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i MA'i C 6 1980 MEMORAhDUM FOR:
John M. Montgomery, Deputy Regional Administrator, Region IV FROM:
Carl J. Paperiello, Acting Deputy Director Office of Nuclear Material Safety ana Safeguards
SUBJECT:
DRAFT NMSS NATIONAL PROGRAM REVIEW REPORT The NMSS National Program Review report is enclosed in draft form for Regional comment.
The report provides the results of the Office.of Nuclear Material Safety and Safeguards' review of 1988 programs under the Headquarters' responsibility as related to your Region. The Headquarters' teams participating-in the review were compriseo of individuals from each of the four elements of NMSS that art involved in Regional activities.
The National Program Review Manual dated Deceruber 11, 1987, was the basis for the review. The National Program Review is basec rict 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 and Regional responses to an NMSS questiornaire.
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 comments 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 comments, 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:
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J REPORT OF NMSS 1989 NATIONAL PROGRAM REVIEW AT NRC REGION IV, ARLINGTON AND DENVER, FEBRUARY 27-MARCH 3, 1989 1.
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Materials Safety and 1
Safeguards review of 1988 programs under the headquarters responsibility of NMSS as related to Region IV (Arlington and Denver) and under the responsibility of NRC Region IV.
The Headquarters Team participating in this review was com-prised 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 IV Division of Radiation Safety and Safeguards (DRSS).
The DRSS Division organi-zation chart is shown on Attachment 2.
The National Program Review Manual dated December 11, 1987 was the basis for the review.
Region IV responses to 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 casewerk and inspection statistics, resource utilization, j
technical assistance and coordination, and the questionnaire. The review is intended to provide a review of effectiveness of both the region and headquarters activities insofar as they relate to Region IV activities and to identify sug-gestions for improving the effectiveness of the joint efforts of NMSS and Region IV.
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.
1 The report is organized so as to present an integrated summary in each of the following area i
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Background and Purpose 2.
Licensing 3.
Inspections 4
Training 5.
Initiatives 6.
Interfaces of Region /NMSS 7.
Resource Ut4 ization 8.
Recommendations / Suggestions f
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LICENSING a.
Materials Safety The Region completed 560 license reviews in FY88, compared to its Operating Plan goal of 549.
This represents 102% of the goal.
For the first 5 months of FY89, 270 licensing cases have been completed compared to a goal of 212.
As of March 1, 1989 there were 117 total cases pending.
The general trend since the last program review is a reduction in total pending casework.
The region has recently hired a new licensing reviewer in the medical area and replaced their licensing assistant. These new individuals have greatly improved the section's ability to complete casework in a timely manner.
In addition, the regions has implemented a policy of cross-training licensing reviewers and inspectors. This should greatly improve flexibility and efficiency in the materials area.
It is already having a positive effect on interaction and communication.
The Headquarters staff reviewed a fraction of completed material licensing actions prior to the visit. The licensing actions are generally in accordance with standard review plans and other guidance documents.
Headquarters staff notes that frequently regional reviewers will contact Headquarters technical staff to obtain guidance on technical issues. This greatly reduces the time required to formally respond to technical assistance requests.
Regional technical assistance requests have been timely and appropriate.
The Region has aggressively pursued licensing procedures to increase the efficiency of licensing procedures.
Examplesinclude(1) pre-screening licenses due for renewal and use of special instructions in the expiration notices to require some applicants to submit complete renewal applications, (2) improved feedback between licensing and inspection personnel, and (3) more tutorial communication between licensing personnel and applicants.
These are improvements over the 1988 program review findings.
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i b.
Uranium Recovery The Uranium Recovery Field Office (URF0) completed 128 licensing cases compared to 93 budgeted for FY88. This exceeded the budgeted amount by 40 percent.
During the first five months of FY89, URF0 completed 51 licensing cases, compared to the budgeted amount of 75 cases for the entire fiscal year. At this rate URF0 will again exceed the budgeted casework for FY89.
