ML20055C223
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SEP 2 91988 MEMORANDUM FOR:
John B. Martin Regional Administrator, Region V FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
NATIONAL PROG?AM REVIEW REPORT Enclosed is the National Program Review report for Region V.
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 V this spring.
A draft of this report was sent to Region V for comment on June 20, 1988.
The conments in Region V's recent response have been incorporated in this report.
Region V deserves credit for exceeding its Operating Plan connitments for the materials licensing and safeguards programs.
The Region also has a good inspection program and conducted itself well during and after the U. S. Testing and Finlay radiography inspection efforts.
The Region has significantly upgraded the quality of their transportation inspection effort for material licensees since our last assessment.
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 conments, and produce a final report within 30 days after receipt of your conments.
Please let us know how we can continue to img) rove tge National Program Review process.
M Rooert Ber-"
[ Hugh L. Thompson, Jr., Director Office of Nuclear f4terial i
Safety and Safeguards i
Enclosure:
As stated s
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V. Stello J. Taylor h
DISTRIBUTION:
N IMDB r/f NMSS r/f IMNS Central CEstep CJenkins GDeegan RWilde JHickey HThompson RECunningham RHall RBernero g
GGardes SBahadur MKnapp AGrella q
RBurnett.
SEE PREVIOUS CONCURRENCE
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4 REPORT OF THE 1988 NATIONAL PROGRAM REVIEW 0F DECENTRALIZED NMSS ACTIVITIES AT REGION V 1.
INTRODUCTION The purpose of this report is to document the National Program Review of decentralized NMSS licensing and inspection programs at Region V.
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 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 This review is based on an examination of completed licensing actions, telephone discussions held with licensing staff throughout the year, and classroom discussions at licensing workshops.
Region V completed 204 licensing reviews in FY87, compared to its adjusted Operating Plan goal of 164. This is 124% of the adjusted target.
During FY87, on average new application reviews were completed in 38 days and amendments in 36 days. Overall turnaround average for all cases, including renewals, was 44 days in FY87.
For the first six months of FY88, Region V completed 103 licensing reviews, compared to its adjusted Operating Plan goal of 90 (114%).
(Revisions are sometines necessary to correlate projected completions with actual receipts.) During the review period, the number of cases pending has remained relatively constant at 29 (in Oct. 86), 39 (in Oct. 87) and at 35 (in March 88).
During FY88, timeliness continues to be outstanding with reviews completed in about 50 days.
Headquarters staff reviewed about 50% of completed actions.
Licensing actions are performed in accordance with applicable Standard Review Plans and are of high quality with few technical or clerical errors. Section and branch-level management play an active oversight 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 improved handling of licensing actions. The staff has implemented a prelicensing visit program to help ensure there are no misunderstandings on the part of the licensee regarding responsibilities.
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2.2 Materials Inspection i
1 The content of this item incorporates feedback from one inspection accompaniment; implementation of guidance provided in NRC Manual Chapters and Inspection Procedures applicable for the materials inspection program; discussions with regional staff throughout the year; during the regional assessment visit on March 16-17, 1988; review of regional inspection reports; notices of violation and NRC Form 591's; and an analysis of Licensing Management System and 766 system sunnary listing of inspection efforts on the relevant inspection modules.
The Region completed 132 materials inspections in FY87, and completed 63 more in the first six months of FY88.
It projects to complete its FY88 goal of 156 inspections by the end of the fiscal year.
Region V conducted an extensive inspection of the radiography firm, Finlay Testing Laboratories, in conjunction with the Office of Investigations.
The inspection was conducted from September 1987 when the original license suspension was issued until early May 1988 when a settlement was negotiated with the licensee.
The resulting inspection report and notice of violations which ns the basis for a Show Cause Order, was so thorough in documenting the willful disregard of the regulations that the licensee agreed to license termination without a hearing.
l Region V continues to coordinate the oversite of U.S. Testing Company with the other regions and several Agreement States.
