ML24319A229
| ML24319A229 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/2024 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| Download: ML24319A229 (1) | |
Text
1 Section 4.6 4.6 Technical Staffing and Training This section addresses the technical staffing requirements and training program the Department will utilize for agreement state staff. The Department uses the NRC Inspection Manual Chapter 1248 Formal Qualifications Program for Federal and State Materials and Environmental Management Programs as a model for technical staffing and for training program elements as described in this section of the application.
Section 4.6.1 describes the organization of the program and provides a staffing analysis to indicate the organization will be sufficient to maintain the agreement state program. Section 4.6.2 describes the staff qualification plan, and Section 4.6.3 describes the qualifications of the current staff. The relevant procedure, RCP-903.1, Qualification and Training is attached.
2 Section 4.6 4.6.1 Technical Staff Organization SA-700 4.6.1.1 As described in Section 4.1.2, the RMP resides within the Radiation Division in the Bureau of Air Management of the Connecticut Department of Energy and Environmental Protection (Department). The current staff responsible for the agreement state work in the RMP are shown in the organization chart for the Radiation Division, Figure 7. The staff implementing the RMP include the Radiation Division Director (the Director), an Office Director (OD), an Environmental Analyst III (EA3), the Supervising Radiation Control Physicist (Supervisor), and four Radiation Control Physicists (Physicists). Other staff members are available to support the program and can be trained to provide defense-in-depth, if needed. While current staffing levels are sufficient to run the program, the Department has budgeted for additional staffing including a supervisory position as funding from license fees are realized. The RMP will also have support from various offices and bureaus within the Department as well as various State agencies regarding legal support, emergency preparedness, law enforcement, prevention, and recovery efforts.
Figure 7 Radiation Division Organizational Chart
3 Section 4.6 The primary document describing the qualifications and training of RMP staff is RCP-903.1, Qualifications and Training. In this procedure, various roles are described. The Director serves the role of managing the training and qualification program. The Director joins the OD, an EA3, the Supervisor, and four Physicists to make up the RMP. These staff will become qualified inspectors and license reviewers following the guidance of RCP-903.1, Qualification and Training and are tracked in RCP-903.1 Attachment 1, Qualifications Journal. The RCP-903.1 and Qualifications Journal are in Section 4.6.2 below.
Staff Needs Analysis An analysis was performed using the forms from the NRC SA-700 Handbook for Processing an Agreement. The Staff Needs Analysis form, Table 4.6.1-1, has been modified to reflect the types of license programs Connecticut will regulate. The values in the table are based on the types and numbers of licensees at the time of this application. The Staff Resource Analysis, Table 4.6.1-2 indicates the time in days available for each of the individuals who may conduct inspections and license review activities. The final form, Table 4.6.1-3, shows the difference between the amount of staff time needed and available. It indicates that for the radioactive material licensees in Connecticut, there is more than a sufficient amount of staff time available. Each of the categories of inspections in the tables include security inspections.
To estimate the time necessary to complete licensing and inspection activities, a review of all Connecticut license activity for 2018 through 2020 was conducted. More recent data was not utilized because of the potential underrepresentation of time during the COVID-19 global pandemic. Currently there are approximately one hundred twenty specific radioactive materials licenses in the state of Connecticut broken down by license type as follows:
License Type (January 2024 data)
Quantity Academic Broad Scope 3
Medical Broad Scope 2
Medical 47 Nuclear Pharmacy 1
Veterinary 4
Measuring Systems 26 Radionuclide Production Using Accelerator 2
Manufacturer and/or Distribution 12 Industrial Radiography 3
Service Providers 5
Self-Shielded Irradiator 1
Research and Development Broad Scope 2
Research and Development 9
Special Nuclear Material less than critical mass 3
Total 120 The time allotted for individual licensing actions is based on a three-year analysis with the assumption that a typical licensing effort will encompass an average of three days to complete,
4 Section 4.6 including email, telephone, and letter correspondence between the RMP staff member and the applicant/licensee. This estimate includes program management and administrative functions.
The inspection program estimates also include time for inspection preparation, travel, inspection report generation and supervisory accompaniments. The RMP staff will follow the NRCs materials program inspection frequencies as indicated in Enclosure 1 of NRC Inspection Manual 2800. This enclosure is used to describe the inspection priority codes assigned to program codes in the RMP procedure RCP-900.1, Review of an Initial Application for a License or an Amendment Request, Attachment 6.
Based on conservative assumptions, including licensing action and inspection activities to support incident and allegation responses, decommissioning, and general licenses, Connecticuts licensing and inspection activities will require 350 staff days for licensing and 426 staff days for inspections each year (the totals in the fifth and eighth columns in Table 4.6.1-1). Mr. Graber can devote a minimum of 129 days to inspection and 106 days per year to licensing activities per year. Mrs. Verderame and Mr. Strickland each can devote 103 days to inspections and 85 days to licensing activities per year. Ms. Perry and Mr. Alford can each devote 45 days to inspections per year and 37 days to licensing per year. Mr. Semancik, Mr. Firsick and Ms. Davies can devote 13, 52, and 26 days respectively to inspections and 11, 42, and 21 days respectively to licensing activities per year. The total number of days per year for inspection and licensing from the RMP staff comes to 517 for inspections and 423 for licensing.
