ML20055C221
| ML20055C221 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/1988 |
| From: | Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 8810110019 | |
| Download: ML20055C221 (23) | |
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S U E a 1988 MEMORANDUM FOR:
William T. Russell Regional Administrator, Region I FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards 1
SUBJECT:
NATIONAL PROGRAM REVIEW REPORT Enclosed is the National Program Review report for Region I.
The report encompasses all regional activities within the HMSS 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 HMSS made its staff visits to Region I this spring.
A draft of this report was sent to Region I for comment on June 20, 1988.
Region I provided detailed comments in its response dated July 8, 1988.
Many of these comments have been incorporated within the final report.
For the most part, the Region is doing a go6d job in implementing progran guidance and inspection manual provisions. The completed materials casework is excellent in terms of its technical adequacy and accuracy.
The inspection reports were of high quality and were consistent with Headquarters policy and guidance.
Some program areas noted for improvement in the coming year are:
some inspections were overdue; supervisors did not accompany each of the inspectors; updated inspection field notes were not used; and administrative turnaround times for licenses and inspection reports were high.
Your July 8 memorandum indicated that these problems were already being corrected.
For example, the Region compensated for a clerical shortage by using overtime, soliciting help from NftSS, and diverting some of its direct staff to indirect effort.
With respect to your comments on safeguards inspection frequencies and resource expenditures, our respective steffs have been working to resolve the issues.
Region I also suggested that NMSS consider merging the NMSS program visits.
We will consider this for 1989.
However, in the past, this has created scheduling problems for both the Regions and Headquarters.
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William T. Russell 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 com1ents, and produce a final report within 30 days after receipt of your comments.
Your other comments concerning report format and emphasis will be considered as we structure next year's report.
Please let us know if there are other ways that we can continue to improve the National Program Review process.
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Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc:
V. Stello J. Taylor
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i REPORT OF THE 1988 NATIONAL PROGRAM REVIEW OF DECENTRALIZED NMSS ACTIVITIES AT REGION I 1.
INTRODUCTION The purpose of this report is to document the National Program Review of decentralized NMSS licensing and inspection programs at Region I.
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 appropr1 ate.
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 conoucive to quality operations li, a:1 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.
FUEL CYCLE AND NUCLEAR MATERIALS PROGRAMS 2.1 Materials Licensing The Region completed 1868 materials licensing actions in FY87, compared to an adjusted projection of 1908 cases (98%).
Through March 1988, 711 cases-have been completed, compared to an adjusted projection of 850 (84%).
Adjustments were made to decrease case completions from the budgeted figures.
The adjustments were made because Region I had to reallocate FTE to clerical support, as discussed below, and since actual receipts through February were below projections.
i During the review period, the number of cases pending has fluctuated from 492 (in Oct. 86) to 357 (in Oct. 87) to 445 (on March 31,1988). Turnaround time for licensing work were very good in FY87.
On average, new applica-tion reviews were completed in 50 days and amendments in 59 days.
Overall turnaround average for all cases, including renewals, was 85 days in FY87.
In FY88, turnaround times have increased. The current average for all cases is 102 days.
Region I is monitoring this trend, and is optimistic that certain recent steps, e.g., improved clerical support, the building consolida-tion, the availability of the IBM 5520 to the materials licensing program and the recent Region I reorganization will help to bring the turnaround time back to FY87 standards.
During the period covered by this review, Region I lost critical clerical staff assigned to support the materials licensing program.
The net deficit was 1.3 staff years of clerical support. Due to the agency's overall overage of staff-on-board, the Region was, for a period, under an absolute hiring freeze and later under strict limitations.
The licensing i
staff. compensated for this situation by (1) soliciting and receiving four staff weeks of clerical support from NMSS, (2) using overtime for q
available staff, and (3) diverting direct staff to cover essential clerical and administrative duties.
The diversion of approximately one staff-year of direct staff to administrative duties was largely
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' responsible for the failure to complete licensing cast. work on schedule.
Also, the necessity of training and rotating staff through temporary assignments resulted in some inefficiencies and delays in the administrative processing of cases. However, by taking these compensating measures, Region I was able to docket all incoming licensing casework and to complete priority cases in a timely manner.
