ML20057A123
| ML20057A123 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/1988 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Ernst M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309130086 | |
| Download: ML20057A123 (21) | |
Text
(, 2c087 FEMORANDUM FOR:
Malcolm L. Ernst Deputy Regional Administrator, RII l
FROM:
Robert M. Bernero, Deputy Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
DRAFT REGION II 1988 NATIONAL PROGRAM REVIEW REPORT Enclosed for your review and comment is a draft National Program Review report for Region II.
The report encompasses all regional activities within NMSS program areas including the fuel cycle, materials, safeguards, transportation, and low-level waste programs.
The report covers 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 II this spring.
These observations are based upon our on-going review of your licensing actions and inspection reports, our inspection accompaniments, the recent NMSS program review visits, and other periodic interfaces such as workshops, seminars, and conference calls.
Before we forward a final version of this report to the Regional Administrator i
and the EDO, we invite any written comments you might have on this draft. As always, NMSS welcomes any suggestions on how we might improve the National Program Review process.
Please provide any comments within two weeks.
Robert M. Berner:
ieputy Director Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated DISTRIBUTION:
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i REPORT OF THE 1988 NATIONAL PROGRAM REVIEW 0F DECENTRALIZED NMSS ACTIVITIES AT REGION II 1.
INTRODUCTION The purpose of this report is to document the National Program Rev',ew of decentralized NMSS licensing and inspection programs at Region :I. 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 f ashion.
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 tc quality operations in all five regions and Headquarters.
Additional information on the process can be found in the NMSS 1:ational Program Review Manual dated December 11, 1987.
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. 2.
FUEL CYCLE AND NUCLEAR MATERIALS PROGRAMS 2.1 Materials Licensing The region completed 607 materials licensing actions in FY87, compared to an adjusted target projection of 600 cases (101%).
The target was adjusted to reflect fewer cases being received than originally projected, and to allow for the newer (higher) labor rates.
During FY87, on the average new license reviews were completed in 45 days, amendments in 34 days, and renewals were processed in a first-in, first-out manner.
Overall turnaround average for all cases, including renewals, was 40 days in FY87.
This is the best turnaround time of all the regions.
During the review period, the number of cases pending has remained relatively constant at 58 (in Oct. 86), 58 (in Oct. 87), and at 63 (in Ma rch 88).
For the first six months of FY88, 319 licensing actions have been completed, compared to a baseline projection of 305(105%).
In FY88, turna'round time has remained the lowest of all Regions.
There were no signification problems noted in the technical adequacy and accuracy based upon our review of completed licensing cases and inspection reports. Minor discrepancies have been discussed with the regional staff on an ongoing basis during the review period.
Licensing actions and inspections are carried out in a consistent manner in accordance with applicable guidance. Documentation of actions is 1
consistently good.
Region II has an excellent staff of licensing reviewers, inspectors, and support staff.
The interaction between the senior staff and less experienced staff is commendable. The interface between licensing reviewers and inspectors is excellent. The use of inspectors to do some licensing is working quite well. Actual resource expenditures are consistent with budgeted projections.
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s 2.2 Materials Inspections In FY87, Region II completed 387 materials inspections, with about 10%
of them reactive. Through February 1988, the region had completed 167 inspections.
This was considerably more than what the Operating Plan had called for through this time period.
In fact, they were performing inspections in advance of their due dates. There were no significant problems noted in the technical adequacy, accuracy, and quality of the inspections or the inspection report findings. However, followup on some expired licenses needs to be more timely. Several such licenses took several months to resolve. Because the region was ahead on its FY88 materials inspections, RII proposed an Operating Plan change that will allow more resources to be allocated for field radiography performance, 10 CFR 150.20 general license inspections, and more licensing effort.
NMSS subsequently approved this proposal.
The region does a fine job identifying potential licensee management problems and stressing to licensees the importance of active management involvement. Another strength of the region is the way in which they deal with problem licensees.