In addition, URF0 reviewed 128 monitoring reports submitted by licensees in FY88, which exceeded budgeted amounts by 35%. URF0 has completed 51 FY89 report reviews through February 1989, which is on schedule for the fiscal year.
The licensing work was reviewed by Headquarters on an ongoing basis, and no significant issues were identified during the review period. The work has been done in accordance with written guidance from Headquarters.
3.
INSPECTIONS a.
Materials Inspections In FY88, 407 materials safety inspections were completed, which exceeded the goal of 383. Through February 1989, 118 inspections were com-pleted, compared to a projected goal of 145. The cause of the current short fall is loss of staff.
Currently, the Region has 2 fully qualified inspectors,1 inspector who has been with the Region for a year, 2 new inspectors, and 1 vacancy. All of the staff is working overtime, which could cause a morale problem, particularly if it continues for an extended period. At the staff level, the region recently requested a reduction in its materials inspection goal commensurate with.5 FTE of labor.
NMSS responded that such an adjustment seemed warranted and asked the region to submit a formal Operating Plan change request from the Administrator j
to the NMSS Director.
Headquarters review of about 60 inspection letters indicated no problems with the quality and documentation of inspections.
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4 Overall, internal communications in the Region appears to be excellent.
The inspectors seemed well informed of Regional goals and generic issues such as implementation of performance evaluation factors and enhanced medical inspections, j
i The Region has not completed any offshore inspections, but plans to complete some by the end of FY89.
Region IV makes good use of telephone calls to supplement inspections, and several calls have led directly to identifying cases significant of non-compliance.
b.
Uranium Recovery Inspections The URF0 completed 37 uranium recovery inspections in FY88, 6% more than the budgeted number of 35.
For FY89 URF0 has completed 7 inspections through February and has proposed a schedule to accomplish the budgeted number of 35 inspections by the end of FY89.
The quality of the inspection reports is very good. A minor comment was raised on consistency in the cover letters for inspections. This was discussed with management and the lead inspector. They agreed with the comment and will resolve it by discussion with the URF0 staff, c.
Fuel Cycle Inspections As an aid in balancing workload and to utilize available resources more efficiently, the Region IV Administrator transferred the inspection function for the Sequoyah Fuels Corporation (SFC) facility (the single fuel cycle facility under the Region's purview, excluding uranium recovery operations) to the Uranium Recovery Field Office (URF0) in the third quarter of FY88. URF0 staff experience brought added strengths to the SFC inspection program (e.g., environmental aspects), but assigned URF0 staff necessarily have yet to gain in-depth familiarity with plant processes and operations.
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This short-term disadvantage of the transfer should be overcome in large measure through conduct of the required team safety assessment in FY89.
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With the completion of enforcement action stemming from the SFC t dent in 1986, and the continued satisf actory performance of the licensee, the level of effort expended on the SFC inspection program was reduced to 0.5 FTE in FY88 (FY88 budget, 0.9 FTE).
All inspection modules were completed and the inspection reports have been technically sound and timely.
On review of the FY88 inspection program and the results achieved, the Region and NMSS management concluded that about 0.5 FTE (or about 300 direct inspection hours) appears appropriate and adequate for the annual routine inspection program.
However, additional effort will be required in FY89 to complete the scheduled team safety assessment.
NMS$ licensing staf f members have accompanied and assisted inspectors on several site visits made over the last year.
Continuation of these accompaniments is considered desirable by both NMS$ and the Region.
Available NMS$ staffing did not permit work on revision of inspection modules for UFe plants to reflect experience over the last two years, as was suggested last year.
With the filling of a key position, NMSS will initiate the work in FY89 and will seek substantive input from Region IV and Region III.
d.
Transportation Safety Inspections Based on the on going HQ review of inspection reports, they continue to be of excellent quality.
Transportation activities were inspected at all operating units at least once in FY88 except for River Bend, FSV (SALP-1) and South Texas-1 (Done in pre-op phase).
