ML20057A128
| ML20057A128 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/1988 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309130094 | |
| Download: ML20057A128 (24) | |
Text
,
JUN 2 019M MEMORANDUM FOR:
James M. Allan Deputy Regional Administrator, RI FROM:
Robert M. Bernero, Deputy Director Office of Nuclear Material i
Safety and Safeguards
SUBJECT:
DRAFT REGION I 1988 NATIONAL PROGRAM REVIEW REPORT Enclosed for your review and comment is a draft National Program Review i
report for Region I.
The report encompasses all regional activities within NMSS program areas including the fuel cycle, materials, sareguards, I
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 I this spring.
j 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 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. Bernero, Deputy Director Office of Nuclear Material Safety and Safeguards
Enclosure:
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REPORT OF THE 1988 NATIONAL PROGRAM REVIEW 0F DECENTRALIZED NMSS ACTIVITIES AT REGION I 1.
INTRODUCTION i
The purpose of this report is to document the National Program Review of decentralized NMSS licensing and inspection programs at Region I.
This review covers the period f rom April 1,1987 through March 31, 1988, with discussion of where the regional programs stood at the end of FY87, es 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 fashion.
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 to quality operations in all five regions and Headquarters.
Additional information on the process can be found in the NMSS National Program Review hanual dated December 11, 1987.
DRAFT 05/13/88 ENCLOSURE RI NPR
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, 2.
FUEL CYCLE AND NUCLEAR MATERIALS PROGRAMS 2.1 Materials Licensing The Region completed 1868 roterials licensing actions in FY87, compared to an adjusted projection of 1908 cases (98%).
Through March 1988, 711 cases have been completed, compared to an adjusted projection of 850 (84%).
Adjustments were made to correlate case completions with receipts and to allow for non-budgeted labor-intensive cases such as 3M and Radiation Technology.*
During the review period, the number of cases pending has fluctuated f rom 492 (in Oct. 86) to 357 (in Oct. 87) to 445 (on March 31,1988). Turnaround times for licensing work were very good in FY87. On ave' age, new applica-tion reviews were completed in 50 days and amendments in 59 days. Overall turnaround average for all cases, including renewals, was 25 days in FY87.
In FY88, turnaround times have increased.
The current average for all cases is 102 cays.
Region I should monitor this trend, and is optimistic that certain recent steps, e.g. improved clerical support, the building consolida-tion, the availabflity of the 5520 to the materials licensing program and the recent RI reorganization will help to bring the turnaround times back to FY87 standards.
There were no significant problems noted in the technical adequacy and accuracy of completed licensing actions. Minor discrepancies have been discussed with the regional staff on an ongoing basis during the review period. Actions are carried out in a consistent manner in accordance with applicable guidance.
The documentation of actions was excellent.
The region has an excellent mixture of senior, intermediate and entry-level personnel in the licensing and inspection programs. The cross utilization of inspectors and license reviewers is excellent.
The staff is very competent with excellent morale.
- NMSS feels that the agency hiring restrictions denied RI the opportunity to meet and exceed FY87 and FY88 licensing completion goals.
DRAFT 05/13/88 ENCLOSURE RI NPR
. 2.2 Materials Inspections Region I completed 1049 material inspection reports and notices of violation (NOV) in FY87. This compares favorably with an Operating Plan goal of 1010.
Included in the inspection reports and NOVs were 322 inspections in Transportation and 118 inspections in Low Level Waste.
On the average, inspection reports and NOVs were issued in 67 days compared to a goal of 20 days. Delays were apparently a result of clerical understaf fing.
When questioned about what plans had been made to resolve the problem, Region I management indicated that they had improved typing services to reduce typing turnaround.
The inspections and reports are of high quality and in accordance with the guidance in Inspection Manual Chapter 2800.
The region deserves particular credit for its extra effort on inspections of allegations (consuming at least one-third staff year), 24 inspections of general licensees, and two reciprocal (radiography) inspections. There also were several special inspections performed of Radiation Technology, Inc.
during FY87 and FY88.
Among Prior ; ties 1, 2, and 3 licensees, there were 18 overdue inspections.
Apparently, management is not closely tracking overdue, high priority inspections.
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" recommended that' priority be given to careful tracking ar acce -
. ment of these high priority licenses.
There were 16 overdue
. cions for priorities 5, 6, and 7.
These could have been covered by using the telephone contact questionnaire as specified in IMC 2800.