One recent example concerns the good job done with Hospital Metropolitano in Puerto Rico. Despite the difficulties from the language barrier and several licensee misunderstandings about NRC policy, licensing requirements, and regulations, the staff ensured that questions and answers were understood by both parties.
2.3 fuel Cycle Inspections The Region II fuel cycle inspection program has met its operating plan goals by completing inspections of the six fuel cycle facilities in l
accordance with MC 2600 for the review period.
During FY87, additional resources were devoted to the completion of the team safety assessments for these facilities, and the Region's leadership in defining the appropriate depth and scope for this new inspection area is commendable.
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. The fuel cycle inspection program is performed under a project syitem using appropriate Region inspection specialists from the Nuclear Materials Safety and Safeguards Branch and the Emergency Preparedness and Radiological Protection Branch. Good coordination between the Branches was evident with project management performed by the Nuclear Materials Safety and Safeguards' Branch. Assignment of the responsibility for completion of particular inspection modules for each facility to the appropriate branch sections has revealed some redundancy in the inspection requirements of the modules that should be recognized in future revision of MC 2600. More importantly, it was recommended that MC 2600 should provide more flexibility for different-iating inspection requirements and frequencies as applied to facilities with widely disparate operations (e.g., the Babcock and Wilcox (B&W) Commercial Fuel Plant vs. the Nuclear Fuel Services facility).
The documentation for inspections and related actions has been timely and consistently of good quality.
It was noted that additional filing space and filing assistance should be provided to relieve the burden assumed by the Senior Fuel Facilities Project Manager / Inspector.
Improvement in this administrative area is scheduled for FY 1988.
The Region Il fuel cycle inspection program is aggressive, thorough and effective.
The inspection efforts have led directly to improved performance by Nuclear Fuel Services at its facility in Erwin, TN, and has resulted in the identification of program deficiencies and management problems at the B&W Naval facility.
Resources for the program appear adequate and are effectively used.
Following identification of the problems at the B&W facility, the resident inspector at NFS was assigned to schedule one-half of his inspection efforts to the B&W facility. The resident inspector's efforts are parallel to the routine inspection program and do not substitute for these schedules and requirements, but do provide focus and attention on selected safety areas.
The Region's initiative and support related to the regulatory improvement program for fuel cycle facilities is recognized and commendable.
In this context, Region II arranged and hosted in October 1987, the first workshop held by the NRC for fuel cycle licensees to discuss agency plans and actions and to seek the views of fuel cycle facility management.
During the review, Region 11 staff and management expressed high interest in proposals for
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s additional training for inspectors, noting a particular need for familiar-ization with chemical safety hazards.
The Region also suggested more inspector accompaniments by licensing staff members, particularly in a participating role (i.e., inspection preparation, assigned functions, and followup), but recognized resource limitations for this type of accompaniment.
2.4 Fuel Cycle And Materials Safety Initiatives The region deserves recognition for the following efforts:
o Strong support and leadership for the FY87 team assessments at fuel facilities, and the related regulatory improvements program being developed for fuel-cycle facilities, Recognition of inconsistencies among license conditions, Regulatory a
Guides, and regulations.
Forceful comitment to emphasize importance of management involvement o
in licensee operations, Leading role in recruiting and training fuel and materials staff.
o 2.5 Recommendations For Action Followup on expired materials licenses in a more timely manner.
o 2.6 Headquarters Regional Interaction No problems were noted. The Region is quite satisfied with the current interaction with Headquarters. However, they did express the hope of more one-on-one interaction between Headquarters and regional staff through semi-annual meetings, inspection accompaniments and visits to Headquarters. The Region also suggested consideration of scheduled, periodic conference calls between Headquarters and the Regions to discuss fuel cycle facility regulatory matters similar to those held for the materials regulatory program.
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i e 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 cases. The review of the Inspection Program covered physical security inspections.
Material control and accounting inspections will be covered in FY 89.