During the 407 materials inspections in FY88, transportation module 86740 was covered 184 times.
P Section Chiefs were noted to have accompanied their inspectors at least once during FY88.
HQ did not accompany RIV inspectors during FY88, although the HQ Sr. Transportation Specialist did accompany 3 URF0 inspectors during an inspection of a mill.
Field note formats used in materials inspections are consistent with MC 87100.
Completed field notes for 12 materials inspections were reviewed and found to be thorough and complete.
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e In the materials program 61 violations were noted during the 184 inspections which covered transportation module 86740.
This is a signifi-cant increase over the 29 non-escalated citations in FYB7.
Three cases were processed leading to escalated actions. Two cases were processed for NOV's to Part 50 licensees involving transportation violations of LLW shipments to the Beatty, NV site.
All inspectors appeared to be aware of and had copies of the recently revised 10 CFR Part 2 Enforcement Policy, and were aware of the revisions therein to Supplement V (Transportation),
e.
Low Level Waste Inspections Region IV has only 10-15 material licensees that generate low-level wastes which are shipped to a site subject to 10 CFR Part 61 requirements. Region IV has excellent field notes which cover the elements of the waste generator inspection module (84850). The materials inspection field note and reports reviewed showed that the inspectors are adequately covering this area; however, the inspectors do not appear to be crediting the time to the waste generator inspection module (84850).
The Region IV low-Level waste generator inspection program for the power reactors covered 6 of 9 operating plants. One of the other reactors was SALP 1, one was in startup, and the third (River Bend) was not inspected. The inspection reports were of excellent quality and completed in a timely manner.
As part of the National Program Review, the HMSS reviewer evaluated the core inspection modules (83750/84750) and concluded that they should be revised to more adequately reflect HMSS waste generator inspection guidance provided in inspection modules (84722/84850).
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4 The discussions with the reactor inspection management indicated that the Region agreed that the core modules did not fully cover waste generator requirements at reactors. NMSS has previously provided comments to NRR on revising the core inspection modules.
NMSS and NRR with input from the Regions, need to continue to work toward resolving this issue.
The Reactor Programs Branch intends to continue performing, as initiatives, the basic / supplemental modules (84722/84850) in addition to the core modules at all operating power reactors.
4.
TRAINING Two new materials inspectors and a 1 new license reviewer are in the early stages of training. The training is progressing well, and they are being cross-trained both in inspection and licensing, which is commendable.
Several people expressed concern that the additional training requirements in the revised IMC 1245 are too ambitious, and that some of the courses are not available.
Headquarters will review this issue.
The URF0 staff have benefited from an aggressive training program to increase the number of qualified inspectors.
All inspectors assigned to inspect transportation in the FRPS have received transportationtraining(courseH-308). Two new materials inspectors (M. Vasquez and L. Kasner) plus one new licensing person (V. Campbell) need to be provided with the training.
Additionally, the Nuclear Materials Inspection Section Chief (D. Powers) has not yet taken this course.
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The reactor inspectors suggested that a refresher course on low-level waste issues and waste classification, packaging, and waste forms would be useful and timely. Nost of the inspectors have had no formal training in this area since the transportation class. The materials inspectors suggested that limited training for Class A wastes would be useful also.
5.
REGION IV INITIATIVES The Region has several initiatives of note in the materials licensing and inspection area to improve safety and efficiency, such as:
Implementationoftheperformanceevaluationfactor(PEF) program.
The effort to upgrade licenses through better and more frequent commur>ica tion.
The effort to better identify applicants that should be denied licenses, based on lack of qualifications and commitment to follow regulations.
The amendment of licenses by complete revisions.
Telephone questionnaire screening as a supplement to inspections.
Efforts to find missing licensees.
Several proposals to improve the agency processes for dealing with difficult enforcement issues, such as character and financial capability.
Workshops with licensee groups.
URF0 staff negotiated an MOU with EPA Region VI on the responsibilities of the respective agencies at the UNC Churchrock uranium mill.
