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L989 MEMORANDUM FOR:
James Liebeman, Director, Office of Enforcement FROM:
A. Bert Davis, Regional Administrator, Region III
SUBJECT:
NON-CITED VIOLATIONS Enforcement Gu Mance Memorandum 89-04 On April 4,1989, you issued the subject Enforcement Guidance Memorandum (EGM) requiring the documentation and tracking of licensee-identified Severity Level IV and V violations which are not cited in a Notice of Violation as permitted by Section V.A of the Enforcement Policy. We understand that the purpose of this effort of documenting and tracking licensee-identified non-cited violations is to provide a basis for evaluating past licensee perfonnance in an inspection area. We are concerned that any past performance database predicated on whether an inspector chooses to document a specific non-cited violation in an inspection report would be flawed and, if used, would not provide with acceptable confidence a proper evaluation of licensee past performance.
Licensee-ideatified violations which result in LERs pursuant to 10 CFR 50.73 are already~ evaluated, documented in inspection reports, and tracked. Other i
licensee-identified violations are documented internally in the licensee's corrective action system and'are tracked within the licensee's organization.
A very small percentage of those licensee-identified violations end up being documented in an NRC inspection report.
It would not be unusual for the licensee to have over one thousand licensee-identified violations within their corrective action system each year.
We believe a more appropriate way to ensure'prcper consideration of licensee-identified past performance problems when considering enforcement matters would i
be to ensure that our inspectors examine the internally identified weaknesses within a given area during their inspection of that area.
This could be accomplished through revision to the NRC inspection procedures requiring review of the licensee's corrective action systems. We are implementing the section of the EGM dealing wi,th NRC-identified Severity Level V violations which are not cited. This dataset will be cosplete and the database will provide useful information. However, we have held in abeyance the implemer.tation of the aspects of the EGM dealing with licensee-identified violations awaiting your consideration of these matters.
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APR 4 1969 agional Administrators NCVs may be referenced in the cover letter to thw inspec report at the Regions option.
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NCys should be identifies in the inspection reports summa of findings, in the same manner as cited violation 6.
during this unresolved items. violations (NCV) were identifie inspection period....'
The NCVs should be documented in the curre
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for NCVs.
When the 766 is replaced, the new system will continue 7.
track NCVs.
i tain the As with other violations, it is the Regions responsibility to ma n NCY data in 766 data current, identify emerging trends, and lated enforce-d to include ment actions.
The above procedures have been coordinated with MRR and th them in the next update to MC 0610.
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William Troskoski (X23281) or me. -Lw James Lieberman, Director Office of Enforcement L. Chandler, OGC cc:
J. Partlow, NRR F. Hebdon, NRR.
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[r wo UNITED STATES NUCLEAR REGULATORY COMMISSION
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September 27, 1990 MEMORANDUM FOR:
Those on Attached List FROM:
Glen L. Sjoblom, Deputy Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
FINAL NMSS NATIONAL PROGRAM REVIEW REPORTS FOR 1990 The NMSS reports providing final documentation of the results of the National Program Review for 1990 have been completed, following incorporation of suggestions from the Regions.
The results had been shared by the NMSS teams during their earlier visits to the Regions.
This report is for information and record purposes and a response is thus not necessary.
G en L. Sjoblo Deputy Director Division of In ustrial and Medical Nuclear Safety, NMS
Enclosure:
As stated l
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1 MEMORANDUM FOR THOSE ON THE ATTACHED LIST Dated: 9/27/90 Malcolm Knapp, Director Division of Radiation Safety and Safeguards, RI J. Philip Stohr, Director Division of Radiation Safety and Safeguards, RII Charles E. Norelius, Director Division of Radiation Safety and Safeguards, RIII Arthur B. Beach Director Division of Radiation Safety and Safeguards, RIV Ross A. Scarano, Director Division of Radiation Safety and Safeguards, RV
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REPORT OF NMSS NATIONAL PROGRAM REVIEW AT NRC REGION III, MARCH 8-9, 1990 1 BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety and 1
Safeguards (NMSS) review of Region III programs under the Headquarters respon-sibility of NMSS. The Headquarters team participating in this review consisted of four persons from the Division of Industrial and Medical Nuclear Safety of NMSS, one from the Division of Safeguards and Transportation, one from the Pro-gram Management, Policy Development and Analysis Staff, and one from the Office of Enforcement. One member of the team was from the Region II office. Addi-t>unal input was received from other elements of NMSS. The principal regional activities are primarily under the responsibility of the Region III Division of Radiation Safety and Safeguards (DRSS).
