ML20056B907
| ML20056B907 | |
| Person / Time | |
|---|---|
| Issue date: | 02/22/1991 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9103120315 | |
| Download: ML20056B907 (14) | |
Text
%,
UNITED STATES
((
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NUCLEAR REGULATORY COMMISSION j
REGION V 0, '
of 1450 MARIA LANE. SUITE 210
,6 WALNUT CREEK CALIFORNIA 94596 FEB 2 21991 MEMORANDUM FOR:
Richard E. Cunningham Director Division of Industrial and Medical Nuclear Safety, NMSS l
FROM:
Ross A. Scarano, Director Division of Radiation Safety and Safeguards
SUBJECT:
1991 NATIONAL PROGRAM REVIEW (MATERIALS),
RESPONSE TO QUESTIONNAIRE Enclosed is our response to the questionnaire forwarded in your January 25, 1991 memorandum concerning the agenda for your staffs' National Program Review visit to Region V during February 26-27, 1991.
We look forward to the NMSS team arrival and hope the enclosed information is helpful in your previsit review of our activities.
If you have any questions concerning the enclosed material, please contact Robert Pate of my staff at (415) 975-0296.
g,p. Scar no, Directorw. <
4,.
Ross Division of Radiation Safety and Safeguards Attachments: As Stated cc w/Attachs: J. Hickey, NMSS J. Martin B. Faulkenberry R. Pate J. Reese Central Files, RV 9/03/20
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4 1.
Using the current version of your regional staffing plan related to the NMSS program, estimate the approximate percentage of time that each individual spends on the following activities: fuel cycle licensing, fuel cycle inspection, materials licensing, materials inspection safeguards activities, and inspections of decommissioned facilities and reactors.
(See Table I for percentage of time spent and Table II for organization structure).
2.
Provide a summary of actual expenditure and accomplishments as compared to operating plan / budgeted expenditures and accomplishments, for FY 90 and FY 91 to date.
(See Tables III-IV).
3.
Are there any changes needed in the estimate of workload projection (licensing actions and inspections conducted) for the current fiscal year? If so, please provide your suggested changes with justification.
Are there any foreseeable barriers to completing inspection modules in accordance with Manual Chapters 2600 and 28007 Fuel Cycle Inspection No changes are needed for FY 91 fuel fabrication inspection program.
However, due to a lack of activities at General Electric Vallecitos, Rockwell International, and General Atomics, only a minimum of time will be spent completing the program. There are no forseeable barriers to completing the MC 2600 inspection modules for FY 91.
Materials Inspection and Licensing There are no foreseeable barriers to completing the MC 2800 inspection modules for FY 91. There are also no apparent changes needed in the estimate of workload projections for licensing actions for the current fiscal year.
Safeguards Fuel Facility Licensing Program Our experience for FY 91 reveals that while 5 casework receipts were projected, we actually received 0 cases, there is no current backlog.
Safeguards Fuel Facility Inspection Program There are no foreseeable barriers to completing the inspection modules for FY 91 in accordance with MC 2681.
4.
Are regional administrative support functions perforved in a timely manner? Are changes needed in the manner in which these support functions are performed?
If so, please be prenared to discuss the changes needed which would result in optimal administrative support for the programs.
Regional support functions are performed in a timely manner.
5.
Please provide your coments on the programs for interaction of Headquarters with your Region.
Please include your comments on the usefulness of the conference calls, licensing workshops, executive management seminars, inspection accompaniments, telephone calls on case reviews, technical assistance provided on a day-to-day basis, standard review plans, guides, etc.
Include in your comments your suggestions and recommendations for modifications, changes, improvements, etc., in the interaction programs.
Materials Licensing and Inspection The conference calls have continued to be useful.
The licensing and special topics workshops are important for comunication and resolution of problems comon to all Regions and Headquarters and should also be continued.
