ML20057A327
| ML20057A327 | |
| Person / Time | |
|---|---|
| Issue date: | 05/18/1989 |
| From: | Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309140020 | |
| Download: ML20057A327 (2) | |
Text
.
s M 101389 MEMORANDUM FOR:
Carl J. Paperiello, Acting Deputy Director Office of Nuclear Material Safety and Safeguards FROM:
John M. Montgomery, Deputy Regional Administrator
SUBJECT:
DRAFT NMSS NATIONAL PRDGRAM REVIEW REPORT As requested in your memorandum to me, same subject, dated May 6, 1989, we have reviewed your draft report. We have provided our comments in the form of a marked-up copy of the draft, as you requested.
We appreciate the positive tone of the draft assessment report, and wish to express our appreciation to the assessment team for their thoroughness and professionalism.
ORIGinSIE#
3,g, M0mG0gERY John M. Montgomery Deputy Regional Administrator
Enclosure:
As stated bec:
R. D. Martin J. M. Montgomery A. B. Beach i
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- w. s MEMORANDUM FOR: John M. Montgomery, Deputy Regional Administrator, Region IV FROM:
Carl J. Paperiello, Acting Deputy Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
DRAFT NMSS NATIONAL PROGRAM REVIEW REPORT The HMSS National Program Review report is enclosed in draft form for Regional coment. The report provides the results of the Office of Nuclear Naterial Safety and Safeguarcs' review of 1988 programs under the Headquarters' The Headquarters' teams participating responsibility as related to your Region.
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 11 1987, was the basis.for the review, The National Program dated December 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 ca u. work, inspection reports, accompaniment of Regional inspectors, review of
- ,sework, and inspection statistics, technical assistance and coordination, and i
coordination and Regionel responses to an NHSS questionnaire.
J 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 towaros 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 j
a marked-up copy, as appropriate. Please provide Regional response by May 23, e
1989. Following incorporation of Regional coments, the final report will be j
r transmitted to the Regions by the NMSS Director.
c x, f. Cf'twh Carl J. P periello,-Acting Deputy Directcr Office of Nuclear Material Safety and SafeDuaros
Enclosure:
As stated h
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REPORT OF NMSS 1989 NATIONAL PROGRAM REVIEW AT NRC RECION IV, ARLINGTON AND DENVER, FEBRUARY 27-MARCH 3, 1989 f
1.
BACXGROUND 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 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 casework and inspection statistics, resource utilization, 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.
The report is organized so as to present an integrated summary in each of the following areas:
1 FROM NRC RIU ARL.TX.
05/30/89 10:03 P.
d -
4 1.
Background and Purpose 2.
Licensing 3.
Inspections 4.
Training 5.
Initiatives 6.
Interfaces of Region /NMSS 7.
Resource Utilization 8.
Recommendations / Suggestions l
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i FROM NRC RIU ARL.TX.
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2.
LICENSING a.
Ma_terials Safety The Region completed 560 license reviews in FY88, compared to its Operating Plan goal of 549. This repr'esents 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 cility, to complete casework in a timely In addition, the regions haf implemented a policy of cross-training manner.
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 1
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 kNYdM.
Examples include (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 comunication between licensing personnel and applicants.
These are improvements over the 1988 program review findings.
3 FROM NRC RIV ARL.TX.
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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
- gek inspectors,1 inspector who has been with the Region for a year, 2 new d-inspectors, and 1 vacancy. All of the staff is working overtime, which f
w could cause a morale problem, particularly if it continues for an extended 0g-period. At the staff level, the region recently requested a reduction in r g
its materials inspection goal comensurate with.5 FTE of labor. NMSS
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responded that such an adjustment seemed warranted and asked the region to submit a formal Operating Plan change request from the Administrator to the NMSS Director.
Headquarters review of about 60 inspection letters indicated no problems with the quality and documentation of inspections.
4 FROM NRC RIV ARL.TX.
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Overall, internal comunications 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.
