ML20055C467
| ML20055C467 | |
| Person / Time | |
|---|---|
| Issue date: | 04/17/1990 |
| From: | Sjoblom G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9005070184 | |
| Download: ML20055C467 (21) | |
Text
___
'APR 171990 MEMORANDUM FOR: Ross A. Scarano, Director Division of Radiation Safety and Safeguards, RV FROM:
Glen L. Sjoblom, Deputy Director i
Division of Industrial and Medicil Nuclear Safety, NMSS
SUBJECT:
DRAFT NMSS NATIONAL PROGRAM REVIEW REPORT The NMSS 1990 National Program Review report is enclosed in draft form for Regional comment. The report provides the results of the NMSS review of 1989 programs under the NMSS responsibility as related to your Region. The National Program Review is based not only on the 1990 visit to the Region, but on the
. collective Regional / Headquarters interfaces throughout the year, through review of licensing casework, inspection reports, accompaniment of Regional inspectors, review of casework and inspection statistics, technical assistance, and Regional responses to an NMSS questionnaire. The report is intended to provide a review of the effectiveness of both the Regional and NMSS activities insofar as they relate to Regional activities.
Please provide Regional comments by May 1, 1990. Following incorporation of Regional comments, the final report will be transmitted to the Regions by the NMSS Director.
g gg g.,
C!c L Sioc'lom Glen L. Sjoblom, Deputy Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
As stated DISTRIBUTION:
NRC Center File NMSS r/f IMNS Central File IM08 r/f GDeegan RWilde JHickey JGlenn CHaughney JJohansen PMcLaughlin IMNS RBurnett GSjoblom d., )
0FC :IM08 n
- IMO
- IMAB MSB
- 3GTR
- PMP 0E
- 5 NAME :GDe
/11:RWilde :JH key :
nn : C, ugh RBurnett:PMcLaugh in:JJoha bo1.
f
en:G
\\DATE:04/$/90 :04/ /90:04/g/90:04/7/90:04/
90 :04/{h/90:04/19/90
- 04//6/90 :014/p/90
---p------
0FFICIAL RECORD COPY (NPRRV/MEM0) l 70l Y
2sg.
(L
-4 REPORT OF NMSS NATIONAL PROGRAM REVIEW j
AT NRC REGION V, FEBRUARY 27-28, 1990 1 BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety and Safeguards (NMSS) review of Region V programs under the Headquarters respon bility of HMSS.
The Headquarters team participating in this review consisted of three persons from the Division of Industrial and Medical Nuclear Safety of I
HMSS and one from the Division of Safeguards and Transportation who visited Region V two weeks earlier (Attachment 1). Additional input from other elements of NMSS and the Office of Enforcement was used in the preparation of this re The principal regional activities are primarily under the responsibility of the Region V 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 V responses to the questionnaire are shown on Attachment 3.
The National Program Review (NPR) is based not only on the visit to the R but also on the collective Regional / Headquarters interfaces throughout th through review of some licensing casework, inspection reports, accompanimen of region-based inspectors, casework and inspection statistics, resource utilization, technical assistance and coordination, and the questionnaire.The NPR is intended to provide a review of effectiveness of both the Region and Headquarters activities insofar as they relate to Region V activities and to identify suggestions for improving the effectiveness of the joint efforts of NMSS, OE and Region V.
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 NRC licensed activities.
The report is organized so as to present an integrated summary in each of the following areas:
I
e s
1.
Background and Purpose 0.
Licensing 3.
Inspections 4.
Enforcement 5.
Training 6.
Initiatives 7.
Interfaces of Region / Headquarters 8.
Resource Utilization 9.
Recomendations/ Suggestions I
2
2 LICENSING a.
Materials Safety Region V currently regulates approximately 300 byproduct materials licensees.
In FYB9, they completed 217 licensing actions, as compared against an Opera Plan Target of 206 (105 percent). They received 219 cases during this timeframe.
Through 1/31/90, the Region had completed 64 cases, or 34 percent of the adjust FY90 goal.
The Region has always maintained a low backlog, but over the last year they made a special effort to complete old cases.
In the past twelve months, the g
backlog was reduced from 12 cases to zero.
The Region has completed cross-qualifying two reviewers to support the materials licensing program.