These allocations of time are considered reasonable. There are 235 workdays per year including holidays, vacations, and weekends. (One FTE is equivalent to 235 workdays or 1880 hours0.0218 days <br />0.522 hours <br />0.00311 weeks <br />7.1534e-4 months <br />.) Mr.
Graber will be 100% devoted to the RMP, while Mrs. Verderame and Mr. Strickland can each devote 80% of their time to agreement state work. Ms. Perry and Mr. Alford will each devote 35% of their time. Mr. Semancik, Mr. Firsick and Ms. Davies will devote 10%, 40% and 20%
respectively of their time. Using these percentages and the standard work year of 235 days, the RMP staff may provide as many as 940 workdays to a program requiring 776 workdays. These calculations are estimates, but indicate a sufficient margin exists with the Department staffing levels. Additionally, Connecticut discussed staffing with Vermont due to similarities in program size. Discussions with Vermont suggested that Vermonts estimate for their staffing is similar to those determined by Connecticut.
A guide for the suggested number of technical staff members is also provided in the Handbook for Processing an Agreement: Agreement States typically employ 1 to 1.5 technical staff members per 100 active licenses. The number of licenses varies from year-to-year, especially with reciprocity, but has historically numbered less than 150. The RMP with 8 staff members and the Director qualifying as Inspectors and License Reviewers meets this guidance. The Handbook also states that the staff must consist of at least two technical staff. Three additional staff members in the Division have commenced taking NRC Agreement State courses to provide professional knowledge and defense in depth the RMP. The Department will always strive to maintain at least two qualified inspectors and license reviewers.
5 Section 4.6 Table 4.6.1-1 Staff Needs Analysis*
License Category No. of Licenses Licensing actions/yr Staff days/
action Licensing staff days Inspections per year Staff days/
inspection Inspection staff days Industrial Radiography 3
0.3 5.5 1.8 3.00 7.63 23 Industrial Measuring
- Systems, Irradiators - Self Shielded 27 3.3 3.3 10.9 5.40 15.13 82 Broad Scope Non-Medical 7
4.7 10.5 49.1 2.53 17.25 44 Nuclear Pharmacy 1
0.3 0.1 0.03 0.50 4.13 3
Medical 31 9.7 3.2 30.6 9.87 12.00 119 Mobile Therapy, High Dose Rate Remote Afterloader 16 28.3 3.6 102 8.00 10.50 84 Medical - Broad Scope 2
3.7 3.1 11.4 1.00 7.50 8
Research and Development, Veterinary, Manufacturing, and Unsealed SNM 19 9.7 14.0 135.2 3.80 9.38 36 Distribution 6
1.7 2.1 4
1.20 4.13 5
Sealed Special Nuclear Material 3
1 2.0 2.0 1.00 2.50 3
Service -
Decontamination, Instrument Calibration 5
1 3.7 3.7 1.27 15.00 19 TOTAL 120 63.7 51.1 349.8 37.57 105.13 426 This table is modified from SA-700 Appendix B to reflect the categories of licenses in Connecticut. Similar license categories have been combined.
6 Section 4.6 Table 4.6.1-2 Staff Resource Analysis (in Days)*
- This table is modified from SA-700 Appendix B to reflect the categories of licenses in Connecticut. Similar license categories have been combined.
Staff Member B. Graber K. Verderame D. Strickland S. Perry C. Alford M. Firsick K. Davies J. Semancik License Category Insp Lic Insp Lic Insp Lic Insp Lic Insp Lic Insp Lic Insp Lic Insp Lic Industrial Radiography 7
1 6
0 6
0 2
0 2
0 3
0 1
0 1
0 Industrial Measuring Systems, Irradiators
- Self Shielded 25 3
20 3
20 3
9 1
9 1
10 1
5 1
2 0
Broad Scope Non-Medical 13 15 11 12 11 12 5
5 5
5 5
6 3
3 1
1 Nuclear Pharmacy 1
0 1
0 1
0 0
0 0
0 0
0 0
0 0
0 Medical 36 9
29 7
29 7
13 3
13 3
15 4
7 2
4 1
Mobile Therapy, High Dose Rate Remote Afterloader 25 31 20 25 20 25 9
11 9
11 10 12 5
6 3
3 Medical - Broad Scope 2
3 2
3 2
3 1
1 1
1 1
1 0
1 0
0 Research and Development, Veterinary, Manufacturing and Unsealed SNM 11 41 9
33 9
33 4
14 4
14 4
16 2
8 1
4 Distribution 2
1 1
1 1
1 1
0 1
0 1
0 0
0 0
0 Sealed Special Nuclear Material 1
1 1
0 1
0 0
0 0
0 0
0 0
0 0
0 Service - Decontamination, Instrument Calibration, Other 6
1 5
1 5
1 2
0 2
0 2
0 1
0 1
0 TOTAL 129 106 103 85 103 85 45 37 45 37 52 42 26 21 13 11
7 Section 4.6 Table 4.6.1-3 Staff Balance Analysis*
Inspection staff days Licensing staff days License Category Needed Available Needed Available Industrial Radiography 23 28 1.8 2
Industrial Measuring Systems, Irradiators - Self Shielded 82 100 10.9 13 Broad Scope Non-Medical 44 53 49.1 59 Nuclear Pharmacy 3
4 0.03 1
Medical 119 144 30.6 37 Mobile Therapy, High Dose Rate Remote Afterloader 84 102 102 123 Medical - Broad Scope 8
10 11.4 14 Research and Development, Veterinary, Manufacturing and Unsealed SNM 36 44 135.2 163 Distribution 5
6 4
4 Sealed Special Nuclear Material 3
4 2.0 2
Service - Decontamination, Instrument Calibration, Other 19 23 3.7 4
Total 426 517 349.8 423 This table is modified from SA-700 Appendix B to reflect the categories of licenses in Connecticut. Similar license categories have been combined.