The DRSS organization chart is shown on Attachment 2.
A January 8,1990 memorandum from Richard Cunningham listed the areas to be covered and transmitted a questionnaire to the regions.
Region III responses to the questionnaire are shown on Attachment 3.
T a National Program Review (NPR) is based not only on the visit to the Region, but also on the collective Regional / Headquarters interfaces throughout the year, through review of some licensing casework, inspection reports, accompaniments of region-based inspectors, review of casework and inspection statistics, resource utilization, technical assistance and coordination, and the questionnaire.
It is intended to provide a review of effectiveness of both the Region and Head-quarters activities insofar as they relate to Region III activities and to identify suggestions for improving safety and the effectiveness of the joint efforts of NMSS, OE and Region III
,The emphasis relates to achieving two goals:
technical quality and timely completion of licensing casework and inspections, on the basis that both elements contribute to assuring the safety of operations involving NRC licensed activities.
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The report is organized so as to present an integrated summary in each of the following areas:
1.
Background and Purpose 2.
Licensing 3.
Inspections 4.
Enforcement
. 5.
Training 6.
Initiatives 7.
Interfaces of Region / Headquarters 8.
Resource Utilization 9.
Recommendations / Suggestions e
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2 LICENSING 2.1 Materials Safety Region III currently regulates a variety of material licenses from simple gas chromotography to complex broad research and development licenses.
In FY89, Region III completed 2159 material licensing actions against an operating plan goal of 1735 (124.4 percent). The number of backlogged cases dropped dramatically from 149 in October 1988 to 31 in September 1989.
The licensing program is currently fully staffed.
Reviewers and the Section Chief are aware of the licensing goals for the fiscal year, and the Section Chief has a system for tracking case completions versus budget and timeliness of pending actions. Although the actual completions are less than budgeted at this time for FY90, Region III has completed approximately the same number of cases that it has received. The material licensing goal shortfall appears to be due in small part to the shortage of license renewal receipts, the use of a senior licensing reviewer for problem licenses cases and lost time due to training of less experienced staff.
Region III, Material Licensing Section performs most'of the licensing reviews and does perform inspections as required.
It is evident that the licensing Section Leader and senior reviewers have formed a strong management team that provides clear direction to the licensing staff.
Headquarters staff reviewed about 10 percent of the completed licensing actions.
These ' ons were in accordance with Standard Review Plans and other guidance documenos.
Region III staff has sought guidance via telephone or technical assistance requests on matters that are technically complex or may have policy implications.
The Haterial Licensing staff has developed and implemented an effective procedure for identification, tracking and followup of expired licenses.
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2.2 Fuel Cycle Licensing All resource-intensive licensing actions for fuel cycle facilities and contaminated site decommissioning are either performed by NMSS or directed by NMSS; thus, fuel cycle facility licensing is a small part of Region III workload. The Region has provided input to NMSS in licensing actions.
Licensing actions by Region III have been correct and issued efficiently.
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3 INSPECTIONS 3.1 Materials. Inspections 4
In FY89, 833 materials safety inspections were completed compared to a goal of 869. Through February 1990, the Region had completed 353 inspections.
The a.nnual goal is 996, so the Region was behind, but they had reduced their number of overdue inspections to 80. There had been over twice this number in September 1989.
Fewer inspections have been performed as a direct result of the resource demands associated with the escalated enforcement activities. During the visit, the Region assured NMSS that it would continue to pursue the target of 991 inspections, but in May decided to request a change in the operating plan.
No problems were noted in the technical adequacy of their inspections. The Region has recently implemented an inspection scheduling program, where a list is generated monthly identifying 8-10 inspections to be performed by each inspector. The selection priority is to conduct overdue inspections first.
Inspectors are free to add additional inspections to this schedule.
