ML20055C218
| ML20055C218 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/1988 |
| From: | Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 8810100263 | |
| Download: ML20055C218 (21) | |
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'o UNITED STATES NUCLEAR REGULATORY COMMISSION n
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WASHINGTON, D. C. 20555 SEP 23 1988 MEMORANDUM FOR:
A. Bert Davis Regional Administrator, Region III FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
NATIONAL PROGRAM REVIEW REPORT Enclosed is the National Program Review report for Region III. The report encompasses all regional activities within the NMSS program areas for the period from April 1,1987 through March 31, 1988 with emphasis on where the regional programs stood at the end of FY87, and where they stood when NMSS made its staff visits to Region III this spring.
A draft of this report was sent to Region III for coment on June 20, 1988.
The comments provided in your July 6,1988 response have been incorporated in this report.
In response to one of your comments, we do intend to re-format this report next year.
The new format should reduce the overlapping areas and repetitiveness of the report.
To clarify one of the Region III coments, the labor rate for materials inspections
(.013) includes time for inspecting against low-level waste (Part 61) requirements.
The labor rate is, in fact, slightly higher than historical data collected from past Region III expenditures.
To sumarize our findings, Region III deserves recognition for its recent significant reduction in the number of licensing cases pending.
The region issues materials inspection reports very promptly and has an efficient inspection scheduling system.
The safeguards inspection effort is also well planned and coordinated.
Region III's pilot performance evaluation factors program is now being used as the model for all Regions.
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Both NMSS and Region III neeo to continue to monitor the age of the backlogged cases, particularly. renewals, and review the success of recent modifications to the allegation system in the Region.
7 N
88Iotoo.26 h M ain.
s A. Bert Davis _
I am not satisfied with the timeliness of this year's National Program Review process and I intend to reduce the delay between completion of the visits and issuance of the draft reports.
In the coming year, I intend to complete the draft report within 30 days, issue it for your review and comments, and produce a final report within 30 days after receipt of your comments.
Please let us know if there are other ways that we can continue to improve the National Program Review process.
@tgned) Robert IdL Smwo i
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards 1
Enclosure:
As stated cc:
V. Stello J. Taylor DISTRIBUTION:
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GGardes SBahadur MKnapp AGrella RBurnett SEE PREVIOUS CONCURRENCE
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REPORT OF THE 1988 NATIONAL PROGRAM REVIEW 0F DECENTRALIZED NMSS ACTIVITIES AT REGION III 1.
INTRODUCTION The purpose of this annual report is to document the National Program Review of decentralized NMSS licensing and inspection programs at Region III. As the responsible program office for non-reactor activities, NMSS continuously reviews regional programs to assure that the Regions are conducting their activities in a technically sound, consistent, timely, and efficient fashion. This report covers the period from April 1,1987 through March 31, 1988, with discussion of where the regional programs stood at the end of FY87, as appropriate.
The National Program Review is designed to facilitate a two-way flow of information (technical support, guidance, suggestions, evaluations, etc.)
in a non-adversarial environment conducive to quality operations in all five regions and Headquarters. Additional information on the process
' can be found in the NMSS National Program Review Manual dated December 11, 1987.
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2 2.
FUEL CYCLE AND NUCLEAR MATERIALS PROGRAMS 2.1 Materials Licensing The Headquarters staff reviewed about 20% of completed licensing cases. Based on these reviews and continuous interfaces with the Region on various technical issues, we conclude that the licensing is clearly technically adequate and consistent, with no shortcomings related to public health and safety.
Licensing actions are performed in accordance with applicable Standard Review Plans, and are generally of high quality with few technical or clerical errors. Section and branch level management play an active role in licensing matters. For actions that have policy implications or are not clearly dealt with in Standard Review Plans, the staff seeks guidance from cognizant headquarters personnel. The staff has made recommendations for topics that require policy or technical guidance.