The Region has not completed any offsh' ore 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 ignificant of non-compliance, b.
Uranium Recovery inspections The URF0 completed 37 uranium recovery inspections in FY88, 6% more than the budgeted numb'er of 35.
For FY89 URF0 has completed 7 inspections through February and ha.s proposed a schedule to accomplish the budgeted number of 35 inspectia.s by the end of FY89.
The quality of the inspection reports is very good. A minor coment was raised on consistency in the cover letters for inspections. This was discussed with management and the lead inspector. They agreed with the coment 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 (URFO) 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.
This short-term disadvantage of the transfer should be overcome in large measure through conduct of the required team safety assessment in FY89.
5 FROM NRC RIV ARL.TX.
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With the completion of enforcement action stemming from the SFC accident l
in 1986, and the continued satisfactory 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 programj jfowever, additional effort will be required in FY89 to complete the scheduled team safety assessment.
NMSS licensing staff members have accompanied and assisted inspectors on several site visits made over the last year.
Continuation of these accompaniments is considered desirable by both NMSS and the Region.
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y Available NHSS staffing did not permit work on revision of inspection g
modules for UFe plants to reflect experience over the last two years, as was j
T suggested last year.
With the filling of a key position, NHS$ will initiate
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he work in FY89 and will seek substantive input from Region IV and Region III.
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Transportation Safety Inspections
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Based on the on-going HQ review of inspection reports, they continue to be of excellent quality.
Transportation activities were inspected at all operating i
N a N a's D ee 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.
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Section Chiefs were noted to have accompanied their inspectors at least once during FY88. HQ did not accompany RIV inspectors during FY88, although theHQSr.TransportationSpecialistdid) accompany 3URF0insp u,5/hh-.
inspection of a mill (AM((
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Field note formats used in materials inspections are consistent with MC 07100.
Completed field notes for 12 materials inspections were reviewed and found to be thorough and complete.
6 FROM NRC R1V ARL.TX.
05/30/89 10:06 P.10 et r e; 1 :59 Au ric
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 MaMHQ$($' citations in FY87. 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 j
j 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 J
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 1
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 coreinspectionmodules(83750/84750) and concluded that they should be revised to more adequately reflect HMSS waste _ generator inspection guidance provided i,n inspection modules (84722/84850).
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7 FROM NRC RIU ARL.TX.
05/30/89 10:07 P.11 00 3e e9 10:Se AM Pl:
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. NH55 has previously provided comments to NRR on revising the core inspection modules. HMSS and HRR with input from the Regions, need to continue to work toward resolving this issue. Thedeft"V Reactor Programs Branch intends to con'tinue 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 i
transportationtraining(courseH-308). Two new materials inspectors j
(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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05/30/89 10:07 P.12 05 rn :::59 Au P: 2
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. Most 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 ifcensing and inspection area to improve safety and efficiency, such as:
Implementation of the performance evaluation factor (PEF) program.
The effort to upgrade licenses through better and more frequent comunication.
The effort to better identify applicants that should be denied licenses, based on lack of qualifications and comitment to follow regulations.
The amendtnent of licenses by complete revisions, i
Telephone questionnaire screening as a supplement to inspections.
Efforts to find missing licensees.
l Several proposals to improve the agency processes for dealing with i
difficult enforcement issues, such as character and financial capability.
Workshops with licensee groups, URF0 staff negotiated an HOU with EPA Region VI on the responsibilities of the respective agencies at the UNC Churchrock uranium mill.
i FROM NRC RIV ARL.TX.
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e URF0 and LLWM developement of a management position on interpreting requirements on erosion protection.
URF0 and LLWM joint 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 insuf.'icient.
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 the:n 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 INT'RACTION d
Interaction between the Regional and Headquarters staffs has been excellent.
URF0 and NHSS 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 improvina.
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05/30/09 10:08 P.14
- 05. 30. 89 10:59 AM P14
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7.