U.S. Testing is i
still operating under an Order modifying the license which requires them to provide radiation safety controls on a site-by-site basis.
Region V is reviewing U.S. Testing's efforts to reestablish a nationally controlled program but has determined that the program is not yet at the stage to rescind the Order.
i No adverse connents or negative observations were observed as a result of the inspection accompaniment.
During the acccmpaniment, it was observed that Inspection Procedure 87100 was followed, as well as guidance given
4 in Manual Chapter 2800.
Inspections were thorough and missionary work was provided for licensees with weak programs. Entrance and exit interviews were conducted properly and results of the inspections were clearly conmunicated to the appropriate licensee management level.
Temporary Instructions (TI) 2800/8, inspections on drilling platforms in off-shore waters under federal jurisdictions by Regions IV and V, and Temporary Instruction 2800/12, Apparent Abandonment of Nuclear Pace-maker Programs, were well-coordinated and completed as requested. Processing of NRC Form 241, and inspection of Agreement State licensees operating under the reciprocity provisions of 10 CFR 150.20, were consistent with the guidance in Manual Chapter 1220.
Region V has an efficient centralized inspection scheduling system.
Management is very supportive of staff training. The inspectors and licensing reviewers have completed the training requirements of Manual Chapter 1245 " Inspector Qualifications." There are plans for refresher training.
The inspection reports and noti s of violations are well written.
Managenent performs a careful review of each notice of violation and inspection report which ensures the accuracy of each violation.
There were six overdue inspections in Priorities 1 and 5.
This is a result of shortage of inspection resources due to allocation of resources for assistance to the Office of Investigations.
On the average, inspection reports were issued in 11.5 days compared to a goal of 20-days. The average time spent per inspection was shown in the computer as 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />; the average time per inspection for other Regions was five hours. This was explained by the regional staff that this was due to large 01 expenditures for two cases.
In fact, Region V data indicate that the average number of hours per materials inspection, excluding U.S. Testing, Finlay, and the fuel fabrication facilities was 6.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />.
5 2.3 Fuel Cycle Inspection The fuel cycle inspection program has been conducted in accordance with Manual Chapter 2600 and the applicable inspection modules using appropriate Region inspection specialists to support the fuel facility inspector.
It was noted that the Nuclear Materials Safety Section, should assure that the inspection specialists receive appropriate orientation on the requirements of the specific license prior to the inspections.
Inspections are scheduled each calendar quarter, based on the required inspections to complete the assigned modules for each facility during the year.
The documentation for inspections and related actions have been timely and consistently of good quality. The program has been conducted in a technically sound and accurate manner within allotted resources.
2.4 Fuel Cycle and Materials Safety Initiatives Region Y establishes good working relationships with applicants and o
licensees by conducting prelicensing visits; The Region participates often in seminars and technical meetings, o
i.e., ASNT, Letterman Pharmacy Seminars, Radiography, and Well logging; and The Region does a good job on initial inspections of new licensees.
o 2.5 Recomnendations for Action 1
l Region V should continue the missionary work, when appropriate, and o
its effective communication with licensees. Also, continue nanagement review of inspection reports and notices of violations before they are sent to Headquarters; and
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In regard to the fuel cycle inspection program, the Region o
recommended that Temporary Instructions should be used more to focus inspection effort for new initiatives and to reduce the effort in other areas at the same time.
It was also noted that TI-2600 (2600-06) should be further revised to provide guidance on what the time interval should be between the original team assessment for a facility and the renewal assessment. The Region expressed a need for further training for the current program as well as on new initiatives introduced to the inspection effort.
2.6 Headquarters /Recional Interface Headquarters will take into account the impacts of escalated
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o enforcements and prosecutions for wrongdoing on routine licensing and inspection effort; Region V requested that more resources be budgeted for the above o
events; i
o Region V felt that the materials conference calls were useful.
It was suggested that periodic, regular teleconferences (or meetings) also be held between regional and Headquarters staff regarding the fuel cycle regulatory program; and Licensing workshops are valuable, according to Region V but they o
need to be more focused on solutions.
