites? Were any significant delays identified and corrective actions put in place in a timely manner? Are policy issues being resolved in a timely manner?
The status of the milestones in SECY 207 for the SDMP sites managed by Region Iis as follows:
l e Aberdeen Proving Grounds - site removed from the SDMP in April
(
1997, license renewed e RTl - site removed from the SDMP in April 1997, license terminated e Heritage Minerals - Delays encountered due to difficulties in
(
licensee obtaining a contractor to prepare a final status survey plan.
1 This is now resolved, and a plan was received November 1997.
Licensee expects to be ready for license termination in August 1998.
e Nuclear Metals, Inc -license has been renewed and transferred to Massachusetts e Permagrain - on schedule, Decommissioning Plan received 21 I
- Passes /METCOA - March 1997 remediation date delayed to October 1997 due to finalization of EPA consent order. Active remediation ongoing.
- Safety Light - milestones met. Contractor has performed site characterization; licensee is entering into discussions with a contractor for preparation of a site remediation plan. DNMS/ ORA continues to work with DOJ and EPA regarding use of insurance proceeds for previous cleanup expenditures. Settlement agreement payments are up-to4at e. License expires in December 1999; close coordination between DNMS and NMSS will be needed on policy issues related to renewal.
e Schott Glass - the November 1996 public meeting was delayed, and will be held February 1998 as a final step before license termination. The delay was identified as due to additional remediation efforts being required; and !s not considered significant.
e Texas Instruments - the license was terminated and removed from the SDMP in February 1997.
- Watertown Arsenal / Mall-Arsenal removed from the SDMP in May 1997; Mall property remains for further characterization.
- Westinghouse Waltz Mill - Decommissioning Plan submitted on schedule and under review.
No delays are considered significant, and there are no outstanding policy issues.
Ill.
Uranium Recoverv Prooram 7.
Please include information on the following questions in Section A, as they apply to the Uranium Recovery Program:
Status of Materials inspection Program-A.I.1-3, A.I. 6.
Technical Staffing and Training-A. Ill.12-15.
Technical Quality of Licensing Actions-A. IV.19.
Responses to incidents and Allegations-A. V. 20-23.
Region I has no uranium recovery licensees.
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._ q IV.
General 8.
Provide a summary of actual expenditures and accomplishments as compared to operating plan / budgeted expenditures and accomplishments for FY 98 to date. Discuss reprogramming changes or diversions of resources foritems unbudgeted.
The following table summarizes FYlP7 operating plan budgeted resources and actual expenditures. DNMS believes this provides a more complete picture than FY98 expenditures would provide at this pointin the fiscal year.
PROGRAM FY97 BUDGET FY97 EXPENDITURES 1 Materials Licensing 8.6 8.7 Materials inspection 9.9 13.7 Event Evaluation 3.8 5.9 Program Initiatives
- 2.9 0.7 Fuel Cycle Inspection 1.1 0.4 I
LLW inspection 0.0 0.0 Matis. Decomm. Insp.
5.6 5.2 Uranium Rec. Insp.
0.0 0.0 React Decomm. Insp.
0.3 0.1 Spent Fuel Stor. Insp.
94 0E TOTAL 34.0 34.7
- Includes regional initiatives, IMPEP, GLA registration program, Part 35, Regulatory Product Development activities, risk assessment, and regulatory guidance activities.
9.
Provide any comments and recommendations regarding the effectiveness of Headquarters support to regional activities and the Region / Headquarters interface. Identify any regional interaction with Headquarters and licensees to improve the quality of your licensing / inspection program.
In general, NMSS support to DNMS is excellent, especially in the area of communications. Routine vehicles, such as biweekly Division Directors calls, monthly IMNS conference calls, and monthly i
decommissioning conference calls are examples. DNMS supports the proposal to hold a Branch Chief /Section Leader counterpart l
meeting in mid-1998 and believes this will further enhance communication. DNMS also appreciated the superb support provided by IMNS to our Regional training seminar held in October, 23 i
e 1997. In addition, NMSS provided excellent support to the collegial meetings held to discuss possible NIH enforcement actions and the quick response to a request from George Washington University Medical Center for a compassionate exemption from the Part 35 patient release criteria. NMSS has greatly improved responses to Technical Assistance Requests (TAR's) and this has helped DNMS resolve several difficult older licensing cases. However, timeliness of TAR responses, particularly those that involve Sealed Source and Device reviews, continues to be a concern to the Region. Providing generic guidance for such things as wrong site misadministration and patient intervention could help reduce the number of TAR's and thereby improve timeliness. Another approach could be to delegate the decision-making and review of TAR's to the HQ Section Leader level.
