ML20057A218
| ML20057A218 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/1988 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309130222 | |
| Download: ML20057A218 (22) | |
Text
JUN 2 01988 MEMORANDUM FOR:
Carl J. Paperiello Deputy Regional Administrator, RIII d
FROM:
Robert M. Bernero, Deputy Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
DRAFT REGION III 1988 NATIONAL PROGRAM REVIEW REPORT Enclosed for your review ana comment is a draft National Program Review report for Region III.
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 III 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, i
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.
j l
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 III 1.
INTRODUCTION The purpose of this annual report is to document the National Program Review of decentralized NMSS licensing and inspection programs at Region III. As the responsible program office for non-reactor activities, NMSS continuously reviews regional programs to assure that the regions are conducting their activities in a technically sound, consistent, timely, and efficient fashion. This report 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.
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 Manual dated December 11, 1987.
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FUEL CYCLE AND NUCLEAR HATERIALS PROGRAMS 2.1 Materials Licensing The Hea', quarters staff reviewed about 20% of completed licensing cases. Based on these reviews and continuous interfaces with the Region on various technical issues, we conclude that the licensing is clearly technically adequate and consistent, with no shortcomings related to public health and safety.
Licensing actions are performed in accordance with applicable Standard Review Plans, and are generally of high quality with few technical or clerical errors.
Section and branch level management play an active role in licensing matters.
For actions that have policy implications or are not clearly dealt with in Standard Review Plans, the staff seeks guidance from cognizant headquarters personnel. The staff has made recommendations for topics that require policy or technical guidance.
Region III has the heaviest workload and the lowest labor rate budgeted for materials licensing of any region. Notwithstanding this fact, RIII 1
completed 2110 materials licensing actions in FY87 compared to a baseline projection of 1946 cases.
This represents 108% of the baseline Operating Plan projection, the best of all regions.
Due to major events such as response to problems at the Wright-?atterson Air Force Base, case completions dropped in late 1987. However, the region developed a
" recovery plan," and as of March 1988, 1219 licensing reviews were completed, compared to an adjusted projection of 893(137%).
This effort has reduced the backlog of cases pending from over 700 (in Oct. 87) to under 500 (in March 88).
RIII made judicious use of overtime to achieve these goals.
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i With respect to licensing turnaround times, FY87 new applications took an average of 55 days to complete. Amendments took an average of 67 days.
Similar actions are taking slightly longer in FY88.
Renewals are normally being handled on a first-in, first-out basis.
- However, there are several old, difficult renewals pending.
Region III played a key role in coordinating Headquarters and regional response to the 3M incident. On January 22, 1988, Ashland Chemical Company (ACC), of Easton, Pennsylvania, notified NRC's Region I office that alpha contamination was detected at their facility. Region I correctly notified both Headquarters and Region III because the static elimination device was distributed to ACC under a Region III license issued to 3M. Region III sent an inspection team to 3M on January 25, 1988, and uncovered facts that eventually lead to several orders halting the distribution and use of the 3M static elimination device. Region III has continued to take the lead in coordinating information exchanges between NRC, the Agreement States, and 3M.
2.2 Materials Inspections The NMSS staff has evaluated implementation of guidance provided in NRC Manual Chapters and procedures applicable for the materials inspection program; discussions with Regional staff throughout the year; the results of the regional assessment visit on March 30-31, 1988; regional inspection reports; notices of violation and NRC Form 591's; the LMS and 766 system summary listing of inspection efforts on the relevant inspection modules; and the results of one inspection accompaniment.
The Region completed 1,113 materials inspections for FY87, and 347 inspections through March 31, 1988.
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i During the inspection accompaniment, it was observed that NRC Procedure 87100 was followed, as well as guidance given in NRC Manual Chapter 2800.
Inspections were thorough and missionary work was provided for licensees with weak programs.
Violations were clearly explained.
Entrance and exit interviews were conducted properly and results of the inspections were clearly communicated to the appropriate licensee management level.
Based on the accompaniment and a review of inspection reports, Region III-l appears to be properly implementing guidance on the conduct and reporting
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of inspections.
