ML20057A295
| ML20057A295 | |
| Person / Time | |
|---|---|
| Issue date: | 05/23/1989 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309130335 | |
| Download: ML20057A295 (7) | |
Text
4 pO C8 c UNITED STATES
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RUCLEAR REGULATORY COMMisslON i
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REGION lli 7e f
799 ROOSEVELT ROAD 0'g GLEN ELLYN. ILLINOt5 60137 49 9
MAY 2 31989 MEMORANDUM FOR:
Carl J. Paperiello, Acting Deputy Director, Office of Nuclear Materials Safety and Safeguards FROM:
Charles E. Norelius, Acting Deputy Regional Administrator, Region III
SUBJECT:
COMMENTS ON DRAFT NMSS NATIONAL PROGRAM REVIEW REPORT We have reviewed the draft NMSS National Program Review Report for Region III as enclosed with your May 6, 1989 memorandum and cur comments are attached. As suggested in your memorandum, we also have attached marked-up copies of appropriate pages from the draft in cases where we recemmend rewording.
Thank you for the opportunity to review the draft.
The review was excellent this year, particularly from the standpoint of professionalism of review team members and the team's interaction with the staff to explore problems.
{Shd Y NtL2%
Charles E. Norelius Acting Deputy Regional Administrator Attachments:
As stated cc w/ attachments:
G. Sjoblom, NMSS A. B. Davis, RIII R. J. Caniano, RIII G. M. McCann, RIII D. J. Sreniawski, RIII D. G. Wiedeman, RIII 9309130335 930830 PDR STPRC ESGGEN
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Attachment Comments on Draft Report 1.
Page 3, Section 2.a.v. Timeliness.
It is not correct that significant amounts of time have been performed by licensing reviewers on inspections.
Also, reviewers performed inspections last year due to licensing having 1 FTE on board that was budgeted for the inspection program.
Suggested changes are in the marked up page attached.
2.
Page 4, Section 3.a.
Recommend some sentences be added explaining that a major reason for the high number of overdue inspections and low inspections completed is due to Region III being unable to hire four new inspectors. Therefore, the Region has on board four less inspectors than j
budgeted. Suggested changes are in the marked up page attached, l
3.
Page 9, Section 4.
It is not correct to state that a training program does not exist for licensing reviewers.
Several years ago, the Region created a qualifications journal for reviewers including a certification process and mandatory training requirements.
Attached is a marked up page 9 with suggested changes to reflect this.
4.
Page 10, Section 5.
We have attached some suggested changes to more correctly characterize the allegations board and materials licensing section chief involvement in meetings with the staff.
5.
Page 11, Section 7.
The Region continues to experience problems in bringing new hires on board.
Since the program review, we have also lost an additional inspector through attrition.
The Region does not expect to be fully staffed in materials inspection until the end of Fiscal Year 1989.
6.
In regard to the recommendations, we plan or have completed the following actions (numbered to correspond to those in the draft):
a.
Assigning Inspections in TI 2800/16 on Monthly Basis We agree with this and are in the process of reprogramming our computer system to " spread out" the resultant inspection due dates.
This should be completed by June 1989.
i 1
b.
Expanding Section Meetings to Include Section and Branch Chief This has been done.
Section Chiefs and sometimes the Branch Chief have attended all section meetings since the program review.
In addition, the Section Chiefs have been directed to lead the meetings.
c.
Consider Changing Allegation Program l
l The Region did consider this and the program was changed in a new regional procedure, effective May 17, 1989. The changes allows DRSS to make decisions regarding whether the inspection report and followup actions are sufficient to close an allegation without prior concurrence from the allegation coordination staff.
l l
Attachment I
d.-
Involving-Licensing Staff Earlier During Enforcement Cases The Branch Chief and Section Chiefs meet at least biweekly to discuss potential enforcement cases which are then placed on a list and routed to the staff. This. process was initiated about-two years ago; however, the Region is making a more concerted effort to see the reviewers are aware of enforcement cases through this mechanism.
e.
Obtain Additional Computers DRSS requested more computers to improve efficiency in inspection and licensing in a memorandum to the Division of Resource Management and Administration on April 12, 1989.
f.
Identify Areas Where More NMSS Guidance is Helpful Mike McCann has been assigned the project manager for developing this list. The scheduled date for completion and providing to NMSS is September 1, 1989.
g.
Training in Transportation and Low Level Waste We agree that certain individuals including new hires should attend the transportation and low level waste course. We have scheduled them for the next course which is to be held in October 1989.
2 1
4-s a Broad Scope License, an unusual case or a totally new activity or license (e.g., a new radiography business), then the Region conducts a pre-license site visit in accordance with NMSS Policy and Guidance Directives.
iii. Casework Assignments.
For the complex program code-cases, Senior Reviewers are given the assignments such as applications for research or Broad Scope.
The Section Leader makes prompt assignments for cases involving amendments and new applications.
Now that there are also licensing goals for renewals, the reviewers know what is expected of them and they work to those goals.
This system has helped to diminish the backlogged cases.
iiii. Adequacy of Headquarters Guidance.
Interest was expressed for revisions to some IMNS Policy and Guidance Directives and Regula-tory Guides.
Region III agreed to prepare and to submit to IMNS a list of those which should be revised within the next year or two with relative priorities and rationales.
v.
Timeliness.
The licensing section has been able to meet or exceed the licensing goals established on December 1, 1988, and will be able to continue to do so with the resources allotted.
