ML20057A249
Text
e pr ' f. f 19F MEMORAt:puti FCR:
Jaraes H. Allan, Deputy Regional Administrator, Region I FR0t;:
Carl J. Paperiello, Acting Deputy Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
DRAFT NMSS NATIONAL PROGRAM REVIEW REPORT The titSS National Program Review report is enclosed in draft form for Regional coment. The report provides the results of the Office of Nuclear Material Safety and Safeguards' review of 1988 programs under the Headquarters' resporsibility as related to your Region.
The Headquarters' teams participating in the review were comprised of individuals from each of the four elements of NMSS that are involved in Regional activities. The National Program Review Manual dated December 11, 1987, was the basis for the review. The National Program Review is based not only on the visit to the Region, but on the collective Regional / Headquarters interfaces throughout the year, through review of licensing casework, inspection reports, accompaniment of Regional inspectors, review of casework, and inspection statistics, technical assistance and coordination, and coordination ana Regional respenses to an NMSS questionnaire.
The report is intended to provide a review of the effectiveness of both the Regions and NMSS activities insofar as they relate to Regional activities.
The emphasis relates to achieving two elements; the numerical goals for casework and inspections as well as the quality of the efforts, on the basis that both elements contribute towards assuring the safety of operations involving NRC licensed activities.
I would appreciate your review of the draft report and any coments relating to the way it portrays Regional efforts.
We would appreciate your comments as a marked-up copy, as appropriate. Please provide Regional response by May 23, 1989.
Following incorporation of Regional coments, the final report will be transmitted to the Regions by the NMSS Director.
[
Carl J. Paperiello, Acting Deputy Director Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated 9309130277 930830 Q'?r7 PDR STPRG ESGGEN cy PDR
r i
i conies M. Aller 2_
DISTRIBUTION:
IMI6 centrcl File fit;SS r/f DD Director's r/f RECunninghan j
GSjoblom JFunches RBurrie t t JGreeves j
l 1
I i
4
- See previous concurrence j
OFC: INN 5 ^
- IMNS *
- IMDA ^
- LLWM
- 5GTR^
- 14M5 ~
N AME : GSj ob l ora / cv : RE C u nn i ng ha m: JFu n ches : J G reev e s : B B u rn e t t : CPa pe h e l lo: RB e rne ro DATE:4/ /89
- 4/ /89
- 4/ /89 :4/ /89 :4/ /89 :4/(/89 4//,/89 j
UttALIAL htLUKU LUVI
/"
)
l a
~. - -.
L:
g 4
James M. Aller
DISTRIBUTION:
IMNS Central File NMSS r/f DD Director's r/f RECunninghan GSjoblom JFunches l
RSurnett JGreeves Y
.../
4 lilb
(
OFC: INNS
.\\
- 1NNS
'A Q. _ _ _ _b. :______\\f.______________
- LL 4M 56
- NM55
- NM55 NAME:G t/cv: REC.f m:J unches:JGreeves:BBurnett:CPaperiello:RBernero
~
a;re;;r-;;;;;;r -;res;;r;re;;r:m;;r;;r;;r,r;;r-Urt1LihL MLLUKU LUF
-o.
-r James M. Allan DISTRIBUTION:
IMNS Central File NMSS r/f DD Director's r/f RECunningham GSjoblom JFunches RBurnett JGreeves i
1 I
i l
i b
un OFC: IMNS
- IMN5
- TMDA
- LLy p T:5GTR
- NM55
- NM55
'I
______a
____________...__.J%.... _________ _______________
$$b[I.____$(($bbY____I[f_$$$_*.*[fI[$$[$I[I!$$"_$$![!*.'$[!$!$[$$$$"$$$.
DATE:4 h /89
- 4/2/89
- 4/ /89 :4/2"//89 :4/ /89 :4/ /89 4/ /89 i
vrriciac nr.cunu curi
)
I
REPORT OF NMSS 1989 NATIONAL PROGRAM REVIEW AT NRC REGION I, KING OF PRUSSIA, MARCH 9-10, 1989 1.
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Materials Safety and Safeguards review of 1988 programs under the Headquarters responsibility of NMSS as related to Region I and under the responsibility of NRC Region I.
The Headquarters Team participating in this review was comprised of individuals from each of the four elements of NMSS that are involved in Regional activities.
The NMSS Team is shown on Attachment 1.
The principal Regional activities are primarily under the responsibility of the Region I Division of Radiation Safety and Safeguards (DRSS).
The DRSS Division.
organization chart is shown on Attachment 2.
The National Program Review Manual dated December 11, 1987 was the basis for the review.
Region I responses tc a Headquarters questionnaire dated February 6,1989 are provided as Attachment 3.
The National Program Review is based not only on the visit to the Region but on the collective Regional / Headquarters interfaces throughout the year, through review of licensing casework and inspection reports, accompaniments of Region-based inspectors, review of casework and inspection statistics, resource utilization, technical assistance and coordination, and the questionnairs.
The review is intended to provide a review of effectiveness of both the Regional and Headquarters activities insofar as they relate to Region I activities and to identify suggestions for improving the effectiveness of the joint efforts of NMSS and Region I.
The emphasis relates to achieving two elements:
the numerical goals for casework and inspection as well as the quality of the efforts, on the basis that both elements contribute towards assuring the safety of operations involving NRC licensed activities.
The report is organized so as to present an integrated summary in each of the following areas:
1
9 1.
Background'and Purpose 2.
Licensing 3.
Inspections 4.
Training 5.
Initiatives 6.
Interfaces of Region /NMSS 7.
Resource Utilization 8.
Recommendations / Suggestions
+
t k
e
~.-
4 2.
LICENSING a.
Materials Safety In FY88, the Region completed 100 percent and 105 percent of budgeted licensing actions for both new licenses and amended licenses and 66 percent of the budgeted renewal licenses.
In total, the Region completed 94 percent of their budgeted license case work.
It appears that the shortfall of completion of renewals was caused by temporary factors such as having new reviewers who were being trained assigned to work on renewals who were less efficient, and a large number of renewals started in FY88 were not completed until FY89.
A check of early FY-89 completions indicates that Region I has recovered from the FY88 shortfall and should have a reduction in its pending case work at the end of FY89.
Region I has made an extensive effort to cross-train their licensing reviewers and inspectors into a single team.
This is extremely helpful if an individual is sick, injured, or on maternity leave in that it allows employees to return to work part-time to perform licensing issues.
Region I had now operated under their new reorganization for one year.
To some extent it has allowed section chiefs and senior staff members to focus their attention on narrower issues.
However, a disadvantage may be that less senior staff members are gaining less experience in some areas than in the past.
Also, currently the Section chiefs seem to be overloaded.
One estimated that each Section chief spends about 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> of overtime per week.
The Regional management should strive to identify ways to alleviate this problem.
Overall the new reorganization appears to be performing well.
There appears to be a healthy team approach in that the sections are willing to help each other as needed.
A select number of Region I licensees' cases were reviewed against NRC Regulations and Standard Review Plans.
The cases are complete, no errors noted.
The extra effort to issue a limited number of licenses to nuclear i
I 1
3
1 cardiology companies is commendable.
This required a significant use of a high cost operation in staff resources but should result in better licensee compliance in the future.
A small sampling of docket files showed that the files were maintained well.
Routing and control of docket files is similar to that of Region IV.
Region I has an excellent system for tracking the status of licensing actions and inspections, b.
Safeguards Licensing The Region I staff maintains a complete set of Regional Guidance Documents and Standard Review Plans related to 10 CFR 70.32 reviews for the technical guidance of license case reviewers.
The documents are up-to-date and consistent with NRC guidance and policy.
The case reviews were technically complete and performed in a sound manner.
Region I achieved a very good average case turnaround time of 38 days in FY88.
Region I completed seven licensing case reviews versus the eight projected completions in FY88 and have completed two reviews versus one receipt in the first quarter of FY89.
Region I utilizes the NMSS Operating Plans Casework Statistic Report #41 to keep Headquarters informed of licensing casework status on a monthly basis.
4 J
~
4
'l S.
INSPECT)0f3 a.
Materinis Inspections In FY86, 1162 materials safety inspections were completed, which is 97 percent of the annual goal.
Through February 1989, 431 inspections were completed, which is 96 percent of the goal for five months of FY89.
Headquarters review of about 60 inspection letters indicated no problems with the quality and documentation of inspections.
Overall, internal communications in the Region is good, and the inspectors were well informed of Regional goals and generic issues such as performance evaluation factors and enhanced medical inspections. Some steif members did suggest that I; ranch staff meetings should be held periodically to aiscuss issues between sections, instead of just within sections.
The Region had not emphasized the use of performance evaluation factors by 611 inspectors yet, but is planning to shori.ly.
There were two notable improvements over 1988.
Section leaders are accompanying inspectors at least once per year, and there is close n.onitoring of overdue inspections.
Some Region I inspectors are apparently not documenting some Severity Level V violations.
In accordance with the October 13, 1988 revision of the Enforcement Policy, discretion may be used to not issue a notice of violation for a Severity Level V violation, provided it is documented in an inspection report or official field notes, the violation is not an isolated violation, not a repeat violation, and corrective action is underway.
b.
Fuel Facility Inspections The Effluents Radiation Protection Section of the Facilities Radiological Safety and Safeguard: Branch has the primary responsibility for the fuel cycle inspectinn program while NMSS Section B inspects other source material licensees.
During FY88 the fuel cycle inspection program was 5
effectively completed.
To date for FY89 the program is on target in all areas except for health physics.
Because of higher priorities (maintenance team inspections, reactor core inspections, reactive inspections, etc.) no f uel cycle health physics inspections have been performed in FY89 yet.
The Region staff stated that resources will be made available in FY89 to the required fuel cycle health pnysics inspections.
NMSS licensing staff members participated in several fuel cycle inspections during the past year and found the inspectors to be conscientious and thorough and well prepared for the inspections.
In addition, the inspections were complete and consistent with NRC policy and guidance.
Both the Region and NMSS consider the NMSS participation to be beneficial and worthwhile.
A review of several inspection reports determined that the reports generally communicated well the results of the inspections and were in accordance with Manual Chapter 0610.
However, the 21 day calendar day goal for issuing inspection reports after the last day of the inspection was not met on one of the inspection reports reviewed.
c.
Transportation Safety During FY88, Region I has continued to inspect transportation activities at materials licensees and fuel facilities using module 86740.
Three hundred and twenty-four inspections of 86740 were performed on materials licensees (as opposed to 322 in FY87).
All of the fuel facilities transportation activities were inspected at least once (eight total inspections) in the 2600 program, since March, 1988.
Section chiefs in all program areas were noted to have accompanied most inspectors at least one time.
Inspection reports and NOV's, RNOV's distributed from the RIDS system have been reviewed by Headquarters on an ongoing basis in all three programs and have been noted to be generally thorough in all program areas.
A number of completed materials inspection field notes were examined in the Region I files.
The formats used for inspections since late 1988 were noted to be new formats which are consistent with the Inspection Manual.
i i
6
In the reactor inspection program, transportation inspections are being perf ormed by a radiatior epecialist in the Effluents Radiation Protection Section of the Facili' a, Radiological Safety and Safeguards Branch. With the one vacancy crea c therein by the recent resignation of the one other transportation /radwa ';< inspection " specialist," current inspections in that section are being done by J. Furia, who is very highly regarded for his competence in this area.
Present planning calls for his doing the Core Inspection Program (0.8 FTE) at all f acilities on the SALP cycle basis, devoting about 16-20 on-site hours (for transportation and solid waste). Region I feels that the CIP had impacted this effort to the extent that to do a thorough job, they used to spend 30-35 hours in these areas.
In FY88, Region I was not able to complete an inspection of each site against the basic module 86721, due to lack of resources.
In FY89, however, Region I has already completed the transportation part of the CIP at 10 sites (14 units), putting them in very good shape at this point in the FY.
d.
Low Level Waste Inspections The Region I low-level waste inspection program was reviewed in the areas reactor, fuel cycle, and materials. The review consisted of examination of information contained in the 766 data system, evaluation of inspection reports, and Region file information on selected inspections and detailed discussion with Region I staff.
The inspection reports in all program areas completed for inspection conducted in FY86 are clear, well-written, technically accurate, and have been issued on a timely basis. The Regional policy and practice regarding accompaniments is sound and the number of supervisory accompaniments exceeds recommended guidance in the manual chapter.