Region III has the heaviest workload and the lowest labor rate budgeted
. for materials licensing of any region. Notwithstanding this fact, RIII completed 2110 materials licensing actions in FY87 compared to a baseline projection of 1946 cases. This represents 108% of the baseline Operating Plan projection, the best of all regions. Due to major events such as response to problems at the Wright-Patterson Air Force Base, case completions dropped in late 1987. However, the Region developed a " recovery plan," and as of March 1988, 1219 licensing reviews were completed, compared to an adjusted projection of 893(137%).
This effort has reduced the backlog of cases pending.from over 700 (in Oct. 87) to under 500 (in March 88).
Region III made judicious use of overtime to achieve these goals.
3 With respect to licensing turnaround times FY87 new applications took an average of 55 days to complete. Amendments took an average of 57 days. Similar actions are taking slightly longer in FY88. Renewals are normally being handled on a first-in, first-out basis. However, there are several old, difficult renewals pending.
Region III played a key role in coordinating Headquarters and regional response to the 3M incident. On January 22, 1988, Ashland Chemical Company (ACC), of Easton, Pennsylvania, notified NRC's Region I office that alpha contamination was detected at their facility. Region I correctly notified both Headquarters L;;d Region III because the static elimination device was distributed to ACC under a Region III license issued to 3M. Region III sent an inspection team to 3M on January 25, 1988, and uncovered facts that eventually lead to several orders halting the distribution and use of the 3M static elimination device. Region III i
has continued to take the lead in coordinating information exchanges between NRC, the Agreement States, and 3M.
2.2 Materials Inspections The NMSS staff has evaluated implementation of guidance provided in NRC Manual Chapters and procedures applicable for the materials inspection program; discussions with Regional staff throughout the year; the results of the regional assessment visit on March 30-31, 1988; regional inspection reports; notices of violation and NRC Fonn 591's; the Licening Management System (LMS) and the 766 system summary listing of inspection efforts on the relevant inspection modules; and the results of one inspection accompaniment.
The Region completed 1,113 materials inspections for FY87, and 347 inspections through March 31, 1988.
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4 During the inspection accompaniment, it was observed that NRC Inspection Procedure 57100 was followed, as well as guidance given in NRC Manual Chapter 2800.
Inspections were thorough and missionary work was provided for licensees with weak programs.
Violations were clearly explained.
Entrance and exit interviews were conducted properly and results of the inspections were clearly comunicated to the appropriate licensee management level.
Based on the accompaniment and a review of inspection reports, Region III appears to be properly implementing guidance on the conduct and reporting of inspections.
Inspectors and section chiefs participate in the assignment of cases.
i Region III has an efficient centralized inspection scheduling system managed by the inspection management assistant.
Such a system is necessary due to Region III's geographic distribution of licensees, and provides appropriate allocation of resources.
Inspections are also scheduled for special events, in response to allegations, and in response to categorical events (e.g., Wright-Patterson precipitated increased AF inspections).
Region III is to be comended for initiating an audit of reports involving Severity Level IV and V violations, and implementing a program to improve inspection reports.
The average turnaround time on inspection reports is very fast:
19 days. This is a remarkable accomplishment in light of heavy workload, including special cases such as the Hines Veterans Administration allegation and extensive assistance to the Office of Investigations on that matter. Management oversight of inspection schedules is outstanding. There were very few overdue inspections and management had good explanations for why they had not yet been completed.
The regional staff also makes good use of telephone contacts to reach low-hazard licensees who are not inspected frequently.
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Training for all inspectors was up to date in accordance with Manual Chapter 1245.
Some concern was expressed by inspectors that allegations were taking too long to resolve.
Region III management instituted a program to speed up the process.
i 2.3 _ Fuel Cycle Facility Inspection This evaluation by NMSS of Region III's fuel cycle facility inspection program is based on review of inspection reports, an inspection accompaniment, communications with the Region staff and the National Program Review team visit to the Region III offices.