Based upon Headquarters review of Region I casework, the technical adequacy and accuracy of completed licensing actions was considered excellent. Minor discrepancies have been discussed with the regional staff on an ongoing basis during the review period. Actions are carried out in a consistent manner in accordance with applicable guidance. The documentation of actions was excellent. The Region has an excellent mixture of senior, intermediate, and entry-level personnel in the licensing and inspection programs. The cross utilization of inspectors and license reviewers is excellent. The staff is very competent with excellent morale.
t 2.2 Materials Inspections P
Region I completed 1049 inspections in FY87.
This is 104% of the Operating Plan goal of 1010. Violations were identified in 307 inspections. On the average, inspection reports and notices of violations were issued in 67 days compared to a goal of 20 days. Delays were apparently the result of the clerical understaffing problem mentioned in Section 2.1.
The inspections and reports are of high quality and in accordance with the guidance in Manual Chapter 2800.
The Region deserves particular credit for its extra effort on inspections of allegations (consuming at least one-third staff year), 24 inspections of general licensees, and two reciprocal (radiography) inspections. There also were 22 special inspec-tf ons performed of Radiation Technology, Inc. during FY87 and three inspections in early FY88.
4 Among over 500 inspections of licenses in Priorities 1, 2, and 3 there were 18 overdue. As part of a recent realignment of the materials program, Region I has directed close attention to assure all inspections are completed in the nominal frequencies. There were 16 overdue inspections for Priorities 5, 6, and 7.
These could have been covered by using the telephone contact questionnaire as specified in IMC 2800.
The questionnaire was never usca auring the review period (the telephone contact format was developed by Headquarters for cases when on-site inspections could not be accomplished because of manpower limitations).
There were only four unresolved expired licenses that the Region is actively pursuing.
The Region completed follow-up on 51 pacemaker licensees and prepared i
a report of their findings as specified in Temporary Instruction 2800/12.
Each of the three Section Leaders accompanied three inspectors, making a total of nine.
The focus of these accompaniments was on junior inspectors.
Pegion I has committed to accompanying all inspectors during FY88 and subsequent years.
Jack Metzger of NMSS also accompanied three Region I inspectors in late 1987.
Two of the inspectors were available during the National Program Review visit and were asked to show their field notes that reflect the inspection findings. A review of field notes indicatea excellent comparison to the reviewer's notes.
However, the materials inspectors are still using the 1982 version of the field notes instead of the standard field notes attached to Inspection Procedure 87100, dated March 23, 1987.
It is recommended that the most current field notes be used to be consistent with Inspection Procedure 87100.
(Region I has committed to convert to the
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standard field notes by September 1, 1988.)
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. 4 Several inspectors were interviewed to determine their training accomplishments and any other items they wished to discuss, including those inspectors that were accompanied in the field.
Two of the inspectors accompanied had taken courses (as specified in Manual Chapter 1245) and had been qualified to perform inspections in additional inspection categories since being accompanied.
One inspector had completed training in nuclear medicine and her qualifications journal indicated she had been qualified in medical Priority 3 inspections, although occasionally she did du inspections in medical Priority 2 broad licenses.
Based upon these observations, NMSS concludes the Region is doing well to assure that the inspectors meet the training requirenents of Manual Chapter 1245.
It should be noted that more regional attention will probably be needed for training in each Region, because of recent changes to Manual Chapter 1245.
t 2.3 fuel Cycle Inspections Region I has conducted its fuel cycle facility inspection program in accordance with Manual Chapter 2600 and the applicable inspection modules.
Appropriate Region inspection specialists have supported the fuel facility inspector, providing thorough coverage. Suitable training has been made available to inspectors not previously familiar with fuel cycle facilities.
The documentation for inspections has been of good quality, and, in the last half-year, the time to issuance of inspection reports has been appreciably reduced.
The program has been conducted in a i
technically sound and accurate manner. Although resource expenditures in FY87 were somewhat greater than anticipated, the expenditure was reasonable in response to problems uncovered.
i Region I is to be commended for its outstanding organization and preparation of the Monitoring Team Assessment, which was conducted very effectively at DOE's West Valley Demonstration project in advance of operation of the supernatant treatment system.