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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 The review of the inspection program covered physical security cases.
inspections. Material control and accounting inspections will be covered in FY89.
3.1 Safeguards Licensing Program The Region V staff maintains a complete set of Regional Guidance Documents, Standard Review Plans, and supplementary Region V instructions related to the licensing process for the technical guidance of license case reviewers.
The Region V documentation has been updated with the latest changes and is consistent with NRC policy and guidance.
The 10 CFR 70.32/72.84 case reviews were performed in a sound, technical manner.
The reviews were complete and generally consistent with NRC policy and guidance.
Incon-sistencies noted during reviews were discussed with licensees and resolved.
Correspondence from Region V was forwarded to Headquarters in a timely manner and properly marked.
Region V achieved an average case turnaround time of 54 days in FY88.
Licensing review completions have exceeded the Operating Plan goals.
Region V completed 10 licensing reviews in FY87 versus five planned licensing reviews.
Region V completed three licensing reviews in FY 88 versus three planned review completions. Region V utilized the NMSS Operating Plan Caseworks Statistics Report #41 to keep Headquarters informed of licensing caseworks status on a monthly basis.
The Region V license reviei<ers were trained at Headquarters in 1982, and the Region has cross-trained additional inspector staff to perform licensing reviews and provide back-ap capability.
8 3.2 Safeguards Inspection Program The Region V staff maintains a complete file of all NRC publications, documents and guidance on planning, conducting, reporting, and follow-up requirements for inspections.
In addition, Region V has issued regional guidance to supplement NRC guidance to the technical staff for the purpose of assuring uniformity in planning, conducting and reporting inspections.
The Region V publications and documents are up-to-date and consistent with NRC policy and guidance. Region V physical security inspection reports were technically sound and consistent with Headquarters and regional policy and guidance.
Supporting evidence for findings and conclusions was included in the inspections reports and clear documen-tation for violations and unresolved issues was included where applicable.
The Division of Safeguards and Transportation staff accompanied a Region V inspector on a physical security inspection at GA Technologies, San Diego, CA,
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in February 1988.
During the inspection the Region V inspector visited the FBI point of contact at the FBI office in San Diego to maintain the Region Y liaison contact with the local FBI.
The inspection was performed in a thorough, comprehensive, technically competent, and professional f
manner.
j Although safeguards regulations do not specifically require fuel facility licensees to establish and maintain physical security quality assurance programs, the Region V inspectors do inspect three modules which fit the definition of quality assurance as "those planned and systematic actions necessary to provide adequate confidence that 3 system or component will perfonn adequately in service." These modules include the Security Program Audit Module, the Records and Reports Module and the Testing and Maintenance Module. The inspectors reviewed records and reports and observed implementation of procedures when possible.
4 Region V established an outstanding Division of Radiation Safety and Safeguards planning and scheduling system and produced the FY88 Master Activities Plan.
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The Plan identifies fuel facilities to be inspected, type of inspection modules to be included in the inspections, target date of the inspections and lead staff through FY89. The plan is refined each quarter.
Region V met the inspection goals established in the Operating Plan and in Manual Chapter 2681 and has scheduled inspections through FY89 to meet the requirements in Manual Chapter 2681. Region V conducted two Category I physical security inspections of two scheduled in FY87, and one of one scheduled through March 31, 1988. Region V also completed one Category II physical security inspection of one scheduled in FY87, and one Category III physical security inspection of one scheduled in FY87.
Region Y staff followed published NRC guidance and instructions in utilizing the 766 system. However, the staff noted that the 766 system does not provide current data and the system does not produce all of the infonnation needed by supervisors.
Region V has not had any turnover among the safeguards inspectors in the past three years. Region V maintains an internal audit system which audits the status of training and refresher training. The Region V audits assist in assuring that the safeguards inspectors receive refresher training required by Manual Chapter 1245.