Inspections are carried out in a manner consistent with applicable guidance.
Appropriate inspection specialists have supported the fuel facility inspector; inspectors were provided adequate opportunity to become acquainted with the facility's documents prior to the inspection.
Inspection reports have been technically adequate and accurate, and of consistently high quality. Documentation of actions is clear and complete. The reports have been issued on average within the 20-day
. goal.
It appears that Region III accomplished the required fuel cycle facility inspections in FY87, but with less than the projected amount of FTE.
In the first part of FY88, resource expenditures were lagging behind projections.
2.4 _ Fuel Cycle and Materials Safety Initiatives Region III aggressively pursues improvements in the materials area.
In particular, they are to be connended for the following initiatives:
Upgrading liaison and telephone communications with each fuel o
facility;
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Completion of a pilot program on perfonnance evaluation criteria
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which will serve as a model for Headquarters and all five Regions; o
Various efforts to improve staff technical training; o
Hosting a wortshop for broad licensees; Initiating an audit of inspection reports involving Severity IV o
and V violations; o
Pursuing contracts with additional medical consultants; o
Developing improved field notes for teletherapy inspections; Improving emergency preparedness modules for fuel cycle inspections; o
- and, Developing a centralized inspection scheduling system.
o 2.5 Recommendations for Action Region III should continue its program to speed up resolution of o
allegations.
The Region III staff suggested that the LMS should be made more o
efficient to cut costs, Region III should continue its missionary work when appropriate o
and continue to provide effective communication with licensees.
7 2.6 Headquarters / Regional Interaction o
The Region has been quick to respond to Headquarters action requests.
Communications with the Region have been generally excellent.
o Headquarters needs to review labor rates for inspection and casework.
(Thisactionhasnowbeencompleted.)
Headquarters and Regions need to continue to work together to o
improve training opportunities (and to support such opportunities with resources).
RIII new budget initiatives were well-developed and will be pursued o
during the budget cycle, particulary recommendations pertaining to the sampling of generally licensed products for design adequacy.
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3.0 SAFEGUARDS LICENSING AND INSPECTION PROGRAMS The review of the regional safeguards licensing program covered the physical security as well as the material control and accounting review cases.
The review of the Inspection Program covered physical security inspections.
Material control and accounting inspections will be covered in FY89.
3.1 _ Safeguards Licensing Program The Region III staff maintains a complete set of Regional Guidance Documents, Standard Review Plans, and supplementary regional instructions related to 10 CFR 70.32/72.84 reviews for the technical guidance of licensee reviewers.
The Region III documents have been updated and are consistent with NRC policy and guidance.
Region III did not receive or complete any 10 CFR 70.32/72.84 case reviews during the evaluation period.
Region III used the NHSS Operating Plan Casework Statistics Report #41 to keep Headquarters informed of the casework status on a monthly basis.
The Region III license reviewer was trained at Headquarters in 1982 and the Region cross-trained additional inspection staff to perform licensing reviews and provide a
. back-up capability.
Region III had no difficulty in replacing the original license reviewer when he left government service.
3.2 Safeguards Inspection Program The Region III staff naintains a complete file of all NRC publications, documents and guidance on planning, conducting, reporting and follow-up inspections.
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9 In addition, Region III has issued guidance to supplement NRC Headquarters guidance to provide detailed instructions for the technical staff to assure i
uniformity in the planning, conducting and reporting of inspections.
The Region III documents and instructions are up-to-date and consistent with Headquarters policy and guidance.
Region III did not conduct any physical security inspections at non-reactor facilities during the evaluation period.
Region III has an outstanding planning and scheduling system for the safe-guards section.
The Section Chief produces an annual computerized inspec-tion schedule which is updated on a quarterly basis.
The Region III inspection schedule will meet the inspection goals in the regional Operating Plan and in Manual Chapter 2681.