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. 2.4 Regional Initiatives The Region is to be commended for implementing the following safety initiatives:
o Realigning the staff to focus attention on certain program areas (particularly creeting a Licensing Assistance Section to improve-clerical support);
o Developing performance based evaluation factors for materials licensees which included the following indicators: managenent oversight and control, quality of operations, personnel training and qualification, resolution of previously identified items; and c
Sponsoring the 1987 broad scope and 1988 irradiator symposia and hosting the Licensing Reviewer Workshop.
2.5 Recommendations For_ Action o
Develop additional inspector expertise in Region l's fuel cycle facilities' systems and processes, as a backup resource for the principal fuel facility inspector; and o
Continue to monitor the completion of inspections of the high priority licensees, to use the telephone contact for the lower priority licenses, in accordance with Manual Chapter 2800, and to-use the official field note formats in inspection.
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. 2.6 Headquarters / Regional Interaction The overall interaction with Headquarters has been excellent.
However, the Region did indicate that there is a need to improve interaction in the medical area. A meeting between Region I and Headquarters has been held since the program review and it appears that this area has been improved somewhat.
This item will be monitored closely during the review year.
The Region hosted the Interoffice Working Group meeting earlier this winter. Region I was quick to recommend new budget initiatives in its March 30, 1988 memorandum.
It also has made recommendations to improve the Licensing Management System (LMS).
(Because of this reconmendation, the LMS Configuration Team will be reconvened.)
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' 3.
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 the physical security inspections. Material control and accounting inspections will be covered in FY89.
3.1 Safeguards Licensing, Program The Region I staff maintains a complete set of Regional Guidance Documents and Standard Review Plans related to 10 CFR 70.32/72.84 reviews for the technical guidance of licensee case reviewers. The documents are up to date and consistent with NRC guidance and policy.
The case reviews were performed in a sound manner. They were technically complete and consistent with Headquarters' policy and guidance.
Inconsistencies noted during the reviews were resolved.
Correspondence from Region I was forwarded to Headquarters in a timely manner and properly marked.
Region I achieved an excellent average case turnaround time of 39 days in FY87, and an outstanding average case turnaround time of 25 days in FY88.
Completed licensing reviews have exceeded Operating Plan goals.
Region I completed 16 reviews versus four planned completions in FYS7 and completed 5 reviews versus four planned completions in FY88.
Region I utilized the NMSS Operating Plan Casework Statistics Report #41 to keep Heaoquarters informed of licensing casework status on a monthly basis.
i The Region I licensing reviewer was trained at Heacquarters in 1982 and i
the Region has cross-trained additional inspection staff to perform licensing reviews and provice back-up capability.
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3.2 Safeguards Inspection Program The Region I staff maintains a complete file of all NRC publications, documents, and guidance on planning, conducting, reporting and follow-up inspections. Region I has issued regional office instructions to supplement NRC guidance in some areas.
The Region I docunients and publica-tions are up to date and consistent with NRC policy and guidance.
Region I inspection reports were clear and prepared in a technically adequate manner.
The Division of Safeguards and Transportation Headquarters staff accompanied Region I inspectors on a physical security inspection of UNC Naval Products, Montville, CT f rom March 14 to March 17, 1988.
The inspection was performed in a thorough and technically competent manner.
Although safeguards regulations do not require fuel cycle licensees to establish and maintain physical security quality assurance programs, the Region I inspectors generally inspect three modules which fit the definition of quality assurance as "those planned and systematic actions necessary to provide adequate confidence that a system or component will perform satisfactorily in service." These moaules include the Security Program Audit Module, the Records and Reports Module and the Testing and Fbintenance Module.
lhe inspectors review records and reports and observe implementation of procedures when possible.
The Region I inspection reports have been consistent with Headquarters' policy and guidance.
However, in FY87, the one physical security inspection at UNC Naval Products, a Category I facility, was conducted by one inspector and expended less than one half of the time utilized by other Regions when conducting a physical security inspection at a Category I facility.
The Region 1 March 1988 physical security inspection at UNC was conducted by two inspectors in order to cover all of the modules and expended approxirstely the same amount of time as other Regions consume in completing a Category I physical security inspection.
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. By conducting only one physical security inspection at UNC Naval Products in FY87, Region I did not meet the requirements in Manual Chapter 2681 with respect to performing semi-annual physical security inspections at Category I fuel facilities.