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URF0 and LLWM developement of a management position on interpreting requirements on erosion protection.
URF0 and LLWM,oint sponsoring of a workshop on alternate concentration limits as one option for meeting the uranium milling groundwater standards in 10 CFR Part 40.
The FRPS is planning to perform the supplemental transportation module 86740 at each operating reactor in FY88 as a supplement to Core Inspector Procedure 83750. This initiative is apparently in response to their general feeling that the degree of coverage of transportation offered by 83750 is generally insufficient. The Region has done an excellent job in preparing new field notes for the low-level waste core inspection program.
The Chief, Nuclear Materials Licensing Section, has taken an initiative to editorially update an old information notice No. 82-47, "Transpor-tation of Non-Fissile Radioactive Material in Type A Packaging." This notice is being mailed to all new licensees as a means of informing them of applicable transportation regulations, and hopefully averting future violations which arise due to ignorance of the regulations by new licensees.
The Region is commended for its efforts to contribute to improved agency processes to ensure sound regulatory decisions.
6.
HQ/ REGIONAL INTERACTION Interaction between the Regional and Headquarters staffs has been excellent.
URF0 and NMSS staff interact and coordinate on a regular basis.
URF0/HQ staff are planning a workshop in June 1989 on erosion protection. The interaction between the offices has been very good and has been improving.
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RESOURCE UTILIZATID[
Thc Table er page 14 shows FlE allocations and expenditures for the review period.
Ir. FY88, expenditure f or materials licensing, niaterials inspection, and fuel feciiity inspection closely approximated the budget allocation.
Although 0.06 FTE were budgeted for safeguards licensing and inspection, nor.e were exper.ded during FY88 or the first quarter of FY89.
Preliminary data for the first quarter of FYS9 shows a rate of twice the FTE being expended for materials licensing than budgeted (0.86 vs. 0.43) while 40% fewer FTE were being expenaec for materials inspections than were budgeted (1.03 vs. 1.72).
Overtiet expended en rateriait licensing in FY88 was 0.4 FTE and for materials inspections was 0.3 fil.
Initicib, the FY88 data indicated that URF0 had expended 2.3 fewer FTE (201) than budgeted in FY88 for uranium recovery activities (8.9 vs.11.2).
However, upor, closer examination of the RIV records, another 1.1 FTE were discovered which had not been included (0.3 overtime and 0.8 licensing assistant) which increases the FY88 FTE expended to 10.0, 9% fewer than budgeted. The first quarter FY89 URF0 FlE expended were slightly low, but understandable in view of the recent holidays and current vacancies.
URF0 has two recent vacancies, one Branch Chief and one Project Manager, which reduces the URF0 staff to 15, 10 direct staff and 5 overhead.
The URF0 Directnr and branch Chiefs are not currently recording their time to RITS direct licensing activities.
As was noted by hMSS last year, they should be allowed to do this to more accurately depict the time expended on licensing activities for planning budget estimates.
RIV should include overtime in the FTE expenditure numbers in the Operating Plan report.
The Region IV DRMA staff agreed with these two recommendations.
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4 URF0 currently has two technical assistance contracts, one of which will be completed the end of April 1989.
The $100K of FY 89 funds had not yet been obligated but will be in March 1989 to ORNL for assistance in analyzing inspection samples.
RIV's staffing plan lines up closely with the budget, but a vacancy does exist in materials inspections. The staffing situation at URF0, is the budget assigned 12.3 direct FTE of work in FY89, but URF0 only has 11.0 direct staff in its current staffing plan and 10 direct staff on board.
RIV has recently acquired two very promising licensing and inspection staff with medical backgrounds which should put the region in a good position to accomplish the NRC mission in the medical area.
8.
RECOMMENDATIONS Closely monitor materials inspection completions, training and overtine, to see whether goals are being met and overtime is being reduced.
Complete offshore inspections in accordance with the Inspection Manual.
The use of computers in the licensing section has greatly improved efficiency and work of the staff.