The Region is exceeding _the schedule for implementing the New Core Inspection Program for reactors in the LLW area and has also applied the supplemental procedure, 84850, as part of most inspections. At the current rate of inspections all plants will be inspected before the end of FY89.
7
1 e.
Safeguards Inspections Region I inspection reports were clear and prepared in a technically sound manner.
A member of the Division of Safeguards and Transportation staff accompanied the Region I inspector on physical security inspections of UNC Naval Products, Montville, CT, from March 14 to March 18 and September 21 to September 25, 1988.
These inspections were conducted in a thorough and technically competent manner.
The Region I inspection reports are completed within a 20 day timeframe established by Regional policy and submitted to Headquarters in a timely manner.
Inspection reports are tracked by the Inspection Report Tracking System which keeps the inspector informed of his deadline and is also included in the weekly report to the Regional Administrator.
Region I performed three inspections of the UNC facility and completed the two semi-annual requirements of Manual Chapter 2681.
These timeframes had been coordinated with NMSS Headquarters and agreed to.
For FY89, one inspection of the UNC Montville facility has been performed and the semi-annual requirements of MC 2681 completed.
A schedule for the remainder of FY89 has been submitted to Headquarters which will have one team inspection comprised of three Regional inspectors in the third quarter of FY89 and one final inspection in the fourth quarter of FY89.
Region I should train an t
alternate inspector as a backup to the Category I facility.
It is ur,derstood that the Safeguards section leader plans to do this as soon as he has the available staff.
On February 15, 1989, the MC&A inspection function was transferred to Headquarters.
Region I staff provided valuable assistance and needed expertise during this transfer process.
A Regional MC&A inspector assisted in three team inspections with Headquarters personnel in the first quarter of FY89.
In addition, licensing assistance was provided on a team visit with Headquarters staff at Picatinny Arsenal on June 15 and 16, 1988.
8
r e
Region I performed one transportation safeguards inspection versus the two scheduled for FY88.
One inspection was cancelled because the shipment was postponed.
For FY89 two transportation inspections are projected and two have been scheduled.
There were no requests from Headquarters for route surveys in FY-88 nor in the first quarter of FY89.
4 TRAINING The Region is aggressively pursuing training of all technical staff in both licensing and inspection.
The training procedures were well organized and clearly documented.
The goal is to qualify all staff for licensing and inspection in all areas.
The IDP is being used extensively in Region I.
Region I has a good qualification journal for materials employees.
A need for transportation course training was identified for two current materials inspectors and the three vacancies which are expected to be filled in the NMS Branch this year.
Regional I sent six persons (two materials inspectors and four Effluents Rad Protection Section inspectors) to the 3 day course at TTC in October 1988).
The Region has a positive approach to training of inspectors in the area of icw-level waste and all inspectors currently doing inspections in this area have received training.
Two new people and the three hires coming on board should be provided training on low-level waste.
All the Safeguards section inspectors are attending the technology transfer courses at Sandia National Laboratories sponsored by NMSS.
NHSS should lay groundwork for educating Regional staff on new regulations; e.g., Part 35, prior to the regulation becoming effective.
Region I has had one training session conducted by the Regional enforcement specialist regarding the new enforcement policy.
Several of the materials inspectors interviewed said that they i
had not attended that session due to travel, nor had they received any information on the policy from their supervisors.
It is suggested that this enforcement policy training be repeated.
9
~
L REGION I INITIATIVES i
a.
The Region I realignment of the materials program, creating three sections responsible for licensing and inspection for specific categories of facili ties, coupled with a fourth administrative section is recognized as a very positive initiative.
It has helped toward improved accountability and timeliness of the many licensing and inspection actions in the Region.
Some continuing attention is needed in that the turnaround time of 50 days for inspection reports for first quarter of FY89 is still not up to the Region I goal of less than thirty days, but much better than the 100 days of first quarter FY88.
b.
The Region I workshops with medical and irradiator licensees have been useful and they are being continued.
c.
The Regional enhanced focus on unauthorized sale or transfer of licensees is commendable.
d.
The Regional response during incidents or large enforcement problems such as the 3M and U.S. Testing cases has been particularly noteworthy, and its continued timely actions when radioactive sources are lost or when involved in transportation incidents, is commendable.
e.
The Region I work on human factors in the medical area is noteworthy and should continue, as this may have broader rewards in reducing future problems.
f.
The region is commended for its intensive enforcement in the case of a major fuel cycle facility and for introducing a SALP to provide the documentation of the licensee's attitude problem.
The Region has also assigned a second fuel cycle facility inspector to provide the needed support and backup strength in this area.
g.
The Region I intensive inspection effort since October 1988 is commendable to complete the transportation part of the CIP at 10 sites (14 units) by this time.
10
s e
h.
The Region is commended for its intensive inspection effort to implement the tiew Core Inspection Program for reactors in the LLW area ahead of schedule and in also applying the Supplemental Module 84850 as a'part of those inspections.
n P
11
6.
NMSS/ REGION I INTERACTION Interaction between Headquarters and the Region has been very good.
The counterpart meetings and workshops and inspection accompaniments scheduled during FY89 should foster this interaction.
Region I has made many excellent generic contributions to the national program in the materials safety area.
Even greater use should be made of Region I expertise in developing such contributions.
However, this process could be more effective through more complete understanding of NMSS and Region I views and approaches on some key matters, particularly in the medical area.
It was suggested that a meeting of staffs to review issues could help to improve this mutual understanding and thereby contribute more to the strength of the national program.
In general, communications have been good between Headquarters and the Region in the fuel cycle area; however, an opinion was expressed that on a least one occasion Headquarters project management action had been taken without consultation with the Region.
More communication between the Region I and the Headquarters Safeguards staff is needed on problems, issues, guidance to the licensee and licensing case reviews.
Region I recommends that:
they have more verbal communication with the NMSS Safeguards reviewer on a consistent basis.
they be placed on all distribution on memos, letters and guidance sent to the licensee.
more lead-time for notifications of meetings be provided.
If possible,
)
the Region would like to have at least three weeks notice so their inspection schedules could be adjusted.
12
s 4
the Section Chief of the Safeguards Section be added to the distribution list of all transportation Safeguards material sent to Region I.
written guidance be provided to UNC Montville regarding the use of the Safeguards classification on documents.
consideration should be given to establishing a monthly conference call in order to discuss generic issues for Category I facilities.
t 1
l l
13
7.
RESOURCE UTILIZATION Tne attached table shows FTE allocations and expenditures for the review period.
Region I has no program support funds in the NMS! mission areas.
The Regional fuel facility safety and safeguards staffing aligns with the budget considering the 2 FTE of support received from the Facilities Radiation Protection Section (FRPS) and the Safeguards Section (SS); specific personnel are not assigned to fuel facility inspections, but are assigned on an availability basis.
Materials licensing and inspection staffing aligns with the budget with one exception.
The Region I staffing plan contains an NMSS funded Licensing Assistant position (1 FTE) which is vacant.
This position has been vacant for about a year and the Region is not actively pursuing filling the vacancy.
The decision not to fill the position is a Regional decision and not one made by the Office of Personnel.
Overoll resource expenditures for FY88 were below projections.
FY88 materials licensing expenditures equaled the budget.
Materials inspection expenditures for FY88 were below budget due to utilization of resources for event evaluation which was unbudgeted and due to diversion of resources to retraining, injury and maternity leave and the move of the Regional office.
For the first quarter of FY89, materials licensing expenditures exceeded projections and materials inspection expenditures were less than projected.
This diversion is continuing in FY89; technical staff members are performing tasks such as preparing inspection documents for mailing which are normally done by the Licensing Assistance Section.
Event evaluation expenditures were below budget.
Materials licensing expenditures exceed the budget due to the Region's initiative to retrain employees.
As part of this effort, reviewers and inspectors are required to complete a number of materials licensing renewals.
For FY88, fuel facility safety inspection expenditures were below budget; however, all inspection activities specified in MC 2600 and appropriate West Valley activities were completed.
For the first quarter of FY89, expenditures were under budget.
While the Region has a plan to fully utilize skills from the other sections in the branch (FRPS and SS), we are concerned about the short staffing in these sections and the potential diversion of FTE from fuel facility inspections to reactor inspections.
14
For FY88, safeguards fuel facility licensing and inspection resources were below budget due to staffing vacancies and unqualified inspectors.
For FY89, the safeguards expenditures are in line with budgeted projections.
Limited decommissioning resources are being expended for training on the new rule; however, no cases have been received for processing to date.
Region I completed 1162 materials inspections in FY88 versus a goal of 1193 (97 percent) with less than budgeted resources.
During the first five months of FY89, Region I completed 431 inspections versus a goal of 447 (96 percent).
The Region completed 1596 materials licensing cases in FY88 versus a goal of 1700 (94 percent).
The shortfall in completions resulted principally from the fact that reviewers-in-training were assigned to work on renewals and their effort exceeded the budgeted labor rate.
During the first five months of FY89, Region I completed 715 materials licensing cases versus a goal of 601 (119 percent).
As mentioned above, this is due to the fact that there are currently a lot of reviewers / inspectors being retrained and the training program includes a requirement to complete a specified number of cases.
The materials staff thought they may benefit from having access to additional personal computers.
The Division of Resource Management and Administration (DRMA) is currently in the process of providing two PC's.
The Division of Radiation Safety and Safeguards should discuss additional needs with DRMA so they can be considered during the Agency's upcoming mid year financial review.
We recommend that Region I consider the staffing plan vacancy for a licensing assistant and their continued diversion of technical staff to perform nontechnical duties.
i
)
i 15
8.
RECOMMENDATIONS NMSS recommended that the Region place greater emphasis on the implementation of Performance Evaluation Factors by all Region I materials inspectors.
Region I recommended that agreed upon assignments made during weekly materials conference calls should be documented by NMSS.
Region I recommended that Navy and Air Force participation in materials workshops be restricted to a time when internal NRC matters would not be discussed.
Region I recommended establishing a manual of licensing guidance based on an integration of existing fuel cycle directives, and have this prepared as a computer accessible database.
Region I recommended establishing a master list of field offices of multisite broad licenses such as radiography and other companies, and that a system of assist inspections be arranged, similar to the military broad licensees.
NMSS recommended that Region I review the FY-89 planned HP support in the fuel facility area to ensure its adequacy.
NMSS recommended that Region I consider obtaining a few more personal computers during the upcoming mid year review.
NMSS recommended that Region I should decide how the resource associated with the vacant materials licensing asristant position will be utilized.
Region I recommended improvements by NMSS in communications regarding safeguards.
NMSS additional Region I staff training on the enforcement policy in i
the transportation area and the effect the enforcement policy changes have on the inspections.
16
\\
NMSS recommended that an additional inspector should be trained as a backup in the safeguards area for Category I facilities.
9 1
l 1
l 17
\\
I 1989 Region I Program Review - Team Members King of Prussia, March 9-10, 1989 Glen Sjoblom, Division of Industrial and Medical Nuclear Safety, Team Leader John Hickey, Division of Industrial and Medical Nuclear Safety Jerry Swif t, Division of Industrial and Medical Nuclear Safety Mike Lamastra, Division of Industrial and Medical Nuclear Safety Ed Flack, Division of Industrial and Medical Nuclear Safety Dale Powers, NRC Region IV Claucia Seelig, Program Management, Policy Development and Analysis Staff Al Grella, Division of Safeguards and Transportation William Floyd, Division of Safeguards and Transportation Leroy Person, Division of Low-Level Waste Manangement and Decommissioning l
18
[iindt Wtd 2 nW:II 1989
~
DIVISION OF RADI Al lOf{_ SAFE TY AND SAF EGUARDS Malcolm 14 knapp - Di rec tor - 5783 WiiIiam V.
Jnhnston - Deputy Di rec tor
- > 310 Constance M.
Yusko - Secretary
- 22/ts fACIL1IIES RADIOLOGICAL SAfLiY AND SAFlGUANDS BRANCH Ronald it. Heitamy - Ch s e r - 5700 Robe r t J. flo re s - S r. Technical Rev i ewe r - 5/13 Sha ron t aw Johnsnn - Secretary
- 2395 Micheio Kirkner - Off' ice Ass *stant 50/2 EMERGENCY PREPAREONESS
[FFtUtNTS_ RAD 1ATION F AQ t (l T II S_ R ADMT ION T2[E.lj 0N EROJECIION_SLQ1 ION PHOff.QIION.StGIION SA F(, GUAR DS St I:140%
W. Laza rus. Chie r - 5208 W.
Pasciak, Chier - 5281 H.