The Region I position is that based on historical performance the Category I facility did not need the required two inspections and that Region I had a shortage of physical security inspectors during FY87. However, Region I neither notified Headquarters of the deviation from the Manual Chapter requirements, nor requested assistance.
Region I produced an adequate planning and scheduling system for FY88.
The Region stated that the system would be updated on a quarterly basis.
The Region I staff complies with the NRC requirements to file inspection report data in the 766 system but Region I staff does not use the system.
Region I staff found the 766 system data to be unreliable in the past so the staff uses the hard copy of inspection reports for planning, follow-up, tracking, and statistics requirements.
Region I completed the first semi-annual FY88 physical security Category I fuel facility inspection within the timefrcme required by Headquarters.
Region I used the requirements in Manual Chapter 1231 and the Region I Divisien of Radiation Safety and Safeguards memorandum to the Chief, Safeguards Section, dated April 18, 1985, subject: " Inspector Qualitication" to train new inspectors. However, Manual Chapter 1245, subject, " Inspector Qualifications", dated 08/01/86, is the current Manual Chapter in use.
Region I was not foliowing the requirements in Manual Chapter IP45 to establish an Individual Development Plan for each qualified inspector and to schedule refresher training for each qualified inspector each four to five years.
Region I depended on-the-job training for qualified inspectors to keep abreast of current technology,
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- 3.3 Licensing and Inspection Initiatives None noted.
3.4 Recommendations for Action It is recommended that Region I:
Perform all of the physical security inspections required by Manual o
Chapter 2681 except as agreed to by Headquarters; and Follow the requirements in Manual Chapter 1245 for qualified o
inspectors by preparing Individual Development Plans and for assuring that qualified inspectors receive refresher training each four to five years.
3.5 headquarters / Regional Interaction Region I responded to Headquarters requests on the following actions:
Region I trained physical security inspectors in health physics o
procedures to enable these inspectors to perform transportation safety inspections in conjunction with their. safeguards inspections; Region I completed a special comparability inspection and report e
within the timeframe requested by Headquarters; tind Region I staff is reviewing Region I 10 CFR Part 70 licensees' special o
nuclear material possession limits and holdings to verify the correct facility category for inspection purposes.
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. Region I would like additional guidance on classification of sensitive information at fuel facilities. This subject was discussed by Headquarters staff during a meeting with licensees and Region I staff in Baltimore, MD on April 21, 1988.
No FTEs have been allotted to Region I to conduct 10 CFR Parts 25 ar.d 95 inspections. Region-I sent a memorandum to R. Brady, Division of Security,
.to inform him of this matter.
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TRANSPORTATION SAFELY AND SAFEGUARDS INSPECTION PROGRAMS The review of the transportation safety inspections program is based on review of completed inspection reports, analysis of 766 data on completion of transportation inspections credited to nodules 86740 and 86721 discussions with regional staf f during the assessment visit on April 12-13, 1988, and one accompaniment inspection with a regional inspector to the Susquehanna Nuclear Station during January 25-27, 1988.
The review of the transportatico sateguards inspection program is based on a review of completed inspection reports, analysis of 766 data on completion of trans-portation safeguards inspections, and discussions with regional staff during i
the assessment visit on February 23, 1988.
l 4.1. Transportation Safety Inspection Programs 4.1.1 Materials Licensees As stated in Section 2.2, 322 inspections of the 1049 materials inspections involved transportation module 86740 in FY87, as compared to 180 in FY86.
Regional staf f attributed the increase to a revision in the method of preparing the 766 form. Approximately 60 transportation safety violations were noted as compared to 87 the previous year.
Regional inspectors were still using obsolete (1982) field notes for collection of inspecticn report detail.
In 1986, standardized updated formats were strongly recommended to all Regiens as part of the Attachn:ent to Inspection Procedure 87100, and the other Regions are currently using the new formats.
(During both the 1985 and 1987 assessment exits, kegion I managenent was advised to convcrt to the new formats.
They have committed to using the new formt by September 1988). About 16 files of completed field notes were reviewed for thoroughness of completion. A number of those observed were only partially completed.
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. As stated in Section 2.2, a total of nine inspectors were accompanied by the Section Chiefs.
The Chief, Nuclear Materials Safety Branch, had recently directed the Section Chiefs to establish a firm schedule to accomplish the required annual accompaniment with each assigned inspector.
