ML24047A249
| ML24047A249 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/2024 |
| From: | Huda Akhavannik NRC/NMSS/DMSST |
| To: | |
| References | |
| Download: ML24047A249 (1) | |
Text
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 us esthe 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 elementsas described in this section of the a pplication.
Section 4.6.1 describes the organization of the program andprovide s a staffing analysis to indicate the organization will be sufficient to maintain the a greement s tate program. Section 4.6.2 describes the staff qualification plan, and Section 4.6.3 describes the qualifications of the current staff. The r elevant procedure, RCP-903.1, Qualification and Trainingis attached.
1 Section 4.6 4.6.1 Technical Staff Organization
SA-700 4.6.1.1 As described in Section 4.1.2, the RMP reside s 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(RDD), the Radiation Division Office Director(RDOD),
an Environmental Analyst III(EA3), the Supervising Radiation Control Physicist (SRCP), and four Radiation Control Physicists (RCP). 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 arerealized. 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.
2 Section 4.6 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 RDDserves the role of managing the training and qualification program. The RDD joins the RDOD, an EA3, the SRCP, and four RCPs to make up the RMP. These staff will become qualified inspectors and license reviewers following the guidance of RCP-903.1, Qualification and Trainingand 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 Handbook for Processing an Agreement. The first form is the Staff Needs Analysis Table 4.6.1-1. The form has been modified to reflect the types of license programs the State will regulate. The values in the table are based on the types and numbers of licensees at the time of this application. The second form is the Staff Resource Analysis, Table 4.6.1-2. This 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 2020was 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
4 Section 4.6 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, including email, telephone,and letter correspondence between the R MP 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 s taff 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 R MP procedure RCP-900.1,Review of an Initial Application for a License or an Amendment Request,Attachment 6.
Based on conservative assumptions, Connecticuts licensing and inspection activities will require 400staff days for licensingand487 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 129days to inspection and 106days per year to licensingactivities per year. Mrs. Verderame and Mr.
Strickland each can devote 103 days to inspections and 85days to licensing activities per year.
Ms. Perry and Mr. Alford can each devote 45days to inspections per year and 37days 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 423for licensing.
These allocations of time are considered reasonable. T here are 235workdays per year including holidays, vacations, and weekends. Mr. Graber will be 100% devoted to the R MP, while Mrs.
Verderame and Mr. Stricklandcan 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% respectivelyof their time. Using these percentagesand the standard work year of 235 days, the RMP staff may provide as many as 940workdays to a program requiring 895workdays. These calculations are estimates, but indicate a sufficient margin exists with the Department staffing levels. Additionally, the State discussed staffing with Vermont due to similarities in program size. D iscussions with Vermont suggested that Vermonts estimate for their staffing is similar to those determinedby 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 8staff members and the RDD 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 of the Radia tion 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 t wo qualified inspectors and license review ers.
5 Section 4.6 Table 4.6.1-1 Staff Needs Analysis*
License Category No. of Licensing Staff Licensing Inspections Staff days/ Inspection Licenses actions/yr days/ staff days per year inspection staff days action Industrial 3 0.3 6.3 2.1 3 8.7 27 Radiography Industrial Measuring Systems, 27 3.3 3.7 12.4 5.4 17.31 94 Irradiators - Self Shielded Broad Scope 7 4.7 12.0 56.1 2.5 19.7 50 Non-Medical Nuclear 1 0.3 0.1 0.04 0.5 4.7 3 Pharmacy Medical 31 9.7 3.6 34.9 9.9 13.7 136 Mobile Therapy, High Dose Rate 16 28.3 4.1 116 8 12 96 Remote Afterloader Medical - Broad 2 3.7 3.6 13.1 1 8.6 9 Scope Research and Development, Veterinary, 19 9.7 16.0 154.5 3.8 10.7 41 Manufacturing and Unsealed SNM Distribution 6 1.7 2.4 4 1 4.7 6 Sealed Special 3 1.0 2.3 2.3 1 2.9 3 Nuclear Material Service -
Decontamination, 5 1.0 4.2 4.2 1.3 17.1 22 Instrument Calibration GL Devices**
TOTAL 120 63.7 19.5 399.7 37.4 120.11 487
- This table is modified from SA -700 Appendix B to reflect the categoriesof licenses in Connecticut. Similar license c ategories have been combined.