Inspectors and section chiefs participate in the i
assignment of cases.
Region III has an efficient centralized inspection scheduling system managed by the inspection management assistant. Such a system is necessary due to Region III's geographic distribution of licensees, and provides appropriate allocation of resources.
Inspections are also scheduled for special events, in response to allegations, and in response to categorical events (e.g., Wright-Patterson precipitated ine lased AF inspections).
Region III is to be comended for initiating an audit of reports l
involving Severity Level IV and Y violations, and implementing a program to improve inspection reports.
The average turnaround time on inspection reports is very fast:
19 days.
This is a remarkable accomplishment in light of heavy i
workload, including special cases such as the Hines Veterans Administration allegation and extensive assistance to the Office of Investigations on that matter. Management oversight of inspection schedules is outstanding.
There were very few overdue inspections and management had good explanations for why they had not yet been completed.
The regional staff also makes good use of telephone contacts to reach low-hazard licensees who are not inspected frequently.
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Training for all inspectors was up to date in accordance with Inspection Manual Chapter 1245.
Some concern was expressed by inspectors that allegations were taking too long to resolve.
Region III management instituted a program to speed up the process.
2.3 Fuel Cycle Facility Inspection This evaluation by NMSS of Region III's fuel cycle facility inspection program is based on review of inspection reports, an inspection accompaniment, communications with the Region staff and the National Program Review team visit to the Region III offices.
Inspections are j
carried out in a manner consistent with applicable guidance.
Appropriate inspection specialists have supported the fuel facility inspector; inspectors were provided adequate opportunity to become acquainted with the facility's documents prior to the inspection.
Inspection reports have been technically adequate and accurate, and of consistently high quality. Documentation of actions is clear and complete.
The reports have been issued on average within the 20-day goal.
It appears that Region III accomplished the required fuel cycle facility inspections in FY87, but with less than the projected amount of FTE.
In the first part of FY88, resource expenditures were lagging behind projections.
2.4 Fuel Cycle and Materials Safety Initiatives Region III aggressively pursues improvements in the materials area.
In particular, they are to be commended for the following initiatives:
Upgrading liaison and telephone communications with each fuel o
- facility, Completion of a pilot program on performance evaluation criteria o
which will serve as a model for Headquarters and all five regions.
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i Various efforts to improve staff technical training, o
o Hosting a workshop for broad licensees.
o Initiating an audit of inspection reports involving Severity IV and V violations, o
Pursuing contracts with additional medical consultants.
o Developing improved field notes for teletherapy inspections, o
Improving emergency preparedness modules for fuel cycle inspections.
Developing a centralized inspection scheduling system.
o 2.5 Recommendations for Actinn Region III should continue its program to speed up resolution of o
allegations.
The Region III staff suggested that the Licensing Management 0
System should be made more efficient to cut costs, Region III should continue its missionary work when appropriate o
and continue to provide effective communication with licensees, A backup capability for the region's only fuel cycle inspector o
should be developed.
The backup should be acquainted with the processes and systems of the fuel cycle facilities in the region.
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2.6 Headquarters /Regicnt Interaction o
The Region has been quick to respond to Headquarters action requests. Communications with the Region have been generally excellent.
o Headquarters needs to review labor rates for inspection and casework.
(Thisactionhasnowbeencompleted.)
o Headquarters and Regions need to continue to work together to improve training opportunities (and to support such opportunities with resources).
o RIII new budget initiatives were well-developed and will be pursued during the budget cycle, particulary recommendations pertaining to the sampling of generally licensed products for design adequacy.
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3.0 SAFEGUARDS LICENSING AND INSPECTION PROGRAMS i
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 FY89.
3.1 Sa/eguards Licensing Program The Region III staff maintains a complete set of Regional Guidance Documents, Standard Review Plans, and supplementary regional instructions related to Part 70.32/72.84 reviews for the technical guidance of licensee reviewers.
The Region III documents have been updated and are consistent with NRC policy and guidance.
Region III did not receive or complete any 70.32/72.84 case reviews during the evaluation period.