Shanhaky, Chier - $258 R.
keimig. Chier - $255 C. Amato - 53914 M.
Austin - 5390 f.
Dragoun - 5313 D.
Cameron, 51/8 C. Conklin - 5342 J.
Furia - 5041 A.
Geyer - 5323 A.
Della Ratta - $213 E.
Fox - 504ts J. Jang - $220 R.
toesch - 5082 W. L anca ste r - 5014 C. Cordon - 5372 J.
Kottan - $214 R.
Nimit/ - 5267 W.
Olsen - 5118 T.
Lopresti - 5391 N. McNamara - 533T P. O'Connell - 5056 C.
Smith - 5/63 R.
Summers - 5083 J.
Roth - 5205 S.
She-bini - 5259 E.
Sylvester - 5308 R.
Struckmeyer - 5380 W.
Thomas - 508:3 htLC1 EAR mal t R I ALS SAF E TY BH AN.Qlt James H.
Joyner - Chier - $251 Ca rro l l Armstrong - Secretary - 5248 NMSS A NHSS U NMSS C LICENSING ASSISIANCE SECT.
J. Clenn. Chier - 5209 J.
kinneman, Chier - 5252 J.
White, Chier - $102 0.
Foster, Chier - 5239 S.
Courtemanche - 5075 F.
Costello - 52/5 J.
Davis - 5250 R.
Brown - $?64 1 Da rden - 5245
- t.. Friedman - $216 D.
ColIins - 50914 R.
Co s sa boor * - S i l '/
J. cresick - 5382 J. Jensen - $149 A.
Kirkwood - 50$O E. Watts
$3398 J. Joustra - 525T T.
Obe rg - 5202 R Ladun - $375 M.
We i senbe rge r - 5313 J.
PeIchat 50t 8 R.
Provencher - 536t4 J. Mii ser - 530:4 J.
Piccone - $169 S.
Rajendran - 5309 H.
laylor - 5311 C.
Schulinghamp - 5078 F. Ullrich - 50t0 f.
Ihompson - $303 4
J. Stambaugh - 6904 W.
Wallace - 5272 H. Va rela - 5268 L.
Tripp - 5071
d s
j Atto.chext 3 4
NUCLEAR MATERIALS SAFETY BRANCH RESPONSE TO NMSS-1989 REGIONAL QUESTIONNAIRE MARCH 9-10, 1989 w
i i
i l
i
\\
ENCLOSURE 3 NHS5-1989 REGIONAL QUESTIONNAIRE This cuestionnaire is for the purpose of obtaining information about regional WMS$ licensing and inspection activities.
The space provided is not adequate for responding to the questions, so we ask that you provide separate sheets for each question an::
Include as part of the response a copy of any response.
pertinent written internal procedure which you have developed and have in place.
It is not necessary for the responses to be sent to NMSS Neadquarters.
Rather, eight copies of the responses should be given to the National Program Review Team when it conducts its review at your of fice.
1.
Using the current version of your regional staffing plan related to the WSS program, specify the approximate percentage of time that each individual spends on the following activities: fuel cycle licensing, fuel cycle inspecuen, materials licensing, materials inspection, safeguards activities, and inspections of decommissioned facilities and reactors.
2.
provide a sumary of actual expenditures and accomplishments as compared to operating plan / budgeted expenditures and accomplishments, for FY88 and FY29 to date.
3.
Are there any changes needed in the estimate of workload projection (licensing actions and inspections conducted) for the current fiscal year?
If so, please provide your suggested changes with justification.
Are there any foreseeable barriers to completing inspection modules in accordance with Manual Chapters 2600 and 2800?
4.
Are regional administrative support functions performed in a timely manner? Are changes needed in the manner in which these support functions are performed? If so, please be prepared to discuss the changes needed which would result in optimal administrative support for the programs.
5.
Please provide your coc:ments on the programs for interaction of Heacquarters with your Region.
Please include your comments on the usef ulness of the conference calls, licensing workshops, executive management semir.ars, inspection accompaniments, telephone calls on case reviews, technical assistance provided on a day-to-day basis, standard review plans, guides, etc.
Include in your comments your suggestions and recomendations for modifications, changes, improvements, etc., in the interaction programs.
6.
Sumarize regior.al initiatives to improve the quality of inspections and license reviews, particularly those aimed toward preventing licensee saf ety problems, or those aimed at licensee's performing their transportation activities in a safe sanner.
7.
Summarize the total nuntber c,f inspections of Transportation activities at K 2800 licensed program facilities (Procedure 86740) including average staf f-hours per inspection and a brief summary of the most typically observed violations.
Summarize (Regions II and V) referrals to other regions of state identified violations on shipments by NRC licensees to commercial burial sites.
Summarize the completion status of inspections of transportation activities at 2600 (#86740) and 2500 (#86740) and
- 86721) program facilities.
Please provide early observations on the impact of the Core Inspection Procedure #82750 on the inspection of transportation activities at 2500 program facMities.
s Tne attached material is in response to Question No. 1 STAFFING AND DIVISION OF WORK A copy of the current NMSB staffing plan is attached.
As in the past, the Region I materials technical staff member typically performs both inspections and license reviews.
The only exceptions involve those staf f members who, because of pregnancy or disability, were only available for limited travel.
Two staff members (Taylor and Schulingkamp) were pregnant or on maternity leave during FY88-89. One staff member (Darden) was injured in a fall at the office in June 1988 and has not yet been released to resume travel astignments. Thus, each of them has concentrated on itcensing work for the past several months, including half time work by Taylor anc Schulingkamp while on maternity leave.
Ms. Taylor has now resumed performing inspections. Ms. Schulingkamp returned to full time duty on March 6, 1989.
Tne actual percentage of time spent by individuals on licensing versus inspection varies depending on a number of factors, including workload, incidents, etc.
As shown in the attachment, for the NMSB in FY89 through February 15, 1989, the ratio is about 2 FTE for inspection to 1 FTE for licensing, Statistics for individuals in the Branch are also shown in the attachment.
Relative to the question on inspections of decommissioned facilities, we have only recently begun charging time to that RITS code and no mea,ingf ul data are available at this time.
5 T
F
'erem-mm--+-++e-r
-e--
- '-~-
2%
4
}
Ost *. COMr04ttMi/ PUS. YlILL FY f59
( 78 8 I frsarma_QLf_lce a A sot-Grade 3erlas mutit __
tim ttMdB f18 Dru ttived muc tee r Me te rf e i s se_{mtv Branch i.-
Chaer CC-t>
osot/130s t
Joyne r, J ame s 18 CC-15 000t t_u seere ta ry ( Typ s ne l Cc-6 05t8 t
Armstrong, cerroti A.
CC-6 0318 1.0 i
}
t t
Office of the chler Subto'tel:
2 0
0 o
T u-ihsoI*e r Me te ri e i s sa fetdtgt iert A Chier CC-15 1306 I
a.o Clenn, John E.
GC-t>
1306 Senior fleelth Pteysicist CC-th 13n6
?
2.u Piecesse, Josephine M.
CC-18e 13u6 Cresick, nery Jean Aleul CC-t as 13t:6 s
MesIth Physiciat CC-t1 1lu6 6.9 p.t Osrden. Torese II.
CG-t3 4306 Courtemenche, Steven R.
CC-t2 1306 Jountro, JtHil th A.
CC-13 1306-Tripp, Lester M.
CC-t3 4306 PeIchet, John M.
CC-12 4306 schut Ingheep,' Clari st ine M.
CC-9 4306 (J. Stemeaugh, E00 1/29/89)
Vecent vesent
=
Section Subtotal:
T~
o
~ 79-0.1 0
9 1
- Wit Hire l
l
L
- - - - - - - - - " - " - - - - - - - - ' " - - - - - - - - - - - - - - - ~ ~ - - - - ^ - -
- ~ ~ ~ ~ ~ ~ ~ ~ ~
M w
gur. CortP0feEftf/P05. IIILE t v 89 tPtiI EC91f31L9f.11Ce a asent-QfAft Stflat Ftrlt _.-
- 8fl affl0 fIA tytthead m-s ee r Ma te rie n s se re t v sec t ion a Cheer CC-15 1106 5
1.0 minnemen. Jolen D.
CC-l>
1306 Sen i o r Hes i t ta Phyt 8cist CG-Ils 1306 2
2.0 Costelse, Francia M.
CC-Ik 1306 Friedmen. Laurence F.
CG-lh 5306 Meelth Physicist CC-13
% )il6 6
Otzerv. Ce a i T..
CC-I) 1106 5.6 0.2 Jensen, Johse I.
CC-33 5306 Ullrich. [liteheth GC-l2
%)n6 ReJendren. Selven CG-Il 1306 W38 face. Weymon L.
CC-9 1346
' Provenche r. Richard S.
CC-12 3306 V8 cent Section Subtotes:
i' o
8.8 0.2 o
Muc t ee r Ma te rie i a Se rs ty Section C Chler CC-l$
13n6 I
White, John M.
I,o CC-IS 8306 i
Senior Mee t th Physicist CC-14 1306 2
2.0 a
Miller John J.
CC-14 1306 Devis Jorden S.
CC-14 1306 -
8eealth Physicist CC-13
%)O6 6
S.9 o.1 Ladun. Rachard H.
CG-13 5306 Thoepson. Thomas M.
CC-83 1306 CoIesne, Devie J.
CC-43 4306 Va re i e, Mich6eI A.
CC-Ii 1306 Taylor, Marlene J.
CC-13 13u6 Kirkwood. Anthony S.
CC-13 1306 V: cent
.i Section subtotes:
9 o
~-
- V~
o.8 o
e e
- FTE Mlre 4
8 1
a
+
1
26
- t QMd C0f1P0ft[NUPUS. IllLE
~
8 Y 89 (P8II filiti! UM_Qf.flC9 9 A l les t -
Grade 5erlma -
m+rr# L MMit fmil PIB Uvisiteved Liggggine Assistg#Me Doction Chier CC-10 03o3 4
Foster, Doris J.
CC-10 0393 1.9 Licens8ag Assistent Vecent CC-9 0303 1
1.0 Processing Assistent CG-S-0 3te) 2 Srown, Aebecca J.
W6tts, Ervin M.
CC-5 03o3 2.0 CC-5 0303 Aeference Assisteset - Fi t esig CC-S 03es3 I
tee l senbe rge r, Margaret M.
CC-6 }/
0303 t.U Cs* rice As s i staret, typing Cossaboon. - flebecca L.
CC-S 03u) t CC-5 0303 3,n Sectton Stabtotal:
'T' O
~ '.V 2
u iT6" a
Brancti Seebtotal:
36 0
79.6
- 11. 8s 6.0 DIVISION 10fAL:
76 26.9 3 's. 7 1,6 17.6 1
1 i
- FTE Hi re Pos i t ions = 6 1/ Pr.
nt.eneumament on y e-t mm.