The inspection documentation is of a high quality. The Region is aggressive
. in identifying management weaknesses which may be precursors to significant violations and in using Performance Evaluation Factors to track potential problem licensees. These are handled with transmittal letters identifying these concerns and with early re-inspection of the licensee.
One area where improvement could be made is in responding to licensee's letters which describe corrective actions. At present, the Region only responds when additional information about the corrective actions is needed.
NMSS requested that the Region re-evaluate whether an acknowledgement letter should be sent if the licensee's response to an fiOV is adequate in order to inform them that their i
corrective actions are acceptable.
Several accompaniments with regional materials inspectors were performed during 1989.
In all cases, the inspectors were observed to be professional and to conduct thorough inspections.
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3.2 Transportation Safety inspection Program Inspection Program and Reports Materials.(2800 Program) - During FY89, Region III continued its program of inspecting transportation activities of materials licensees in accordance with MC module 86740.
Field note formats in use are consistent with MC 87100.
Completed field notes from 11 FY89 inspections were audited and found to be thoroughly accomplished. The HQ ongoing review of format reports, NOV's, RNOV's (from RIDS) has indicated that reports continue to be of high quality.
During FY89, of the approximately 3000 materials licenses in Region III, some 833 inspections were performed, during which the transportation module 86740 was covered 399 times, averaging one hour staff time per inspection. Most violations noted were severity levels 4 or 5.
A number of escalated cases have been processed as reactive efforts, wherein transportation violations have been included.
Fuel Facilities-(2600 Program)
All of the major fuel facilities in the region have been inspected against transportation module 86740 at least once since the last program review in March 1989. Only one non-escalated violation was noted, involving excessive surface contamination on a spent fuel cask. The inspection reports in this area also continue to be of high quality.
Reactor Inspcetion Program (2500)
During the last program review (3/89), it was nhted that a major realignment of the responsibility for transportation /LLW activities was taking place.
Essen-tially, at that time the Rad Controls /EP (RCEP) Section (W. Snell) within the Reactor Programs Branch (L. R. Greger) was being tasked to do transportation /LLW inspections at all Region III reactor sites, using a " specialist" approach with one experienced inspector (C. Gill) assisted by a yet-to-be-hired trainee.
No transportation inspections were to be performed by the other experienced inspec-tors in the Rad Controls / Chemistry Section (RCC) (M. Schumacher).
As it turned out the new-hire did not accept the position, and it was subsequently necessary a
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to transfer an experienced inspector (W. Grant) into the RCEP Section to assist C. Gill.
It was also then necessary, in order to accomplish the core program, to assign some of the inspections back to several of the trained inspectors (R. Paul, M. Kunowski, and D. Miller) in the RCC section.
In effect therefore, at present, the inspections are being~done by " generalists" from the two sec-tions, with each inspector assigned a certain number of plant sites / units to cover the " Health Physics" area, which in'cludes transportation /LLW.
It was noted that at least two of the experienced inspectors (W. Grant and D. Miller) will be retiring in the near future, which will necessitate the hiring and training of new replacements.
During FY89, the reactor inspections of transportation /LLW have included essentially only the core inspection procedures 83750 and 84750.
Region III does track the percentage of time expended on the activity areas in each procedure, using a module tracking form maintained by the Chief, RCC Section.
Region III estimates that about 10 percent of the staff hours expended on module 83750 goes into inspecting transportation activities, amounting to about 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> / site.
Region III management feels that core procedure 83750 does appear to be adequate in providing sufficient effort in transportation inspections.
They have stated that if no programmatic weaknesses are found, supplemental modules 86721 or 86740 "may" be utilized as a Regional initiative. Actually, however, in FY89, this amounted to very few instances. Written reports from the transportation inspections continue to be satisfactory.
During discussions with three of the inspectors from the two sections, each expressed a dissatisfaction that comunications are not as good as they used to be (before the realignments), with respect to being kept informed of results of other inspections, problem areas, sharing of information, and having the oppor-tunity to routinely review the inspection reports from the other inspectors.
3.3 Fuel Facility Inspections In FY89, Region III gave its fuel cycle facilities an adequate amount of inspection. The inspections of these facilities have been thorough and com-petently performed, as evidenced by the inspection reports, by inspection accompaniment reports, and by feedback from other NRC staff who have been present.