3.3 Licensing and Inspection Initiatives t
Region V is to be commended for the following initiatives:
o Region V worked with Region III in providing technical assistance to Region III for an MC&A inspection in August 1987. Region III provided assistance to Region V for the physical security inspection program.
Region V procured a lap top computer which is used by inspectors o
during inspections to process draft inspection reports. This initiative has improved the efficiency of inspectors in providing more timely inspection reports.
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10 3.4 Recommendatfons for Action No recommendations noted.
3.5 Headquarters / Regional Interaction Region V has been very responsive to Headquarters' requests for the following actions:
Region V trained physical security inspectors in safety and health o
physics procedures to enable the inspectors to perform transportation safety inspections in conjunction with their safeguards inspections; Region V inspectors completed special comparability inspections within o
the time requested by Headquarters and submitted reports in a timely manner; and Region V staff reviewed all Region V 10 CFR Part 70 special nuclear o
material licensees possession limits and holdings to verify the correct facility category for inspection purposes.
Region V Suggested that inspectors from each region perform a limited number of inspections in other Regions as part of a cross-fertilization program designed to improve uniformity and efficiency of the safeguards inspection program.
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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 en completion of transportation inspections credited to Modules 86740 and 86721, discussions with regional staff during the assessment visit on January 25-26, 1988, and one accompaniment inspection with a Region V inspector to the Palo Verde 1-3 Nuclect Stations in Arizona during February 22-24, 1988. The review of the Transportation Safeguards Inspection Program is based on review of completed inspection reports, analyses of 766 data on completion of transportation safeguards inspections and discussions with regional staff during the assessment visit on February 5,1988.
4.1 Transportation Safety Inspection Program 4.1.1 Materials Licensees A significant improvement in the coverage of transportation during the inspection of materials licensees was noted. Completed field notes from 12 recent materials inspections were randomly selected for examination.
All were found to contain complete entries of information relating to transportation activity. Additionally, the formats of all of the field i
notes confomed to the appendix tc Inspection Procedure 87100, except for the medical inspection fonn, which had not yet been revised to
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incorporate a minor revision issued last year by Headquarters. This form was revised at the time of the NMSS review and the revised fom is currently in use by Region V.
l Region V has in its area about 333 active materials licensees of which 132 were inspected in FY87.
Eighty-seven of the inspections covered module 86740 resulting in 14 transpo tation violations of Severity Levels 4 and 5.
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4.1.2 Fuel Cycle Facilities I
In the Region V area, there are five active fuel cycle facilities.
During FY87,14 inspections were performed with module 86740 covered at least once per facility. The inspection reports continue to indicate sufficient depth of coverage of inspections of transportation activities.
The Nuclear Materials Safety Section has recently been provided with additional FTE's from the Emergency Preparedness Section to assist on fuel facility inspections.
4.1.3 Reactors Region Y has in its area a total of 12 operating power reactors at seven locations. One of these, Humboldt bay, is nearing completion of decommissioning. Records indicated that the programmed annual inspection of transportation activities for FY87 was completed and for FY88 complete by March 1988.
Inspection reports continue to be thorough, complete, and timely.
Six operating research reactors are located in Region V, with a large number of others either mothballed or undergoing decommissioning.
All of the operating research reactors were inspected during the year using i
supplemental module 86740.
Reactor inspections resulted in a total of five non-escalated transpor-tation violations.
No escalated actions or referrals from Washington or Nevada involving Region V licensee waste shipments were noted.
The Section Chief accompanied assigned inspectors at least once during the past year, howsver, the transportation mcdule was not programmed for coverage during these inspections.
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13 4.2 Transportation Safeguards Inspections Region V was not scheduled for safeguards transportation inspections in FY87. Region Y completed two of the three transportation safeguards inspections scheduled for FY88. The inspection reports were technically complete, consistent with NRC policy and guidance and submitted in a timely Region V is ahead of schedule in meeting its Operating Plan manner.
goals.