These people split their effort as reviewers and inspectors and reduced the burden on the primary license reviewer.
In addition, the Licen-sing Assistant performs some reviews of the more routine types of licensing casework.
The Headquarters staff reviews a fraction of completed materials licensing actions and inspection reports as they are completed by the Regions. Both licensing and inspection actions are in accordance with Standard Review Pl Inspection Manual Chapters, and other guidance docuinents.
Region V staff has sought guidance via telephone or technical assistance requests on matters that are technically complex or may have policy implications. They have suggested that Headquarters upgrade certain reviewer guides, license conditions and model licenses.
The Region is using telephone contacts for minor deficiencies in licensing submissions.
This has resulted in improved turnaround time and some resource savings.
One item of concern to the regional staff relates to the apparent shortage of qualified Radiation Safety Officers for Veterans Administration licensees, and their reduced access to top management at certain hospitals.
Region V and Headquarters agreed to monitor this item closely.
3
l The Region recommended several actions for NMSS consideration:
)
NMSS should assure that adequate guidance and assistance is provided o
to the Region for implementation of the decommissioning rule, NMSS managers should discuss which inspection program items need to be o
tracked with their regional counterparts at the next Executive Seminar, NMSS should continue to study the proposed two-step licensing process, o
under which final licenses are issued after a site visit by the licensing staff.
This process is most appropriate for medical use licenses, due to their complexity, but may also be suitable for other categories of licensees.
NMSS should update the Service and Training Information System.
o I
b.
Safeguards Licensing Region V completed five 10 CFR 70.32 case reviews during FY89.
These reviews were performed in a sound technical manner and were consistent with NRC policy and guidance.
Region V utilizes the HMSS Operating Plan casework statistics Report #41 to inform Headquarters of the licensing casework status on a monthly basis.
4
3 INSPECTIONS a.
Materials Inspections In FY89,180 materials safety inspections were completed compared to a goal of 127.
This figure includes 31 inspections of the Department of Agriculture, U.S. Air Force and U.S. Navy permittees, which are licensed by other regions.
Through January 1990, the Region had completed 27 inspections. The annual goal is 125, so the Region was somewhat behind, but they had no overdue inspections.
Fewer inspections have been performed as a direct result of the resource demands associated with the escalated enforcement activities with U.S. Testing.
During the visit, the Region assured NMSS that it would continue to pursue the target of 125 inspections.
NMSS performed six inspection accompaniments with materials inspectors in 1989.
In all cases, the inspectors were conscientious and thorough, with a professional rapport with licensee personnel, and with effective use of exit meetings with licensees' management. There was also an awareness of NMSS guidance concerning inspection frequency and recently issued Information Notices, indicating that Region V keeps its inspectors well informed.
The Region is encouraging safety-oriented, performance-oriented inspections that emphasize the licensees' implementation of safety programs rather than paperwork.
As further evidence of Region V's close contact with its licensees, they held a workshop for San Francisco Bay Area medical licensees in FY39 to discuss the regulatory requirements of 10 CFR 35 and the proposed quality assurance rule.
This workshop was well received and another is planned in Hawail later this year.
During the review visit, the Region requested guidance on whether it was acceptable to record uncited violations on the Form 591 for easy reference.
MMSS agreed to discuss the issue with the Office of Enforcement.
5
b.
Safeguards inspections Region V met the inspection goals established in the FY89 Operating Plan and Mr. Burnett's memorandum of August 15, 1988. The physical security inspections and five Material Control and Accounting (MC&A) inspections were completed during FY89.
It should be noted that as of February 15, 1989, the MC&A inspection function was transferred to Headquarters. The region contributed valuable assistance to this transfer and one of their inspectors was assigned to Headquarters. Copies of all inspection reports are sent to Headquarters. Review of these reports show that they are thorough and technically competent.
Safeguards Transportation Inspection Program c.
Region y completed three safeguards transportation inspections in FY89.
In addition, one route survey was performed at the request of Headquarters, d.
Fuel Cycle Inspections The Emergency Preparedness and Radiological Protection Branch was assigned responsibility for fuel cycle inspections in 1989 with a new lead inspector.
The new inspector has been given a mandate to take a " fresh look" at the approach useu in his inspections, and suggest improvements that he thinks are appropriate.