Inspection accompaniments are valuable for a better comon understanding of regional activities. Reviewer's guides, review plans, license conditions, and codel licenses should be upgraded. Also, final guidance is needed to replace the draft guidance for well-logging applications prepared relative to Part 39.
Training is needed to implement the new 10 CFR 20.
Safeguards Licensing and Inspection Interaction between the regional safeguards inspector and the licensing reviewer and their NMSS counterparts has been effective and such interaction is conducted on an as needed bases.
Telephone calls on case reviews are made on an "as needed" basis.
In all cases where a licensee change appears unacceptable; where policy or generic issues may be involved; or where a potential problem is identified or perceived; the case is telephonically discussed between the Region and the Headquarters cognizant program office.
Fuel Cycle Inspection The fuel cycle counterpart calls have been helpful. Routine communications have been excellent, particularly in support of Advanced Nuclear Fuels (ANF) and Rockwell International.
Headquarters assistance with problems identified during facility inspections have been most beneficial and we encourage continued support in this area.
We continue to support fuel facility counterpart meeting in Headquarters.
6.
Summarize regional initiatives to improve the qualilty of inspections and license reviews, particularly those aimed toward preventing licensee safety problems, or those aimed at licensees performing their transportation activities in a safe manner. Discuss the status of the performance evaluation factors program.
Materials Licensing and Inspection The following initiatives have been continued:
Inspectors are encouraged to spend more time on perfonnance based inspection activities while at licensees' facilities. Every opportunity is taken to inspect work in progress at fixed facilities or field job sites.
More time is spent with the licensees in discussing the license conditions and the associated regulations.
Performance factors are still being utilized to identify weaknesses in licensed programs.
Problem licensees have reduced inspection frequencies and management meetings.
Medical workshops have been used as a forum for interaction on licensing and irispection issues.
Transportation module 86740 is reviewed during each inspection where applicable.
Safeguards Licensing and Inspection The inspector experience base has been expanded in the areas of routine inspections and route surveys. This was accomplished by providing the opportunity for inspectors with little previous experience to work with experienced inspectors in these areas. This provides the Region with a resource pool available as necessary.
Fuel Cycle Inspection The fuel facility inspector is doing an excellent job of surfacing and continuing to investigate safety issues.
For example, fire protection, bioassay issues, and the criticality accident monitoring system at ANF are current concerns.
Considerable effort was expended by a sumer hire and the fuel facility inspector to reorganize and update the fuel facilities' filing system.
7.
Sumarize the total number of inspections of transportation activities at MC 2800 program licensed facilities, including a brief summary of most typically observed violations, including any escalated enforcement actions. (Procedure 86740). Summarize the number of referrals (from Regions II and V) which were processed by your region regarding enforcement action against licensee shippers in your region who trade errant shipments to either of the three commercial low level waste burial sites.
Sumarize the completion status of the annual inspections of transportation activities at MC 2600 licensed fuel facilities and a brief sumary of findings.
Describe whether transportation activities were included on any of the major team inspections of fuel facilities.
Sumarize the completion status of inspections of transportation activities at MC 2500 (2515 and 2545) licensed reactor facilities.
(MC procedures 85721, 86740, or 86750). Please provide your evaluation of whether Core Inspection Procedure 86750 has been adequate in providing sufficient effort in the inspection of transportation activities.
Research Reactor Licensees (MC 2545)
Procedure 86740 involved one hour or more of effort for the 6 inspection efforts during January 1,1990 to February 2,1991. There were no violations during this time period.
Procedure 86721 and 86750 were not required to be performed during this time.
All transportation modules (86721, 86740, 86750) were perfonned as required in the inspection cycle.
Power Reactor Licensees (MC 2515)
Table VI summarizes module modules 86721, 86740 and 86750 completions at operating reactors for the period January 1,1990 through February 2, 1991.
Procedure 86750 provides for the implementation of the inspection requirements and guidance on solid low-level waste and transportation of radioactive materials previously included in 83750 and 84750.