4.3 Regional Initiatives Region V is to be commended for:
Completion of the transportation course H-308 by all inspectors o
assigned to inspect transportation activities, through attending the course at Technical Training Center or at Region V in December 1987; Significantly upgrading the quality of their transportation o
inspection effort of materials licensees since the last assessment; and J
Submitting suggestions to Headquarters on actions that might be taken o
to improve materials licensees awareness of and compliance with transportation regulations.
l 4.4 Recommendations For Action No recommendations.
4.5 Headquarters / Regional Interaction Region V staff has had a 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 our review of the completed inspection reports, analysis of 766 system data of low-level waste inspection reports credited to inspection modules 84850 and 84722, two accompaniment inspections to Advanced Nuclear Fuels, Inc.
and the Palo Verde Nuclear Generating Station, and discussion with Region V staff during the visit on February 25 and 26,1988.
5.1 10 CFR Part 61 Low-Level Waste Inspections - Materials For the materials inspection program, 30 inspection reports were credited to the inspection of low-level waste of the 132 inspections performed in FY87. The number of actual low-level waste inspections performed by the Region may be higher than the 30 reports attributed to Inspection Procedure 84850 since Region V inspectors credit other inspection modules, such as 83822 and 87100, for their low-level waste inspection efforts.
As part of the NMSS National Program Review, Region V's materials inspection files were examined at the Region V offices to determine the completeness of the inspector field notes. Of the twelve files selected, all were found to have been adequately completed and of excellent quality.
The formats of the inspector field notes were reviewed and all but one, the medical inspection form, were determined to be consistent with the recommendations provided in Inspection Precedure 87100 Appendix.
s 15 5.2 10 CFR 61 Low-Level Waste Inspections - Fuel Cycle Facilities With respect to the Part 61 inspection program for fuel cycle facilities, all major fuel facilities were inspected during the review period. The low-level waste inspection coverage at these facilities is provided by staff of the Nuclear Materials Safety Section. The low-level waste management's inspection accompaniment in June 1987 showed inspection coverage of the facility's low-level waste management program to be thorough and of excellent quality.
The inspection reports of these facilities are prepared on a timely basis.
5.3 10 CFR Part 61 Low-level Waste Inspections - Reactors At power reactor facilities, low-level waste inspections were performed at 11 units of the seven reactor sites, with an average of five hours spent per inspection.
One unit, 'Palo Verde 3, was not generating low-level waste, which accounts for this unit not being inspected. Another unit.
Humboldt Bay, is at the final stages of it decommissioning. Therefore, the FY87 low-level waste inspection coverage at reactor facilities is 100%.
The Facilities Radiological Protection Section Chief accompanied each of his inspectors on an annual basis during the review period.
5.4 Low-Level Waste Disposal Site Inspections The inspection of the special nuclear material license at the Richland, WA, low-level waste disposal facility is assigned as the responsibility of the Nuclear Materials Safety Section. Currently, this facility is scheduled for an annual inspection frequency.
The disposal facility inspections have been perfonned in accordance with all of the inspection requirements and have provided excellent feedback to Headquarters on the low-level waste disposal operations utilized at this facility.
The inspector has demon-strated a thorough knowledge of 10 CFR Part 61, and both the NRC and the State of Washington licenses in place at the disposal facility.
Region V has consulted with low-level waste management staff on facility inspection matters and in the interpretation of license requirements.
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The Region is to be commended for its effort in cooperating with low-level waste management staff in developing license requirements which facilitate inspections.
5.5 Low-Level Waste Management Initiatives The Region is to be commended for implementing the following initiatives:
frequent analysis of environmental data and subsequent follow-up o
telephone conversations with the licensee at the Richland, WA, low-level waste disposal facility; and Consultation with low-level waste management staff regarding inter-o pretation of license requirements.
5.6 Recommendations for Action For the materials inspection program, begin crediting the appropriate low-level waste inspection procedure to provide a more consistent tracking System for these inspection efforts.