...m
.m a
mmc i
w
PA6E i
SLMARY OF COMPLETED NORX FOR SECT!0N A FOR PERIOD STARTINS 681001 AND ENDIN6 890215 FTE FTE T0iAL TOTAL Nib AMEND RENEN INSPECT ASSIST FTE FTE FTE LESS WITH MAME LICENSE LICEhSE LICEhSE LICENSE INSPECT LICENSE INSPECT AS$1ST ASSIST ASSIST CRISf!NA SO OL!hSKAMP 7
.04
.00
.00
.04
.04 JEAh SRES!CI 7
23 16 7
.16
.24
.10
.40
.50 JDANN Y. SIMBAUGH 1
.00
.00
.01
.00
.01 JOHN SLENA 21 4
.08
.00
.00
.08
.08 JOHN FELCHAT 3
5 3
7 2
.04
.10
.03
.15
.18 JOSEPHINE PICCONE 3
6 5
12 4
.06
.16
.06
.24
.30 JUDITH JOUSTRA 4
27 3
15
.10
.22
.00
.33
.33 LESTER TRIPP 46 15 10 2
.26
.15
.03
.41
.44 STEVEk COURTEMANCHE 7
0 4
41
.08
.61
.00
.69
.69 TERESA DARDEh 5
60 12
.24
.00
.00
.24
.24 eiOTAL A 33 ISO 76 101 16 1.06 1,51
.24 2.56 2.82 i
1
PAEE
SUMMARY
OF COMPLETED WORK FOR SECTION B FOR PERIOD STARTINS 881001 AMD ENDINS 890215 FTE FIE TOTAL TOTAL NEW AMEND RENEh INSPECT ASSIST FIE FTE TE LESS WITH NAME LICENSE LICENSE LICENSE LICEkSE INSPECT LICENSE INSPECT iS$1ST ASSIST ASSIST BETSY ULLRIO 8
12 19 1
.09
.28
.01
.38
.39 FRAB COSTELLC 10 51 2
4 4
.18
.06
.06
.24
.30 JOHN JEhSEn-4 13 3
5 1
.07
.07
.01
.14
.16 J0kN KINNEU.a 1
.00
.00
.00
.00
.00 LouRENCE FRIEDMAh 2
3 1
.02
.16
.00
.19
.19 RICK PROVENCHEF 15 25
.00
.22
.37
.22
.60 SELVAh RA;Ek* rah 5
16 7
24 2
.11
. 36
.03
.47
.50 THOR OBER6 2
20
.01
.30
.00
.31
.31 WAYMCh bALLACE I
10 7
31 8
.07
.46
.12
.54
.66 tiOTAL 5 22 102 34 129 41
.56 1.93
.61 2.50 3.11 1
1 1
o PAGE
SUMMARY
OF COMPLETED NOAK FOR SECT 10N C FDA PERICD STAAilh6 881001 AND ENDING 890215 FIE FTE TOTAL TOTAL hEt AMEND RENEN INSPECT ASSIST FIE FTE FTE LESS WITH AAMI LICENSE LICENSE LICENSE LICENSE INSPECT LICENSE INSPECT ASSIST ASSIST ASSIST ANTHONr KIRn0C 16 2
4 11
.05
.06
.16
.11
.28 EAVID COLL!ks 30
.00
.45
.00
.45
.45 JACK DAv!!
24 49 9
.29
.00
.00
.29
.29 JCHk MILLES 2
12
.00
.18
.00
.16
.18 MARLEh! TA h0F 1
13 17 8
.14
.12
.00
.26
.26 WIKE VAREJ 3
11 17 9
.l5
.13
.00
.28
.28 RICHAPL LACO 33 1
.00
.49
.01
.49
.51 TOM THOM? Son 2
15 14 12 1
.13
.16
.01
.31
.33
- TOTAL C 30 los 59 108 13
.76 1.62
.19 2.38 2.58 i
i
PASE 4
SUMMARY
DF COMPLETED WDRK FOR SECTION D FDR PERIOD STARilk6 681001 AND ENDINS 890215 FTE FTE TOTAL TOTAL neb AMENO RENEW INSPECT ASSIST FTE Fii Fii LESS WITH MARE LICENSE LitENSE LICENSE LICENSE INSPECT LICEhSE INSPECT ASSIST ASS DORISF0$iEE 2
2
.01
.00
.00
.01
.01 RE610h 1 1
6
.02
.00
. 00.,
.02
.02
- TOTAL D 3
6
.03
.00
.00
.03
.03 TOTAL Bi 396 169 336 70 2.42 5.07 1.05 7.49 8.54 l
1 l
l
4 Tne attached materials are in response to Question No. 2 EXPENDITURES / ACCOMPLISHMENTS VERSUS THE BUDGET Included in the attachments are the following:
A printout from RITS for FY88 showing the expenditure of FTE by the NMSB A month-by-month chart showing the number of inspections completed (i.e., by issuance of 591 or inspection documentation) in FY88 and the average time required for issuance.
A month-by-month chart showing the number of licensing actions completed (i.e., by issuance of the license document) in FY88 and both the total backlog of actions and the backlog of news / amends.
Tne same documents as above for FY89 through February 15, 1989.
Productivity in FY 1988 for licensing and inspection was as follows:
Licensing Completions
% vs. Budoet New 221 100%
Amendments 1070 105%
Renewals 305 66%
1596 94%
i The region used 8.24 FTE to accomplish materials licensing versus the budgeted 8.18 FTE.
The shortfall in completion of renewals resulted principally from the fact that reviewers-in-training were assigned to work on renewals and their effort exceeded the budgeted labor rate.
Further, a large number of renewals started in FY88 were not issued until FY89.
Inspections Completions
% vs. Budget 1136 95%
. ~
_, ~
\\,
1 l
Ouestion Nc. 2 2
l During FY88 the region expended 12.78 FTE on the materials ' inspection program, a snortfall of 3.5 FTE.
However, about 1.7 FTE of technical resources had to ce diverted to performing clerical duties during the year due to inability to fill two clerical vacancies. Other significant resource expenditures that prevented realization of the inspection goal included:
Relocation of the Region I office 0.3 FTE
+
Radiation Technology trial 0.2 FTE Injury and maternity leave 0 4 FTE
+
Reorganization and retraining 1.0 FTE
+
These diversions of resources total 3.6 FTE.
Co sidering the above, the NMSS believes the accomplishing of 95*4 of the bu geted inspections represents a significant achievement.
I o e f
b t
,y.-
, ~., _,,
e s
=
i t-_-
A==
==
=
t.
==
==
<=
=
e i
1 4
9 4
4 4
0 f
4 1
a em -
6 5
I I
u t
1 J
e e
e 9
0 4
0 0
l t
e f
f I
I I
e i
t 6
4 1
4 4
i i
e ho e 'r i,**
8'*
O c arS C*
OP ** O N
- e 89 f
i e=
w e= c 3 N
- A O **
"4F16 8 Pe se enn om 49 Pi C arg i
i e=
N to N.s 3JO.* T P. @ m wm
>= k. N e=
4 *= in 6
w* e= N N eb
& N tr* r* N 4"OO OOO a O o* tr's i
1 em 4 P. O *.
- '6 +9 e @ O
- )** *J N e= om e*
fi % O 4 4
C l e e e o e e e o e e e e e e e e e e e e e e to h l
Pg F
N em 4N i e 3 0 e= e= et 9 = " 4 9 em w9 9 i E 2 9 e.
O 4 0
V $
0 t
i 9
4 0
t I
t 6
9 I
l i
='9 N en N *s e ca ON>
- =*N**
'3 O O e o o s*s I
i
- , f4 ** ** tr ON@ CD =#
- '*8* *** (O ar' e e*
F e *= OA N 3
9 e #
===.e, e4 1m W %)
h* 0 *^ to N PJ *d 1 45 em c
.,1 g
am 4 O "" s'* ar% N
- em Q@J s'b e e T qin g e em g
ee #
e= N P 4 ("i O 4 4== N **
O N N
- =e=*=
O to S 4 s
ei s.s e em N t 4 e e e a ee e e e e e e e e a e e o e e e 7
4 y *= g en
- =
u" MNNP=
se 1
in, w 6 ens 8aNq m
8 eh I
'l 9
t 6 Oe a
sA E
w t a
ein 9 s
e em t 3
i 9
G 4
4 IJ 8
0
% o I
e
- w>
f f
N4O O e l
amme o f fs t
6 i O 4
>04 I O 4
4 2w t t t
u's 4 & r; =*
> to 4 >= eo
"") O C '"*
) C 3 y e ~d to et t
i e e e e e e e g e e e e e o e e e e e e e A
er 0
J B
4 O vs rm *e pas e ya em e m'* e e e w.e.a N.= e s e
& se 4 4 4
to P O se o=
4 Ch @ C em 4ePd N d =a ad N 19 O ne E be el I ea
(
aC L T C
N 4 ** @ so
- N J W NNN e F' N@
8 O 1
h 4 4
4 4 6 4 4 4== o4 9 s na, 9
n=
6 4 4 4 4 A
Pe e w% O C ad W D w= ort 4p emo=
cec i
i
- u 6
I a 64 6 0 0 9
J,J Q S M e t
== 4 ;
6 e 2 e e'
- d C e=
)
- P-va <'
O w e 46 O O #3 sri m c, o
e== c 4 s D I e e e e e o e e e o e e a e e o e e e o e I ts 3 2ea r, e-C M J
- = es N *= 7 P'9 N to er5 o= e= *=
E 't) & C 6 0 Z 0
== Q s's ss
=9 N =P e O NNes 4 om 83 e.
==
0 7 g
P. N **
e==
em e* k P s es 4
t s
t 4 a= N >=
T I
==*n e
t
- 4 4
4 4
4 0
8 t
J
- 2 g
- = 6m e O N t'*>N*
C e u% ne O O C.
N e sa e u
4 4 e
o e e e e e e e e e o e a e a e e e e e e
")
5 J s.4 l Pm M If, Pa= %
N PS e
- s O O M *i *%
eem M N ** O 2
0 0 t="
t e e o's ist in d >= o= to o=
- % *' N
- d asN N e em D.
9. O 9 4 Ce
'3 ** 4 0 en e= F4 st =J N c4 N e* p.
p rd 4 w (*)
l 4
4 4
4 4 4 4 4 t
(,' 2 8 4
em 4*
- Jen N O 4%
4 % t t 4
0
- = =% en ts 9
E e
0 5
0 e
f I
I Ils 9
0 O
f f
B e
6 9
ana 2
9 e
o=
"3
==
4 0
es C
e e
3 2
v
>=
2 0
1 m
o"*==
O
- .s
- E O
O
=^
l e
e
.is n.
=r u
v l
e e
- * = ;:
2 w
e e
t
>= u w
Q w
6=
w 2
1 I
e 2
owwT T
wee er s
n av s a s z
Za n,
>= 2 o
.n 3
u sa w j
t es 8
==
4 to D >s a
O av 3
tr u
==
e4 2
- e* e4 t *=
9
>= en e 2.J %
2 me >
2 OO eE ao 2 2 am 0 *=
6
'r 4 >
2 *e== 6-hm C>e C
wC e= 64 ww I
l O *w
=*
4 u
== es #4
.A E
63
.A er F 3uu 3
f k a wwC
- > = = = =
.J wO
==
at O *aJ u
e*==
3 e
u **
> D
.J 42 Q
2 a.*
u ww 2.J s 0
4 w&
2 ** Q Q io e ins >
w k 4 e
4L **
3 0
6'd > e=
T 2
4 Yu u
alf F
w so w (1 3 e
e 2
- = u e. e=
==
& D its 2
eu dL I
32w 4
e a pi.
34 9 a 44 u cr o
su tiJ
.J u
O e.
=A w a
== u O w O ur 4
sls o sw
- W as w
2u no E w I
l
[
== inJ av er & c u
sk '3 c
==
8" &
v
>=
ne ens as es er a
a v
va 2
as
==
e t
I w==
n=
t.S 2
2 *e ea 9
8 ab O O
w I
te O N
4 9
na
.J u
u O
4 4
2
.J sed 9
9
==
4 t=
9 0
1
.J f"i e
i
a,
==
s 0
4 t
t t
0 e
i e
t i
i N
D l
0 f
w f
9 I
0 0
4 1
e f
I 4
t 6
I e
4 0
0 0
l I
f 8
4 1
4 4
0 t
I g
ei c e a em OeN N eA e A S.
NNP
- ** N m) @ o= N 4 sa'n te te t
0 o O *w P9 4*J in O - e to O O DOO N @ O C aA e & M O eA em e
g c sa pa a w #m re d N e 7 ew N N N to P' C O en O O en e em q% N 4
e
% m 4 es 4 w" D Nte 4 J J d4d N J d om ** O O *= om en e t
0 em W DOOrw t C
N N >=
8 F eJ
- C o* O N O C O O em art e "e t
ce e o e e e e e e o e o e e e e e e e e o e e e e g se w 4 en w*
- e=**
P'" Pd Pd 1J ep I
- E t I. OI 4 > *#9 I
I h F 4 I
O 6 9
U 0 e
s i
9 9
6 6
I e
i 4
4 5
A >= C 4 A ** **
rOCQO OOO O O O O C't O O O O O O s
e
- v. 4 "3 Q *. C eo a
)O c O O *: O C "J G O C r* O O O C ej e
e ooO4 N+
c J J 't a f
O #7 '"1 CI G G O O O O O O O c's s
em 5
.e e' cre c N **
m CCOC r't OO O "4C O O C O O O O O T
e
- - e e o O e= 0NN
- 1OOOO OOO O #"Io r1 O O O O O O O w
t mree e e e e e e e e e e e e e e e e e e e e e e e e e e 7
0 4PN i
- = \\
=
- en w a la ea e
v 9 en tA t t De a b*
I w3 3
8
== 0 e
8 m 8 O
l 0
e t
9 J
0 I
Ju<
I a
m4 *=
&4 N l M t
- e. WO 9 er 6
u.