New personnel should be assigned the use of computers as soon as possible.
1 The cross-training of licensing and inspection personnel has improved communication between sections. This should be expanded to include senior personnel.
NMSS, with input from the Regions, needs to resolve with NRR comments on the LLW generator inspection program for reactors in the core inpsection modules (83750/84750).
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The Region requested additional training as a refresher course on J
low-level waste issues and waste classification packaging and waste forms for reactor inspectors and some additional limited training for materials inspections.
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FTE AND PROGRAM SUPPORT FUNDS UTILIZATION REGION IV -1989 The following table shows FTE allocations and expenditure for the review period FY89 FY88 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT-DEC.-0CT-DEC.
Materials Licensing
- 2. 6 3.0 115
- 1. 7 0.4 0.9 225 Materials Inspection
- 5. 2 4.8 92 6.9
- 1. 7 1.0 59 Fuel Facility Insp.
- 0. 9 0.5 56
- 0. 9
- 0. 2 0
0 Event Evaluation 0
0 0
0.5 0.1 0
0' SG Fuel Facility Lic.
0.02 0
0 0.02 0
0 0
SG Fuel Facility Insp.
0 0
0 0
0 0
0 4
SG Transportation Insp.
0.04 0
0 0.04 0.01 0
0 i
LLW Inspection 0.15 0.04 4
Reactor Oecommissioning 0
0 0
0.1 0.03 0
0 i
Materials Facility Decom.
0 0
0 0.1 0.03 0
0 Uranium Recovery Lic.
9.3 6.7 72 7.5 1.9 1.7 89 UMTRAP 0
- 1. 8
- 2. 0 0.5
- 0. 3 60 Uranium Recovery Insp.
- 1. 9 1.5 79
- 1. 9 0.4 0.2 50 NMSS Section Supervision
- 0. 7
- 1. 3
- 0. 3 NOTES-1)
FY88 expenditures from Region IV FY88 Year-End Operating Plan.
2)
FY89 expenditures from Region IV FY89 Operating Plan (as of 12/31/88).
LLW inspection resources are included in materials, fuel facility, uranium recovery and transportation inspections.
- Section supervision expenditures included in Nuclear Material Safety activities above.
The following table shows program support funds allocations and obligations for the review period.
FY88 FY89 PROGRAM ACTIVITY BUDGET OBLIGATED %
8UDGET OBLIGATED %
Uranium Rec. Lic.
100 100 100 100 0
0 NOTE:
FY89 funds obligation as of 2/28/89 14
1989 Region IV Program Review - Team Members Arlington and Denver - February 27 - March 3,1989 Glen Sjoblem, Division of Industrial and Medical Nuclear Safety, Team Leader Donald Loosley, Program Management, Policy Development and Analysis Staff Leland Rouse, Division of Industrial and Medical Nuclear Safety j
Michael Lamastra, Division of Industrial and Medical Nuclear Safety Al Grella. Division of Safeguards and Transportation Dennis sollenberger, Division of Low Level Waste Management and Decommissioning John Mickey, Division of Industrial and Medical Nuclear Safety Robert Brown, Region II Myron Fliegel, Division of Low Level Waste Management and Decommissioning l
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U P Af 1!U M PECOvfHi F IE t D OfFem R s.Cliard 1 Ilo n go r 1 Ilir et ior Rornon [: l lall. Depu t y thrector R. Dole Smit h.
Director Carof A.
Dube. S_m.retory NUCLEAR MATERIALS SAFETY ORANCH
.._ _ HEACIOR l'HOGRAMS HPANCil Otoine M urroy. Chie f William L Fi sh e r.