5.7 Headquarters / Regional Interaction The Region has communicated well with Headquarters on low-level wa'ste inspection matters since the beginning of the review period.
The request for low-level waste management's interpretation of low-level waste site license requirements is an example of such interaction.
These interactions have proven beneficial for both low-level waste management and the Region in identifying and surfacing these relevant low-level waste management issues.
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6.
URANIUM RECOVERY LICENSING AND INSPECTION Not applicable to Region Y.
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FTE AND PROGRAM SUPPORT FUNDS UTILIZATION The following table shows FTE allocations and expenditures for the review period. Region V has no program support funds in the NMSS mission a reas.
FY88 FY87 ANNUAL 8UDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT.-DEC. OCT.-DEC.
Materials Licensing 1.9 1.9 100 1.9
.48
.44 92 Materials Inspection 2.7 3.5 130 3.3
.83
.94 113 Fuel Facility. Inspection 2.1 1.9 90 2.4
.60
.52 87 SG Fuel Facility Lic.
0.2
- 0. 2 100 0.2
.05
.02 40 SG Fuel Facility Insp.
1.1 1.5 136 1.1
.28
.33 118 SG Transportation Insp.
0.1 0
0
.2
.05 00 0
LLW Inspection Total 8.1 9.0 111 9.1 2.29 2.25 98 NOTES:
1)
FY87 expenditures from FY87 RITS RRAT report; section supervision prora ted.
2)
FY88 expenditures from FY88 RITS RWAT report (as of 1/2/88); section supervision prorated.
3)
In FY87, Licensing Assistant FTE (0.7) was added to materials licensing budget allocation.
4)
In FY88, Licensing Assistant FTE (1.0) was added to materials licensing (0.5) and materials inspection (0.5) budget allocations.
+ Resources are included in materials, fuel facility and transportation inspections.
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1 19 The regional nuclear materials licensing, nuclear materials inspection and safeguards programs are fully staffed.
The fuel facility inspection program is understaffed; there is no identified vacancy in the FY88 staffing plan. At the end of April, Region V stated the fuel facility program will remain understaffed and that the excess budgeted resources will be reprogrammed to the materials area due to increased FTE requirements of Finlay Testing.
Overall resource expenditures in FY87 exceeded projections.
Total FY88 resource expenditures are below projections.
During FY87, Region V completed 124% of their revised materials licensing casework goal with actual resource expenditures equalling budgeted projections. Expenditures and casework completions for FY88 exceed projections. Materials licensing labor rates were revised in FY87. The FY87 completions and FTE expenditures indicated that further labor rate changes based on FY87 data were necessary. NMSS reviewed the data and incorporated revised licensing labor rates into the FY90 budget.
Materials inspection resource utilization exceeds projections for both FY87 and FY88. This is due to considerable FTE being expended in technical assistance to 01 for cases such as Finlay Testing. The baseline FY88 operating plan goal indicated Region V would have to complete more inspections than required by following frequencies in Manual Chapter 2800. Region V requested and received an operating plan adjustment due to this.
As discussed above, excess resources are being used for 01 support.
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Fuel facility inspection resource expenditures were under projections in both l
FY87 and FY88.
Region V, however, is completing inspections in accordance with Manual Chapter 2600. Also, there is inadequate administrative support in this j
area. Region V believes their total overhead allocation is insufficient to l
support all of the agency programs they carry out. NMSS sent a memorandum to l
Office of Administration and Resource Management on this subject requesting an l
analysis to support the formulation of the FY90 budget.
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r 20 During FY87 in the safeguards and transportation program, Region V expended over 20% more FTE's than budgeted. Based on limited FY88 data, resource expenditures for safeguards fuel facility inspections are in line with projections. Safeguards fuel facility licensing cases are on schedule and safeguards transportation inspections are running slightly ahead of projections.
In summary, Region V has effectively utilized nuclear material safety mission area resources. They reallocate to high priority areas when circumstances warrant and keep NMSS management informed. They are fully staffed with very qualified professionals that work well together.
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