Region III used the NMSS Operating Plan Casework Statistics Report #41 to keep Headquarters informed of the casework status on a monthly basis. The Region III license reviewer was trained at headquarters in 1982 and the Region cross-trained additional inspection staff to perform licensing reviews and provide a back-up capabili ty.
Region III hao no difficulty in replacing the original i
license reviewer when he left government service.
3.2 Safeguar(2 i.3pection Program The Region III staff maintains a complete file of all NRC publications, documents and guidance on planning, conducting, reporting and following-up inspections.
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In adaition, Region III has issued guidance to supplement NRC Headquarters guidance to provide detailed instructions for the technical staff to assure uniformity in the planning, conducting and reporting of inspections.
The Region III documents and instructions are up to date and consistent with Headquarters policy and guidance.
Region III did not conduct any physical security inspections at non-reactor facilities during the evaluation period.
Region III has an outstanding planning and scheduling system for the safeguards section. The section chief produces an annual computerized inspection schedule which is updated on a quarterly basis.
The Region III inspection schedule will l
meet the inspection goals in the Regional Operating Plan and in Manual Chapter 2681.
The Region III staff follows NRC instructions in using the 766 system and has established supplementary regional instructions for use by inspectors.
The section chief noted that the information in the 766 system is not current and that the system does not provide much of the information needed by supervisors to implement the safeguards program.
Three inspectors have left Region III in the past three years.
Replacements for the departed inspectors were hired in an average of two months.
The new inspectors were trained in accordance with Manual Chapter 1245, Inspector Qualification, and Regional Procedure 1231A. Training required for new inspectors, as well as refresher and supplementary training for qualified inspectors are included in the detailed annual Region III Safeguards Schedule together with all of the reactor and fuel facilities planned inspections.
3.3 Licensing and Inspection Initiatives Region III is to be commended for working with Region V in borrowing material control and accounting technical expertise not available in Region III for an MC&A inspection of a Category III fuel facility.
Region III loaned a physical security inspector to Region V for a physical security inspection.
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i 3.4 Recommendations for Actions None noted.
3.5 Headquarters / Regional Interaction Region III was responsive to Headquarters' requests on the following actions:
o Region III trained safeguards inspectors in safety and health physics aspects of transportation inspections to enable them to perform trans-portation safety inspections in conjunction with safeguards inspections.
o Region III staff reviewed all of the Region III Part 70 licensee SNM possession limits and holdings to verify the correct facility category for inspection purposes.
Region III recommended that their inspectors participate with other Regions in implementation of inspection programs at active fuel facilities. The staff noted that the cross-training benefits of this approach would be very valuable.
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s 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 86721, discussions with Regional staff during the assessment visit on March 30-31, 1988, and one accompaniment inspection with a facil-ities Radiation Protection Inspector to the LaSalle Nuclear Station on March 28-29, 1988. The review of the Transportation Safeguards Inspection Program is based on review of completed inspection reports, analysis of 766 system data on completed inspections and discussions with Regional staff during the assessment visit on February 3,1988.
4.1 Transportation Safety Inspection Program 4.1.1 Materials Licensees Based on 766 system data for FY87, coverage of transportation activities under Module 86740 during inspection of materials licensees continues to be excellent.
Of approximetely 2850 active materials licenses in Region III, about 1100 were inspected.
Five hundred eighty three inspections were transportation related under Module 86740, with some 50 violations of transportation requirements reported. Two escalated civil penalty action's were processed. As of March 1988 Region III had a backlog of 67 inspections that were overdue. The two section chiefs accompanied each of their inspectors at least once during the reporting period. The field note formats in use by materials inspectors were consistent with the formats in MC87100. Completed field notes from 12 inspections in FY87 were selected randomly for examination and found to be complete in all respects.
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i 4.1.2 Fuel Cycle Facilities The five major fuel cycle facilities located in Region III were all i
inspected against the transportation Module 86740 at least once during FY87. These inspections are performed by the one fuel facility inspection specialist who had been recently reassigned administratively from the Facilities Radiation Protection Section of the Emergency Preparedness and Radiological Protection Branch to the Radiological Effluents and Chemistry Section therein.
All of the inspection reports generated for fuel facilities appear to be very thorough, of excellent quality and prepared on a timely basis.