Chief Eugene Hates. E 'r n er g en cy Response Carol Hill. Secretory Coordinator Stacey Rosenberg, Se c r e t ary NUCLEAR MATERIALS INSPECTION SECTION SECURITY Ar4D EMERGENCY NUCLEAR MAT ERI ALS PREPAREDNESS SECTIOr4 FACILITIES RADIOLOGICAL Dole A. Powers. Chief LICENSING SECTION OTECDON SEC MH D ovid B. Spitzberg. Senior R. Jerry Everett. Chief Ronoid E. Bo.r. chi.t Rodiotion Speciofist James K elly. Senior Physical D.on choney, s.nlor F tion Anthony Colnes. Radiation Security Specialist sp.c Specialist Ch arles L Coin. Chief Ronald C ald w ell, Phy sic al Blair Nic h olo s.
5.nior Rs fon Wesley Holley. Radiation Vivion Campbett. Health Physicist Security Speciolis t sp.cic Specialist Jackie Whitten. Health Physicist A. Druce E~o r n e s t. Physical L.orry Ric k.t son. Rodlotion Lorenzo Wilborn. Radiutiori Billie G ru syn s ki. Lic en sing Security Speciolist k
Specialist Assistant Nem en Terc. Ernerg ency Ru se.Il Wise, Radiat on Sp,gon, g
Gerald Vosquez Radiation Preparedness Analyst A
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Using the current version of your regional s+.affing plan related to the NMSS program, specify the approximate percentage of time that each individual spends on the following activities:
fuel cycle licensing, fuel cycle inspection, materials licensing, materials inspection, safeguards activities, and inspections of decommissioned facilities and reactors.
PERCENT OF TIME SPENT ON INDIVIDUAL F.C.
F.C.
MATERIALS MATERIALS SAFEGUARDS DECOM. FACIL.
LICENSING INSPECTION LICENSING INSPECTION INSPECTION Fisher 20 75 5
Cain 95 5
Campbell 80 20 Gruszynski 100 Whitten 95 5
Powers 5
95 Gaines 100 Holley 95 5
Kasner 20 80 Spitzberg 5
90 5
Vasquez 100 Vacancy 100
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Provide a summary of actual expenditures and accomplishments as compared to operating plan / budgeted expe:.ditures and accomplishments, for FY88 and FY89 to date.
Licensing and inspection expenditures and accomplishments during FY88 and the first quarter of FY89 are summarized below and on the following i
pages.
LICENSING Actions Budgeted Hours FY Licensing Actions Completed Goal Hours Expended (Direct Effort) 1988 A.
New Applications 71 60 795 615 B.
Renewals 153 189 2,010 938 C.
Amendments 336 300 795 1,094 Subtotal 560 549 3,600 2,647 D.
Miscellaneous 330 1,287 (LA Direct, Info.
3,930 3,934 Req., ie. Site Visits, etc.)
1989 A.
New Applications 14 188 127 (1st Q) 8.
Renewals 40 338 428 C.
Amendments 106 213 Subtotal 160 W
526 768 0.
Miscellaneous 113 516 (LA Direct, Info.
639 1,284 Rea., Lic. Site Visits, etc.)
INSPECTION Inspections Budgeted Hours FY Materials Inspections Completed Goal Hours Expended 1988 1.
Routine Inspection 2,754 2,086 2.
Reactive Inspection 150 427 Total 405 T
2,904 2,513 1989 1.
Routine Inspection 55 931 503 (1st Q) 2.
' 73 88 969 549 18 38 46 Total
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FifClON IV - TV 1988 OPIRATING PtAN
?3 MISSION AREA:
Natclear Materia l Safety arid Sa regua rels Regisla tion HAJOR PROGRAM:
Fuel Fac413 tles and Nuclear Material Users PLAMNED ACCOMPLISHMENT: Al f iee l facility inspections p) Material inspection D! Tec L. Inspec L inn _ lioners fla se I ine f = pen <teil ry 19an fitJrftlet _
t o f ra t e.
VarIasu;e A.
IMLiscilliy_J nspections (Sequoyah Iueas) 6*in 307
( 38 6) 8.
Meterial Inspections 1.
Routine Inspection
?, 7';ta
?.n86 (668) 2.
Reactive letspection
__ ISO _
_ 8:27.