3.1 Safeguards Licensing Program The Region II s'aff maintains a complete set of Regional Guidance Documents, Standard Review Plans and Regional Office Instructions related to Part 70.32/70.84 reviews for the technical guidance of license case reviewers.
The Region II documents are up-to-date and consistent with NRC policy and guidance.
The Part 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.
Inconsistencies noted during reviews were discussed with licensees and Headquarters' staff and resolved.
Two cases which required resolution of policy issues were transferred to Headquarters.
Correspondence from Region II was forwarded to Headquarters in a timely manner and properly marked.
Region II achieved an outstanding average case turnaround time of 30 days in FY 87 and an outstanding average case turnaround time of 27 days in FY 88.
i Licensing review completions exceeded the Operating Plan goals. Region II i
completed 41 case reviews in FY 87 vs 37 planned case reviews.
Region II completed 16 case reviews in FY 88 vs 22 planned case review completions because case eceipts have been lower than projected. Region II utilized the NMSS Ope-ing Plan Casework Statistics Report #41 and supplementary reports as n essary to keep Headquarters informed of licensing casework status on a monthly basis.
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i The Region II license reviewers were trained at Headquarters in 1982 and the Region has cross-trained additional inspection staff to perform licensing reviews and provide back-up capability.
3.2 Safeguards Inspection Program 4
The Region II staff maintains a complete file of all NRC publications, documents and guidance on planning, conducting, reporting and following-up inspections.
In, addition, Region II issued Regional Office Instructions to supplement NRC guidance and provide detailed guidance to i
the technical staff for the purpose of establishing uniformity in the planning and conducting of inspections and in processing inspection documentation.
The Region II publications and documents are up-to-date and consistent with NRC policy and guidance. Region II physical security inspection reports were technically scand and consistent with Headquarters and Regional policy and guidance.
Srpporting documentation for findings and conclusions was included in inspection reports and clear documentation for violations and unresolved issues was included where applicable. SGTR staff accompanied Region II inspectors on physical security inspections at NFS, Erwin, TN in July 1987 and B&W Naval Nuclear Fuel Division, Lynchburg, VA in January 1988.
Each of the inspections was performed in a thorough, comprehensive, professional and technically competent manner.
4 Although safeguards regulations do not specifically require fuel facility licensees to establish and maintain physical security quality assurance programs, the Region II inspectors do inspect three modules which fit the definition of quality assurance as "those planned and systematic actions necessary to provide adequate confidence that a system or component will perform satisfactorily 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.
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8-Region II completed four Category I physical security inspections of four scheduled in FY87 and two Category I physical security inspections of two scheduled through March 31, 1988.
Region II completed one Category III physical security inspection of one scheduled in FY87. The inspections were completed within the timeframes required by Headquarters and the inspection reports were submitted in a timely manner.
Region 11 established an outstanding planning and scheduling system and has produced and updated inspection and associated action schedules for FY 88.
The Region met the inspection goals established in the Operating Plan and as set forth in Manual Chapter 2681.
Region II has established Regional Operating Instructions to supplement NRC instructions for the 766 system and the Region staff utilizes the system to the extent practical. However, the staff noted that the data in the 766 system is not current and the system does not provide all of the information needed by supervisors.
One inspector left Region II in the past two years. A replacement was hired in three months. The new inspector was trained in accordance with NRC Manual Chapter 1245, Inspector Qualifications, other applicable guidance and Regional Operating Instructions. After inspectors are qualified to start inspecting, Individual Development Plans (IDS) are prepared on a yearly basis for each inspector which identify further needed refresher training. Training goals and nceds are also identified in the Region II NMSS Branch FY88 Operating Plan.
3.3 Licensing and Inspection Initiatives Region II is to be commended for participating in pre-licensing efforts associated with the All Chemical Isotope Enrichment, Inc. (AlChemIE) plan to buy and utilize DOE centrifuge machines to enrich common elements for medical, industrial and research purposes.
Region II used its own resources for this unbudgeted effort.
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3,4 Recommendations For Action No recommendations noted.