This change, along with the reduced levels of licensee operations at most Region V facilities, allowed the Region to realign its regulatory attention accordingly.
The new inspector has developed an improved schedule for inspecting the facilities in accordance with Inspection Manual Chapter 2600, and was as that the regional files of formerly-licensed sites were complete and in order.
He made effective use of HQ specialists to supplement his expertise.
At the same time, he has been actively monitoring the progress of ongoing hearings related to his facilities.
The inspector recommended that he participate in a fuel facility inspection at another region to gain another perspective.
NMSS agrees and also suggests that he invite other inspectors to accompany him during certain Region V facility inspections. The inspector also requested that Head-quarters develop an inspection module for shutdown of possession-only licensees.
6
Although the Region did not fully expend its budgeted resources in the fuel cycle program, there was no program impact. Because of this, NMSS recomends the possible transfer of some fuel cycle inspection effort to the materials inspection program.
A review of inspection reports during FY89 determined that the inspection reports generally communicated well the results of the inspection and were in accordance with Manual Chapter 0610. The 21 day calendar day goal for issuing inspection reports after the last day of the inspection was met on the majority of the inspection reports reviewed.
NMSS licensing staff members accompanied or participated in three inspections during the appraisal period and found the regional inspectors to be conscientious and thorough and well prepared for the inspections.
In addition, the inspections wore complete and consistent with NRC policy and guidance.
Both the Region and NMSS consider the NMSS participation in inspections to be beneficial and worthwhile, e.
Transportation Safety Inspections Materials Inspection Program-During FY89, transportation inspection goals within the regional master plan were exceeded.
In the materials program, 97 inspections were performed against module 86740 in FY89 (127 materials inspections had been projected and 180 were actually performed). Twenty-six violations were noted, none of which was escalated.
(During FY88, there were 108 inspections using module 86740, with 34 violations observed).
All of the field note formats noted to be in use by RV are consistent with MC 87100.
Completed field notes for eight recent inspections were audited and found to be complete in every case. Headquarters' ongoing review of formal inspection reports, 591's, and RNOV'S from the RIDS system indicates that the reports continue to be of high quality. The materials inspection acting Section Chief is new to Region V, having recently transferred from Region IV, where he was a Senior Inspector. He has, however, already been on two accompaniments with his inspectors.
7
4 Fuel Facilities-All of the licensed fuel facilities in the region were inspected at least once against module 86740 in FY89.
Inspection reports of the fuels facilities inspections have been reviewed on an ongoing basis by Headquarters and they are noted to cc cinue to be of very high quality.
The fuel facilities inspector is new to his position. However, he is a very experienced inspector, having been reassigned from the Facilities Radiation Protection Section in late 1989 upon the retirement of the former Fuel Facilities Inspector.
Reactors-During FY89, transportation activities were inspected at all operating reactors at least once, using either the Core Inspection procedure 83750, or the 86721 or 86740 modules, with the latter two modules being as regional initiative effort and 83750 as the Core Inspection Program.
Inspection reports continue to be reviewed on an ongoing basis and continue to be of very high quality. The Section Chief for the Facilities Radiation Protection Section was on rotational assignment for much of the FY, however, the former Branch Chief has now assumed that position after having returned from a one-year assignment to the IAEA in mid-1989.
Research Reactors-Inspections of transportation activities using module 86740 were performed at 8 of the 11 research reactors in Region V during FY89, with the other 3 having been completed in early FY90. The average effort in these inspections is approxirately five hours per inspection.
Core Inspection Program-Region V management feels that Core Inspection module 83750 has been providing an adequate level of inspection effort on transportation. They do not have precise data to indicate the exact percentage of time in that module which is actually devoted to transportation.
However, they estimate that it is probably between 15-20 percent, based on general experience. As stated above, however, Region V has also been performing either the basic module 86721 or supplemental module 86740 at its facilities.
For FY89, Core Procedure 83750 was performed at four facilities, 86721 at three facilities, and 86740 at five facilities.
The hours expended to the radiological controls modules was the greatest for the one SALP-3 category facility, Palo Verde, with lesser time correspondingly for the SALP-2 and SALP-1 facilities.
In general, Region V feels that the transportation programs at the operating reactors in their region have been going quite well during the past several years.