8 O s
se.3 4 8 O 1
J 2 u 8 I N rw C. M ae ** *=
9 to N *= **
N P=P.
e o D N N O O te O N P.
=
e e e a e e o e e e e e e e e ee e e a e e e e e s
=a en I
=#
t ec w= O c ** e? to a'T e- **.a d NNN o o O 4 #6 e's 4 o a c N
& ba 5 e e
C ** 3 CDCN e* aod4 PJ *J N
- eo N P= e", ev emNNN I a=
et 4==
s NO w
ee
- en en < 4 OOO as M W e
NN 4 0 1
- 4 4 4 4 6
% t t a h t
a 4 ew w 6
a=
l e= w=
NN
= e
www N4 tr*
r, a:,
ei e O 8
4
= *
- C 4
8
- * * =
e=
v 8
4 e 9 0
$ 0 t
me *.J d3 0
.u H l
> es D 4 as as 8 N P. O O O O wt C* e N e 4 wWd c e== O e O O O O w* e c ae e 3 # 3g e e e e e e o e e e e e e e o e e e e e e e e e e e ta e JO g et M
- N O pa ** *= en so NNN e e 4 ers ee a
e OZ$
4N O C J *"a N O O 13 40 20 9N N
em te to e 2 8
'4
- =e=
e=
N ww e
I e
0 t
e er 8
9 e
i I
a.
g 3
.J 6 er 6
Je O O em C 4 0 O w* am 46
- s"
- 9 *'t am a ta rdM O Q m O Ne.
V g ee 4
e e e e e e e e e e e o e e e e e e e e e e e e e e l
3 g
.J 49 l O Pe O C N '@ th trl M) N eA to w't to w%
9 M== 0 M O ar =a D e e
?
9 D fr 4 O O CD 9" S A e6
% N ed W 4 M "" #9
- 1 e p N @ N M *J a= es e J39
- %f G e*
46 W9 4 M to to to 1r *4 si d *k N s' e3 3
44 f") 4 4 4
% t e & Z $
es *=
N ve
. t,t t t t t t t
g 4
' ye a
em P4 sat fem J em N h.
l l'
4 0
- = va 0
0 0
9 3
0 he >
g g
em 2 4
4 n=8 e
e u
We I
g 9
4 J bt 8
4 M
bl=
i N
e f
w 6
3&
a 4
==
Q
'u os i
e g
3d i.s me u g
g J
en s.
w a.
a Jo g
3 M
2 e4
== tA g m. su e.
wg i
g e
no er u 4: 2T 2
er g
3 a
n= D 69 w 6.
u w e-a na 3
-g M O hm & 7 dg I O g9
{
,J lu W tu g
g w
ee os se w
O ned u
u w
2 to ** E l
g r a
y es u im F F wuO e.e O
D e o es >===
l 1
g au 4
ew M
be 4 w er >=
6 4
et > ** > em 6-g e=
0
.J e2>Ww WO em 2
SK M >= 69 D 1
q
,0
...O. 3 o.v, v,
g =
u uw e
pu 3 3
.m g W
et O2u s
r 1
g 6
y O > 2 tr 4
==
.J a 2
>=
a n,* > 1 *= R U es i
3 9
ee t me et ag &
p.
(
u T
e F W tu to e.J43 3 j
g 4
46 eA E e4 me 4.J e=
es as g
am w gg me 3 g
0
- e 2 er Z.J ed to
.J es 69 N
us 2 tr 2 Es 2 2 e
e O
tu C au o **
de T *4 L9 au
> ad== ar em tu a o u
]
g 9
u w u.e >en
- e e.
u en t9 2
O ar as O ma E er ** =e we t
i EJ
- = 2 s u
v D en nu er a=
neo et 2 O O Q K 2 **
6 j
nu
.J **.J 2 =E g
uJd E
V
.J*=meik at et 3 p E et e
e I
ens u
- e 1
4 ha at
'A er 4
0 0
48 ef N
t 4
E 2
O O
t 4
>=
4 2
4 I
O 2
se e
i O
9 0
m R-4
=
3 6
4 i
1 e
t i
e i
e 3
t 1
3 8
w e
4 6
0 m
5 8
k 9
i 6
I t
t 4
e e
t 6
8 3
e i
1 1
6 I
A ** N A A 6
8 e Li O se em 0
0
+ C %
- se a
e
- = N C 4 0 e
i OOC 00 t
G 4 e e e e e 4
w* u. t 0
- I f 6 een ; I 6
e= w9 I e
'L T t e
O 4 I
tJ e t
6 8
I I
I e
I 6
8 8
0 8
8 JOOOO t
e c n F. C
- i 0
V C O O
'")
I am 9 OF COM e
d 9 OOOOO v
e > a-e e e o e a 2
I wA 6 4
0 4e W t or ea i
r 8 ed v 8 6
3*
s t
w t C
6
- I 8
6 w i 3
8 6
4 4
J t
t c'.
e e
fw>
t i
O4 J G M i
- = e O I et 1
4 0 O I
>Cw e O O
4 2 4 0
e O==#CO e
t i
e e e o e e e t
.J t
N e 4944 s m.
I w t
ewe &e E>
a 3 w g
0 C e
v4 4 has 8 >
l
.34 O t
i "A G l
4
= v I
e er 69 8 8 O I
wJO
$ se4
- *
- 3 8 3 2 i O O O C9 O 1m e 6 9 3 g
- e e e a L at t ZO l N
NN w
e CI e 0 2 9
I I
E e
a t
t
's e
3 8
0 0
8 6
6 J
e 3 4
OeeOC ws e4 1
e e e e e 3
i sA 0 r m C N e4 7
g D5 8
- me e O O 4 43 0 3
an, O 4 0 CE 3' 8 I
I 4
8 1
4 6
8 6
8 w
i e
t i
6e 0
0 2e 4
8 O f I
e
- 6 2 0
0
>tO E
e 4 O =*
5 I
ha %>
0 0
2wd 6
l taJ > $
3 e
Tw4 8
8 v4 Je&
8 8
at w6 w t
6 O
P Z cr 4 T e
e OO&
G==
0
.a, e==
3 t **
8 YF2 e
e a w w is, O
l 2
QOO I
se Z22 e
c w en. w 9
i O
&4&
4 4
Q w.4J e.s e
4 OOO 4
6 w
.! 2 2 9
l J
- me an A
0 y
c P
e e
be 1
I M
N -
e e
e Ow&
g 4
g Q
me us w a
4 4
44 e 4
0 O
I I
-W,.
01/07/53 M O I r R I A L 's NP5 FT 19t3 PAGE 4 ad bC L( A R M4TtCIAL5 5AJ tTV A%3 5 A F T C a tJ k D S d B A t.( -4 PUD-CDD*
- A FFFORT ITEN 8,60L49 NON-Rt t,
! IT AL H0045 Ofsrti F i r ' '.
3 HOUd$
HOUR $
Fft*$ (171)
CONUMf O l
5 ?,397.0 1 246.1 5se%45.1
?!. lit 7%
25.1191'1 i
Y l
1 i
t l
I i
h i
7' e
V
--m
--a m-
S N
O ITA E
S L
N N
O O
I O
8 TI V
N A
S S
8 L
Y Y
O A
A 9
S VI D
D 1
G G
G O
S N
V V
N A
A I
N D
0 N
O I
3 F
I T
CR)
E E 'S b
P
,m E
0 7 a PB1 j
G S
., 3 f
SM 9
,e U
.\\
A NE 5 f
L e
~
U s
T I
N J
S P S
',7
,4 1
~
5 4 U
L E S J
9,'
s Y
7-s A
E
~
AS M
sp R
H y
L o, ' '. -
f I
P T
n R G(
s\\
\\.\\
A N
e R
t E
2 1
/
.~
'[
/*
MM
~
AD e "/,
!,e B.
/
s 4
t
\\
i t
MN t
\\
N g
. /9
,~
A E
\\
J c \\'s-a C
e E
/e -
i j
D Y
}' 9 V
7 t
F
,' \\
=
O
. 7 o
N o,' \\
T 3
4_m C
t O
~
S 0
O 0
0 0
0 o
o o
o o
L 0
a 6
4 2
0 s
s 4
n 2
i 1
1 1
1 T
Q[O mzO@L$z._.
A E.n M
i
!l
irf 0-<
m.t.
a50 00 i-DC T
u O.(
m
'Q 1
a l
O 741 v x u w w w t o-.
hU 7
7
,g 84 y.
45 *Jx % A'Y D A'\\' ' ' ' '
F Og h
61 26 g
k 56 %' N A s % N AC - xs
'1-s Z
42 E
)f( )u
'* %"AJ% A'A % % A A % % A',%sA'% % u'
. L.-
yI 501 9
o 4-
>Z b
401J%J 4 V K 1
~
93
[
65 o
13 E
E D
E E
i d
U O
o G
DETELPMOC SNOITCEPSNI
l I
S D
N D
N O
N G
E I
E T
O M
E M
L A
L A
K
/
P
/
D C
W M
W 8
N B
N C
N A
E O
E S 8 E
G N 9 E
~
~
L O1 IT C 0 mC P
~
A3 NI
/////
o E
S 2
I 6N5 3
3 S~
G 1
GR 6~
R F// //l' U 2
A N E 4
3 g~
L N p/ //l' U 1
B I
1 J
S 6
M n?
N 7
N 2,
O ? ///' U 8
4 J
E 5
3 E T
/
- 7///
M 8
Y A
C P
~
4 m0 RH ILE 7
2 E 2 l~ / / / PT S
A N 8
R O S
7 A
8 4
2 y
?l'///
MM LG 4
9 3
E B
A N 2
7 r
E r/l//'
4 2
F N
I R D 2
3 n
N 4
9 4
2
~i/ /'
A E
J N
T e
C A E 7
E 8'
87//'
D M
y 2
E V
Y 6
O 5'
S F///'
8 8
N 9
2 F
3 8
2 2
9 C
4 T
3 g:///'
O C
I L
0 o
0 0
0 O
0 O
0 0
0 L
7 e
4 3
2 T
O QbgoU A
M
74 Q
.7
.e Q
- c. 4 es g
en s.
ed e.4 em r=
c,
.e o.,
,, e i
I e
t 8
8 9
0 t
t 8
4 e=
t 8
0 I
us 4
I wS I
6 6
6 9
1 8
4 9
0 0
t 4
9 4
1 t
e e
r 4
a e
e N o 4 r, es e e w.4
- C' m e e ee4d
'T e1 *'
a m
t.
e
<c e4 e o e r. c Noseme N4NN en an te cs e1.
o ro N N **
e w - cm e s
+ *e # w N ca N e.u 3
rs v N e-ev N e N.- em
- O a e N h, e= ewmm nOO e==.3 N w 'e' N O O O O C O O OOOO OCO a s i
s C O **
2 e e e e e e o e e e e o e e e e o e e e e e 0 & 2 i em e=
a C t e
ee e
I a
e a
i N =^ O O O N== as e
- O O ne d 4 eeNN OOO t
i e O
'"1 e" *= # J== "e sc N e o P= N
'e'O W5 9
00N*
4 to OCO e
a e 2o<.N OOew ee T
pa en et es e+
e se e e
=%
o o s ** e o e e== 0 O saen w=
c= e o a
aw e es O O r-O N en r. tw O O O O *= =
000C OM0 I h N t e o e o e e e a e e e e e o e e e e e e o e i
t.s i
a=
sua p Pb i
1 4
i i
t e
e e
e o e
- r em es 6. n' **
e-
- s t' k o es
- c *% e o r= 0 g
4 J /* -
C'C* * **
>= " af *# O CD e er* * = *
- NNN
- 6. er e "e #
e
= a
- r
.a
?
== tw *= N ** m
- =0NN f* O e *- N e e **
4 m,e 4
em
) ew ** M A
- 98. NNrw m e of e wi' O*+3 eset
. OON ew N e e= ea
.;, O O O e-
- COOO OOO e e o e e e e e e e o e e o e e e a e e e e t.e om
- =
P. p*
I 1
8 8
Z t
I v
I I
2 0 **
4
<a 8 m t
CE 1 O f
em ee a
"'s e
J e
9 I t
JOO4 sc O e ** s'=
0COOOO O M 89 ea OOO e t-cr I
I e e e o e e e o e o e e e e e e e e e e o e e.* em O 6
.J I
J ee's e N ers O O em *.
t.1 e O D f9 O eNOO N rw *w and as e as I
9.# ** f om e t'
- e P.
