ML20057A221
| ML20057A221 | |
| Person / Time | |
|---|---|
| Issue date: | 07/06/1988 |
| From: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309130227 | |
| Download: ML20057A221 (3) | |
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6 1988 MEMORANDUM FOR:
Robert M. Bernero, Deputy Director, Office of Nuclear Material Safety and Safeguards FROM:
Carl J. Paperiello, Deputy Regional Administrator, Region III
SUBJECT:
DRAFT REGION III 1988 NATIONAL PROGRAM REVIEW REPORT This refers to your memorandum of June 20, 1988, enclosing for our review and comment a draft National Program Review report for Region III.
Region III reviews this report as very positive and has few significant coments.
Attached to this memorandum are more detailed minor comments from the staff.
From an overall regional perspective, we see this report as a fine report.
With respect to a comment in the report that one of our section chiefs accompanied only three inspectors during the review period, we note that our records show that he accompanied six of his seven inspectors during the review period and by the end of the fiscal year, will have accompanied all of them.
For your information, Region III has a Regional Procedure that requires a minimum amount of accompaniment and site visits to be made by all Region III supervisors and managers up to and including the Regional Administrator's office.
This prom dure was instituted around August of last year to insure that all inspectors would be observed in the field by their supervisors and all regional managers would have an opportunity to visit and evaluate management performance at major facilities in Region III.
I have been pleased to have an opportunity to review and comment on this
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Carl J. Paperi llo Deputy Regional 'dministrator
Attachment:
As stated 9309130227 930830 PDR STPRG ESOGEN
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DETAILED STAFF COMMENTS 1.
The report is somewhat repetitive since many of the different Headquarters programs are conducted by the same people in Region III. For example, the backlog of Region III inspections is mentioned in several places.
The accompaniment of three of six inspectors by one Section Chief is mentioned in several places.
2 The report itself would lead one to believe that there was a rather significant effort in many different areas.
However, when looking at the FTE and program support listing on Item 7, Page 19, it is clear that some of the programs are quite small and possibly this could be reflected somewhat in the write-up. Of particular interest, is the write-up of low level waste inspections.
The write-up in 5.1 would show that 345 inspection reports were credited to the inspection procedure on low level waste inspections, and the write-up sort of describes the general materia' inspection program. On the other hand, there is no FTE budgeted at all for the low level waste inspection program.
It would seem appropriate for the NMSS report to either give appropriate credit to the Region for conducting inspections in an area where no FTE is given, or to budget FTE for low level waste inspections.
3.
In Sections 4.1.3,4.4, 5.3 and 5.6, it is unclear whether the findings and recommendations refer to accompaniments of inspectors during inspection of transportation and low level waste inspectors or inspectors in general.
If the former, we strongly disagree with the recommendations inasmuch as such accompaniment effort will impose an enormous resource burden on our section chiefs (approximately 24 to 30 inspector accompaniments for the purpose alone per year). We do not disagree with the latter interp "tation of the recommendations and have normally been able to adhere to ;he same; however, we do disagree with the findings that the Facilities Radiation Protection Section Chief accompanied only three of his six inspectors during the review period.
Our records show that the section chief accompanied six of seven inspectors during reactor inspections within the review period.
4.
In Section 7 of the report, there is mention that NMSS is concerned that fuel facility inspection expenditures were well below budget in FY87 and the trend is continuing for FY88.
Regin III would like to point out that while we may not have expended all our allocated FTE in this area, all of our allotted FTE in the fuel facility inspection program is expended in other NMSS areas which are currently not adequately budgeted such as spent fuel shipments, contaminated sites, and the transportation inspection program. (This was discussed with NMSS reviewers and we are optimistic that the FTE allocation will be properly distributed in the future.)
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, There is also mention in this section of a recommendation for the Region to have a backup capability for the one fuel cycle inspector. Region III does have an experienced fuel facility inspector (Mr. K. Ridgway in i
another Division) who could be called upon in an emergency.
In addit on, the Region has purposely assigned health physics inspectors to periodically accompany the assigned fuel facility inspector to increase their familiarization with the fuel facilities in order that they can be called upon in an emergency. These two backup sources to the current inspector Region III feels is the most cost effective FTE utilization currently available to us.
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