The questionnaire was apparently never used during the review period (the telephone contact format was developed by Headquarters for cases when on-site inspections could not be accomplished because of manpower limitations).
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DRAFT 05/13/66 ENCLOSURE RI NPR
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. There were only four unresolved expired licenses that the Region is actively pursuing.
The Region completed followup on 51 pacemaker licensees and prepared a report of their findings as specified in Temporary Instruction 2800/12.
Each of the three Section Leaders accompanied three inspectors, making a total of nine; however, most junior inspectors were not accompanied.
It is recommended that a high priority be placed on accompaninent of junior inspectors.
Jack Metzger of NMSS also accompanied three Region I inspectors in late 1987.
Two of the inspectors were available during the NPR visit and were asked to show their field notes that reflect the inspection findings. A review of field notes indicated excellent comparison to the reviewer's notes.
However, the materials inspectors are still using the 1982 version of the field notes instead of the standard field notes attached to inspection procedure 67100, dated March 23, 1987.
It is recommended that the most current field notes be used to be consistent with 87100.
Several inspectors were interviewed to determine their training accomplishments and any other items they wished to discuss, including those inspectors that were accompanied in the field. Two of the inspectors accompanied had taken courses (as specified in MC 1245) and had been ovalified to perform inspections in additional inspection categories since being accompanied. One inspector had completed training in nuclear medicine and her qualifications journal indicated she had been qualified in medical priority 3 inspections, although occasionally she did do inspections in medical priority 2 broad licenses. Based upon these observations, NMSS concludes the region is doing well to assure that the inspectors meet the training requirements of Inspection Manual 1245.
It should be noted that more regional attention will probably be needed for training in each region, because of recent changes to 1245.
DRAFT 05/13/88 ENCLOSURE RI NPR
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. 2.3 Fuel Cycle Inspections Region I has conducted its fuel cycle facility inspection prograai in accordance with MC-2600 and the applicable inspection modules.
Appropriate Region inspection specialists have supported the fuel facility inspector, providing thorough coverage. Suitable training has been made available to inspectors not previously familiar with fuel cycle fecilities. The documentation for inspections has been of good quality, and, in the last half-year, the time to issuance of inspection reports has been appreciably reduced. The program has been conducted in a technically sound and accurate manner. Although resource expenditures in FY87 were somewhat greater than anticipated, the expenditure was reasonable in response to problems uncovered.
Region I is to be commended for its outstanding organization and preparation of the Monitoring Team Assessment which was conducted very effectively at DOE's West Valley Demonstration Project in advance of operatiun of the supernatant treatment system.
2.4 Fuel Cycle And Materials Safety Initiatives The region is to be contended for implementing the following safety initiatives:
realfgning the staff to rocus attention on certain program areas 1
o (particularly creating a licensing Assistance Section to improve clerical support).
o developing performance based evaluation factors for materials licensees which included the following indicators: management oversight and control, quality of operations, personnel training and qualification, resolution of previously identified items.
sponsoring the 1987 broad scope and 1988 irradiator symposia and o
hosting the Licensing Reviewer Workshop.
DRAFT 05/13/88 ENCLOSURE RI NPR
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. 2.5 Recommendations For Action o
Develop additional inspector expertise in Region I's fuel cycle facilities' systems and processes, as a backup resource for the principal fuel facility inspector.
o Continue to track licensing and inspection turnaround times and notify HQ if recent actions do not improve the situation. Particular attention should be paid to the timeliness of clerical support.
o Once the Agency hiring restrictions dre lifted, recruit to fill staff vacancies. As new responsibilities are added to the FY89 materials programs, staff should be added accordingly.
Increase the number of accompaniments of inspectors by supervisors, o
particularly for junior inspectors.
As stated in 2.2 above, priority should be given to closely o
1 monitoring the completion of inspections of the high priority licensees, to use the telephone contact for the lower priority licenses, in accordance with Inspection Manual Chapter 2800, and to use the official field note formats in inspection.
Surface any problem regarding interactions with Headquarters prior to o
the National Program Review visits.
1 2.6 Headquarters / Regional Interaction l
The overall interaction with Headquarters has been excellent.
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However, the Regions did indicate that there is e need to improve interrction in the medical area. A meeting between Region i and Headquarters has been held since the program review and it appears that this area has been improved somewhat.
This item will be monitored closely during the review year.