RESOURCE UTILIZATION
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The Table en page 14 shows FTE allocations and expenditures for the review period.
In FY88, expenditure for materials licensing, niaterials inspection, and fuel facility inspection closely approximated the budget allocation.
t Although 0.06 FTE were budgeted for safeguards licensing and inspection, none were expended during FY88 or the first quarter of FY89. Preliminary data for the first quarter of FY89 shows a rate of twice the FTE being expended for j
materials licensing than budgeted (0.86 vs. 0.43) while 40% fewer FTE were being expenced for materials inspections than were budgeted (1.03 vs.1.72).
Overtime expended on materials licensing in FY88 was 0.4 FTE and for materials inspections was 0.3 FTE.
Initially, the FY88 data indicated that URF0 had expended 2.3 fewer FTE (20%) than budgeted in FY88 for uranium recovery activities (8.9 vs.11.2).
\\
However, upon closer examination of the RIV records, another 1.1 FTE were discovered which had not been included (0.3 overtirne and 0.8 licensing assistant) which increases the FY88 FTE expended to 10.0, 9% fewer than budgeted. The first quarter FY89 URF0 FTE expended were slightly low, but understandable in i
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 Director and Branch Chiefs are not currently recording their time to RITS direct licensing activities. As was noted by liHS$ last year, they should be allowed to do this to inore accurately depict the time expended on licensing activities for planning budget estimates. RIY should include overtime in the FTE expenditure numbers in the Operating Plan report. The Region IV DRMA staff agreed with these two recomnendations.
11 FROM NRC RIV ARL.TX.
05/30/89 10:09 P.15 05,3C 89 10: 59 AM Pl*
i URF0 currently has two technical assistance contracts, one of which will be completed the end of April 1989.
The $100X of FY 89 funds had not yet been obligated but will be in March 1989 to ORNL for assistance in analyzing inspection samples.
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RIV's staffing plan lines up closely with the budget, but a va ncy does exit,t in materials inspections. The staffing situation at URF0, s the budget b
assigned 12.3 direct FTE of work in fY89, but URF0 only has 11.0 direct staff g
in its current staffing plan and 10 d'.: rect staff on board.
RIV has recently acquired two very promising licensing and inspection staff with medical backgrounds which shsuld put the region in a good position to accomplish the NRC mission in the melical area.
8.
RECOMMENDATIONS C
poselymonitormaterialsinspectioncompletions,trainingandovertime, 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 pes 3Lic.
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- b +3d The cross-training of licensing and inspection personnel has improved comunication between sections. This should be expanded to include senior personnel.
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5 m HMSS, with input from the Regions, needs to resolve h NRR comments on
' the LLW generator inspection program for reactors in the core inpsection modules
((83750/84750)'
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9 12 FROM NRC FIV ARL.TX.
05/30/89 10:10 P.16 CS.30 99 10:56 AM P:6
The Region requested additional training as a refresher course on e
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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13 FROM NRC RIV ARL.TX.
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-P.17 TOTAL P.17 05.30.89 10:59 AM Pl?
9 FTE AND PROGRAM 3UPPORT FUNDS UTILIZATION REGION IV -1989 The following table shows FTE allocations and expenditure for the review period FY89 FY88 ANNUAL 8UDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT-DEC. OCT-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 SG Transportation Insp.
0.04 0
0 0.04 0.01 0
0 LLW Inspection 0.15 0.04 Reactor Decommissioning 0
0 0
0.1 0.03 0
0 Materials facility Oecom.
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 JV FY88 Year-End Operating Plan.
2)
FY89 expenditures from Region IV FY89 Operating Plan (as of 12/31/88).
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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.
FYB8 FY89 PROGRAM ACTIVITY BUDGET CBLIGATED %
BUDGET OBLIGATED %
Uranium Rec. Lic.
100 100 100 103 0
0 NOTE:
FY89 funds obligation as of 2/28/89 l
14 FROM NRC RIU ARL.TX.
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