ML20056G639
| ML20056G639 | |
| Person / Time | |
|---|---|
| Issue date: | 06/09/1993 |
| From: | Yuhas G NRC |
| To: | Faulkenberry B NRC |
| Shared Package | |
| ML20056G560 | List: |
| References | |
| NUDOCS 9309070004 | |
| Download: ML20056G639 (6) | |
Text
_ -.
a s
June 9, 1993 Note To:
B. F. Faulkenberry i
Regional Administrator t
From:
G. R. Yuhas, Chief Radioactive Materials Safety Branch
SUBJECT:
ADDITIONAL CCHMENTS ON NUCLEAR MATERIALS PROGRAM TREATMENT IN THE DRAFT REGION V REALIGNMENT STUDY Since the relocation of nuclear materials safety runction appears to be the i
only option considered in all cases, I feel it appropriate to offer several additional comments.
Relocation of the materials functinn to Region IV will reduce the service provided to the Western United States and Pacific Territories, j
OPTION 1 MATERIALS IMPACT:
Comment: The draft fails to adequately describe the impact'on our mission in the area of nuclear materials safety area.
Specifically, the daily contact with users and potential users of nuclear materials will be l
exacerbated, Siemens Power Corporation which employees about.900, operates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, and currently is rated to produce 700 metric tons of fuel per year is planning a $20 million dollar expansion and needs significant NRC oversight; General Atomics while currently decommissioning its HTGR fuel fabrication facility, continues to sell TRIGA reactors to produce fuel and to pursue development of advanced reactor technologies; major decommissioning activities like the San Francisco Presidio and the Sacramento Army Depot require extensive contact not only with the licensees but also with the public; the States rely on frequent NRC response to radiological events to assuage public concern; and finally, Region V generated 12 enforcement actions, including four orders in the last year, which required considerable NRC management involvement. While the number of licensees located in Region V is small (260), Region V inspects another 360 permittees of master materials licensees from 4
other regions and actively seek out field inspections of State licensees operating in the Bay Area, Alaska, Hawaii and other federal jurisdictions.
The proposed Region IV organization that would assimilate the Region V work load lacks adequate management oversight.
Region II is' described as having a similar caseload as the proposed Option 1, yet Region IV would rather elevate the Deputy Director to SES rather than create a Branch Chief to match the Region II organization.
The nuclear materials area represents the most realistic opportunity for growth in the NRC. As reactors enter the end of their useful life they will create a significant work load for NRC health physics staff. The oversight of State Programs and the potential increase in scope to include accelerators also looms on the horizon.
The i
purpose of the Branch Chief is to provide the technical oversight and direction to the staff and input to the SES so that they can
00 I
d focus on policy development and direction.
Comment: Option I states that " Consolidation of the Region V materials program in Region IV would provide more assurance of consistent application of the materials program throughout the combined Region V."
Consistency is a small reward for the lack of defense in depth, loss of talent, experience, and representation in a large part of the nation.
Comment. Option 1 states that "The review and evaluation of inspection l
results and development of enforcement actions would not be affected,"
How can adding another 200 licensing cases to one Section Chief and i
another 115 inspections to the other Section Chief, including one escalated enforcement action per month not adversely affect quality?
Oversight of fuel facilities alone requires at least half of a Section Chief's time.
Comment: Option I states that "To ensure that there would be no impact to direct inspection effort, FTEs have been included under this option to offset the estimated increased travel time."
No mention is made of how this option will assure a reasonable amount of direct Section Chief oversight of inspection, pre--
licensing visits, and enforcement actions in the field considering their additional work load.
Comment:
Option I states that "The larger base of employees would be a positive impact with more expertise available and more opportunity for cross training and development."
j This opinion is not supported by fact.
Region V in part because of its smallness, has historically trained its health physicists and i
rotated its personnel to achieve the broadest base of technical expertise to support the agency mission.
Nothing described in Option 1 presents a better approach to personnel development.
Comment: Option 4 indicates that 19 FTE will be saved by relocating materials to Region IV.
If all my present branch, including our licensing assistant were totally eliminated nine FTE would be saved.
My question is where did the other ten FTE savings come from.
Recognizing the outstanding productivity of the Region V materials effort it is does not seem reasonable that ten overhead FTE could be eliminated if we were moved to Region V.
==
Conclusion:==
The assessment of impact on the agency mission by consolidation of the nuclear materials function in Region IV appears superficial.
We suggest that consolidation of the nuclear materials function in 107
s i
Region IV will result in overloaded Section Chiefs, less direction effort per FTE, less management oversight of field activities, reduced support to the States, less comunication with the public and the licensees, decreased NRC response to minor incidents, and limit our ability to respond to future ch; es in regulatory scope.
G.3 G. P. Yuh s
~
7 r
L L
108
1 l
e.
OPTIOh 1
Alaska REGION IV REGION lil 4
WA i
yh ME MN MT ND
)
REGION I t
OR WI I
l N
h j
i bMI NY MA ID SD f
WY IA RI
^
gy
~
NE j
lt IN NJ UT C0 L
M0 E
fjD CA KS D.C.
-=
u gy AZ NM E
TN b'
a o_
e SC Hawall N
O MS Al GA s
i REGION ll i
=
FL
- Regional 0ffice E Technical Training Center i Uranium Recovery Field Office
- Headquarters i
109
e RIV/RV Materials Licencees and Permittees 8P 64 L P - Permittees 40 p 94 (
7L L - Licensees p
(
/
47 P d 47 L 16 L 81 L y
i l
RI 4L Ousm 11 P Rlli 30 L 6P 12 L 0
6L 191 P t
46 L 26 P 261 L 9L 2, L w
- g Rll
,3 i
66 L RV Totale Permittees Licensees 361 260 t
l l
r
.a
f Alaaka REGION IV REGION 111 REGION V WA MN MT VI ME ND
)
REGION I OR WI 4
~
s ID SD
\\ M1 MA f
gy WY
(
IA R1
/
)
, NE j
IL IN NJ UT C0 L
M0 E
fjD I
CA A
KS D.C.
i g
NC N
2 Hawall LA AS Al GA l
)
REGION 11 i
am FL i
l e Regional 0llice IE TechnicalTraining Center i
A UraniumRecoveryFieldOffice i
- Headquartets i