However, the receipts of applications have been greater than pro-l jected (by about 9 percent) in the budget, which potentially com-promises the plan to meet the goals.
The Branch separates the licensing staff from the inspection staff in that the former are in one section while the latter are in two other sections.
The l
. Branch believes this works best, given their experience and person-nel.
To assist in bringing new reviewers on-board, new hires spend a minimum of 4 to 6 seeks in an inspection sectien t:
obtain that perspective.
The review process, organization and l
training appear to c etribute to the meeting of the timelicass I
goals.
However, the license reviewers are called upon from time-to-time to spend @ fk r,t r = t; ;f time performing I
inspections because of the Dacklog in that function, which in the past has resulted in a large backlog of licensing actions. La>f Kv, l
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vi.
Enforcement Durino Licensing.
The Licensing'Section noted several cases wherein, through vigorous pursuit of licensing inquiries, on going violations have been identified resulting in enforcement actions without the need for an immediate inspec-tion (inspections are to be scheduled as soon as practical).
The Region is to be commende'd for this effort.
vii. Quality of Effort.
Based on Headquarters review of licensing actions, routine interactions with Region III, and the interviews during the NRP visit, Region III is to be commended on the quality of its licensing reviews.
b.
Fuel Cycle Licensing Because all significant licensing actions in this area are either performed by NMSS or directed by NMSS, fuel cycle facility licensing is an inconsequential part of Region III workload.
The Region has provided input to HMSS in licensing actions.
3.
INSPECTIONS a.
Materials Inspections In FY88 Region III completed 830 inspections and closecuts vs. an operating plan target goal of 743 (118 percent).
Through December 1988 the Region has completed 231 inspections.
This is somewhat below the operating plan target of 323 inspections during this time perfod.
In addition, Region III has a significant number (approxi-mately 170) of overdue inspections 4 egion III was confident, however, R
that the Region woulef incre=ce its effort and reac5 its goalt for inspections in FY89.
There were no apparent problems noted in the technical adequacy, t
accuracy, or quality of inspections or inspection documentation.
Some minor items associated with report quality control (i.e. typos, missing boilerplate wording, etc.) were noted and discussed with
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(e) The development of an Inspector Qualification Journal designed to specifically address the special training and qualification needs of materials inspectors.
dowmodd WUI While the training program for inspecti personnel is -c;l ~ ;.ou?i.. m,
I a similar program for license reviewers not yet er!-t.
Though such tvnti.viA a v
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b e t r cm.. (.uattHyt'e4 3 evmal e Asl e.<r+,tt eafIm. praceti,itiatea It is recommended thM. acti b,h t!!Hu}1L. o W.,",% ll(,'ff,", [;g,,,,,, on be in s.cu, jI,M 1
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+a per': m The Region has about five positions that should be designated for training in the area of low level waste and transportation inspection.
Two of these positions are located in the Emergency Preparedness and Effluents Section and they should be given top priority for this training course, if they are assigned to these areas.
5.
REGION III INITIATIVES Region III has recently brought about a significant reduction in its licensing casework backlog.
During a concerted effort over a two week period, for cases having some combinations of involving:
they could be done quickly, there is a good inspection history, the application is unchanged, the licensee is a known commodity, no significant policy changes; then each license reviewer was assigned to complete 10 licensing actions per week.
For those remaining, reviewers were given goals of completing four (some were given 5) cases to complete each week.
This action lead to a substantial reduction in the backlog.
I I~
b, II 9
l
Region III has made several commendable initiatives in the past year with regard to fuel cycle facilities and previous source material users.
One is the quarterly report on facilities in decommissioning which provides a good status report on these long-term activities.
This provided useful input to an overall NRC listing of contaminated sites.
Another, more recent initiative is the preparation ol' Master Activities Plans for fuel facilities, first furnished NMSS by memorandum of January 12, 1989.
The Master Activities Plan provides a good status summary, an evaluation of the licensee, and proposed dates for inspection with areas of emphasis to be included.
Training of a second fuel facility inspector is also a notable Regional initiative.
i The Region took the initiative to establish an allegations board e V r d t C E to oversee the allegations program.
This has achieved improvement la k ar4 of[IAA^
thoughnottothecompletesatisfactionofmanagementandstpff.
As a sug-gestion for further improvement of this process, 1
II may w o
place responsibility for materials related allegation decisions in DRSS.
The region's ef forts to identify the need for waste classification guidance for activated metals is appreciated.
n The materials inspection staff has recently initiated a weekly meeting of inspectors frem both inspection sections to discuss potential problem areas, 1
issues that have been identified, and areas of inconsistency.
This effort continued as a valuable means for increasing communication among the inspectors.
As a further enhancement, the Regional Section leaders' par-i ticipation would increase the flow of information between management and
'I staff, an.d would provide an opportunity for management guidance on interpretation and resolution of emerging issues, and results of monthly conference calls with NHSS. Sea kO**) (#lV' in /,'etsi; ffaw. ft) in tune f,*J ni}/ Z w'fA 5isf f Ad iYs rtJVIt) Att f fol i^fotnAf,*9~
6.
H0/ REGIONAL INTERACTION Interaction between Headquarters and Region III counterparts has been extensive and considered excellent.
Region III st3ff suggested that NMSS issue additional guidance on the use of the medical questionnaire once OMB clearance is obtained.
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