8
O 4 ENFORCEMENT This section provides the results of the Office of Enforcement's (0E) review of the region's answer to the OE questionnaire involving the region's treatment of recurring violations and their exercising discretion under V.G.I of the Enforcement Policy and Severity Level V violations.
This questionnaire was part of DE's participation in the NMSS National Program Review.
Treatment of Recurring Violations The Director of Enforcement has requested that each region prepare written instructions to assure Severity Level IV and V violations for material licensees are properly reviewed to determine whether they represent a significant management breakdown (Severity Level III problem) or repetitions, and, if so, appropriate enforcement actions are considered.
The region indicated that training was provided on repetitive violations and enforcement discretion to all members of the staff in October and Decem 1989.
In addition, repetitive violations are being identified to the licensee during inspection closeout interviews and to the Section Chief upon return to the region.
Repeat violations are documented in the inspectors' field notes and the region has standard wording that is used in cover letters to document repeat violations.
The region evaluates repeat violations for safety significance and to determine whether an enforcement conference is required on a case-by-case basis in accordance with Regional Policy 0201.
OE reviewed several non-escalated enforcement cover letters and NOV's October 1989 to February of 1990 and confirmed that the region did identify repeat violations in the cover letters to the licensees.
Enforcement Discretion Training on Enforcement Discretion was given in October and December 1989.
The region has formal guidance written in Region V Policy 0201.
The region uses the 766 and the region outstanding items tracking system for repeat and 9
non-cited violations (NCVs) in the Safeguards and Fuel Facility Sections.
There is no tracking system in the materials section other than the inspector's documentation in the field notes of the inspection. The Region proposed that Form 591 be used to record NCYs for easy rehr.. ice.
f 10
e 5 TRAINING The five individuals responsible for regulating materials licensees have completed nearly all the required training listed in Inspection Manual Chapter 1245.
Based on a matrix provided by the Region, a few inspectors need to complete the Radiotherapy and Brachytherapy course (H-313). Overall, the training program is working well and all inspectors have completed the Trans-portation and Low-level Waste course.
(Two Region V inspectors completed the course in October 1989.) One very recent new hire, Laban Coblentz, in the Facilities Radiation Protection Section will need to be provided with this training. All Region V physical security inspectors and their Section Chief completed the HMSS-sponsored Technology Transfer course at Sandia Laboratories.
Other newer courses have not been easily available to Region V staff, but efforts should be made for inspectors to attend the courses at their earliest opportuni-ties.
These courses include the redesigned Sampling and Analysis course (H-310) and the OSHA Orientation course (H-107). The OSHA course is being scheduled several times in the future and Region V should try to schedule their inspectors (both materials and fuel cycle) at the most convenient time and location.
The Region deserves credit for its series of self-initiated training seminars.
In the past year, the Region has offered its staff training from industry experts and regional specialists on the following topics:
emergency preparedness and radiation protection explosive detectors radioactive waste internal dosimetry i
below regulatory concern protective action decision-making technical writing computer utilization In addition, outside supplemental course work is encouraged, and supported to the
+
extent allowed by resources.
11 l
Based upon discussions between Region V and NMSS, it was recomended that NMSS consider developing supplemental courses on nuclear pharmacies, quality assurance philosophy, theory and practice, brachytherapy science and technology, and human factors.
The medical community may also benefit from NRC's human factors work.
12 1
6 INITIATIVES BY THE REGION The following Region V initiatives were underway throughout the year:
inspectors were encouraged to spend more time on performance based licensee activities a checklist was being developed for radiography and portable gauge license renewals to identify their Part 71 QA procedures for transportation activities performance evaluation factors were being used to identify weaknesses in licensee programs a medical workshop was conducted in the Bay Area in 1989 - a second worksho is being scheduled in Hawaii in 1990 the fuel cycle inspection program has been restructured comensurate with the level of activity at each fuel facility an alternate safeguards inspector has been trained contacts have been made with categories cf licensees most likely to be affected by the decomissioning rule a SAFESTOR and Part 61 radioactive waste management inspection was conducted at Humboldt Bay. Also six Part 61 inspections were conducted at power reactors.