DRAFT 05/13/88 ENCLOSURE R1 NPR
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- The Region hosted the Interoffice Working Group meeting earlier this winter.
RI was quick to recommend new budget initiatives in its March 30, 1988 memorandum.
It also has made recommendations to improve the Licensing Management System.
(Because of this recommendation, the LMS Configuration Team will be reconvened.)
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DRAFT 05/13/88 ENCLOSURE RI NPR
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. 3.
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 the physical security inspections.
Material control and accounting inspections will be covered in FY89.
3.1 Safeguards Licensing Program The Region I staff maintains a complete set of Regional Guidance Documents and Standard Review P7ans related to Part 70.32/72.84 reviews for the technical guidance of licensee case reviewers. The documents are up tc date and consistent with NRC guidance and policy.
The case reviews were performed in a sound manner. They were technically complete and generally consistent with Headquarters' policy and guidance.
Inconsis-tencies noted during the reviews were resolved. Correspondence from Region I was forwarded to keiadquarters in a timely manner and properly marked.
Region I achieved an excellent average case turn around time of 39 days in FY87 and an outstanding average case turnaround time of 25 days in FY88.
l Completec licensing reviews have exceeded Operating Plan Goals.
Region I completed 16 reviews vs 4 planned completions in FY87 and completed S reviews vs 4 planned completions in FY88. Region I utilized the NMSS Operating Plan Casework Statistics Report #41 to keep Headquarters informed of licensing casework status on a monthly basis.
The Region I licensing reviewer was trained at Headquarters in 1982 and the Region has cross-traineo additional inspection staff to perfonn licensing reviews and provide back-up capability.
DRAFT 05/13/88 ENCLOSURE RI NPR J
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3.2 Safeguards Inspection Program The Region I staff maintains a complete file of all NRC publications, documents and guidance on planning, conducting, reporting and following-up inspections. Region I has issued Regional Office instructions to supplement NRC guidance in some areas.
The Region I documents and publications are up to date and consistent with NRC policy and guidance. Region I inspection reports were clear and prepared in a technically adequate manner. SGTR Headquarters staff accompanied Region I inspectors on a physical security inspection of UNC Naval Products, Montville, CT from March 14 to March 17, 1988. Tho inspection was performed in a thorough and technically competent manner.
Although safeguards regulations do not require fuel cycle licensees to establish and maintain physical security quality assurance programs, the Region I inspectors generally inspect three modules which fit the definition of quality assurance as "those planned and systematic actions necessary to provide acequate 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 review records and reports and observe implementation of procedures when possible.
The Region I inspection reports have been consistent with Headquarters' policy and guidance.
However, in FY87 the one physical security inspection at UNC Naval Products, a Category I f acility, was conducted by one inspector and expended less than one half of the time utilized by other Regions when conducting a physical security inspection at a Category I facility. The Region I March 1988 physical security inspection at UNC was conducted by two inspectors in order to cover all of the modules and expended approximately the same amount of time as other Regions consume in completing a Category I physical security inspection.
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DRAFT 05/13/88 ENCLOSURE RI NPR
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. By conducting only one physical security inspection at UNC Naval Products in FY87 Region I did not meet the requirements in NRC Manual Chapter 2681 with respect to performing semi-annual physical security inspections at Category I fuel facilities. The Region I safeguards supervisor stated that the Category I facility did not need the required two inspections and that Region I had a shortage of physical security inspectors.
However, Region I did not notify Headquarters of the decision to deviate from the Manual Chapter requirements.
Region I had a shortage of two to three physical security inspectors in FY86 and FY87.
It took as long as a year to fill a vacancy.
(It took other Regions an average of two to three months to fill physical security vacancies under the same circumstances.) Region I performed one physical security inspection at a Category 11 fuel facility in FY87 that was not required by Manual Chapter 2681.
Region I produced an adequate planning and scheduling system for FY88.
The Region stated that the system would be updated on a quarterly basis.
The Region I staff complies with the NRC requirements to file inspection report data in the 766 system but Region I staff does not use the system.
Region I staff found the 766 system data to be unreliable in the past so the staff uses the hard copy of inspection reports for planning, follow-up, tracking and statistics requirements.
Region I completed th3 first semi-annual FY88 physical security Category I fuel facility inspection within the timeframe required by Headquarters.