Improved operational computer systems and management information systems would help provide inform,ation to HQ that could and should be available through centralized management 3
information systems. This questionnaire is one example, and guidance consolidation project outputs are another. Even though significant improvements in guidance are likely to come out of the guidance consolidation project, a commitment to making the information easily usable on-line would be helpful. Another area that warrants attention is the role of the headquarters SDMP project managers and interface with regional staff. An internal instruction that outlines the respective responsibilities of the NMSS PM and the regional inspector would be extremely useful in assuring smooth regulatory review of licensee decommissioning activities.
10, in which areas of licensing and inspection guidance do you need the most training? Please provide a list by priority, highest first.
- 1) Decommissioning handbook training; 2) generic inspection guidance on patient intervention and wrong site misadministration;
- 3) inspection and enforcement guidance on security and control of RAM issues; 4) guidance on the licensing and inspection of new medical modalities, such as intravascular stints, new uses of HDR and the gamma knife; 5) training on human use research/ informed consent /FDA issues. In terms of formal course offerings required by IMC 1246, the most pressing needs are for Health Physics Topical Review, Environmental Transport and Finance for Non-Financial Professionals.
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a V.
Decommissioning 11.
Identify all licensees that initiated decommissioning during the review period (do not include those licensees that were terminated during the review period, as DWM will use the LTS to compile this information).
i l
Schott Glass Heritage Minerals Watertown - GSA Ronson Metals USArmy it. Monmouth Evans Area Mobil Corporation Tenneco Chemicals Nuclear Laundry Rental Services USArmy Westwood Atlantic Metals 12.
List the decommissioning inspections that were carried out during the review period. Please indicate if the inspection schedules required by Manual Chap 2602 were prepared for licensed facilities undergoing decommissioning and if this schedule was developed, indicate inspections that are overdue by more than 25% of the inspection due date. Indicate which inspections revealed that licensees were not conducting their decommissioning in accordance with the approved decommissioning plan and describe how these projects were managed.
Inspection schedules are generated on a quarterly basis for decommissioning activities, and were performed on schedule. When failures to follow the decommissioning plan were identified, corrective action was requested from the licensee, and received.
The following decommissioning inspections were conducted during the review period.
Tenneco Chemicals Ludwig Honold AT&T Clark Nuclear Laundry Rental Services Curtiss Wright Molycorp Mobil Corporation USArmy Westwood Atlantic Metals Ronson Metals Norton Co.
i 1
25 1
I
=
r Schott Glass Heritage Minerals 13.
Identify all licenses (both terminated and otherwise) that have received in-process inspections of licensees' final survey programs and confirmatory surveys, in accordance with IP 87104 and IP 88104, during the review period. Describe the inspection activities covered during inspections of these licensees.
Combustion Engineering i
l Schott Glass Ronson Metals Norton Co.
USArmy Westwood Mobil Corporation AT&T Clark Tenneco Chemicals Molycorp Texas instruments Pesses/METCOA Westinghouse Waltz Mill Forest Hills Cheswick Blairsville Engelhard Industries These inspections were designed to review licensee performance as the decommissioning progressed, and not wait until the licensee
{
submitted a fina! status survey. Activities included physical i
observations, video recording of activities, use of specialists from other engineering disciplines, independent measurements, and interviews with licensee staff and contractors.
14.
List all appropriate staff who have not yet met the qualification requirements of Decommissioning Inspector as identified in Manual Chapter 1246. List the courses or equivalent training / experience they need to attend and a tentative schedule for completing these requirements.
See response to Question 13 in Section A on Staff Qualification.
26
a 15.
Identify by name, license number and type all licensees with outstanding decommissioning financial assurance reviews. Describe the outstanding issue and the plans to resolve the issue.
None. -December 1997 DNMS Monthly Report l
' -List of inspection Frequencies Extended or Reduced -List of Inspector Accompaniments in FY96 and FY97
( -DNMS Staffing Plan
' -Response to 1996 IMPEP Review l
l 27 l
9 ATTACHMENT 1 DECEMBER 1997 MONTHLY REPORT 1
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