3.5 Headquarters / Regional Interaction Region II has been very responsive to Headquarters' requests on the following actions:
Region II trained the 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 II inspectors completed special comparability inspections and o
reports within the time frames requested by Headquarters, o
Region II staff reviewed all Region II Part 70 licensees' SNM possession limits and holdings to verify the correct facility category for inspection purposes.
Region II recommended that Headquarters prepare and publish inspection procedures for the physical security inspections at the AlChemIE facility at Oak Ridge, TN as soon as possible. The staff also noted that Region II FTE expenditures on the AlChemIE facility were unbudgeted and could impact the fuel facility inspection program.
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i d 4.
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 on completion of transportation inspections credited to Modules 86740 and i
86721, discussions with Regional staff during the assessment visit on February 11-12, 1988, and two accompaniment inspections with a Region II inspector to the B&W Commercial Fuels, and B&W research facilities in Lynchburg, VA during February 3-4, 1988. The review of the Transportation Safeguards Inspection Program is based on a review of completed inspection reports, an analysis of 766 system data on completion of trans0ertation inspections, discussions with Regional staff during the asse:. anc visit to Region II en February 17, 1988 and one accompaniment inspection with a Region II inspector at the port of Savannah, Ga. (Garden City) on June 16, 1987 No shortcomings were noted of any type.
4.1 Transportation Safety Inspection Programs 4.1.1 Materials Licensees Based on 766 system data for FY87, the Region II augmented coverage of transportation inspections, noted in the 1987 assessment, has been maintained.
Of approximately 1000 materials licensees, 387 were inspected in FY87.
Transportation Module 86740 was involved in or related to 226 of the inspections resulting in 19 reported transportation violations, all severity levels 4 or 5.
As of March 1988, Region II had no backlog of inspections that were overdue.
Copies of the blank field notes used by materials inspectors were obtained and reviewed. All of the four formats in use were noted to be consistent with that recommended in the Attachment to Manual Chapter 87100.
Six randomly selected, completed field notes were examined and found to be fully completed, including the transportation section.
All of the inspectors assigned to the section were accompanied by the Section Chief at least once during the reporting period.
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. 4.1.2 Fuel Cycle Facilities Transportation activities at the six major licensed fuel facilities in Region II are performed by the Facilities Radiation Protection Section of the Emergency Preparedness and Radiological Protection Branch. All facilities were inspected for transportation Module 84850 at least annually. A total of 11 inspections were performed resulting in two minor violations.
The quality and timeliness of report preparation were excellent.
4.1.3 Reactors The 766 system data and information provided by Region II indicated that fc" operating power reactors in FY87 32 inspections had been credited to Module 86721 (Transportation-Basic) and 13 to Module 86740 (Transportation-Supplemental).
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A total of 25 violations of transportation requirement! 9 re reported, all severity level 4 or 5, except for 3 severity level 3 items. Overall, the program plan for inspection of transportation activities at Part 50 licensed facilities had been fully completed for FY87.
Inspectors were accompanied by the Section Chief at least once, and in many cases more frequently, during the year.
The quality and timeliness of report preparation were excellent.
4.2 Transportation Safeauards Inspections Region II completed the two scheduled inspections in FY87.
Region II is scheduled to perform 8 inspections during FY88. Inspection of the only shipment in Region II in the first half of FY88 was completed prior to l
Ma rch 31,1988.
However 3 additional inspections were completed shortly l
after April 1,1988 and the remaining 4 planned inspections have been scheduled. The one inspection in FY87 was accompanied by SGTR staff.
The
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inspection was accomplished in a thorough, comprehensive, technically 4
competent and professional manner.
Coordination with the state governments, 4
the Georgia Port Authority and the U.S. Coast Guard was outstanding. The inspection reports were technically complete, consistent with NRC policy i
and guidance and submitted in a timely manner. Two severity level 5 violations against the licensee were noted in the FY87 report.