O N e e.
re en er e
== e= en km E w I am 3
4 ers e m N N ca em
,. e E 4 an.r B C e
e 4
e-t e=
va e=
rd d e4 4
9 8
16 e EJ e i
t t
- t e== ew I as w*
I
.4 's C 0 m er e o O O C5 en O O e6 =a O th Q O O O O sa ** m OOO
.e n' C 4 i O I
.e
,.e,.e
,= e e e e e e e e e e o e e e e o e e
e 4 e. y e ? Cr g es
- 9 ga N O.J 4
ee Ag PJ em er W e ecI e
.r e
NNNNN ue K Q t 2 e
w=
=Ne 3
8 l
es er to i
g 2e e
e aw a
e I
s t
v a
a O
4
.s e
eOOe
- -C"r*"**
OC i
O O. *"* O OCOO O r") O r
e se a
e e e e e e o e e e o e
e e e e e e e e l s se,
N o-m n-e< e s..r e<
a ea c o e.e N-sm e--
e "3 Gr g r
P em f'"
em er's on. Ne i
e
.e e.- oe -
- J tb N wi to Ny NN
- e.m **
{
e em Oe s
s s e 3. I t
- A
)
e.
e
==
rw 4 1
I l
e e
t 4
8 h.
4 1
E 8
4 e
O O
f W
0 9
0 1
1 4
6 IA i
4 0
e.
I l
g Er e
j 8
4 O
e=
4 4
ns 2
+8e 1
i e
p la su 8
4 4
I 2
t 4
==
W O
O e
e 6
e=
- e
\\
e 6
0 2
b 4J Z
en 6-O t
4 ta.
VC e ? kJ ef M
j 2 O.a t
g sg f.'a C O
- ) L* 6 e=
Oe sa a
5 A t
ew a
= = = > U o.*
.2 ** 3 et O
- =
j
> s, u
c
.J==es 3 t **
t 7
vw 2 a9 C et sa.J
- e.s O
e
- d 0==
t O
se & '.a 2
&.J T2 aL e= =
3 en i
e t
- a 6*
3 EL as w
- =.J e e p
av s.
a9 j
s e
>e
- zo e.e us er =
u., se = m 2
OO ar i
e a
en
.J r== >
m-
- s' tL e r
g i
k &
e.
end b
4 >*
a*
s' 5 u-C' sa. O l
I f3 h b'
db Ee' 4 aJ O
.J ab
- eA
.J
==
0 W **
.J e.s e.e W
e e
e6 ** *
- e a
e>
+1
- 3N o
e,n u
e t
., 2 2 me ?
ta
.r ** *
- t
'429 6
e= eu 69 g
g w
== > O F
- == t.J
- J
.A 8Y C
u e
2 s
t
?
== u a
==
e-U as
.J e")
. > EL 2
4 fL T
t 4
C e-3,.*, ao, 3 4 EK
- e t 'e o
a u
.J V
3 e== v C
e.
a O e., ed 3
OwOE
==
== 4 4
es.
]
3 t
> eu er e er u-se es O se u J.J m a=
3&
U l
O 3
9 w Ch I
4 ws a
g au **
e-0 2
i 4
6
& Q C
2 uJ Z
l D*
4 i
e
- s. *
.,J W
I O
s t
2 ed u.*
l 4
4
.s e
to i
O I
8 j
l
.m s'
-e
. c..
T x
s
~
.r
. O s
I 1
4 0
6 i
e I
f 4
I I
N 4
6 6
8 tu -
t I
aP e
e e
f f
g.
f 8
8 4
0 4
i e
t 6
1 0
s e
9 0
4 4
e e
e er.= ori N im N e. =m et aa eee en e O <.a e en e **
e O #
O.O N e 3
P. as e w O== *>
S
- rw
>= N @ e N N
- 9 et e 9.a w e e ma N
- =em w 4 O N O eee N e=en e e c
- = * * =
3 = I i 4 New e O== 4 w e oOO N Om *= ed O O te em e I *
.7 e
N in
- e O== C C C *J 6 COO OOOONN 9ee p
p**
8 e e e e e e o e e e e e e e
- e e e e o e e t
'"2 a
- =
- =
e E a
e V I e
a I
e I
6 C ea s., &
c to o O er* JS N
- I *F J 3 C= O O O O O O "3 s
e Oec en e em' N
.c== ** C e6 m. **
- 't **
COOOno em oO e
a s
==
e o A-e er e no NNN OOOOCO OOO a. be g
.a oc c N e4 t O N er O N
.=e===
m~3OOOO OOO t== e 4 a
== N - N O==00Oe se OOC O 'J O O C, O COO a aA e e e e e e e e e e e e e e e o e e e e e e e e s
=., e
- e l
t e
8 9
4 4
0 e
s O ** O N o *= N N e C N O O O =3 e. O
- =s ("* ~3 e
e o N #a s^
ooeNeNN
- m e em ooOOOO OOO t
a=
e O4 * ' ' * *
- 6 e O.4 sg N se d.9 OOO300
- 3 O *4
- . se #
O ft a T*
=d*e= O era e im **
e-*===
0 C. 4 3nC m f* O 3 *= N 6
=# er N en ONCOOep COO OOOOOO OOO 4
I e e e e o e e e a e e e a e e o e e e e e e e A.e t
ma 8 em N N
8 4
0 4
T 4
6 v
s s
2 I **
4 e
f e i
e a 3 1
% er, 8 C S
20
>=
f I 8
^ J N *J O O O O e en em an em en en C O C en en en e en -
t' > a e
4 e o e e e e o e e e e e e e e e e e e e e e e
- ma ?
8 a N4ese -
O 4== o e N N e eD sa eneeoee eee
.- e.
g as a
,= m e<c p-4 *= e= em t.ll en O
- =e=*=
e,n C ee af* 91D
- =o=*
- a. w e.
t e-e ne e e
N 4N
=N 4,e Jw4
.a. e,
9 O t
= 4
- s t e n a
t a=
3 e= w= en om s*
er 3
i e= *= e=
s.*
a 8
r.s s'
I e
g 6 J l
- * = =
3
=.e e i Ju G e ea 4
- O at U O O O O O as O f'S O tlD c ae to O O OOO e6 a aS4 e e e e e e e e e e e e e o e e e e e e o e e
=e== v 0 2O f N N e= *.
e e= N rm ee d 4 =F We6 =a N N O O r'
."T at t 4
f* I $
e=
c r" e=
em N e= N e= em en
+C e 2
- J e2 8
- =
ce 3
4 er a r.,
I f
14 0
1
=a 6
e ad 4
I s'
6 8
s er a
== in N e.
O O O O sa P't *=
en e e6
- O er5 ee to e
- 'A em s
2 4 as t
- *
- e o e e a e e e e e o e o e o e e e e e e
tsa e
O,= N =>
>= ea f6 o as N e 4.a a
- a= N.s P o eoe 1 3 tr e 3
.***N
S 1 eM4e w em,
eA P sm si f
- N e.e eA e v *,, e er" R d., me rJ d e
= +
we
=a -9 **
0 =-.3 4 4 4 %
s 4 6 g 3 3 2 6
- =*=e P*
0 e
,= e= a=
t i
E 4
0 9
0 0
4 0
8 0
a f
I e
t 0
8 8
0 4
e u
6 a
I I
61 4
9 9
w 1'-
ME e
s o=
== eo a
e
- =
va as n
=*
2 2
e a
er o
= = = ** eL Jo in-O et 0
l O
6*
2 en e4 C ese me E >= 4 =J se 2
e a
na e
er w I
o.
4,s 2 e T 2
8 F e
a en f
=J ens e
>= 3 68' >e sie L
W m, e., *=
w 2
ed *"' e= 2 er se at erZ W O e
r 8 >
0 wwee w
- en== w ts
==
("t W t **
4 d
V is.u o
en a en y o a.-
F 4 u er O ew
(*
..a us I
e 2
== e e me e
me w2
- J C
2 ar JJ >=
p=
ge a
e
==
.J 2 2
.J ar 2 :p w at v
woe e.*
2 i
g
- eia w.e o
er a es 69 u
s*-
ene w
er 4
8 a t' 3vv
==
0
- t+
9==
3 o
t.J O2 se e.e r
e 4
3w w****
v 2 em 2e>
I*
Ed *JO e
e aJ 2 d.d L
en as m*
=J
- e **
u 7
=a E e >.4 4
g 6 **
w
=
2 at
- =
4.J 2 >
=a as 0
0 w.J eu O 3 2 2 2 en O W
3e f mE O e*l W
.O.
t t
- 5 2 a r*
w e e,J no e
'w me d F ** ed a=
+3 s
s 5>
e en, 2 w en. O ea n e
2
>=
U tr O *4 2
O 4
l 2U e 3. ud dr
- Z *e e4 M v5 i.e V
+9 O and e au M
e t
==*e
== at et au
.A *=.A er e.
==
0 e
uJ 2 er er r
EL f
9 e ta T
E w
0 0
2 *=
>=
E M
'3 t
4 C
O O
ese at t
t u
u 2
2 u
4 e
ce ses o=
4 e
e
.4
<as O
F V
0 t
0 0
\\
__2 n.
s.
~
4 3
0 6
f 9
9 0
9 9
1 a
4 e
t 4
0 f
tw 6
4 0
8 8
e I
l I
I I
8 i
i 1
5 6
8 8
8 i
f 8
1 0
l 3
- e. e 4 O r C q q O e) e e
C 3 no e ed 4 @ me@
D & f>
0 mA g.2 l
- = C e % e es e f OOO e. 1 0 4 00 e O N O O O COO 9 ee B t 4 v' C Q os CNN OOO 3 e na 4 e e e o e e e o e e e 3 a 2 i e-NN g
t' 4
4 w i I
i 6
9 0
t O Q O O O *3 O n 3OO 9
e m1200000O eor i
- 4 OOOOCOOO OOO l
m ** t C r. C D O O. C C ORO 9
e-
. I L '3 '" w O r OO OOO e wN 4 e o e o e e e e e e e t
6 6
6 0
4 I
e s
e i
I
(" cCOO?OO O
! O e
t "J C t' O O O C Q OOO 4
saa e COOCOOOO O ** c 4 w ** I
- FtJIS O O C O
^ 3 f7 g w re a
<3 C O c o L C p COQ f we a e e e e o e e e o e e e
w e 1
I e
E 8
6 J
0 t
F 0
w*
t e
i e 9
e f O 4
+ en a o e
~4 8 2 8
km N e O V I m 4 4'
OOO f* 3 em 4
6 e e e o e o e e e e e
- = =. O 9
A 4
4 ** e 80 e N N N NNN
-t 8 e t
- e N
N NN
- s. s a e
e.
3 O er w e
- e. N
- w i O B
b e
I a=
0 an e
.A e
4 0
he 0
6 Ed M i
1 e
i 3 9
e== u a
.s.**
e
.a m O I e a e O **.A O art Oee OOO e r= c 6 #
"l': e e e e e e e e e e e e me s-w 3 2Og 4 e m e.
NN
.s e a e *" If we e
e er wa7 s 2 e
e,=
=
0 4
4 e& K l
l T *1 8
9
>w 0
g
.J B
3 J
l 9
3 5 'ar e
f N C 8"' f. '" ** es COO 2
B e n
e o e e e o e e e e e s
.4 e e 4 e ar er e= N se e e e, A.
8 Dms en O A tw A**
t
.? 3 s C ?o r
.)
r 0
L' E t t
4 s t 6 ;s T 4
- =
en v*
5 4
e e
f 8
0 8
8 0
0 4
4 9
4 1
0 0
0 e
9 4
0 4
0 0
0 9
0 0
4 0
0 9
0 8
9 8
8 8
9 9
6 E 9
e
)
e.*
0
.1
.d r 'w sv g
i e-8 va es e Y
O s==
3 n.e
> e C e.e er G
3 e-et om * * > +
M e.e W e>
sn#
e== 4 W ef 8
g
==
3 tg 7
.9 4
8 em N
3 ** ' 9 >- 4 7
0 I
L#
O P V.849 J 8
0
- t k
- b.
3 8
8 k
au f *s 22 G
e e
e-w in==== w *= m y
f,,
8 l
Z ee 4 C en K me J
e w
em m
.d 2 O C 2 6
e t
{
E V
.J > *is seS
.J e
p 4
e n.-
we c
85 0
0 t$
R 64 0
0 4
e A
4 i
F O
e o
e e
=
2 O
e e
e t
=
s j
4 4
)
O e
I I
r
w.
g
-h-
..C m
g 3
3 3
4 r
h 0
t 6
4 4
1 8
0 0
4 MP G
f 4
0 n*#
4 4
UP e
e e
e e
b 8
9 4
5 9
6 4
I 6
0 0
0 5
0 0
0 I
I 4
I
- F e
O e r.