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l The inspection reports are consistently of high quality. They address open items and their disposition; they state the inspection modules covered and activities conducted. The inspection reports are well written, and issued reasonably close to the timeliness goal.
Observations by NMSS staff accompanying the primary fuel cycle facility inspector and his backup indicate that they conduct the inspections well, and maintain a proper relationship with the licensee.
Region III staff expressed an interest in visiting other fuel cycle facilities to improve their depth of understanding; this might be accomplished by accompaniments on other Region I
inspections, or by visits to DOE facilities.
The Region is to be commended for bringing on a backup to the primary fuel cycle facility inspector.
3.4 Safeguards Inspections Region III fuel cycle facility safeguards activity is only a small part of the Region's total safeguards activity.
However, the Region has appropriately established inspection priorities and allocated appropriate resources for this program. The Region maintains a well trained and highly motivated Safeguards I
staff. Region III continues to maintain effective communications with headquarters ad is responsive to special headquarters' requests and initiatives.
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i 4 ENFORCEMENT 4.1 Background and Purpose This report provides the results of the Office of Enforcement (OE) participation in the NMSS Program Review.
OE's review involved primarily the Region's treat-ment of recurring violations and exercise of discretion under V.G.1 of the Enforcement Policy and for Severity Level V violations.
4.2 Treatment of Recurring Violations In response to the Office of Inspector General's (OIG) recommendations, in a draft report on the Enforcement Process, the Director, Office of Enforcement, requested among other things in a memorandum dated August 2, 1989 and made final by memorandum August 30, 1989 (EGM 89-09) that each Region prepare written instructions to assure that Severity Level IV and Y violations for materials licensees are properly reviewed to determine whether they represent a significant management breakdown (Severity Level III problem) or are repeti-tions and, if so, appropriate enforcement actions are considered.
The regional instructions were to be prepared and submitted to OE within 90 days along with plans for training of regional personnel within six months of issuance of the regional instructions.
Written instructions entitled, " Consideration of Repetitive Violations When Issuing Severity Level IV and V Violations," (RP 0400J) were prepared and issued February 14, 1990.
Formal training was given December 14 and 21,1989.
Discussions with materials inspectors, Section Chiefs, and the NMSS Branch Chief indicated the licensee's history is reviewed prior to inspection. Should repeat violations be identified during the inspection, they are emphasized and discussed with the licensee at the close of inspection.
Upon return to the Region, the repeat violations are discussed with the Section Chief.
Repeat violations are documented in inspectors' field notes or formal inspection 4-1
4 reports.
Inspection letters and Notices of Violation (NOVs) sent to the licensee identify those violations which are repeats.
Tracking of repeat violations is through the documentation kept in the licensee's docket file.
There is no computerized program to track repeat violations.
OE's review of inspectors' field notes, inspection letters and NOV's indicated that repeat violations are being identified and Regional Procedure RP 0400J is being followed.
Region III has considered but not issued any civil penalties at the Severity Level IV for repeat violations in the materials program.
There has been one case where a violation was identified for the third time (Magna Chek, Inc.) The repeat violation was addressed in the cover letter to the licensee, who took corrective measures to rectify the situation.
4.3 Enforcement Discretion V.G.I and Severity Level V Violations Written instructions regarding this topic are contained in Regional Procedure 0400Kentitled"Non-CitedViolations"(RP0400K).
Formal instruction on this subject was given to the regional staff on December 14 and 21,1989. The Regional procedure is enclosed as Attachment 4 Discussion with several materials inspectors indicated that they are aware of and have used enforcement discretion during inspections in accordance with the regional procedure and enforcement policy.
Non-cited violations (NCVs) are documented in inspection reports or inspectors' field notes.
The Region has developed a paragraph to highlight NCVs in the inspection letter giving credit to the licensee for identification of the violation and the corrective actions taken.
The 766 system is used to track NCVs.
4.4 Other Topics Reviewed Audits of non-escalated actions: The Regional Director of Enforcement
{
indicated 80 percent of letters and NOVs are reviewed by his staff, i
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Manual Chapter 0400 Standard Format for non-escalated enforcement actions:
OE discussed Region III's lack of the Docket Number on licensee letters and NOVs. The NMSS Branch Chief indicated he would take action to conform with the Standard Format.