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, 4.3 Regional Initiatives Region II is to be commended for:
o Submitting to Headquarters a draft Information Notice which was used as a basis for issuance of IEN 87-31 on Blocking, Bracing, and Securing of Radioactive Materials Packages in Transportation, Sponsoring an information meeting with all NRC fuel cycle licensees in o
Atlanta, GA in November 1987.
Completion of the transportation course H-308 by all inspectors o
assigned to inspect transportation activities, through attending the course at TTC or at Region II in June 1987.
4.4 Recommendations For Action No recommendations.
4.5 Headauarters/ Regional Interaction Region II has had s."
ellent interaction with Headquarters' staff and communicated well with Headquarters on transportation safety issues, problems, and reactive cases, l
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o 5.
LOW-LEVEL WASTE INSPECTION PROGRAM (10 CFR 61)
The review of the Low-Level Waste Inspection Program is based on the review of completed inspection reports, analysis of 766 system data on low-level radioactive waste inspection reports credited to inspection procedures 84850 and 84722, accompaniment of a regional inspector during an inspection at the Barnwell, South Carolina low-level waste disposal facility, and discussion with Region II staff during the visit on February 12 and 13,1988.
5.1 10 CFR 61 Low-Level Waste inspections - Materials Eased on discussions with the regicn and analysis of the 766 system summaries, there were no staff hours credited to low-level waste management inspection procedures at materials licensee facilities during FY87. The 766 system data is probably not indicative of the 10 CFR 61 inspection coverage during materials inspections due to inspectors crediting other inspection procedures, such as 87100 and 86740, for their low-level waste inspection efforts.
It should be noted that the majority of low-level waste generators and brokers in the region are licensed by Agreement States, leaving few of the 387 inspections performed by the Region during FY87 attributeble to the inspection of such licensees.
As part of LLWM's National Program Review, the materials inspection files were examined at the Region II offices to determine the completeness of the inspector field notes.
The field notes for the Barnwell, South DRAFT 05/18/88 ENCLOSURE RII NPR
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Carolina low-level radioactive waste disposal facility were reviewed and found to contain adequate information.
Since there were no hours credited to low-level waste inspection coverage in the 766 system during FY87, the review of other files was limited to evaluating field note formats.
The four types of inspector field notes were determined to be consistent with the recommendations providea in Manual Chapter 87100 Appendix.
During this review it was noted that the industrial / academic field notes contained sections for Part 61 coverage during materials licensee inspections.
5.2 10 CFR 61 Low-Level Waste Inspections - Fuel Cycle Facilities With respect to the Part 61 inspection program for fuel cycle facilities, eight inspection reports were issued for the six Region II fuel cycle facilities, with an average of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per inspection credited to inspection procedure 84850. One violation, a severity level 5, was issued as a result of these inspection efforts.
5.3 10 CFR 61 Low-Level Waste Inspecticns - Reactors At power reactor facilities, low-level waste inspections were performed at eighteen of the twenty reactor sites, with an average of four hours spent per inspection.
Two of the twenty reactor sites, Bellafonte and Watts Bar, are not currently generating low-level waste, resulting in 100% low-level waste inspection coverage within the region during FY87.
A total of five violations were issued in twenty-three inspections during this period, all of which were severity level four. Based on discussion with the region, it was learned that section chiefs accompany their inspectors at least once per year, and in many cases, more frequently.
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. 5.4 Low-Level Waste Disposal Site Inspections Region II has the responsibility of annually inspecting the SNM license at the Barnwell, South Carolina low-level radioactive waste disposal facility.
The FY87 SNM inspection at Barnwell was carried out similarly i
to inspections conducted at other materials licensee facilities and was noted to have been performed in accordance with all of the inspection requirements with no observed variations from program requirements.
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'5.5 Low-Level Waste Management Initiatives The region is to be commended for implementing the following initiative:
o The Regional State Liaison Officer routinely transmits notifications and copies of violation reports regarding deficiencies in NRC-licensee low-level waste shipments to the Barnwell, South Carolina low-level waste disposal facility to the appropriate NRC Region.