Region I uses the requirements in Manual Chapter 1231 and the Region I DRSS memorandum to the Chief, Safeguards Section, dated April 18, 1985, subj ect:
" Inspector Qualification" to train new inspectors.
- However, Manual Chapter 1245, subject, " Inspector Qualifications", dated 08/01/86, is the current NRC Manual Chapter in use.
Region I is not following the DRAFT 05/I3/88 ENCLOSURE RI NPR
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. requirements in Manual Chapter 1245 to establish an Individual Development Plan for each qualified inspector and to schedule refresher training for each qualified inspector each 4-5 years.
Region I depends on on-the-job training for qualified inspectors to keep abreast of current technology.
3.3 Licensing and Inspection Initiatives None noted.
3.4 Recommendations for Action It is recommended that Region I:
Perform all of the physical security inspections required by Manual o
Chapter 2681, particularly for Category I facilities; Perform all of the inspection modules required for each physical o
security inspection in a comprehensive manner; follow the requirements in Manual Chapter 1245 for qualified o
inspectors by preparing Individual Development Plans and for assuring that qualified inspectors receive refresher training each 4-5 years.
3.5 Headquarters /Regiorial Interaction Region I responded to Headquarters requests on the following actions:
Region I trained physical security int.pectors in health physics o
procedures to enable these inspectors to perform transportation safety inspections in conjunction with their safeguards inspections, Region I completed a special comparability inspection and report o
within the timeframe requested by Headquarters.
DRAFT 05/13/88 ENCLOSURE RI NPR
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. o Region I staff is reviewing Region I Part 70 licensees' SNM possession limits and holdings to verify the correct facility category for inspection purposes.
Region I would like additional guidance on classification of sensitive information at fuel facilities. This subject was discussed by Headquarters staff during a meeting with licensees and Region I staff in Beltimore, MD on April 21, 1988.
ho FTEs have been allottea to Region I to conduct Part 25 and Part 95 inspections. Region I sent a memorandum to R. Brady, SEC, to inform him of this matter.
1 DRAFT 05/13/88 ENCLOSURE RI NPR.
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- 4.
TRANSPORTATION SAFETY AND SAFEGUARDS INSPECTION PROGRAMS The review of the Transportation Safety Inspections Program is based on review of completed inspection reports, analysis of 766 data on completion of transportation inspections credited to Modules 86740 and 86721, discussions with Regional staff during the assessment visit on April 12-13, 1988, and one accompaniment inspection with a Regional inspector to the Susquehanna Nuclear Station during January 25-27, 1988.
The review of the Transportation Safeguards Inspection Program is based on review of completed inspection reports, analysis of 766 data on completion of transportation safeguards inspections and discussions with Regional staff during the assessment visit on February 23, 1988.
4.1. Transportation Safety Inspection Programs 4.1.1 Materials Licensees Of some 3020 active materials licenses in Region I, 1049 were inspected in FY87.
322 inspections involved transportation Module 86740 in FY87, as compared to 180 in FY86.
Regional staff attributed the " increase" to a revision in the method of preparing the 766 form. As of March 1988 Region I had a backlog of about 35 inspections that were overdue. Approx-imately 50 transportation safety violations were noted as compared -to 87 the previous year. Regional staff was neither aware of nor could they offer a rationale as to the apparent lower number of violations uncovered during an apparent substantially larger number of inspections.
Regional inspectors were still using obsolete (1982) field notes for collection of inspection report detail.
In 1986, standardized updated formats were strongly recommended to all Regions as part of the attachment to Manual Chapter 87100, and the other Regions are currently using the new formats.
(During both the 1985 and 1987 assessment exits, Region I management was advised to convert to the new formats.) About 16 files of completed field notes were reviewed for thoroughness of completion. A number of those observed were only partially completed.
DRAFT 05/13/88 ENCLOSURE RI NPR
- Of some 23 inspectors, a total of only eight were accompanied by the section chiefs. The Chief, Nuclear Materials Safety Branch, had recently directed the section chiefs to establish a firm schedule to accomplish the required annual accompaniment with each assigned inspector.
4.1.2 Fuel Cycle Facilities The six major fuel cycle facilities located in Region I were all inspected against the transportation Module 86740 at least once during FY87. These inspections are performed by the one Fuel Facility Inspection Specialist. During the past year he has been assigned to the Effluent Radiation Protection Section of the Facilities Radiological Safety and Safeguards Branch.