$ e een 9 @
g e T 4 2D 8 m l
- 8 *= ** 9 e 6 W2 t k t
O 8 9
v0 f
f i
1 4
9 7 0
0 +
a j t 1 or e e a e *. g e l b k.
t e f
- 0 #
l t
i 4
4 8
8 8
6 l
4 t
i J t
a 4 **
i s ;e t i.
t
- N 1 E O $
e I
w 0 f 4
e e
6 Z
6 6
v 9
9 2
i e l
4 f &
0 G
G @
- CD 9 C 5
T
$ 1 0 #
O >a e
a e
e"*=
0 0
.J t E uw e e i e
>'A w
4
- aC 4 at e 8 3 9
4
$ >=
f f 6*
et t
t e.
L A i
t TJ E 0
t e
t J t
.a es w I
- a. e e
.J 6 3 9 te tw $ #
e aw O f I 34 e
= = = = v e 2oem i e t 4 CI 8
==.
an EC 4 Y t
3 8
1 e er is 8
e Ee f
9 s
e e
.d f
f u
i e
i En t C 2
0 e e e 9
.4 e i O 9 3 TE l e
- 3 3 ee 9 6e O e s t O Z t I
e*
8 0
8 8
8 8
9 4
5 t
4 0
0 t
i I
e 0
0 8
4 0
4 9
0 I
0 4
i 5
t t
4 6
I I
8 5
5 0 K t
t =
0 0 >
4 9 **
e e
t i
8 9
9 8
9 e
a 0
t t
8 e
s 1
4 8
8 l
l o
I 9
4 4
A 9
'3 4
0 a
4 m
O 0
7 0
0
MATERIALS IN S P ECTIO N S FY 1989 THRU MARCH 1,
1989 (LESS 591'S)
CO-FINDINGS:
72
~
70--
'b[
VIOLATIONS co-l'.,
....... AVG DAYS VIOLATIONS
/ i
.__.__ AVG DAYS NONE
/
1, so--
4e a
\\
\\.
O
\\
\\3' 49e 1,
4 Op
' N s2 5, U
0" l
w so-
\\
=
p a;
~/
\\
l 10--
1) 10- -
l 4
o 2
OCT DEC FEB APR JUN AUG l
NOV JAN MAR MAY JUL SEP MATLS MONTH
MATERIALS IN S P ECTIO N S FY 1989 THRU MARCH 1,
1989 110--
INSP TYPE:
99--
591 OTHER 77--
.5 SS--
8 m
SS--
g M
z g_.
O es m
/
33-M N
y.
2 11- -
)
O-d d
I l
t i
e i
OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP MTL591 MONTH
MATERIALS LICENSING ACTIONS FY 1989 THRU MARCH 1,
1989 595 593 LEGEND:
546 549 BACKLOG 500--
514
_ _ NEW/ AMEND COMPLET!ONS 4co- -
b NEW/ AMEND O
316 312 O 300--
\\
276
- ig; N
en N
/
259 m
200-p f
o s
r-2
[' C
! Q m
5
?Y l '~ ~
$l/'
f a
/
/
l
/
l f
l
/
1 ik i
/
/
/
/!!
l" 0
OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP MATLLIC MONTH
. m
a The following comments are in response to Question No. 3 WORKLOAD PROJECTIONS As usual, receipts of new materials license applications and for materials amendments to existing materials licenses have run behind projections during the first 5 months of FY89.
It is expected that receipts of applications will increase and the final workload will approximate those in the operating plan.
Currently, completions for new licenses and amendments are running behind the operating plan, but ahead of receipts. We expect to complete the number of new licenses and amendments called for in the operating plan by September 30, 1989. Total licensing actions completed in FY 89 will exceed projections by nearly 20%.
Inis will be the result of completing approximately 350 materials renewals, well in excess of the projected workload. There are several reasons for this.
1.
A large amount of FTE was expended on materials renewals during the last 2 months of FY88, but the actions were not con.pleted until FY89.
2.
Two employees on maternity leave were able to work part time.
Because of timeliness requirements, their assignments were limited to review of renewal applications.
3.
For Health Physicists to fully meet the requirements for the job, as forth in the position descr.iption, it is necessary that the set training of each employee include completion of a minimum of 30 renewal or new applications.
This training has required considerable expenditure of FTE on licensing reviews of renewal applications.
Current projection based on completed inspections, indicate that approximately 1050 materials inspections will be completed during FY89.
This is very close to the projected workload and we do not propose any changes at this time.
We anticipate full compliance with Manual Chapter 2800 once OMS clearance is received for the medical questionnaire, i
l 1
i
~
~
^1^
c-1 i
The following comments are in response to Question No. 4 ADMINISTRATIVE SUPPORT The NMS Branch depends on several administrative support units that are external to the Branch, but also has several internal functions which contribute to the overall operation.
The main internal support group unit is the Licensing Assistance Section.
This group was organized in April 1988 with Doris Foster as Chief.
Several functions are handled by the Licensing Assistance Section (LAS), including:
processing and docketing of incoming mail.
preparation of licensing actions for reviews by the technical staff.
typing of certain high priority work, such as escalated enforcement actions, preliminary notifications, urgent inspection reports, and special projects.
filing, maintenance and retrieval of docket files.
clerical effort involved with the documentation of inspections, inquiries, etc.
implementation of the materials " returned mail" procedure.
preparation for signature of amendmentrnot requiring technical reviews.
Administrative services provided by groups outside of the Branch include travel, typing of all licensing and routine inspection documentation, inspection tracking system support and computer data entry contract support.
1 The groups that provide administrative support typically perform their functions in a timely manner. However, timeliness is a function of workload and availability of personnel.
For example, in the processing of incoming mail received by NMSB, it has typically taken an average of three days for the mail to be available for Fees or for the reviewer to evaluate. Recently, the average has gone up to four days because of illnesses to LAS staff members and because of the beginning of year concentration of holidays.
The Word processing Center (WPC) types essentially all licenses and does the bulk of routine inspection documentation typing.
The WPC turnaround time is generally between two and three days, which is acceptable. This is a sig-nificant improvement f rom past experience, which, at times, tended to run 10 or more days, particularly for routine inspection documentation.
,n-e u
Question Nc. 4 2
Mate-ials decket filing continues to be done in a meticulous and timely Documents generally are filed on a daily basis.
Unfiled materials are canner.
kept in reacily accessible areas so that they are always available.
The Computer Assistant in DRMA inputs inspection data for the RITS Inspection Tracking System for DRSS. We have experienced difficulty in the past with the accuracy of information in the system.
For example, reports that had been issued still showed as overdue and inspections that had been performed did not show up at all.
In addition, occasional data entry errors result in inaccurate summary cata, sucn as average time to issue inspection documentation.
The Computer Assistant has instituted procedures that allow NMSB to review and correct the weekly rescrt before it is published.
Lack of backup support for the Computer Assistant is an occasional problem, resulting in delays in data entry, but this problei ic: acts only the availability of current statistics or tracking i n f e rma ti cr.
I In the latter part of 1988 NMSB began utilizing a DRMA computer contractor for routine data entry to the LTS and to the Region I inspection tracking system.
For the first few months there was considerable turnover in that staff and they were of little help to the Branch.
Within the last few months, however the contractor's staff has become more stable and they have become a great asset and have reduced the workload of the Branch.
Wne there have been.a number of improvements in the administrative elements' in CRMA and the Branch, a number of both direct and support activit:es pre sently are being performed by other than the appropriate staff member.
Since the reorganization that resulted in establishment of the LAS and selet-tien of Ms. Foster as the Section Chief, the Licensing Assistant position has remained vacant, pending demonstration to the Regional Administrator that the position is needed.
In tne meantime, the duties originally performed by the Licensing Assistant (such as implementation of the returned mail procedure, the purging of erroneous information from the computer data base, and the preparation of simple licensing actions) are being performed by other members of the staff, including the Processing Assistants, Reference Assistant, LAS Section Chief or members of the technical staff.
Similarly, some tasks normally done by members of the LAS., such as the preparation of inspection documentation for mailing, still must be done by a member of the technical staff because of the admin-i istrative staff's involvement with other work.
l
The following comments are in response to Question No. 5.
INTERACTIONS WITH HEADOUATERS USEFULNESS OF CONFERENCE CALLS Monthly teleconferences between NMSS and the regional offices provide a forum for the sharing of information that is important to all of the participants.
However, our current teleconferencing practices do not always result in the exchange of high quality information.
We believe that the calls too often involve region-specific problems and run too long.
We suggest that the agenda be restricted to items that are generic, and be constrained to about one hour.
NMSS should assure that topics which relate to a region-specific problem or concern are resolved separate from the teleconference.
Each topic that is discussed should be resolsed or assigned for resolution, with a due date as necessary.
Following, a report of the teleconference should be prepared and distributed. Agreed upon assignments should be regarded as Action Items and handled accordingly.
LI_ CENSING WORKSH0p Ihe Licensing and Inspection Workshop held in Atlanta on January 10-11, 1989, was well done.
However, the real worth of the effort will only be realized wnen planned actions are completed.
Relative to this effort, we believe that it is not in the best interest of the agency to invite representatives from the Departments of the Air Force and Navy to attend the entire conference.
Rather, these licensees should be invited to make specific presentations and participate in selected discussions that directly concern their respective programs.
Their presence for the entire duration of the conference may prevent open discussion and the ready exchange of information, some of which may be predecisional, internal, or investigative in nature.
In the future, participation by such NRC licensees in aff airs that are clearly internal to the NRC shoula be carefully considered.
One of the benefits commonly expressed relative to the workshop was the opportunity to compare approaches and problem solutions with other regions. We believe that such benefit could be further enhanced by i
selective and discrete exchanges of personnel (including inspection, (e--
1 1
l
\\
Question No. 5 2
licensing and management personnel) among the regions and HQ. We believe that such exchanges should be of short duration and directed toward specific areas of interest or concern INSPECTION ACCOMPANIMENTS Recent interviews with several of our inspectors and license reviewers indicate inspection accompaniments may be useful in maintaining HQ personnel cognizant of regional techniques and protocols, and the scope and type of licensed programs that the regions regulate. However, the inspection personnel usually view such accompaniments as a one way exchange, and are sometimes led to believe that their performance is being critically evaluated.
In such cases, the inspector tends to be uncomfortable with the accompanying HQ personnel.
Since accompaniments are not performed to critique the performance of the individual inspector, the actual purpose of the exercise should be explained by the accompanying personnel.
Several inspectors voiced the opinion, that, when interviewed by members of the National Program Review Team, the emphasis appeared to be too narrowly focused on the administrative, documentation, and production aspects of their job, as opposed to inquiries directed toward examples of how the inspector views and exercises responsibility for public health and safety. We recommend that the statistical and production aspects of National Program Review be reserved for management interface.
TELEPHDNE CALLS ON CASE REVIEWS AND TECHNICAL ASSISTANCE PROVIDED ON A DAY-TO-DAY BASIS We are generally pleased with the assistance provided by Steve Baggett, and recognize that the timeliness problems associated with Source and Device reviews is largely a function of resources available.
He has, however, been very prompt in responding to questions from the staff and usually handles specific information requests within 24 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Similarly, emergency requests for guidance in the medical area have. been handled promptly and the information provided has been useful.
Problem areas include the generally long delays by NMSS in responding to written TARS and the lack of feedback on the quality of licenses or inspection reports issued by the Region.
STANDARD REVIEW GUIDES / REGULATORY GUIDES / POLICY AND GUIDANCE DIRECTIVES 5DLRCE AND DEVICE CATALOG We are generally pleased with the quality of information published for licensing and regulatory guidance, but note that certain Reg Guides should be considered for technical revision.
We often receive comments from licensees indicating that they have difficulty in understanding the applicable Reg Guide. While some of this
Question No. 5 3
difficulty may be a function of the licensee's limited knowledge, the NRC should assure that published guidance documents exhibit clarity, conciseness and uniformity.
Utilization of the Source and Device Catalog could be enhanced by a better indexing system.
Currently, we file the material alphabetically according to manufacturer.
However, such a system has limited usefulness as the manufacturing concerns change in name and ownership.