The Region III staff follows NRC instructions in using the 766 system and has established supplementary regional instructions for use by inspectors. The Section Chief noted that the information in the 766 system is not current and that the system does not provide much of the information needed by supervisors to implement the safeguards program.
Three inspectors have left Region III in the past three years. Replacements for the departed inspectors were hired in an average of two months.
The new 4
inspectors were trained in accordance with Manual Chapter 1245, Inspector Qualification, and Regional Procedure 123IA. Training required for new Inspectors, as well as refresher and supplementary training for qualified inspectors are included in the oetailed annual Region III safeguards schedule together with all of the reactor and fuel facilities planned inspections.-
3.3 Licensing and Inspection Initiatives Region III is to be commended for working with Region V in borrowing material control and accounting technical expertise not available in Region III for an MC&A inspection of a Category III fuel facility.
Region III loaned a physical security inspector to Region V for a physical security inspection.
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10 3.4 Recommendations for Actions None noted.
3.5 Headquarters / Regional Interaction Region III was responsive to Headquarters' requests on the following actions:
Region III trained safeguards inspectors in safety and health physics o
aspects of transportation inspections to enable them to perform trans-portation safety inspections in conjunction with safeguards inspections, Region III staff reviewed all of the Region III 10 CFR Part 70 o
licensee special nuclear material possession limits and holdings to verify the correct facility category for inspection purposes.
Region III recommended that their inspectors participate with other Regions in implementation of inspection programs at active fuel facilities. The staff noted that the cross-training benefits of this approach would be very valuable.
11 4.
TRANSPORTATION SAFETY AND SAFEGUARDS INSPECTION PROGRAMS The review of the transportation safety inspection program is based on review of completed inspection reports, analysis of 766 system data on completion of transportation inspections credited to modules 86740 and 86721, discussions with regional staff during the assessment visit on March 30-31, 1988, and one accompaniment inspection with a facil-itles Radiation Protection Inspector to the LaSalle Nuclear Station on March 28-29, 1988.
The review of the transportation safeguards inspection program is based on review of completed inspection reports, analysis of 766 system data on completed inspections and discussions with regional staff during the assessment visit on February 3,1988.
4.1 Transportation Safety Inspection Program 4.1.1 Materials Licensees Based on 766 system data for FY87, coverage of transportation activities under module 86740 during inspection of materials licensees continues to be excellent. Of approximately 2850 active materials licenses in Region III, about 1100 were inspected.
There were 583 inspections that were transportation-related under module 86740, with some 50 violations of transportation requirements reported.
Two escalated civil penalty actions were processed. As of March 1988, Region III had a backlog of 67 inspections that were overdue.
The two Section Chiefs accompanied each of their inspectors at least once during the reporting period.
The field note farmats in use by materials inspectors were consistent with the formats
Completed field notes from 12 inspections in FY87 were selected randomly for examination and found to be complete in all respects.
12 4.1.2 Fuel Cycle Facilities i
The five major fuel cycle facilities located in Region III were all inspected against the transportation module 85740 at least once during FYS7. These inspections are performed by the one fuel facility inspection specialist who had been recently reassigned administratively from the Facilities Radiation Protection Section of the Emergency Preparedness and Radiological Protection Branch to the Radiological Effluents and Chemistry Section therein.
All of the inspection reports generated for fuel facilities appear to be very thorough, of excellent quality, and prepared on a timely basis.
One fuel facility, Genercl Electric, Morris. Il spent fuel storage facility, continues to receive rail shipments of spent fuel from Cooper Station in Nebraska.
Each shipment is usually inspected by the fuel facilities inspector upon its arrival at Morris.
One Notice of Violation was processed, which involved excessive surface contamination on a spent fuel cask.
4.1.3 Reactors
. The Region III inspections of transportation activities at operating power reactors were performed as programmed.