Proofreading: OE discussed errors found in OE's review of 25 non-escalated actionswithissuedatesfromDecember1,1989throughFebruary 15, 1990.
In addition OE discussed the following subjects with management and the technical inspection staff:
Model citations Communications Permanent versus temporary job sites in radiography Reviewing qualifications of new physicians, physicists, RS0's, radiographers etc. during inspection Records violations Report writing, MC 0610 35.999 transition policy Information Notices From these discussions, the following actions items were identified:
OE should issue a Model Citation which has been found acceptable to OGC.
Regions should have a chance to. review these for input, Region III needs to conform with Manual Chapter 0400 Standard Format on i
non-escalated actions.
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OE will continue to review non-escalated actions and develop a more formal review to give feedback to the Regions, h
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5 TRAINING In the area of training, a training plan is developed yearly, which includes 2-3 training courses for each inspector.
With few exceptions, the training was completed.
Each new inspector is given a qualification journal which contains comprehensive self-study examinations, and checkoffs for inspector accompaniments. This process concludts with an oral board with regional management.
The training program as it relates to providing supplemental and developmental training for seasoned, experienced inspectors was reviewed.
Inspectors inter-viewed indicated that improvements have been made in this area especially
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over the past several years.
The Region is attempting to allow professionals to attend at least one professional development course on an annual basis, personnel interviewed indicated that they had received developmental training recently, e.g., RERO, professional society meetings, OSHA training.
In fact, Region III staff comprises the majority of the class for the December 1989 OSHA training.
Because of the increased attention to fuel cycle facilities and to cleanup of contaminated sites, the Region might derive future benefits by directing part of the training of new inspectors toward these areas.
At least six people will need to be furnished with the transportation training course H-308, all from the Reactor Programs Branch. At the present time, all of the inspectors in the two Materials Inspections Sections have had this training. Several of the license reviewers have also had this training, however it apparently has not been a request.
Region III did send 4 materials inspectors to the most recent H-308 course at TT,C in October 1989.
The materials licensing staff believe they would benefit from having someone from the Division of Low Level Waste Management and Decommissioning come to Region III when a financial certification plan is recived to train licensing 6-1
3 reviewers on how these plans should be reviewed and handled.
The Headquarters NMSS team Connitted to inform the appropriate Division in the program of this Concern.
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1 6 INITIATIVES BY THE REGION Consistently applied performance evaivation factors to identify weaknesses in licensee programs.
Scheduled and planned inspections monthly at the Branch level.
Drafted an Information Notice on Part 21 after the Region identified inadequacies in several licensees' Part 21 procedures.
Initiated special " lessons learned" training based on inspection experiences.
Conducted an emergency drill at Combustion Engineering-Hematite.
Developed teletherapy servicing checklist for inspections.
Initiated management audits of enforcement correspondence.
Detected and initiated corrective action when management found some less-than-adequate responses to NOV's from licensees had been accepted.
Trained a backup fuel facility inspector.
Had Branch Chief accompany inspectors.
Conducted phannacy workshop in Chicago.
Provided significant input and support to national workshop with Agreement States in November 1989.
Provided supplemental training to staff by attending professional society
- meetings, i
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Developed inspector's guidance book which details procedures for such activities as preparing PN's, the morning report, etc.
Conducted cross training between inspection and licensing staffs.
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t 7 HEADQUARTERS / REGION III INTERACTIONS Both NMSS and Region III believe that interactions have been useful and effective in all the areas in inspection and licensing.
Region III has been very respon-sive to NMSS requests for information or short term requests for.special inspec-tions.
Region III has kept NMSS aware of developing issues and coordinates actions closely with NMSS.
Materials licensing and inspection staff and NMSS have been well represented at workshops and seminars conducted during the past year.
The interaction between Headquarters and Region III. staff continues to be excellent with respect to transportation matters.
Interaction between Headquarters and Region III fuel cycle staff has been extensive and is considered excellent.
Region III staff have been able to attend several important meetings between NMSS and fuel facility licensee management, and this has helped maintain the regional understanding of the status of the licensing activities, and has provided regional insight.