Previously he had been assigned to the Safeguards Section within the former Nuclear Materials Safety and Safeguards Branch. All of the inspection reports generated for fuel facilities continue to appear to be very thorough, of excellent quality and prepared on a timely basis.
4.1.3 Reactors Inspection of transportation (and solid radwaste) activities at operating power reactors is performed by the Effluent Radiation Protection Section of the Facilities Radiological Safety and Safeguards Branch. Two of the inspectors therein perform as " specialists" to conduct inspections of these activities at all of the 21 sites (30 units) located in Region I.
Manual Chapter 2515 and the Region I Operating Plan call for an annual inspection of transportation Mo'dule 86721 at operating power reactor sites.
In FY87 the program had 74% completion (14 of 19 sites).
The Section Chief attributed this backlog to two factors: first, insufficient resources, and secondly, the strong dominance exerted by the Regional Reactor Projects people in developing inspection priorities.
The content, thoroughness and timeliness of completion of the inspection reports appears to be excellent.
Each of the two specialists was noted to have been accompanied at least once by the Section Chief in the past year.
DRAFT 05/13/88 ENCLOSURE RI NPR
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. 4.2 Transportation Safeouards Inspections Region I was not scheduled for transportation safeguards inspections in FY87.
Region I completed one of the two Transportation Safeguards Inspections scheduled for FY88.
The inspection report was technically complete, consistent with NRC policy and guidance and submitted in a timely manner. Region I is on schedule in meeting its Operating Plan goals for FY88.
4.3 Regional Iritiatives Region I is to be commended for:
Conduct of a special 2-week in-house training session for materials o
inspectors during May 1988; o Preparation and submittal of a draft Information Notice to Headquarters to alert licensees on transportation problems associated i
with shipments of contaminated equipment between reactor facilities; and Having the inspection staff assigned to inspect transportation o
activities complete the transportation course H-308, either at TTC or at Region I in November 1987.
4.4 Recommendations For Action i
It is recommended that Region I:
Implement the immediate adoption of Revised Materials Inspection-o Field Notes based on the Attachment to Manual Chapter 87100 formats; 1
Accomplish at least annual accompaniments of each materials inspector o
l by the responsible section chief; and DRAFT 05/13/88 ENCLOSURE RI NPR
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o Reduce the inspection backlog of overcue transportation inspections at operating power reactors so as to perform at least an annual inspection at each site.
4.5 Headquarters / Regional Interaction Region I staff has had a good interaction with Headquarters staff on problems, issues and reactive cases involving transportation matters.
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. 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 of low-level radioactive waste inspection reports credited to inspection modules 84850 and 84722, and discussion with Region I staff during the visit on April 12 and 13,1988.
5.1 10 CFR 61 Low-Level Waste Inspections - Materials For the materials inspection program,118 inspection reports were credited to the inspection of low-level waste of the 1049 inspections performed in FY87. As of March 1988, there was a backlog of 30-40 overdue rcutine inspections. As part of the National Program Review, materials inspection files were examined at the Region I offices to determine the completeness of the inspector field notes. Of the 16 files selected, most were found to have been adequately completed. The review, however, showed that the field note formats were outdated and inconsistent with the recommendations provided in Manual Chapter 87100 Appendix.
Currently, the region is using field note formats developed in July 1982. Updated field note formats were provided to the region in 1984 and standardized updated field note formats were recommended in the Manuai Chapter 87100 Appendix in 1986. The formats in use during this review period did not reference Part 61.
As a minimum, it is recommended that the waste disposal section of the field notes be updated to include Part 61.
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. Inspector accompaniments by the three section chiefs was limited in FY87; only eight of twenty-three inspectors were accompanied during this review period. According to the NMS Branch Chief, the number of section chief accompaniments will increase to a frequency of once annually per inspector, starting in FY88.
The region deserves particular credit and recognition for its effort in the inspection effort at Radiation Technology, Inc., which expended considerable staff resources throughout FY87 and for conducting a licensing and inspection workshop for Broad Scope Licensees which included training on Part 61.
5.2 10 CFR 61 Low-Level Waste Inspection - Fuel Cycle Facilities With respect to the Part 61 inspection program for fuel cycle facilities, all major fuel facilities were inspected at the time of the regional visit.
The low-level waste management inspection coverage at these facilities is excellent, both in inspection frequency and quality.
The region also participated in an advisory capacity on low-level waste management activities at the West Valley Demonstration Project by providing technical and administrative support throughout FY87.