The use and adherence to Policy and Guidance Directives could be enhanced significantly by better organization and document control. We recommend that alternatives to the existing system be considered, including:
(1) Reorganizing and promulgating the existing guidance documents in a NMSS Manual; and, (2)
Incorporating Policy and Guidance Directives in t database that is accessible by computer.
Use of a computer-accessible data file for this material would also permit timely revision of the documents.
INSDECTOR AND LICENSE REVIEWER TRAINING We continue to have difficulty in scheduling Nuclear Materials Training courses that are required for personnel qualification.
Too often the courses are not available or are offered sporadically.
For example, while teletherapy is now considered as a Priority 1 program, we have very few personnel with sufficient training and experience to perform critical reviews, and a training program has not yet been established to fulfill this need.
DISSEMINATION OF INFORMATION It has been observed that information may be distributed to licensees before it is available in the regional offices. The latest example includes NUREG/BR-0133, Working Safely With Nuclear Gauges. Our inspectors had inquiries concerning this document before they even knew it existed. We recognize that information distribution is usually accomplished via contracted services.
If it is not possible to supply advance information to the regions, then including the regional offices on the contractor's mailing list would seem appropriate. We have noted a concerted effort to provide Information Notices to the regions prior to publication, an effort that is appreciated.
MULTI-REGIONAL INSPECTIONS Certain licensee types, principally large radiography companies, may maintain a corporate office in one NRC region and have several field offices and places of use in other NRC regions. Usually, the license is administered by the region in which the corporate office is located.
Examples include, U. S. Testing (Region V), Industrial NDT (Region II),
s Question No. 5 4
Magnaflux (Region III), and PSI-Pittsburgh Testing Laboratory (Region I).
In these cases, the NRC regional offices may not be aware of the fact that a radiography field of fice is established in their jurisdiction.
Consequently, these licensed activities may not be inspected.
Region I was not aware of Industrial NOT field operation in Mexico, Maine until Region II requested our assistance in following up on a source disconnect.
We recommend that an effort be made to identify the location of such fielc offices, and tnat a system of regional assist inspections, similar to that employed for inspecting Navy and Air Force licensed activities, be estaolished.
m
The following comments are in response to Question No. 6 REGIONAL INITIATIVES DURING FY88 AND FY89 THROUGH FEBRUARY 28, 1989 1.
Implemented the " Recommendations for Action" contained in Sections 2.5 and 5.6 of the " National Program Review Report" dated September 29, 1988.
Region I routinely monitored the status of completion of inspections a.
of high priority licensees and began using'the " official field note formats" in all inspections.
The region has been able to accomplish inspections, even in tne lower priorities, in a timely manner and has not had to resort to the optional use of the telephone contact procecure, b.
With one exception (an inspector who became pregnant and concentrated licensing), all inspectors were accompanied on inspections at or least once by their Section Chief during FY88.
That practice has continued during FY89 with each Section Chief. accompanying at least two inspectors thus far (a total of 11).
It is our intent that each inspector will be accompanied during FY89.
2.
Aggressively pursued qualification (by an oral board) of all materials inspectors.
The status of each technical member of the Branch is shown in the attachments.
Thus far in FY89, seven inspectors have met (and passed) oral boards, and nine more are expected to meet oral boards before the end of FY89.
The additional flexibility that will result from this progress is expected to enable the region to meet or exceed its inspection goals for the FY.
3.
Aggressively pursued qualification (in accordance with the attached program outline) of all materials license reviewers.
This two phase process is well underway, and nine reviewers have completed at least one of the steps and been authorized by the Regional Administrator to sign licenses.
The training program associated with the qualification process has enabled the region to issue licenses (including renewals) well in excess of its budgeted goal at this time and the annual goal is also expected to be exceeded.
4.
Developed and coordinated a national seminar for operators of NRC and Agreement State-licensed irradiators.
The seminar was held in Arlington, Texas on May 24-25, 1988, and was attended by approximately 100 repre-sentatives from the approximately 36 active irradiators in the U.S. and f rom NRC/ Agreement State regulatory authorities.
The meeting was transcribed and a draft of a NUREG has been prepared by Region I, j
I I
4.
Question No. 6 2
5.
Developed several Information Notices for issuance by NMSS, including:
Criminal Prosecution of Licensee's Former President for Intentional Safety Violation (89-02)
Dose Calibrator Quality Control (89-12)
Unauthorized Transfer of Ownership or Control of Licensed Activities (89-25)
Loss and Thef t of unsecured Licensed Material (submitted for review February 7, 1989) 6.
Participated in a number of meetings and seminars in support of NMSS in the medical area.
In addition, the region identified, during inspection of recently-licensed nuclear medicine and nuclear cardiology private practices, an apparent generic problem.
Inspection of six such facilities in late 1988 and early 1989 revealed that all six had initiated coerations without satisfying all requirements of the license.
As described in a memorandum dated February 27, 1989, from S. Ebneter to R. Cunningham (copy attached), Region I has initiated a new procedure in an effort to assure safe operation of these facilities and to avoid repetition of the problem.
7.
In February 1989, the NMS Branch Chief initiated a monthly audit of inspection documentation issued during the preceding month as a quality control check.
Findings are then provided to the appropriate Section Chief.
Focus is on clarity of communication of problems to the licensee (in both the cover letter and in the Notice of Violation) and on consistency of the inspectors' techniques of inspection and documentation.-
Format, grammar and spelling errors are also noted.
8.
Heightened awareness and aggressiveness with which we identify and pursue cases in which licenses have been transferred to new owners without informing NRC.
The Region I program was described in a memorandum dated December 30, 1988 from Bill Russell to Hugh Thompson and Jim Lieberman, (copy attached) and a draf t Information Notice was forwarded for NMSS consideration (being issued as IN 89-25).
9.
Purchased two cutaway radiography cameras and related equipment for use in training the inspection staff. A training session using the new equipment was held in February 1989.
Similar orientation sessions were held (prior to receipt of the training aids) for the Division of Reactor Safety (DRS) in November 1988 and for the Region I resident inspectors in December 1988 to f amiliarize them with the radiation safety requirements imposed on radiographers. DRS and resident inspectors often encounter radiographers doing work under their byproduct material license at reactor sites.
Question No. 6 3
10.
Developed a training program on the requirements of Part 35 to be p esented to licensee nuclear medicine technologists and radiation safety staff.
These training sessions, to be initiated March 10, 1989, will be presented at 12-14 Region I facilities.
11.
Coordinated, and scheduled for April 27, 1989, a seminar for all of the Harvard-af filiated institutions, on the NRC's expectations and requirements relative to radiation safety programs that are performed under contract by the Harvard radiation safety staff.
12.
Plan and present, as soon as the final direction of rulemaking for medical quality assurance is determined, a series of workshops explaining tne rule.
The workshops will be held in several major metropolitan areas and will be directed at medical physicists and radiotherapists.
13.
Aggressively pursued appropriate enforcement for those licensees unable or unnilling to comply with NRC requirements.
This included the conduct of 21 enforcement conferences in FY88 and 10 thus far in FY89.
14.
Reduced the average time required for issuance of inspection documentation from over 100 days in the first quarter of 1988 to less than 50 days as of the first quarter of 1989.
15.
Made a significant contribution to the effort to develop performance evaluation factors.
The region has utilized the factors as described in its memorandum to Mr. Cunningham dated September 28, 1988.
16.
Planned and implemented a major reorganization of the Nuclear Materials Safety Branch to focus attention on the. safety problems of types of f acilities, rather than focusing on licensing versus inspection of all facilities.
17.
Aggressively recruited to fill all funded vacancies in the technical staf f, including selection of a medical program specialist.
18.
Developed a book of guidance on inspection documentation, including model citations, which received widespread notice within the agency.
19.
Began the development of an organized book of detailed guidance on the formatting of license documents.
20.
Began reviewing licenses for which financial assu,ance is required. Most of the staff has attended formal workshops given by NMSS and specific procedures and guidance are in preparation by Region I
QUALIFICATION STATUS - MATERIALS SECTION A 07-MAR-89 f
f PEPORT TO INSPECTOR ORAL LIMITED FULL IDP t.AME PEGION I JOURNAL BOARD LICENSING LICENSING l
J.
PELCHAT IN ECD ECD ECD IN HEALTH PHY$
MAY-87 PROCESS 05/31/89 03/31/89 05/31/89 PLACE I
t l
L.
TPIPP IN ECD APPROVED ECD IN f
l HEALTH PHYS JAN-88 PROCESS 03/31/89 01/11/89 04/30/89 PLACE I
S. COURTEMANCHE COMPLETED PASSED ECD ECD IN HEALTH PHYS JAN-86 02/15/89 03/31/89 07/31/89 PLACE T.
DARDEN IN ECD ECD ECD IN HEALTH PHYS MAY-82 PROCESS 04/30/89 03/31/89 07/31/89 PLACE C.
SCHULINGKAMP IN ECD ECD ECD MATERNITY HEALTH PHYS Nov-87 PROCESS 04/30/90 10/31/89 04/30/90 LEAVE t
J.
GRESICK IN PASSED APPROVED ECD IN l
SENIOR HP JUL-88 PROCESS FRSS 01/11/89 04/30/89 PLACE J.
JOUSTRA COMPLETED PASSED APPROVED APPROVED IN HEALTH PHYS APR-84 05/01/88 02/17/87 01/11/89 PLACE J.
PICCONE COMPLETED PASSED APPROVED APPROVED SENIOR HP MAP-87 12/22/88 10/22/87 NA J.
STAMBAUGH IN ECD ECD ECD IN HEALTH PHYS JAN-89 PROCESS 02/28/90 02/28/90 08/30/90 PREP
i t
OUAL!FICATION STATUS - MATERIALS SECTION B 07-MAR-89 REPORT TO INSPECTOR ORAL LIMITED FULL IDP NA~E REGION I JOURNAL BOARD LICENSING LICENSING F.
COSTELLO l
COMPLETED PASSED APPROVED SENIOP HP l
JAN 77 02/27/78 NA 04/04/86 NA L.
FF! EDMAN COMPLETED PASSED APPROVED l
l SENIOR HC JAN-77 01/10/78 NA 10/22/87 NA l
c
)
J.
JENSEN COMPLETED PASSED ECD ECD IN l
HEALTH PH15 AUG-85 02/14/89 03/31/89 09/01/89 PLACE T.
OBERG REG lli GRAND ECD TBD IN HEALTH PHYS AUG-84 03/05/76 FATHERED 08/01/89 PLACE R.
PROVENCHER IN ECD ECD ECD IN HEALTH PHYS SEP-88 PROCESS 10/01/89 01/01/90 07/01/90 PLACE I
RAJENDRAN IN ECD ECD ECD IN lS.HEALT* PHYS MAY-87 PROCESS 04/30/89 06/01/89 06/01/90 PLACE E. ULLRICH COMPLETED PASSED ECD ECD IN HEALTH PHYS MAR-87 02/16/89 03/31/89 09/01/89 PLACE w, WALLACE IN ECD ECD ECD IN HEALTH PHYS MAR-87 PROCESS 04/30/89 06/01/89 06/01/90 PLACE
s s
GUALIFICATION STATUS - MATERIALS SECTION C 07-MAR-89 REPORT TO INSPECTOR ORAL LIMITED FULL IDP NAME REGION I JOURNAL BOARD LICENSING LICENSING J.
DAVIS COMPLETED PASSED APPROVED APPROVED SENIOR HP OCT-73 10/22/87 NA J.
MILLER COMPLETED PASSED APPROVED APPROVED IN HEALTn PHYS JUN-84 11/28/88 10/22/87 PLACE l
T THOMPSON IN ECD APPROVED APPROVED IN HEALTH PHYS JAN-84 PROCESS 04/30/89 10/22/87 PLACE R.
LADUN IN ECD ECD TBD IN HEALTH PHYS OCT-82 PROCESS 05/31/89 06/30/89 PLACE D. COLLINS IN EXCEPTED ECD TBD IN HEALTH PHYS SEP-81 PROCESS FRPS 12/31/89 PLACE l
A.
tIRKWOOD IN PASSED
PHYS OCT-88 PROCESS FRPS 12/31/89 PLACE L-H E A L T H I
M VARELA IN ECD ECD T'BD IN HEALTH PHYS Nov-80 PROCESS 06/30/89 06/30/89 PLACE u
M.
TAYLOR COMPLETED PASSED ECD ECD IN HEALTH PHYS JAN-84 01/12/89 06/30/89 01/31/90 PLACE r
.,_