Region leadership, however, remarked that there were occasions when they had not been informed of such meetings early enough to permit rearranging their schedules.
More effective interactions between NHSS and the region at the planning stage for an operational safety team assessments (MC2600) could significantly improve the coverage of this assessment in all areas appropriate to operational safety.
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8 RESOURCE UTILIZATION The attached table shows FTE allocations and expenditures for the review period.
Region III has no program support funds in the NMSS mission areas.
During FY89, Region III expended approximately 92 percent of the budget resources for the NMSS programs.
The slight deficiency was a result of not being fully staffed. The Region has been aggressively recruiting personnel for the Nuclear Materials Safety program. The Region has hired three new inspectors and three new reviewers which has corrected the situation noted in the final FY89 National Program Review Report ',hereby inspection staff was 4.0 FTE below the budget. The Region needs to continue allotting overhire positions to assure NMSS functions are fully staffed.
Region III completed 833 materials inspections in FY89 versus a goal of 869 (96 percent). Through February FY90, Region III completed 353 materials inspec-tions versus a goal of 418 (84 percent). A significant number of inspections were completed in January and February due to management's attention to this area.
In FY89, they completed 2159 materials licensing actions versus a goal of 1735 (124 percent). This was. a_ciomplished with expenditures in excess of resources budgeted. During this same period, Region III has achieved a significant reduction in pending materials licensing cases.
In the first six months of FY90, Region III completed 921 materials licensing cases versus a goal of 1105 (83 percent). There has been a notable significant decrease in backlogged casework in Region III since October 1988 (149 versus 31 in March 1990).
Region III is providing assistance to Headquarters in the threat assessment area.
Currently there are no resources in the budget for this effort.
The majority of Regional expenditures for FY89 were under expended in all NMSS mission areas. This trend is continuing in FY90, but due to aggressive recruiting and hiring, Region III has been fully staffed as of January.
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I RESOURCE UTILIZATION FOR RIII REGION III RESOURCE UTILIZATION The following table shows FTE allocations and expenditures for the review period
.FY90 FY89 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT-JAN. OCT-JAN.
Fuel Facility Licensing 0.04 0.03 75 0.05 0.02 0.001
-5 Fuel Facility Insp.
3.3 1.2 36 2.0 0.7 0.4 57 Materials Licensing 7.0 9.3 133 9.8 3.3 3.2 97.
Materials Inspection 15.1 12.8 85 14.4 4.8 4.7 98 Event Evaluation 1.4 1.7 121 1.9 0.6 1.0-117 NMS Section Super.
2.9 3.6 124 3.5
-1.2 1.2 100 NMS Subtotal B'.7~
E 96 3T E TG IE T
SG Fuel Facility Lic.
0.2 0.1 50 0.2.
0.07
.01 14 SG Fuel Facility Insp.
0.1 0
0.1 0.03
.01 33 SG Transp. Insp.
0.24 0
0.24 0.08 0
0 NMTS Section Super.
0.2 0.02 10 0.1 0.03
.003 10 SG Subtotal G
H 16 G
G
.023'
.11' LLW Inspection 0.25 0
0
'O.25 0.08 0-0 Reactor Decomm.
0.1 0.1.
100 0.2 0.07 0
0 Materials Decomm.
0.5 0
0 0.5 0.2 0.2 100 LLW Subtotal G
E 12.
E G
U T/
NMSS Total 31.29 28.85 92 33.24 11.18 10.7 96 NOTE:
FY89 expenditures from regional input provided in response to FYP/ Green Book update in 12/89.
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a 9 RECOMMENDATIONS / SUGGESTIONS 9.1 For NMSS:
1.
Continue to plan workshops based on interest areas.
2.
Consider region based workshops for training of license reviewers.
3.
Establish a better notification system to alert regions when a sealed source and device review is completed so that accompanying amendment is quickly acted upon.
4.
Provide in region training on actual funding plans when they begin to arrive.
5.
Reconsider having inspection staff complete medical quality assurance questionnaires.
6.
Develop a new medical preceptor form.
7.
Work with the Technical Training Center and the Office of Governmental and Public Affairs to provide more opportunities for new staff to attend basic health physics courses such as at ORAU.
8.
