ML20055C219
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MEMORANDUM FOR:
Robert D. Martin Regional Administrator, Region IV FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material S
_ afety and Safeguards
SUBJECT:
MATIONAl. PROGRAM REVIFW REPORT Enclosed is the National Program Reviaw report for Region IV. The report encompasses all regional activities winiin 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 IV this spring.
A draft of this report was sent to Region IV for connent on June 20, 1988.
The comments provided in the recent response signed by Mr. Montgomery have been addressed in this final report.
The Region IV uranium recovery licensing and inspection program and the transportation program are operating well. The fuel cycle program provides proper oversight of the Sequoyah Fuels facility. The materials licensing and inspection programs improved greatly during the course of the year. The number of pending materials cases continues to decline and the ' inspection I
program has also improved significantly since the time of our review.
-s However, the report does identify the need to assure thorough coordination and cross-training between reviewers and inspectors.
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 connents.
Please let us know if there are other ways that we can continue to improve the N'tional Program Review process.
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(Signed) Robert W. Bernero l
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
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REPORT OF THE 1988 NATIONAL PROGRAM REVIEW OF DECENTRALIZED NMSS ACTIVITIES AT REGION IV 1.
INTRODUCTION The purpose of this report is to document the National Program Review of decentralized NMSS licensing and inspection programs at Region IV. This review 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.
As the responsible program office, NMSS prepares this report each year ~
to assure that the regions are conducting their activities in a technically sound, consistent, timely, and efficient fashion.
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 Yive Regions and Headquarters.
Additional information on the process can be found in the HMSS National Program Review Manual dated December 11, 1987.
2 2.
FUEL CYCLE AND NUCLEAR MATERIALS PROGRAMS 1
2.1 Materials Licensing The Region completed 468 license reviews in FY87, compared to its adjusted Operating Plan goal of 506. This represents 92% of the goal. On average, new actions were completed in 69 days, amendments in 61 days, and renewals were generally processed on a first in-first out basis.
Overall turnaround average for all cases, including renewals, was 120 days in FY87.
For the first six months of FY88, 236 licensing cases have been completed, compared to a baseline projection of 274(865). Since the program review visit, from April through June, Region IV has done a much better job.
Through June, 429 cases have been completed, compared to a projection of 412 i
(104%). Through March 1988, on average, new actions were completed in 67 days, amendments in 43 days, and renewals were generally processed on a first in-first out basis. Overall turnaround average for all cases, including renewals, was 144 days through March.
From October 1986 until March 1988, the number of cases pending remained relatively level at about 180. At the same time, there was a heavy backlog in the auditing of completed
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11 censing actions by regional management pending the arrival of a new Section Leader.
In the past three months, the number of cases pending dropped significantly, particularly for license renewals.
l Licensing actions are carried out in a consistent manner in accordance with applicable guidance.
There were no significant problems noted in the technical adequacy and accuracy of completed licensing cases. Minor discrepancies have been discussed with the regional staff on an ongoing basis during the review period.
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3 2.2 Materials Inspection The materials inspection area was most heavily impacted by the Sequoyah Fuels Corporation accident and subsequent actions.
The majority of this impact was experienced in FY87, resulting in the reduced rate of materials inspections (194 inspections completed). From October 1987-March 1988, 136 inspections were completed (somewhat behind the projected rate).
But, since the period of the assessment, a new supervisor has been assigned as Chief Nuclear Materials Inspection Section.
Increased planning, coupled with utilization of a small amount of resources from other NMSS programs, has permitted a return to the projected inspectice goal as of the end of May.
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There were no significant problems noted in the technical adequacy and accuracy of inspections or inspection report findings. Headquarters was only able to schedule one accompaniment of an inspector during FYB8. This accompaniment was of a special unannounced inspection of a radiation therapy department in response to an allegation o'T multiple items of noncompliance.
The inspection included measurements of dose rates, a review of personnel monitoring records, and interviews with individuals at all levels of the organization.