4.1.2 Fuel Cycle Facilities The six major fuel cycle facilities located in Region I were all inspected against the transportation Module 86740 at least once during FY87.
These inspections are performed by the one fuel facility inspection specialist. During the past year he has been assigneo to the Effluent Radiation Protection Section of the Facilities Radiological Safety and Safeguards Branch.
Previously he had been assigned to the Safeguards Section within the former Nuclear FMterials Safety and Safeguaros Branch.
All of the inspection reports generated for fuel facilities centinue to appear to be very thorough, of excellent quality, and prepared on a timely besis.
4.1.3 Reactors inspection of transportation (and solid radwaste) activities at operating power reactors is performed by the Effluent Radiation Protection Section of the Facilities Radiological Safety and Safeguards Branch. Two of the inspectors therein perform as " specialists" to conduct inspections of these activities at all of the 21 sites (30 units) located in Region I.
Manual Chapter 2515 and the Region I Operating Plan call for an annual inspection of transportation module 86721 at operating power reactor sites.
In FY87, the program had 74% completion (14 of 19 sites).
The Section Chief 1
attributed this backlog to two factors: first, insufficient resources, and secondly, the strong dominance exerted by the regional reactor projects people in developing inspection priorities.
The content, thoroughness and l
timeliness of completion of the inspection reports appears to be excellent.
Each of the two specialists was noted to have been accompanied at least once by the Section Chief in the past year.
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. 4.2 Transportation Safeguards Inspection _s Region I was not scheduled for transportation safeguards inspections in FYB7.
Region I completed one of the two transportation safeguards inspections scheduled for FY88. The inspection report was technically complete, consistent with NRC policy and guidance and submitted in a timely manner. Region I is on schedule in meeting its Operating Plan goals for FY88.
4.3 Regional Initiatives Region I is to be commended for:
Preparation and submittal of a draf t Information Notice to Headquarters o
to alert licensees on transportation problems associated with shipments of contaminated equipment between reactor facilities; and Having the inspection staff assigned to inspect transportation o
activities complete the transportation course H-308, either at TTC or at Region I in November 1987.
4.4 Recommendations For Action It is recommended that Region I:
Reduce the inspectinn backlog of overdue transportation inspections o
at operating power reactors so as to perform at least an annual inspection at each site.
4.5 Headquarters / Regional Interaction Region I staf f has had a good interaction with Headquarters staff on problems, issues, and reactive cases involving transportation matters.
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LOW-LEVEL WASTE IhSPECTION 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 radioactive waste inspection reports credited to inspection modules 84850 and 84722, and discussion with Region I staff during the visit on April 12 and 13,1980.
5.1 10 CFR 61 Low-Level Waste Inspections - Materials Of the 1049 materials inspections performed in FY87,118 inspection reports were credited to the inspection of low-level waste. As part of the National Program Review, materials inspection files were examined at the Region 1 of fices to determine the completeness of the inspector field rctes. Of the 16 files selected, most were found to have been adequately completed. However, as stated earlier, the Region is using field note formats developed in July 1982. The formats in use during this review period did not reference 10 CFR Part 61.
It is recommended that the waste disposal section of the fiela notes be updated to incluoe 10 CFR Part 61.
The Region deserves particular credit and recognition for its effort in the inspection effort at Radiation Technology, Inc., which expended considerable staff resources throughout FY87, and for conducting a licensing and inspection workshop for Broad Scope Licensees which included training on 10 CFR Part 61.
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. 5.2 10 CFR part 61 Low-Level Waste Inspection - Fuel Cycle Facilities With respect to the 10 CFR Part 61 inspection program for fuel cycle t'acilities, all major fuel f acilities were inspected at the time of the regional visit.
The low-level waste management inspection coverage at these facilities is excellent, both in inspection frequency and quality.
The Region also participated in an advisory capacity on low-level waste management activities at the West Valley Demonstration Project by providing technical and administrative support throughout FY87. Their support and performance for low-level waste management on this project is excellent.