Their support and performance for low-level waste management on this project is excellent.
5.3 10 CFR 61 Low-Level Waste Inspection - Reactors At power reactor facilities, low-level waste inspections were performed at fourteen of the twenty-one reactor sites, with an average of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> spent per inspection.
Two of the twenty-one reactor sites Shoreham and Seabrook, are not currently generating low-level waste, so the FY87 solid radioactive waste management inspection coverage within the region is better than the reported 67%. According to the Effluent Radiation Protection Section Chief, the lack of inspection coverage at five reactor sites is attributed to two factors: (1) limited staff resources and (2) the inspection priority directives given by the regional Reactor Projects people.
For FY88, it appears that 10 CFR 61 inspection coverage at power reactors will be similar to FY87.
DRAFT 05/13/88 ENCLOSURE RI NPR
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. Both of the inspectors that perform low-level waste inspections were accompanied by their section chief during the review period.
5.4 Low-Level Waste Disposal Site Inspections This section is not applicable to this region.
5.5 Low-Level Weste Panagement Initiatives The regiori is to be comnended for implementing the following initiatives:
Developing a two week in-house inspector training program for o
materials inspectors which will include training in low-level waste management inspection.
This course is scheduled for May 1988, Requesting headquarters to develop guidance on 10 CFR 61 enforcement o
policy.
Conducting a broad scope licensing seminar held in April 1987 which o
included training on Part 61.
5.6 Recommendations for Action For the materials inspection program, adopt inspection fi-eld note o
formats to include 10 CFR 61 and begin annua.1 inspector accompaniments by their section chief.
For the reactor inspection program, decrease the current backlog of o
solid radioactive waste inspections during FY88 and perform annual inspections at each facility.
DRAFT 05/13/88 ENCLOSURE RI NPR
, 5.7 Headquarters /Reaicnal Interaction Region I staff has communicated well with HQ on low-level waste management inspection matters.
The request for LLWM guidance pertaining to 10 CFR 61 enforcement policy and the request for assistance with a licensee's manifest problem are two examples of such interaction. The region / headquarters interaction proved beneficial for both the region and headquarters in identifying and surfacing these relevant low-level waste management issues.
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. 6.
URANIUM RECOVERY LICENSING AND INSPECTION Not applicable to Region I.
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. 7.
FTE AND PROGRAM SUPPORT FUNDS UTILIZATION The following table shows FTE allocations and expenditures for the review period.
Region I has no program support funds in the NMSS mission areas.
i FY88 FY87 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT.-DEC. OCT.-DEC.
Materials Licensing 7.8 8.2 105 8.2 2.1 2.4 114 Materials Inspection 16.1 18.2 113 16.3 4.1 4.5 110 Fuel Facility Licensing 0.1 0
0 0.1 0
0.3 Fuel Facility Inspection 2.4 2.2 92 4.1 1.0 0.8 80 SG Fuel Facility Lic.
0.2 0.3 150 0.3 0.1 0.1 100 SG Fuel Facility Insp.
2.0 1.1 55 2.0 0.5 0.1 20
)
SG Transportation Insp.
1.6 0.4 25 0.2 0.1 0
0
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LLW Inspection Totai 30.2 30.4 101 31.2 7.9 8.2 104 NOTES:
l 1)
FY87 expenditures frorr FY87 RITS RWAT report; section supervision prorated.
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 materials licensing program is fully staffed.
The resource data for the materials inspection program are ambiguous. RWAT figures (See Table above) indicate full staffing. But, Region I generated data (through January 1988) indicate that staffing shortages exist in the materials inspection DRAF1 05/13/88 ENCLOSURE RI NPR
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, program.
These shortages are resulting from the Agency's hiring restrictions, which permit only about 3 new hirees for the Region each month. This level allows RI to offset attrition, but will probably result in FTE underexpenditures for FY88.
The situation is compounded by the 3M Po-210 failure which consumed over 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of staff time through March 1988. This unbudgeted item puts an additional strain on the materials program. The Region understands that its ability to face new budget initiatives in FY88 and beyond may be inhibited by the NRC hiring restrictions.
During FY8'i in the Safeguards and Transportation program, Region I under-expended FTEs in inspections due to a shortage of inspector personnel. Based on j
limited FY88 data, resources are being expended at a rate slightly lower than expected due to limited inspections.
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