The survey methods and record reviews were thorough and the interview techniques excellent. The inspection report was complete. The overall conduct of this inspection was exemplary. NMSS and Region IV will try to schedule more inspections in the future, during which NMSS can accompany the inspectors. -To their credit, the Region has shown a vast improvement in transmitting inspection report results to licensees.
They now have an average turnaround time of 30 days as compared to 57 days in the last review period. Also, NMSS noted during its review the dedication of the licensing and inspection staffs to the materials program.
4 The Region utilizes two reviewers and one licensing assistant in licensing case work anB five inspectors in the inspection program.
During the last review, the Region made a commitment to hire an additional inspector.
This commitment was put on hold due to an overage of FTE's in the reactor area. On July 3, one additional inspector was lost due to transfer. Region IV is actively recruiting to hire additional individuals in the materials area. Utilizing.these individuals to do both inspections and licensing reviews would assist them in reaching Operating Plan targets for licensing actions and inspections. Region IV has recently implemented the use of overtime, which should also partially relieve the staffing problem.
Recruitment actions are under way to fill these vacancies.
At the time of the program review, the NMSS staff noted the following specific areas of concern:
a.
There was a lack of cross training for inspectors to learn about the licensing process; b.
There had been no off-shore inspections in FY88; c.
Some inspectors indicated a lack of time to properly prepare for scheduled inspections; and d.
The Region very seldom submitted licensing and inspection topics for conference call discussions (improvement noted since March).
In one case shortly after the program review, the inspection and licensing staffs failed to coordinate in a timely manner.
In this case, the Wichita Veterans Administration operated in noncompliance over an extended period of time and without an inspection. Closer attention by both the licensee and NRC Region IV could have resolved the issue in a more timely manner.
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2.3 Fuel Cycle Inspection During FY87 and into FY88, the Region has maintained an appropriate, augmented inspection schedule and oversight effort for the Sequoyah Fuels Corporation UF6 production plant, the single fuel cycle facility under the Region's purview (excluding the URF0 responsibilities).
Inspection reports have been technically sound and timely. The Region has effectively communi-cated with NMSS on Sequoyah Fuels Corporation activities and provided excellent coordination and leadership in bringing enforcement matters stemming from the facility accident in January 1986 to a close. With the improved performance of the licensee, the Region appropriately is reducing its effort in FY88, but recognizes that the facility demands more inspection attention than is called for presently by Manual Chapter 2600.
T 2.4 Fuel Cycle and Materials Safety Initiatives o
Region IV has recommended, and NMSS has approved, a plan to use Uranium Recovery Field Office inspectors to conduct some materials inspections; o
Region IV did a superb job sponsoring a recent workshop on problem licensees, in particular radiographers and well-loggers; o
Based upon its experience with Sequoyah Fuels activities over the past two years, regional staff strongly encourages revision of the applicable inspection modules and will provide major input.to a coordinated effort with Region III and NMSS; and o
In order to balance workload more evenly for the fuel cycle and materials programs, Region IV recently transferred the inspection function for the Sequoyah Fuels facility to the Uranium Recovery Field Office.
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2.5 Recommendations NMSS recossends that Region IV:
o Establish cross training for inspectors on licensing procedures; o
Set up a schedule for doing several off-shore inspections; and o
Recruit at least two additional inspectors / reviewers for the.
i materials program.
i 2.6 Headquarters / Regional Interface No interface problems were noted. The Regional Administrator made the following observations:
Certain NRC regulations such as 10 CFR Part 40 need updating and there o
is a need to relock at our reciprocity provisions.
(Part 40 revision does not have a very high priority in Research; however, l#tSS will be discussing this issue with them.);
e Headquarters needs to establish a consistent policy in dealing with o
" bad performers," such as keeping an agency-wide bad performers list.
(This item is assigned to the Office of Enforcement for action.);
o The Regional Administrator is connitted to reducing the inspection and licensing backlog through increased efficiency.