Inspections were performed by radiation specialists from the Facilities Radiation Protection Section of the Emergency Preparedness and Radiological Preparedness Branch. Of the 20 sites and 27 units in the Region,, 23 annual inspections were credited to module 86721 and two to modules 86721 and 86740 combined. Three sites, each rated SALP-1, were not inspected, due to the reduced inspection effort allowed for such facilities. One other unit is being decommissioned and is not on a normal inspection effort.
The reports generated from the inspections appear thorough and complete, and prepared on a timely basis.
13 4.2 Transporta' ion Safeguards Inspections Region III completed one transport safeguards inspection in FY87.
Region III is scheduled to complete five transportation safeguards inspections in FY88. As of March 31, 1988, four had been completed.
The inspection reports were technically complete, consistent with NRC policy and guidance, and submitted in a timely manner. Region III is ahead of schedule in meet-ing its Operating Plan goals.
4.3 Regional Initiatives Region III is to be commended for:
o Having had all their inspectors assigned to inspecting transportation activities complete the transportation course H-308, either at TTC or the course conducted at Region III in September 1987; o Initiation of in-house training sessions on health physics and the NRC Manual; o Implementing a trial program for " performance indicators" in the materials inspection program; and o Conducting a licensing and inspection workshop for Broad Scope Licensees in October 1987.
4.4 Recommendations For Action None.
4.5 Headquarters / Regional Interaction Region III staff has maintained an excellent interaction with Headquarters staff on problems, issues and reactive cases involving transportation matters.
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LOW-LEVEL WASTE INSPECTION PROGRAM (10 CFR PART 61)
The low-level waste inspection program review is based on an analysis of 766 system data on low-level waste inspection reports credited to inspection modules 84850, 84722 and 84522, the review of completed inspection reports, an accompaniment inspection with a regional inspector at the La Salle Nuclear Generating Station, and discussion with Region III staff i
during the visit on March 30 and 31,1988.
5.1 10 CFR Part 61 Low-Level Waste Inspections - Materials For the materials inspection program, 345 inspection reports were credited to inspection procedure 84850 of about 1100 inspections performed by the Region during FY87. As of March 1988, there was a backlog of 67 overdue routine inspections, only four of which are Priority 1.
The NMSS Section Chiefs have accompanied each of their inspectors during this review period.
As part of low-level waste managements's National Program Review, Region III materials inspection files were examined at the Region III
. offices to determine the completeness of the inspector field notes. Twelve files were selected randomly; all were found to have been adequately completed and of excellent quality. The review also showed that the field note fonnats were consistent with the recomendations provided in Inspection Procedure 87100 Appendix.
The Region deserves particular credit and recognition for its effort in the inspection effort at Wright-Patterson Air Force Base, which expended considerable staff resources throughout FY87.
s 15 5.2 10 CFR Part 61 Low-Level Waste Inspections - Fuel Cycle Facilities During FY87,10 CFR Part 61 inspections were performed at the five major fuel cycle facilities by the Fuel Facilities Radiation Specialist.
Each of these facilities was noted to have been inspected against module 84850 at the time of the regional visit.
i 5.3 10 CFR 61 Low-Level Waste Inspections - Reactors For the Region III 10 CFR Part 61 inspection program at power reactor facilities, low-level waste inspections were performed annually at each of the units by two sections in Region III during FY87.
Three sites, Kewaunee, Monticello and Prairie Island, were rated SALP-1 and therefore did not receive 10 CFR Part 61 inspections due to the reduced inspection effort allowed for these facilities. Another unit, Lacrosse, is currently being decommissioned and is not routinely inspected in the area of low-level waste.
According to 766 system data., an average of six hours is credited to nodule 84722 per inspection.
In addition, four units were inspected
. against module 84522 during the review period.
5.4 Lcw-level Waste Disposal Site Inspections This section is not applicable to this region.
5.5 Low-Level Waste Management Initiatives The Region is to be conrnended for conducting a licensing and inspection workshop for Broad Scope Licensees which included training on 10 CFR Part 61 during October 1987.
i 16 5.6 Recomendations for Action
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None.