One fuel facility, the General Electric, Morris, Il spent fuel storage facility, continues to receive rail shipments of spent fuel from Cooper Station in Nebraska.
Each shipment is usually inspected by the fuel facilities inspector upon its arrival at Morris. One notice of violation was processed which involved excessive surface contamination on a spent fuel cask.
4.1.3 Reactors The Region III inspections of transportation activities at operating power reactors were performed as programmed.
Inspections were performed by radiation specialists from the Facilities Radiation Protection Section of the Emergency Preparedness and Radiological Preparedness Branch.
Of the 20 sites and 27 units in the Region, 23 annual inspections were credited to Module 86721 and 2 to Modules 86721/86740 combined.
Three sites, each rated SALP-1, were not inspected, due to the reduced inspection effort allowed for such facilities.
One other unit is being decommissioned and is not on a normal inspection effort. The reports generated from the inspections appear thorough and complete, and prepared on a timely basis.
The Section Chief accompanied only three of his six inspectors during the reporting period.
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s 4.2 Transportation Safeguards Inspections Region III completed one transport safeguards inspection in FY87.
Region III is scheduled to complete five transportation safeguards inspections in FY88. As of March 31, 1988, four had been completed.
The inspection reports were technically complete, consistent with NRC policy and guidance and submitted in a timely manner.
Region III is ahead of schedule in meeting its Operating Plan goals.
4.3 Regional Initiatives Region III is to be commended for:
o Having had all their inspectors assigned to inspecting transportation activities complete the transportation course H-308, either at TTC or the course conducted at Region III in September 1987; o Initiation of in-house training sessions on health physics and the NRC Manual; o Implementing a trial program for " performance indicators" in the materials inspection program; and o Conducting a licensing and inspection workshop for Broad Scope Licensees in October 1987.
4.4 Recommendations For Action Region III should develop and implement a schedule so as to effect at least an annual accompanirent by the Facilities Radiation Protection Section Chief with each inspector in the Section.
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i 4.5 Headouarters/ Regional Interaction Region III staff has maintained an excellent 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 Low-Level Waste Inspection Program review is based on an analysis of 766 system data on low-level waste inspection reports credited to inspection modules 84850, 84722 and 84522, the review of completed inspection reports, an accompaniment inspection with a regional inspector at the La Salle Nuclear Generating Station, and discussion with Region III staff during the visit on March 30 and 31,1988.
5.1 10 CFR 61 Low-Level Waste Inspections - Materials For the materials inspection program, 345 inspection reports were credited to inspection procedure 84850 of about 1100 inspections performed by the region during FY87.
As of March 1988, there was a backlog of 67 overdue routine inspections, only four of which are priority 1.
The NMSS section chiefs have accompanied each of their inspectors during this review period.
As part of LLWM's National Program Review, Region III materials inspection files were examined at the Region III offices to determine the completeness of the inspector field notes.
Twelve files were selected randomly; all were found to have been adequately completed and of excellent quality.
The review also showed that the field note formats were consistent with the recommendations provided in Manual Chapter 87100 Appendix.
The region deserves particular credit and recognition for its effort in the inspection effort at Wright-Patterson Air Force Base, which expended considerable staff resources throughout FY87.
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s 5.2 10 CFR 61 Low-Level Waste Inspections - Fuel Cycle Facilities During FY87, Part 61 inspections were performed at the five major fuel cycle facilities by the Fuel Facilities Radiation Specialist. Each of these facilities was noted to have been inspected against module 84850 at the ime of the regional visit.
5.3 10 CFR 61 Low-Level Waste Inspections - Reactors For the Region III 10 CFR 61 inspection program at power reactor facilities, low-level waste inspections were performed annually at each of the units by two sections in Region III during FY87.
Three sites, Kewaunee, Monticello and Prairie Island, were rated SALP-1 and therefore did not receive Part 61 inspectione due to the reduced inspection effort allowed for these facilities. Another unit, Lacrosse, is currently being decommissioned and is not routinely inspected in the area of low-level waste.
According to 766 system data, an average of six hours is credited to module 84722 per inspection.