_27(_.
Intet 2.904 2.513 (398)
F Y'e9 nan 5%g (<p1.t /st/st,
RE GIO98 IV - IV 1989 OPfRAflNG PtAN 22 MISSION AREA:
SiteClear Material Safety and Safegeta rris Itegisla t ion MAJOR PftOCRAM:
Nieclear Material Safety PL ANNED ACCOMPt ISitMf MT: Licensing Musclear Materla t avut lual facilities total Total Bactilog Planssed Ac t ea.i t Arttutis P res lec ted Raadgeted Actual Hours I IU/l/Gli R_SC_0 } P L E leuculp ts 4:omp lan t ed Completjppa troisrs mfd (e.d I
I.
L1 1811D1_AC11 PS l
[D rect Erfort A.
New Appilcations 750 12F 8
RenewnIs I,350 1:24 C.
Amendeentt*
213
{
Sa4totst 2, If u e 164 i
D.
Mi sce llanooses 1
(LA Direct. Info. Reg..
8tML._,,
. _ _5] L.
l Lle. Site Vlafts, etc.)
2,550 1,284 I
s incleades terminations l
= ~ _
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14tGION IV - fY 1989 OPERA 7 t NG PLAN pj*
MISSICII AREA:
pasclear Material Safety and Sa regina rds ftegislation seAJOR PROGftApt:
Fuel Facilities and Nuclear Material Users PL AftetE D ACCOMPL I SHME N T : A) Tesel facility leispec t iotas it ) Ma te r i a l inspection C) Event Evaluation Dltect_inspectionlioim tin ser I i ne Imeetided Hilgel__
to Date_
d 1
A.
W acillL d RSet9tlens t Seageseysh rseeIs) 599 0
8 Statoria l Insoectlelig 1.
Routine inspection
-3.725 503 2.
_l'r0 46_
i total 3.875 549 i
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C.
Event [velteetion 2 848 e
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s 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 Msaus) Chapters 2600 and 2800?
No changes appear to be needed in the FY89 licensing workload projection.
However, minor changes could be necessary if certain training opportunities arise for the medical license reviewer.
The mutual cross-training of the medical license reviewer and the medical inspector also could affect the licensing workload projection.
Some change may be needed in the FY89 inspection workload projection.
Major causes are the recent loss of an experienced inspector (not yet replaced), and the recent hiring of two inexperienced inspectors.
Of the latter two inspectors, one replaced the 1988 loss of an experienced inspector; the other is a new medical inspector, who is being cross-trained with the medical license reviewer.
We see no barriers to completing Manual Chapter 2800 inspection modules.
However, we have not yet made good progress in setting up an offshore inspection program.
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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.
Regarding materials licensing, regional administrative support functions generally have been timely.
However, licensing efficiency will irorove when a computer is obtained for the medical license reviewer.
Regarding materials inspection, regional administrative support functions could be improved in four respects.
First, inspector folders could be kept more up-to-date.
Second, inspector folders could be mailed to URF0 more timely.
Third, 766 and LMS special printouts could be provided more promptly.
Fourth, the recruitment process has been slow.
On the other hand, travel support has been excellent, as has been the DRMA assistance in telephoning gauge and well-logging licensees.
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5.
Please provide your comments on the programs for interaction of Headquarters with your Region.
Please include your comments on the usefulness of the conference calls, licensing workshops, executive management seminars, 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 recommendations for modifications, changes, improvements, etc., in the interacting programs.
Interaction between Region IV DRSS and NHSS has been very good.
The NMSS staff has been responsive to Regional requests.
Monthly conference calls generally are useful in learning of other Regions' experiences and of NMSS guidance.
However, NMSS should speed the discussions along in order to conserve manpower.
HMSS sponsored workshops, such as the recent one in Atlanta, are excellent.
Management meetings, such as the recent meeting in Region IV and the November 1988 meeting in Region II, also are excellent.
- However, there is considerable redundancy, which might be avoided by going to an alternate year schedule.