The Region is seeking Headquarters support in several new initiatives to improve efficiency. (Specific comments on this item were addressed separately.);
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The Region would like sore flexibility in the budgeted resources by o
NMSS.
(Additional information should be provided on this subject by RegionIV.)
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3.
SAFEGUARDS LICENSING AND INSPECTION PROGRAMS Not applicable to Region IV.
4.
TRANSPORTATION SAFETY AND SAFEGUARDS INSPECTION PROGRAMS The review of the Transportation Safety and Safeguards Inspection Pro 9Fam 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 17-18,1988, and one accompaniment inspection with a regional inspector to the Wolf Creek Nuclear Station during March 14-16,1988. ~.
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4.1 Transportation Safety Inspection Program y
4.1.1 Materials Licensees Region IV currently has 890 active materials licenses of which about 200 were inspected in FY87. Transportation Module 86740 was covered 99 times, resulting in 29 non-escalated. Severity Level 4 or 5 violations and six escalated actions involving transportation violations.
These involved three enforcement conferences with licensee management, two Orders issued modifying licenses, and six civil penalties ranging from $250 to $1,500.
Also one referral from a state-licensed waste burial site involving a Region IV materials licensee waste shipment was processed. As of March 1988, Region IV had no backlog of inspections that were overdue.
The FY88 Region IV materials licensees Transportation Safety Inspection Program was on schedule.
Region IV is using five different formats of field notes for collection of data in materials inspections. However, these were noted to be consistent with the fonnats recommended in Inspection Procedure 87100.
It was also noted that the minor revision in 1987 involving the transportation section of the medical inspection format had also been implemented into the Region IV format. Completed field notes from the files from eight recent
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inspection reports were selected at random, representing all of the
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assigned inspectors. These were found to be complete in all the required detail. The Section Chief had accompanied each materials inspector at least once during FY87.
4.1.2 Fuel Cycle Facilities Region IV has only one major fuel cycle facility, Sequoyah Fuels, which is covered by the Nuclear Materials Inspection Section. This facility has j
involved a considerable expenditure of resource effort over the past several years.
Examination of the inspection plan for this facility indicated that in FY87 the transportation module 86740 had been completed.
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4.1.3 Reactors Region IV has in its area a total of nine operating power reactors at eight
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locations. Transportation activities had been inspected in FY87 at all' operating units.
Region IV continues to utilize prescribed formats of field notes in its reactor inspections of radiation protection and transportation activities (at reactors in the other Regions these are used for materials inspections, but not for reactors). The individual inspectors indicated that they highly favor using such field notes and find them to be very useful in assuring thorough inspection coverage.
During the inspections of transportation activities over the past year, there were no escalated or non-escalated violations identified.
The Section Chief accompanied each assigned inspector at least once, and in most cases more than once during the past year. Many of these accompaniments involved the transportation modules.
4.2 Transportation Safeguards Inspections None were scheduled and none were performed during the rating period.
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4.3 Regional Initiatives Region IV is to be cosmended for:
o Having had all inspectors who are assigned to inspect transportation activities complete the transportation course H-308; and o
Continued preparation of outstanding inspection reports in the reactor program; and pioneering the use of prescribed, comprehensive field notes in reacter inspections.
4.4 Reconnendations For Action.
None 4.5 Headouarters/ Regional Interaction Region IV staff has had 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 review of the Low-Level Waste Inspection Program is based on the review of completed inspection reports, analysis of 766 system data of low-level waste inspection reports of inspection modules 84850, 84722, and 84522, an accompaniment inspection with a regional inspector at the Wolf Creek Nuclear Generating Station and discussions with Region IV staff during the visit on March 17 and 18,1988.
5.1 10 CFR Part 61 Low-level Waste Inspections - Materials For the materials inspection program, two inspection reports were credited to the inspection of low-level waste of about 200 insp2ctions performed in FY87.