It currently provides a sufficient level of effort and no changes should be proposed for 86750.
In regard to violations, one non-cited licensee-identified violation involving a failure to properly block and brace a component in radioactive material shipment resulted from a partially completed 86750 inspection at WNP-2 (50-397/91-03). The performance of 86721 at Trojan (50-344/90-31) identified a Severity Level IV violation of 10 CFR 30.41
" Transfer of byproduct material" requirements.
In this case the licensee failed to verify that the transferee's license authorized receipt of the type, form, and quantity of the byproduct material transferred.
Material Licensees (MC 2800)
Procedure 86740 involved one hour or more of effort during 104 materials inspections occurring during FY 90.
Eleven item of noncompliance relating to transportation requirements were noted.
Fuel Facilities (MC 2600) i Procedure 86740 involved up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of effort during the inspection of three fuel facilities during FY 90. No transportation inspections have been completed for FY 91 to date. No items of noncompliance relating to transportation requirements were noted. See Table VI.
8.
Provide a training summary for each inspector and reviewer in tabular form.
For each inspector, state which courses listed in Manual Chapter a.
1245 have been completed, when oral boards were completed, what types of inspections the inspector is certified for, and which courses were waived and the reason.
b.
For each license reviewer, state which courses listed in Manual Chapter 1245 have been completed, and which types of licenses the reviewer is authorized to sign.
Inspector qualification training files are maintained for each Division inspector. Because of the effort that would be required to consolidate the requested training data, we believe the desired information can be l
most efficiently evaluated by examining information which is documented in the qualification training files.
As discussed with Jose Picone on February 15, 1991, she agreed that this infonnation would be reviewed during the actual visit.
i i
OE Input for NMSS National Program Review 1.
In the past 12 months, what type and frequency of training has been conducted by the region in enforcement matters?
James Lieberman conducted OE training on January 24, 1990.
2.
Please estimate the number of Severity Level IV and V violations that were disputed by the licensee during the past 12 months.
Three violations were disputed in FY 90.
Enforcement issues are currently being discussed with the V. A. San Diego, as well.
3.
Please estimate the number of Severity Level IV and V violations that were withdrawn after issuance during the past 12 months.
Three were withdrawn.
4 Please describe the type of internal audits, other than the normal concurrence process, that the region has undertaken for inspection reports and Severity Level IV and V violations during the past 12 months?
Region V has no formal audit program for inspection reports and Severity Level IV and V violations beyond the normal concurrence process.
5.
In the past twelve months, what is the average time from insepction to issuance of NOV's with Severity Level IV and V violations? What is the regions's timeliness goal for these cases?
Region V determines the average time from inspection to issuance of reports (including NOV's or 591's) for all materials cases. The average turn-around time is 12 to 13 days. The timeliness goal is 30 days.
6.
In the past twelve months, have you had one or more cases involving the third repeat of a Severity Level IV or V violation, and, if so, what enforcement action was taken on the case?
We have had no cases of this type.
7.
Within the region, are there differences in the handling of repeat violations among the Safeguards, Fuel Facislity, and Materials areas?
No.
i
Table I Page 1 of 2 RESPONSE TO ITEM NO. 1. NMSS 1991~ REGIONAL QUESTIONNAIRE Percentage of Time Spent by Each Indivisual
- Fuel Cycle Materials Materials Safeguards Safeguards Name Inspection Licrensing Inspection Licensing Insp. & other Decommissioning Supervision NMFF Branch R. Pate, Chief **
NMFF Branch 5
5 10 80 J. Montgomery Sr. Matis. Spec.
20 50 30 B. Riedlinger Sr. Health Physicist (Lic.)
90 10 F. Pang Radiation Specialist 100
- 0. Skov Sr. Rad. Specialist 20 70 10 P. Zurakowski Rad. Specialist (retired 1/91) 100 K. Prendergast Rad. Specialist 100 C. Hooker Fuel Facility inspector 75 10 15 A. Rivers **
Licensing Assistant (Temp.)