Inform Regien III when scheduling meetings in NMSS with Region III licensees well in advance of the meeting time.
9.
Reassess resources provided for enfor' cement activities.
9.2 For OE:
1.
Provide opportunity for region to comment on proposed standard citation list.
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2.
Provide guidance on enforcement regarding implementation of the decommissioning rule.
9.3 For Region III:
1.
Consider including transportation as a part of team safety assessments.
2.
Identify areas where licensing and inspection staff feels additional or upgraded NMSS guidance would be useful.
3.
Consider notifying licensees when the Region finds a response to an NOV to be an acceptable 0400 and consider decision not to aknowledge an acceptable response to an NOV.
4.
Continue the use of overhires to assure full staffing. Anticipate staff increases budgeted in FY91 and FY92.
5.
Examine current phone system and call forwarding policy to determine cause of nonanswered phone calls.
6.
Region III management should monitor very closely the progress, or lack thereof, in the realigned assignment of inspections of transpor-tation/LLW to the two Reactor programs Branches. Actions should be taken to enhance comunication regarding inspection results between and within the two sections.
7.
Continue excellent support of seminars and workshops.
8.
Continue excellent support of rotational assignments with other regions and HMSS.
9.
Consider having inspectors. accompany Region II during fuel facility inspections.
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Headquarters Review Team
- John Glenn, Chief, Medical, Academic and Comercial Use Safety Branch, Divsfon of Industrial and Medical Nuclear Safety, NMSS Michael Lamastra, Leader, Comercial Section, Medical, Academic and Commercial Use Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS Jerry Swift, Leader, Advanced Fuel and Special Facilities Section, Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS Cheryl Trottier, Leader, Programatic Safety Section. Operations Branch,
. Division of Industrial and Medical Nuclear Safety Alfred Grella, Sr., Transportation Specialist. Domestic Safeguards and Regional Oversight Branch, Division of Safeguards and Transportation, NMSS Elizabeth Jacobs-Baynard, Program Analyst, Program Analysis Branch, Program Management, Policy Development and Analysis Staff NMSS Team Member.From Region II William Cline, Chief, Nuclear Materials Safety and Safeguards Branch, Di-vision of Radiation Safety and Safeguards, Region II t
- Team Leader A-1
DIVISION OF RADIATION SAFETY AND SAFEGUARDS l
Strector C. E. acratius Deputy Ofrector vnCAut feCh. estt.
O. G. Wiedesen Secretary M. Meenan i
Reacter Progrees stanch L. R. Greger, Chief mu teer Meterlets safety tranch Roseter Programs Spec., VACANT B. 3. Mettett, Chief A. Putte, Secretary J. E. Leser, Secretary Radiotegiset Centrets &
Radletaticot Centrole &
Safetuseds Section Cheatstry Seattert Emer. Preo. Section Materiste Licenelne Nuclear Meterfele Safety Duclear Materlate safety section section 1 l
l l
Section 2
- 83. C. Schumacher. Chlef W. G. Snett, Chlef J. R. Creed. Chlef C. M. McCarn. Chief D. J. trenlawski, Chlef R. J. Cenlane, Chief s
E. 3. Andre D. % Scree J. L. Selenger
- 2. 3. settaman J. E. Foster W. J. Adam C. M. Christcffer C. C. Casey J. L. Lynch **
J. f. souse C. f. Sill I. P. Cetloff C. M. France A. 8. Janugka W. S. Grant J. s. Ensceter C. f. fretter E. R. Mateen I. J. Madeds D. a. Citzbons M. A. Kuiouskt R. L. Lefrenlere C. L. Pirtle W. T. King
- 2. M. Pankratt R. C. Gattone S. J. m tny D. f. Mitter J. P. Petterson D. A. Nersey C. J. Lambert R. A. Paul
- 1. J. Ploekt L. J. Nuoter
- 8. A. Parker J. R. N11auer YACARI J. D. Jones J. W. Patterson W. P. Reichhold C. L. Sheer J. 4. Madera I. L. $laraone E. G. Mutt W. J. Slawinski P. J. Petke
- e. v. acahon P. R. vacherton Detailed to Pasttien
=*
cbtleeted
=*= notationet Aselgruent to needquarters W
Attachment /
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