The number of actual low-level waste inspections performed by the Region may be higher than thc two reports attributed to Inspection Procedure 84850 since Region IV inspectors credit other Inspection Procedures, such as 83822 and 86740, for their low-level waste inspection efforts.
As part of low-level waste management National Program Review, Region IV materials inspection files were examined at the Region IV offices to deter-mine the completeness of the inspector field notes. Of the eight files selected, all were found to be of excellent quality and to have been completed in adequate detail. Upon review of the field note formats, it was determined that the five formats utilized by the Region were consistent with the recommendations provided in Inspection Procedure 87100 Appendix.
It was noted that 'during FY87 materials inspectors were accompanied by their supervisor on an annual basis or better.
.l 11 5.2 10 CFR Part 61 Low-level Waste Inspections - Fuel Cycle Facilities With respect to the 10 CFR Part 61 inspection program for fuel cycle facilities, one fuel facility, Sequoyah Fuels Corporation, is located in the Region and was inspected during FY87. According to the 760 system data, inspection module 84850 showed nine hours credited to the inspection of low-level waste management at this facility.
5.3 10 CFR 61 Low-level Waste Inspections - Reactors At power reactor facilities, low-level waste inspections were performed at seven of the eight operating reactor sites, with an average of four hours credited to Inspection Procedure 84722, and five hours credited to the supplemental Inspection Procedure 84850 per unit.
Although one site, Cooper, was not inspected during FY87, it had been inspected in CY86 and CY87, just missing the fiscal year review period.
In addition to the low-level waste inspection coverage at operating reactors, the Region also provided preoperational inspection coverage at the South Texas I and 2 units.
During this review period, Region IV was the only Region which routinely inspected low-level waste at reactors against the supplemental inspection procedure in addition to the minimum / basic low-level waste inspection efforts. The Region deserves particular credit for its effort in the development and implementation of inspection field notes for low-level waste. The formats of these notes are exemplary by providing a detailed checklist of the applicable 10 CFR 61 requirements.
5.4 Low-level Waste Disposal Site Inspections This section is not applicable to this Region.
12 5.5 Low-Level Waste Management Initiatives The Region is to be comnet.ded for implementing the following initiative:
o The development of 10 CFR Part 61 inspection field notes for low-level waste inspections at reactors.
5.6 Recommendations for Action For the materials inspection program, begin crediting the approp.riate low-level waste inspection procedure to provide a more consistent tracking system for these inspection efforts.
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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 additional training materials regarding 10 CFR Part 61 and other applicable infonnation for low-level waste inspections.
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URANIUM RECOVERY FIELD OFFICE (URFO)
This assessment is based on the review of completed inspection reports, licensing reading file, RITS and 766 system data, management conference calls, and discussions with URF0 staff during a regional visit on May 2 and 3, 1988.
6.1 Uranium Recovery Licensing URF0 completed 122 Title II licensing actions in FY87 compared to its FY87 Operating Plan goal of 78. This exceeds the Operating Plan goal by 56%.
No adjustment of the baseline goal was needed. The breakdown of actions, were two new applications, three renewals, 38 major amendments, 64 minorf amendments, four 10 CFR Part 40 amendments and 11 technical assistance to Agreement States.
In addition to the Title II licensing work, URF0 completed 19 UMTRAP reviews. This exceeded the Operating Plan goal of 15 by 27%. URF0 also completed 148 reviews of monitoring and operational data repnrts which exceeded the Operating Plan goal of 95 by 56%.
For the first six months of FY88, 67 licensing actions have been completed. This would indicate that URF0 will exceed its FY88 Operating Plan goal of 74 by the end of the fiscal year.
URF0 has also completed 95 reviews of monitoring and operational data reports which already reets their Operating Plan goal for FY88.
From a technical standpoint, the URF0 has done an excellent job of following written guidance for the radiation protection aspects of uranium recovery licensing. There has been considerable discussion on the specific reclamation design' criteria that must be met in order to show compliance with 10 CFR Part 40 Appendix A.