- This is the number of devices located in Connecticut, not licenses.
6 Section 4.6 Table 4.6.1-2
Staff Resource Analysis (in Days)*
Staff Member B. Graber K. Verderame D. Strickland S. Perry C. Alford M. Firsick K. Davies J. Semancik Insp Lic Insp Lic Insp Lic Insp Lic Insp Lic Insp Lic Insp Lic Insp Lic License Category Industrial Radiography 7 1 6 1 6 1 3 0 3 0 3 0 1 0 1 0 Industrial Measuring Systems, Irradiators 25 3 20 3 20 3 9 1 9 1 10 1 5 1 2 0
- Self Shielded 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 25 30 20 24 20 24 9 11 9 11 10 12 5 6 3 3 Afterloader Medical - Broad Scope 2 4 2 3 2 3 1 1 1 1 1 1 0 1 0 0 Research and Development, Veterinary, 11 40 9 32 9 32 4 14 4 14 4 16 2 8 1 4 Manufacturing and Unsealed SNM Distribution 2 1 1 1 1 1 1 0 1 0 1 1 0 0 0 0
Sealed Special Nuclear Material 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 Service - Decontamination, Instrument 6 1 5 1 5 1 2 0 2 0 2 1 1 0 1 0 Calibration, Other TOTAL 129 106 103 85 103 85 45 37 45 37 52 42 26 21 13 11
- This table is modified from SA-700 Appendix B to reflect the categories of licenses in Connecticut. Similar license categories have been combined.
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 27 29 2.1 3
Industrial Measuring Systems, Irradiators - Self 94 100 12.4 13 Shielded Broad Scope Non-Medical 50 53 56.1 59
Nuclear Pharmacy 3 3 0.04 1
Medical 136 145 34.9 36 Mobile Therapy, High Dose Rate Remote 96 102 116 121 Afterloader Medical - Broad Scope 9 10 13.1 14
Research and Development, Veterinary, 41 44 154.5 161 Manufacturing and Unsealed SNM Distribution 6 6 4 5
Sealed Special Nuclear Material 3 3 2.3 3 Service - Decontamination, Instrument 22 23 4.2 5 Calibration, Other GL Devices*
Total 487 517 399.7 423
- This table is modified from SA-700 Appendix B to reflect the categories of licenses in Connecticut. Similar license categories have been combined.
- This is the number of devices located in Connecticut, not licenses.
SA-700 4.6.1.2 The State has modified the forms from Appendix B of the SA -700 Handbook to reflect the types of licenses in the State. The types of licenseslisted in the table are a mix of license programs that the State 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 Departmentsestimated workload for each staff member is accepted based on organization, policies, practices, and procedures the State 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 t he 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 RDDwill take all steps available to replace staff that either leaveor retire from the Department working in the RMP. One element of this is technical training and the qualifications of other Radiation 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 (Compact) on radiological health protection. By statute in each of the six states in the Compact, assistance is to be provided when a Compact s tate requests it. Assistance from a Compact state can be, and has been in the past, provided to augment a requesting Compact s tates 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 Connectic ut 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, lif e 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 addresse s 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 currenttechnical staff are described in this s ection of the application.
Current technical staff qualifications are substantiated by having:
- 1. Completed all 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 for two weeks with qualified NRC License Reviewers performing licensing actions at the NRC Region 1 Offices in King of Prussia, Pennsylvania;
- 4. Reviewed the NRC regulations, policies, plans and procedures being incorporated into Connecticuts application to become an a greement s tate; and
- 5. Engaged for more than three years writing, reviewing and revising RMPPs, regulations and other components of Connecticuts a pplication to become an agreement s tate.
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, Resumes.
SA-700 4.6.3.2 All current technical staff have met the RMPs qualification requirements as listed above. The Radiation Division Director has submitted a Letter of Current Staff Qualification demonstrating the current technical staff has met the qualifications required for the State to becoming an agreement state. A table providing formal training and on-the job training based f rom staffs RCP-903.1 Qualifications Journal has been provided. Resumes of each qualified staff has been provided also.
10 Section 4.6