As we stated last year, Region V continues to spend time discussing NRC's regulatory program with the licensees to ensure there is a full understanding of the regulatory policy and practice, new regulations, and interpretations.
The Region believes that this encourages development of a cooperative interac-tion between the NRC and the licensee, rather than an adversarial relationshi In FY89, the Region V initiated and completed the goal of providing an alternate certified inspector for the fuel facility physical security inspections.
13
7 HEADQUARTERS / REGION Y INTERACTIONS Both NMSS and Region V believe that interactions have been useful and effective in all the areas in inspection and licensing. Region V has been very responsive to NMSS requests for information or short-term requests for special inspections and responsive to new initiatives from NMSS, such as the medical quality assurance questionnaire.
The interaction between the Region V fuel cycle inspector and Headquarters licensing staff was considered excellent.
The inspector received technical support from a fire protection specialist and help on uranium bioassays during one of his inspections.
The counterpart calls also worked out well.
Materials licensing and inspection staff have been well represented at worksh and seminars conducted during the past year.
The Region requested that HMSS Safeguards personnel participate in the periodic NRR/ regional safeguards conference calls.
These may also address generic safe-guards issues.
Specific safeguards issues have been effectively discussed on an individual basis over the telephone by Region V and NMSS staff.
The interaction between Headquarters and Region V staff continues to be excel with respect to transportation matters.
At the completion of the transportation review visit, an informal training session was held with about ten of the insp to discuss transportation regulation interpretations, future changes, etc.
14
8 RESOURCE UTILIZATION The table on the following page shows Full Time Equivalent (FTE) allocations for FYB9 and FY90 through January 1990.
Because Region V has the fewest materials licensees, only about 300, it has the fewen resources allocated to support NMSS activities.
These limited resources were reduced further with the transfer of the material control and accounting inspection function to Headquarters in mid FY89.
This makes it essential for the Region to maintain full staffing for each of its budgeted positions and to assure that cross-training has occurred for functions performed primarily by one person.
To the Region's credit, this cross-training approach is working well.
The primary materials license reviewer is receiving some support from two other individuals who are usually inspectors, and from a third individual, the Licen-sing Assistant.
The new fuel facility inspector received good support from other technical specialists in the Branch and from his licensing counterparts at Headquarters.
The safeguards inspector also has a qualified backup.
The Region is aware of reduced levels of licensee operations at several of its fuel facilities.
It has realigned its inspection effort accordingly.
Therefore, 1
it did not fully expend its budgeted allotment in FY89 and is not expected to do so in FY90.
These resources were transferred to the materials inspections pro-gram last year and a similar reprograming decision looks to be appropriate this year, particularly because of the extra resources the staff has had to dedicate to the escalated enforcement activities for U.S. Testing.
NMSS recommends that resources be reprogramed in this fashion to allow the Region to complete the 125 materials licensee inspections required in the FY90 Operating Plan.
HMSS mentioned the proposed increase of 0.5 FTE in resources for the FY91 materials program.
This could create a new position for another materials inspector.
The Region V DRMA staff agreed to monitor this situation during the FY92 budget cycle.
15
The only existing Region V vacancies are two Section Leader positions. One is in the Nuclear Materials Safety Section. This position is being filled on an acting basis by a former inspector with considerable experience from Region IV.
The other vacancy is in the Emergency Preparedness Section. The Branch Chief was serving as an acting Section Chief during the time of the review.
The Region has good clerical support and a conscientious Licensing Assistant.
This helped them eliminate their small licensing backlog at the time of the review.
REGION V 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
0 0
0 0
Fuel Facility Inspection 2.3 1.23 53 2.0 0.66
.40 61 Materials Licensing 1.5 1.7 113 2.0 0.66
.59 89 Materials Inspections 3.5 4.63 132 3.2 1.07
.84 79 Event Evaluation 0.3 0.29 97 0.6 0.2
.65 325 Transportation Insp.
0.2 0.12 60 0.18 0.06
.00 0
SG Fuel Facility Lic.
0.2 0.13 65 0.12 0.04
.01 25 SG Fuel Facility Insp.
2.0 0.9 45 0.2 0.07
.13 186 Low-Level Waste 0.2 0.04 20 0.15 0.05
.04 80 Decommissioning 0.1 0
0 0
0 0
Reactor Decomm.