The remaining technical issues will be jointly resolved by URF0 and Headquarters through the development of specific guidance for tailings reclamation. Until this guidance is developed, this area of the review cannot be evaluated in more detail.
14 6.2 Uranium Recovery Inspections From a uranium recovery inspection standpoint, 28 inspection reports were signed in FY87. This compares with the Operating Plan goal of 35.
Although the number of mill inspections was lower than the Operating Plan goal, the URF0 had to temporarily delay a number of scheduled inspections due to pending licensing reviews for those facilities.
Those inspections that were delayed were completed in October 1987.
The URF0 also completed five materials inspections in support of other Region IV activities. The average time from completion of the inspection to issuance of the report was 28 days.
For FY88, through March 31, 1988, the URF0 has coupleted 15 inspections with an average time of 21 days to issuance of the report.
i URF0 has developed draft inspection field notes which have added to the '
quality of the uranium recovery inspection program.
Inspection reports reviewed were considered to be outstanding. The inspection reports and l
field notes showed that the guidance in Manual Chapter 2600 had been followed.
6.3 Uranium Recovery Initiatives The URF0 is to be commended for implementing the following initiatives:
o The development of a Memorandum of Understanding with EPA defining the NRC/ EPA responsibilities at the Churchrock uranium mill site; o
The completion of the Atlas Corporation surety issue; o
Upgrading the'New Mexico licensees' programs to be consistent with other NRC-licensed sites; o
The development of detailed inspection notes for uranium recovery facilities; and
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The interaction with interested parties with concerns at uranium recovery facilities including close interaction with the respective state agencies.
In addition, throughout the rating period. Region IV has provided increased management support for the URFO.
6.4 Reconsnendations for Action To identify and resolve areas needing policy and technical guidance, URF0 and Headquarters staff should continue to work interactively. The following four specific reconsnendations are offered:
o Where possible, staff exchanges such as that being done by M. Knapp of NMSS and R. Bangart, Region IV should be considered; o
Headquarters and URF0 staff should continue to work jointly to resolve policy and technical issues. One area where joint efforts should be focused is the process to be followed in the review of applications and issuance of license amendments for the use of alternative concentration limits; URF0 and Headquarters staff should conduct some joint inspections of o
construction activities at Title I sites; and Headquarters staff should periodically accompany URF0 staff during o
inspections of Title II facilities.
i 6.5 Headquarters /Regiohal Interaction The URF0 has been responsive to Headquarters action requests. Conversely, i
the URF0 has asked for Headquarters technical assistance / concurrence in accordance with the delegation for the uranium recovery program. The URF0 has requested that guidance be developed in the following areas-
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Financial Surety / Parent Cospany Guarantee; and Tailings reclamation including soil erosion long tern stability, and o
the use of maintenance in design evaluations.
There have been periodic conference calls with NMSS and URF0 management to discuss program direction and implementation.
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7.
FTE AND PROGRAM SUPPORT FUNDS UTILIZATION The following table shows FTE allocations and expenditures for the review period.
FY88 FY87 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED 1
BUDGET OCT.-DEC. OCT.-DEC.
Naterials Licensing 2.3 2.3 100 2.6 0.6 0.6 100 Materials Inspection 5.7 3.6 63 5.7 1.3 0.7 54 Fuel Facility Inspection 0.9 2.5 278 1.1 0.3 0.1 33 SG Fuel Facility Lic.
0.02 0
0 0.02 0
0 0
SG Fuel Facility Insp.
0 0
0 0
0 0
O SG Transportation Insp.
0.1 0
0 0.04 0'
O 0
LLW Inspection Uranium Recovery Lic.
10.2 9.3 91 9.3 2.1 1.8 86 Uranium Recovery Insp.
1.9 0.8 42 1.9 0.4 0.4 100 Total 21.12 18.5 88 20.66 4.7 3.6 77 NOTES:
1)
FY87 expenditures from Region IV FY87 Year-End Operating Plan.