In addition, four units were inspected against module 84522 during the review period. The Facilities Radiation i
Protection Section Chief accompanied three of his six inspectors during
- the review period.
l 5.4 Low-Level Waste Disposal Site Inspections This section is not applicable to this region.
5.5 Low-Level Waste Management Initiatives The region is to be commended for conducting a licensing and inspection workshop for Broad Scope Licensees which included training on Part 61 during October 1987.
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i 5.6 Recommendations for Action for the reactor inspection program, implement annual inspector accompaniments by the appropriate section chief.
5.7 Headquarters / Regional Interaction There has been limited opportunity for Headquarters / Regional interaction on low-level waste inspection matters.
Recently, the region has expressed interest in receiving further guidance on the inspection of low-level waste storage facilities.
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's 6.
URANIUM REC 0VERY LICENSING AND INSPECTION Not applicable to Region III.
e e
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.1 7.
FTE AND PROGRAM SUPPORT FUNDS UTILIZATION The following table shows FTE allocations and expenditures for the review period.
Region III has no program support funds in the NMSS mission areas.
FY88 FY87 ANNUAL 8UDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED 8UDGET OCT.-DEC.
OCT.-DEC.
Naterials Licensing 7.7 8.6 112 8.0 2.0 2.5 125 Materials Inspection 14.2 14.3 101 13.3 3.3 3.3 100 Fuel Facility Licensing 0.4 0.1 25 0
0 0.4 Fuel Facility Inspection 2.4 1.8 75 3.3 0.8 0.3 37 SG Fuel Facility Lic.
0.2 0.2 100 0.2-0.1 0
0 SG Fuel Facility Insp.
0.5 0.1 20 0.5 0.1 0
0 SG Transportation Insp.
0.2 0
0 0.2 0.1 0
0 LLW Inspection Total 25.6 25.1 98 25.5 6.4 6.5 102 NOTES:
1)
FY87 expenditures from 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 inspection and safeguards programs are fully staffed.
The materials licensing program staffing exceeds the budget slightly.
Fuel facility inspection staffing consists of one full-time fuel facility inspector and portions of time expended by various emergency preparedness and radiation specialists.
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s Overall resource expenditures for FY87 and FY88 are inline with projections.
However, fuel facility inspection expenditures were below budget in FY87 and the trend is continuing in FY88.
Even though fuel facility inspections are being performed adequately and in accordance with program guidance, NMSS is concerned about how resources are being expended in this area.
While Region III is fortunate to have a well-qualified, experienced fuel facility inspector, they do not have a specific person cross-trained to provide backup capability.
As stated above, various emergency preparedness and radiation specialists have been involved in selected aspects of the fuel facility inspection program.
Since NMSS has provided sufficient resources to allow for this backup training, Region III should consider applying them.
During FY87, Region III completed 108% of their baseline materials licensing casework goal.
They accomplished this goal by expending more resources than budgeted.
Expenditures in FY88 also exceed budgeted projections; this is partially due to overstaffing in this area.
Region III's labor rates, based on FY85 and FY86 data, are the lowest of all regions.
NMSS is currently rcviewing FY87 labor rate data for incorporation into the FY90 budget.
Overall materials inspection resource utilization is inline with expectations for both FY87 and FY88.
However, a large portion of these resources have been utilized for non-routine inspections such as Wright Patterson, 3M, Case Western and Advanced Medical Systems.
We agree with Region III's diversion of resources to these high priority requirements.
NMSS has approved an operating plan change to reflect a shift from routine to reactive inspections.
During FY87 in the Safeguards and Transportation program, Region III completed twice as many licensing cases as budgeted. However, safeguards fuel facility inspection expenditures and safeguards transportation inspection expenditures were belew budget in FY87.
Based on limited FY88 data, resource expenditures are running behind due to scheduling of physical security inspections late in the fiscal year.
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e In summary, Region III has effectively utilized nuclear material safety mission area resources. They reallocate to high priority areas when circumstances warrant and keep NMSS management informed.
We recommend, however, that the staff utilization in the fuel facility inspection area be examined to provide backup capability.
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