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5.7 Headquarters / Regional Interaction There has been limited opportunity for Headquarters / Region interaction on low-level waste inspection matters. Recently, the Region has expressed interest in receiving further guidance on the inspection of low-level waste storage facilities.
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URANIUM RECOVERY LICENSING AND INSPECTION Not applicable to Region III.
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17 7.
FTE AND PROGRAM SUPPORT FUNDS UTILIZATION The following table shows FTE allocations and expenditures for the review period. Region III has no program support funds in the NHSS mission areas.
FY88 FY87 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT.-DEC. OCT.-DEC.
Materials Licensing 7.7 8.6 112 8.0 2.0 2.5 125 Materials Inspection 14.2 14.3 101 13.3 3.3 3.3 100 1
Fuel Facility Licensing 0.4 0.1 25 0
0 0.4 Fuel Facility Inspection 2.4 1.8 75 3.3 0.8 0.3 37 SG Fuel Facility Lic.
0.2 0.2 100 0.2 0.1 0
0 SG Fuel Facility Insp.
0.5 0.1 20 0.5 0.1 0
0 SG Transportation Insp.
0.2 0
0 0.2 0.1 0
0 i
LLW Inspection i
Total 25.6 25.1 98 25.5 6.4 6.5 102 NOTES:
1)
FY87 expenditures from FY87 RITS RWAT report; section supervision prora ted.
2)
FY88 expenditures from FY88 RITS RWAT report (as of 1/2/88); section supervision prorated.
- LLW inspection resources are included in materials, fuel facility and transportation inspections.
l The regional materials inspection and safeguards programs are fully staffed.
The materials licensing program staffing exceeds the budget slightly. Fuel facility inspection staffing consists of one full-time fuel facility inspector and portions of time expended by various emergency preparedness and radiation specialists.
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18 Overall resource expenditures for FY87 and FY88 are in line with projections.
However, fuel 1"acility inspection expenditures were below budget in FY87 and the trend is continuing in FY88. Nonetheless, fuel facility inspections are being performed adequately and in accordance with program guidance. Some reprogramming has occurred to other NMSS program areas such as spent fuel shipments, contaminated sites, and the transportation inspection program.
While Region III is fortunate to have a well-qualified, experienced fuel facility inspector, they do not have a specific person cross-trained to provide backup capability. As stated above, various emergency preparedness and radiation specialists have been involved in selected aspects of the fuel facility inspection program. One of these individuals is an experienced fuel facility inspector who could be called upon in an emergency.
During FY87, Region III completed 108% of their baseline materials licensing casework goal.
They accomplished this goal by expending more resources than budgeted.
Expenditures in FY88 also exceed budgeted projections; this is partially due to overstaffing in this area.
Region III's labor rates, based on FY85 and FY86 data, were the lowest of all Regions.
In the FY90 budget NMSS revised these labor rates to make them consistent with actual FY87 labor rate data.
Overall materials inspection resource utilization is inline with expectations for both FYS7 and FY88. However, a large portion of these resources have been utilized for non-routine inspections such as Wright Patterson, 3M, Case Western, and Advanced Medical Systems. We agree with Region III's diversion of resources to these high priority requirements.
NMSS has approved an Operating Plan change to reflect a shift from routine to reective inspections.
During FY87 in the safeguards and transportation program, Region III completed twice as many licensing cases as oudgeted. However, safeguards fuel facility inspection expuditmes and safeguards transportation inspection expenditures were below budget in FY87. Based on limited FY88 data, resource expenditures are running behind due to scheduling of physical security inspections late in the fiscal year.
s 19 In summary, Region III has effectively utilized nuclear material safety mission area resources.~ They reallocate to high priority areas when cJrcumstances warrant and keep NMSS management informed.
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