2)
,FY88 expenditures from Region IV FY88 Operating Plan (as of 12/19/87).
- LLW inspection resources are included in materials, fuel facility, uranium recovery and transportation inspections.
The following table shows program support funds allocations and obligations for the review period.
FY87 FY88 PROGRAM ACTIVITY BUDGET OBLIGATED BUDGET OBLIGATED Uranium Rec. Lic.
100 100 100 100 20 20 NOTE:
FY88 funds obligation as of 12/31/87
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The regional vranium recovery program is fully staffed. The nuclear material safety program is understaffed (9 FTE on board vs. 9.4 budgeted); and the safeguards program is overstaffed (0.5 FTE on board vs. 0.06 budgeted).
Overall resource expenditures in both FY87 and FY88 are below projections.
During FY87, Region IV completed 92% of their revised materials licensing casework goal with expenditures equalling budgeted projections. Expenditures for FY88 are in line with projections, but casework completions were behind until March.
Region IV has an identified materials licensing vacancy in the FYB8 staffing plan. Robert Martin's March 4,1988 memorandum indicates the position has not been filled due to regional staffing priorities in other areas. A second vacancy is now open.
(Recent correspondence from Region IV 1
indicates that active recruitment is underway to fill these staffing vacancie$.
Until the positions are filled, the Region has implemented the use of overtime to relieve the problem.)
Materials inspection expenditures were significantly behind projections in FY87 due to reallocation to Sequoyah Fuels.
NMSS agreed with Region IV's diversion of resources to this high priority requirement. The limited FY88 data available, however, show an underexpenditure of resources in both the materials and fuel facility inspection areas. The Sequoyah fuels accident has had a negative effect on the materials inspection program.
Region IV recognizes this and has established a recovery plan to ensure attainment of FY88 materials inspection goals.
NMSS agrees with Region IV's plan to use URF0 inspectors to conduct materials and fuel cycle inspections in conjunction with their uranium recovery inspection trips.
We understand this change will not significantly impact the uranium recovery program.
URF0 completed 56% more' licensing cases and environmental monitoring and inspection report reviews in FY87 than projected in the budget while expending 0.93 FTE fewer FTE than budgeted.
This anomaly can be attributed to three factors:
(1) underestimating the licensing workload during budget fonnulation, (2) over-j estimating the labor rate for licensing casework, and (3) requiring URF0 Branch
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19 Chiefs to record all their time in the RITS system as overhead, even if some of it is expended on licensing casework. However, URF0 uust be given credit also for utilizing their resources very efficiently in conducting its licensing program. This same trend in FTE utilization occurred the first quarter of FY88.
All URF0 program support funds were obligated in FY87; " continuing resolution" constraints limited the obligation of FY88 funds to $20K during the first quarter of FY88.
URF0 completed 28 inspections in FY87 compared to 35 in the budget projection while expending only 42% of the budgeted FTE.
(The other seven inspections were deferred until early FY88 due to pending licensing actions on recently acquired New Mexico sites and comercial in-situ sites.) The low FTE expended is thought to result from the method used to account for inspection time in the RITS system (onsight effort times 3) which may not accurately reflect the total effort. The first quarter FY88 inspection FTE utilization is on schedule.
Lack of adequate administrative support is a joint concern of MSS and Region IV. The lack of a full time Office Service Assistant within the Division of Radiation Safety and Safeguards has an adverse impact on the materials licensing program.
The Executive Director for Operations policy regar'ing regional overhead requires that Regions manage their total overhead d
staffing as necessary to adequately support the programmatic and administrative activities of the region.
ESS is aware that Region IV believes their total overhead allocation is insufficient to support all of the agency programs they
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carryout. MSS has sent a memorandum to the Office of Administration and Resource Management on this subject requesting an analysis to support the formulation of the FY90 budget.
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