5.3 10 CFR 61 Low-Level Maste Inspection - Reactors At power reactor facilities, low-level waste inspections were performed at 14 of the 21 reactor sites, with an average of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> spent per inspection. Two of the 21 reactor sites, Shoreham and Seabrook, are not currently generating low-level waste, so the FY87 solid radicactive waste management inspection coverage within the Region is better than the reported 67's. According to the Effluent Radiation Protection Section Chief, the lack of inspection coverage at five reactor sites is attributed to two factors: (1) limited staff resources, and, (2) the inspection priority directives given by the regional reactor projects people.
For FY88, it appears that 10 CFR Part 61 inspection coverage at power reactors will be similar to FY87.
Both of the inspectors that perform low-level waste inspections were acccmpanied by their Section Chief during the review period, i
5.4 Low-Level Waste Disposal Site Inspections I
This s' ection is not applicable to this Region.
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, 5.5 Low-level Waste Managenent Initiatives The region is to be commended for implementing the following initiatives:
o Requesting Headquarters to develop guidance on 10 CFR Part 61 enf orcement policy; and Londucting a htvad scope licensing seminar held in April 1987 which o
included training on 10 CFR Part 61.
5.6 Recontendations for Action For the materials inspection program, adopt inspection field note c
formats to include 10 CFR Part 61 and begin annual inspector accompaniments by their Section Chief.
(Region I has comn:itted to these actions already in its July 8,1988 memorandum).
for the reactor inspection program, decrease the current backlog of o
solid radiocctive waste inspections during FY88, and perforn; annual inspections at each facility.
- 5. 7 Headquarters / Region Interaction Region I staff has conc-unicated well with Headquarter on low-level weste managentent inspection r.atters.
The request for low-level waste management guidance perteining to 10 CFR Part 61 enforcement policy, and.the request for assistance with a licensee's man 11est problem are two examples of such interaction.
The Headquarters / Region interaction proved beneficial for both the Region and Headquarters in identifying and surfacing these relevas.t low-level waste manegement issues.
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URANIUM RECOVERY LICENSING AND IfiSPECTION Not applicable to Region I, i
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FTE AND PROGRAM SUPPORT FUNDS UTILIZATION The following tabic shows FTE allocations and expenditures for the review period.
Region I has no program support funds in the NMSS mission areas.
FY88 FYB7 M;t:UAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT.-DEC.
OCT.-DEC.
Materials Licensing 7.8 8.2 105 8.2 2.1 2.4 114 Materials Inspection 16.1 18.2 113 16.3 4.1 4.5 110 Fuel Facility Licensing 0.1 0
0 0.1 0
0.3 Fuel Facility Inspection 2.4 2.2 92 4.1 1.0 0.8 80 SG Fuel Facility Lic.
0.2 0.3 150 0.3 0.1 0.1 100 SG Fuel Facility Insp.
2.0 1.1 55 2.0 0.5 0.1 20 SG Transportation Insp.
1.0 0.4 25 0.2 0.1 0
0 LLW Inspection Total 30.2 30.4 101 31.2 7.9 8.2 104 h0TES:
1)
FY87 expenditures from FY87 RITS RWAT report; section supervisior, prorated.
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.
Proposed revision:
The regional materials licensing and inspection programs are fully staffed with licensing and inspection professionals.
However, as discussed in Section 2.1, there has been a serious shortage of clerical support for these functions which has resulted in the diversion of direct staff to perform clerical duties.
i 0 While the RWAT figures (See Table above) indicate full resource utilization, the diversion of staff to perform critical clerical functions impacted direct expenditures in the materials inspection area.
Another factor affecting direct resource expenditures, in both the naterials licensing and inspection areas, is the number of direct effort hours per staff year. The previous NMSS budget was built with the assumption of approximately 1500 direct effort hours per staff year.
Recently, NMSS recalculated this value for inclusion into the labor rates developed for the FY90 budget and discovered that the Region I rate is approximately 1300 direct effort hours per staff year. Based on actual experience, NMSS also changed the method of budgeting for section supervision in the FY90 budget; this has resulted in a more accurate reflection of direct effort hours per staff year. Both of the above budgetary changes, which will take effect in October, should assist in a more accurate reflection of regional resource expenditures on programmatic accomplishments.
During FY87 in the safeguards and transportation program, Region I under-expended FTEs in inspections due to a shortage of inspector personnel. Based on limited FY88 data, resources are being expended at a rate slightly lower than expected due to limited inspections.
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