5.6 Recommendations for Action For the materials licensee inspection program, begin crediting the appropriate low-level waste management inspection procedure to provide a more consistent tracking system for these inspection efforts.
5.7 Headquart_ers/ Regional Interaction The region has communicated well with Headquarters on low-level waste management inspection matters.
The request for LLWM guidance pertaining to the quality assurance requirements of 10 CFR 20.311 and the request for assistance with a licensee's radwaste solidification questions are examples of such interaction. The Region / Headquarters interaction proved beneficial in identifying and surfacing these relevant low-level waste management issues.
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4 6.
URANIUM RECOVERY LICENSING AND INSPECTION Not applicable to Region II.
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' 7.
FTE AND PROGRAM SUPPORT FUNDS UTILIZATION The following table shows FTE allocations and expenditures for the review period.
Region II has no program support funds in the NMSS mission areas.
FY88 FY87 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT.-DEC. OCT.-DEC.
Materials Licensing 2.6 3.8 146 3.1 0.8 0.9 113 Materials Inspection 6.1 5.6 92 6.3 1.6 1.7 106 Fuel Facility Inspection 5.9 7.1 120 6.6 1.7 1.4 82 SG Fuel Facility Lic.
0.9 0.5 56 1.0 0.3 0.2 67 SG Fuel Facility Insp.
4.9 5.7 116 4.9 1.2 1.7 142 SG Transportation Insp.
0.1 0.2 200 0.4 0.1 0
0 LLW Inspection Total 20.5 22.9 112 22.3 5.7 5.9 104 NOTES:
1)
FY87 expenditures from FY87 RITS RWAT report; section supervision prorateo.
2)
FY88 expenditures from FY88 RITS RWAT report (as of 1/2/88); section supervision prorated.
- LLW inspection resources are included in materials, fuel facility and transportation inspections.
The regional nuclear material safety and safeguards mission area programs are fully staffed.
Overall resource expenditures in FY87 exceeded projections in most areas. Total FY88 resource expenditures are inline with projections.
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o 4 During FY87, Region II completed 101% of their revised materials licensing casework goal with more resources than originally budgeted. Materials licensing labor rates were revised in FY87 based on prior year data.
The FY87 completions and FTE expenditures indicate that further labor rate changes based on FY87 data may be necessary.
NMSS is currently reviewing these data for incorporation into the FY90 budget.
Matericls inspection resource utilization is inline with expectations for both FY87 and FY88.
Region II is ahead of schedule in conducting inspections at licensees in accordance with frequencies specified in Manual Chapter 2800.
They are conducting inspections at some facilities in advance of the scheduled frequency in order to meet the FY88 operating plan goal.
NMSS discussed that it was not our intention to set an operating plan goal that required " working ahead" of specified frequencies. Based on these discussions, after the visit i
Region 11 requested an operating plan adjustment.
Some of the excess resources have already been used for general license inspections and some will be used for field radiography inspections.
Fuel facility inspection resource expenditures exceeded projections in FY87, but are behind in FY88 according to limited FYS8 data.
Region II has taken the ir.itiative to reallocate these fuel facility inspection resources based on the current requirements at each facility.
For example, they have redirected approximately one-third of the NFS resident inspector's time to the B&W fa cility.
Region II is meeting its operating plan goals in this area by completing inspections in accordance with Manual Chapter 2600.
During FY87 in the Safeguards and Transportation program, Region 11 expended 108% of their allocated resources for safeguards fuel facility licensing and transportation and fuel facility inspections.
Resource expenditures for FY88 are inline with projections.
In summary, Region II has effectively utilized nuclear material safety mission DRAFT 05/18/88 ENCLOSURE RII NPR
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. area resources. They reallocate to high priority areas when circumstances warrant and keep NMSS management informed.
They are fully staffed with a mix of very qualified junior and' senior level professionals who work together well.
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