50 50 m
Table I Page 2 of 2 RESPONSE TO ITEM NO. 1, NMSS 1991 REGIONAL QUESTIONNAIRE Percentage of Time Spent by Each Indivisual
- Fuel Cycle Materials Materials Safeguards Safeguards Name Inspection litrensing Inspection Licensing Insp. & other Decommissioning Supervision J. Reese, Chief SEPNPR Branch 5
5 10 L. Norderhaug Sr. Phys. Sec. Spec.
5 10 M. Schuster Sr. Phys. Sec. Spec.
5 D. Schaefer Phys. Sec. Insp.
5 Fuel Cycle Licensing is not done in Region V Involved in the inspection process but not dedicated to performing actual inspections
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laule 11 Page 1 of 1 ORaANIZATION STRUCIURL DIVISION OF RADIATION SAFETY AND SAFEGUARDS DIRECTOR - Roas Searono Deputy Director Frank Wenslowski Secretary - Chris Barrigo 87^* Tyg337y"E"*
Secretary - Gene Moller-Duck Rodlotion Specialist - Friedo Toylor Ternporary - Ann Rivers Jouts Homer State Unioon ornoor Deon Munthlm REACTOR RADtOLOC8 CAL PROTECTION BRANCH SAFEGUARDS. EMERGENCY PREPAREDNESS. AND NUCLEAR MATERIA 4.3 AND NON-POWER REACTOR BRANCH FUEL FABRICATION BRANCH CHIEF - Crug Yuhoe CHIEF. James R::::
CHIEF - Bob Pete Radiation Protection -
Mike Cliffe Emergency Respone* -
Dean Chaney Emtflo Gortfo Fuel Facilities -
Warren TenBrook Chuck Hooker Louis Corson Emergency Preparedness -
Lobon Coblentz Cell Good Materfolm -
Hot Roaldes Art McQueen Jim Montgomery Both Rieditnger Security -
Frank Pong Doug Schuster Dove Skov LeRoy Nordertioug Kent Prendergast Dennie Schoefer Vacant Reactor inspector.
Ucensing Ameistant -
Phil Quelle Ann Rivers (Temp) 12/10/90
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0 Table V RESPONSE TO ITEM NO. 7 NMSS 1991 REGIONAL QUESTIONNAIRE TIME SPENT ON LOW LEVEL WASTE ACTIVITIES SEPNPRB Inspection Resources to NMSS - January 1,1990 - February 2,1991 Actual Modules Reported: 86721, 86740 and 84850 Research Reactors Module 86740 (hours General Atomics 4
UC Berkeley 1
Univ, of Arizona 1.5 Univ. of Washington 13 General Electric 1
Total 703 Power Reactors Module 86721 Module 86740 Module 86750 San Onofre 41 0
0 Diablo Canyon 0
10 0
Rancho Seco 17 0
0 Trojan 23 0
30 WNP-2 2
0 4
Palo Verde 0
0 0
Totals 83 10 34 Total SEPNPRB hours to NMSS = 20.5 83 10 34 147.5 Data Source:
766 Data System i
l
6-P Table VI RESPONSE TO ITEM NO. 7, NMSS 1991 REGIONAL QUESTIONNAIRE TRANSPORTATION INSPECTIONS MODULES 86721, 86740 AND 86750 COMPLETIONS AT OPERATING POWER REACTORS AND FUEL FACILITIES 86721 86740 86750 1990 1991 1990 1991 1990 1991 WNP-8/11/90 TROJAN 1/21/91 Rancho Seco 2/10/90 1
Diablo Canyon S/5/90 San Onofre 3/17/90 Palo Verde
- GA 7/20/90 ANF 8/17/90 GE-VAL 9/7/90
- No completions for modules noted i
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.