Region IV strongly advocates inspection accompaniments to strengthen both the NMSS and Regional staffs and to improve rapport between them.
Region IV generally finds NMSS technical assistance to be obtained easily and to be beneficial.
One significant exception, however, has been the inconstant direction provided by NHSS regarding the V. A. Nuclear Network.
The HMSS Newsletter, to which Region IV is a fairly active contributor, is an excellent publication as attested to by licensee and NRC personnel.
However, the Regions should be provided enough copies for all DRSS personnel.
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6.
Summarize regional initiatives to improve the quality of inspections and license reviews, particuiarly those cimed toward preventing licensee safety problems, or those aimed at licensee's performing their transportation activities in a safe manner.
Region IV has been and will continue to be a strong proponent of initiatives to strengthen its materials licensing and inspection programs.
Initiatives pursued during this program review period include:
1.
Licensing efforts to upgrade licensees, to simplify inspection, and to reduce enforcement action.
Use of special instructions in the Notice of Expiration a.
requiring certain applicants to submit a complete renewal application.
(Initiated) b.
Evaluation of applicants' character and competence through written correspondence (including revisions to NRC Form 313) and through prelicensing visits.
(The Form 313 revision is being pursued by HMSS.
The visits have been initiated.)
Improved feedback between licensing and inspection personnel.
c.
(Initiated) d.
More tutorial communication between licensing personnel and licensee / applicant.
(Initiated) 2.
Investigating bases for license denial.
(Referred to NMSS, but Region IV has denied licenses in some cases.)
3.
Identification of wrongdoers.
(Referred to NMSS) 4.
Generating interest in the forthcoming impact of the decommissioning rule.
(Initiated) 5.
Ensuring that well-logging applicants are aware of the potential cost of americium source disposal.
(Initiated case by case) 6.
Providing DOT Type A packaging guidance to certain applicants.
(Initiated) 7.
Admonishing applicants to provide accurate information.
(Under review by Region IV counsel)
F 7.
Summarize the total number of inspections of Transportation activities at MC 2800 licensed program facilities (Procedure 86740) including average staf f-hours per inspection and a brief summary of the most typically observed violations.
During approximately the calendar year 1988, Region IV and URF0 inspected materials licensees against Procedure 86740 on 184 occasions.
Approximately 1.3 staff-hours, average, were devoted to inspecting against this procedure.
The 184 inspections identified 61 violations, as summarized below.
REQUIREMENT VIOLATIONS 49 CFR 172.200 (Shipping Papers) 22 172.203 (Shipping Pu..:'rs) 3 173.415(a) (Type A Pu:kages) 16 173.476(a) (Special Form Approvals) 12 Others 8
61
~
"In three cases, the transportation violations found contributed to an escalated enforcement NOV.
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t 8.
Recommending (to NMSS) ways to increase the efficiency of processing license renewals.
(See February 23, 1989, memo from R. D. Martin to R. M. Bernero.)
Revise licenses in conjunction with inspections.
a.
b.
Vary the license term inversely with inspection interval.
Increase terms of all licenses to 6 years.
c.
d.
Use standard procedures.
9.
Amending licenses in entirety, rather than page by page.
(Initiated) 10.
Gauge user telephone questionnaires.
(Initiated) 11.
Well logger written questionnaires.
(Sent experimentally to nine licensees.
Region IV will ask NMSS to obtain OMB approval for further use.)
12.
Performance evaluation factors.
(Initiated, but not really a Region IV initiative.)
13.
Pursuit of missing licensees.
(Initiated, except for use of contracted " skip tracers.")
14.
Technical assistance request regarding disposal of americium well-logging sources.
(See February 15, 1898, memo form R. D. Martin to R. M. Bernero.)
15.
Brief telephone calls to well loggers.
(Completed. Also contemplated for other types of licensees.)
16.
Well logger and radiographer workshop in Tulsa.
(Completed.
Also planning a medical workshop, probably in Oklahoma City.)