0 0
0.2 0.07
.01 14 Materials Decomm.
0 0
0.1 0.03
.01 33 NMS Section Supr.
0.7 1.34 191 1.0 0.33
.40 121 NMTS Section Supr.
0.1 0.1 100 0
TOTAL TT T TG 9T G
G M
95 NOTE:
FY89 expenditures from Regional input provided in response to FYP/ Green Book update in 12/89.
16 l
9 RECOMMENDATIONS / SUGGESTIONS a.
For HMSS:
1.
Discuss the key inspection items HMSS wishes the Region to track at the next Executive Seminar.
2.
Clarify the lines of responsibility between NRR and NMSS with respect to reactor decommissioning activities.
3.
Consider increased resource needs for enforcement activities.
4.
Consider participating in NRR/ regional monthly conference calls on safeguards issues.
5.
Continue to provide updated reviewer guides, license conditions and model licenses.
6.
Continue to study the two-step licensing process for new materials licenses.
7.
Consider developing a shutdown inspection module for " possession only" fuel cycle licensees.
8.
Update the Service and Training Information System.
9.
Consider developing or revising training in areas such as nuclear pharmacy, brachytherapy, quality assurance, and human factors, b.
For OE:
1.
Provide guidance to the Regions on listing uncited violations on Form 591.
Specifically, how can we track repeat offenders?
2.
Continue monitoring inspection letters to assure appropriateness of violations cited and identification of repeat violations in letters and NOVs.
3.
Develop a more formal audit program to give regions feedback on Severity Level IV and V violations.
17
c.
For Region V:
- 1. Monitor the materials inspection program to complete the required 125 inspections for FY90.
- 2. Arrange for the new fuel facility inspector to participate in at least one inspection at a similar facility in another region.
- 3. Invite other inspectors to participate in Region V fuel facility inspections.
- 4. Continue to make an effort to have materials inspectors complete the required courses in Inspection Manual Chapter 1245. Most of the required training has already been completed, but a few inspectors still need to take training to complete certain requirements, particularly the new OSHA Orientation Course.
- 5. Following the FY92 budget cycle, coordinate recruitment efforts to assure that NMSS programs remain fully staffed.
(This is important because growth is forecast in FY91).
- 6. Ensure that licensing and inspection staff promptly receive all Headquarters to Regions and Headquarters to licensee mailings that discuss agency policy, programs, and technical matters.
- 7. Continue to ensure that the written quality of documents is high while not requi.-ing multiple revisions that do not change technical content.
Writing quality is a matter of interest to the Commission and the EDO.
18
Headquarters Review Team
- John W. N. Hickey, Chief, Operations Branch, Division of Industrial and Medical Nuclear Safety, NMSS Norman L. McElroy, Section Leader, Medical and Academic Section, Medical, Academic and Commercial Use Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS George J. Deegan, Sr. Program Analyst, Operations Branch, Division of Industrial and Medical Nuclear Safety, NMSS Alfred Grella, Sr. Transportation Specialist, Domestic Safeguards and Regional Oversight Branch, Division of Safeguards and Transportation, NMSS
- Team Leader l
l l
i 19 l
Table II Organization Structure ATTACHMENT 2 DIVIS!ON OF RADIATION SAFETY AND SAFEGUARDS DIRECTOR - Ross Scarono Secretary - Chrfe Borrfgo STATE AND GOVERNMENT AFTAIRS STAFF EMERGENCr PREPAREDNESS AND RADIOLOGICAL PROTECTION BRANCH NUCLEAR MATERIALS SAFETY w
State Agrooment Officer AND SAFEGUARDS BRANCH Jock Horner CH1EF - Oreg Ybhoe CHIEF - Bob Pete State Uoleon Officer Secretary - Oone Moller-Duck Doon Kunihiro Secretory - Chris Borrfgo Senior Motorfois inspector -
Jim Montgomery FAcmJnES nacentoasemL EMEnoEMer PREPAREDNESS PRENEtmON SECHON 3ECDON NUC1 EAR N SAFEDUARDS SECDON cuer - rhwe w nes se SEtmOPe CHNF =
- m. cans
, g, y
CHEF - Doug Schuster aves. eures.
M--
Art
- t;;;; =
~-
-s
=
6
" '-