SA-700 4.6.1.2 Connecticut has modified the forms from Appendix B of the SA-700 Handbook to reflect the types of licenses in the state. The types of licenses listed in the table are a mix of license programs that Connecticut will regulate. The Department has staffed the program with enough qualified personnel based on the analysis provide. The Department will have 8 qualified personnel (5 fully qualified, 3 partially qualified including the Director) which is more than adequate of the needed technical staff required for inspections and license review. The Departments estimated workload for each staff member is accepted based on organization, policies, practices, and procedures Connecticut has adopted.
8 Section 4.6 4.6.2 Formal Qualification Program SA-700 4.6.2.1 The qualification program is described in RCP 903.1, Qualification and Training. The procedure is attached to this section of the application. Individual accomplishment of the qualification process is documented in that persons qualification journal. In general, individuals are trained to conduct inspections and to do license review activities through training classes and on-the-job training. Individuals maintain proficiency through on-going training that enhances licensing and inspection professional abilities. These are described in RCP 903.1, Qualification and Training, attached in this section of the application. Individual completion of the qualification components are documented in that persons Qualification Journal.
The processes described in RCP-903.1 are for future staff. The qualifications of current technical staff are described in section 4.6.3 of this application. The Director will take all steps available to replace staff that either leave or retire from the Department working in the RMP. One element of this is technical training and the qualifications of other Division staff. This will be undertaken after the current staff members assigned to the RMP are qualified.
Connecticut is a statutory member of the New England Radiological Health Conference (NERHC) which maintains the New England Compact (the Compact) on radiological health protection. By statute in each of the six states in the Compact, assistance is to be provided when a Compact state requests it. Assistance from a Compact state can be, and has been in the past, provided to augment a requesting Compact states staff when there is a temporary vacancy. This could be used by Connecticut should such a vacancy occur and strain the states RMP licensing and inspection work completion capabilities. A copy of the Compact is found in Section 4.1 of this application. The enabling legislation in the State, which is identical to that in the other five New England states, is statutory and found in the Connecticut General Statutes (CGS), Chapter 446a Section 22a-159, New England Compact on Radiological Health Protection. This is also included in Section 4.1 of this application.
SA-700 4.6.2.2 Each technical staff position meets the requirements of a bachelors degree in the physical, life science or engineering; or an equivalent combination of education and experience has been substituted for the degree. The Department has submitted RCP-903.1 as a written qualification plan. The procedure also addresses job specific training and experience that can be substituted for educational requirements.
9 Section 4.6 4.6.3 Qualification of Current Technical Staff SA-700 4.6.3.1 The qualifications of the current technical staff are described in this section of the application.
Current technical staff qualifications are substantiated by having:
- 1. Completed the required initial Agreement State Training as described in Radioactive Materials Program Procedure (RMPP) RCP-903.1 Qualification and Training;
- 2. Accompanied NRC Inspectors conducting inspections of Connecticut licensees;
- 3. Worked with qualified NRC License Reviewers performing licensing actions;
- 4. Reviewed the NRC regulations, policies, plans and procedures being incorporated into Connecticuts application to become an agreement state; and
- 5. Engaged for more than three years writing, reviewing and revising RMPPs, regulations and other components of Connecticuts application to become an agreement state.
Documentation of these qualifications for the individuals listed above is found in Appendix 4.6.3-1, Letter of Current Staff Qualification, Appendix 4.6.3-2, Current Staff Qualifications, and Appendix 4.6.3-3, Resumés.
Once the individuals listed above have completed their initial qualification, the individuals will maintain their qualifications by completing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of refresher training in a requalification schedule of 24 months. The beginning of each requalification cycle will be determined using the month and year the inspector completed their initial qualification.
SA-700 4.6.3.2 All current technical staff have met the RMPs qualification requirements as listed above. The Director has submitted a Letter of Current Staff Qualification demonstrating the current technical staff has met the qualifications required for Connecticut to becoming an agreement state. A table providing formal training and on-the job training based on staffs RCP-903.1 Qualifications Journals has been provided. Resumes of each qualified staff are provided.