ML20057A328
| ML20057A328 | |
| Person / Time | |
|---|---|
| Issue date: | 08/04/1989 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309140021 | |
| Download: ML20057A328 (27) | |
Text
4 AUG 5 8 9 99 MEMORANDUM FOR: Robert D. Martin Regional Administrator, Region IV FROM:
Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
FINAL REGION IV NATIONAL PROGRAM REVIEW REPORT Dy memorandum dated May 6,1989, from Carl J. Paperiello, then Acting Deputy Lirector, NMSS, the NMSS National Program Review (NPR) draft report, covering FY 1989 for Region IV was transmitted to your office for comments. Region IV comments were transmitted back to Headquarters by memorandum from John M.
Montgomery, dated May 18, 1989, and have been incorporated in the report.
The final NPR report is enclosed for Region IV information. Since the NMSS team approach was effective during this year's visit to the Regions, NHSS plans to continue this approach next year.
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/w Robert M. Bernero, Director Office of Nuclear Material Safety
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9309140021 930830 PDR STPRC ESGGEr f-
s' REPORT OF NMSS 1989 NATIONAL PROGRAM REVIEW AT NRC REGION IV, ARLINGTON AND DENVER, FEBRUARY 27-MARCH 3, 1989 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 HMSS as related to Region IV (Arlington and Denver) and under the responsibility of NRC Region IV. 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 NHSS 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 Organization 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 on Attachment 3.
The NPR is based not only on the visit to the Region, but on the collective regional / headquarters interfaces throughout the year, thorough 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 suggestions 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 l
the following areas:
l l
l 1
Q 1.
Background and Purpose 2.
Licensing 3.
Inspections 4
Training 5.
Initiatives 6.
Interfaces of Region /NMSS 7.
Resource Utilization 8.
Recommendations / Suggestions 2.
LICENSING a.
Materials Safety The Region completea 560 license reviews in FY88, compared to its Operating Plan goal of 549. This represents 102 percent of the goal. For the first five 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 In addition, the Region has 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 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 i
2
greatly reduces the time required to formally respond to technical l
assistance requests. Regional technical assistance requests have been timely and appropriate.
l The Region has aggressively pursued licensing procedures to increase the efficiency of licensing activities.
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 communication between licensing personnel and applicants.
These are improvements over the 1988 program review findings.
b.
Uranium Recovery The Uranium Recovery Field Office (URFO) 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 percent.
URF0 has completed 51 FY89 report reviews through February 1989, which is on schedule for the FY.
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 3
In FY88, 407 materials safety inspections were completed, which exceeded the goal of 383.
Through February 1989, 118 inspections were completed, compared to a projected goal of 145.
The cause of the current short fall is loss of staff.
Currently, the Region has two fully qualified inspectors, one inspector who has been with the Region for a year, two new inspectors, and one vacancy.
At the time of the NPR all of the staff were working overtime, which could have caused a morale problem, but this practice has since j
been terminated.
The Region recently requested a reduction in its materials inspection goal equal to about.5 FTE.
NMSS approved this Operating Plan change request midway through the FY.
Headquarters' review of about 60 inspection letters indicated no problems with the quality and documentation of inspections.
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.
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 significant cases of non-compliance.
i b.
Uranium Recovery Inspections The URF0 completed 37 uranium recovery inspections in FY88, 6 percent more than the budgeted number of 35.
For FY89 URF0 has completed seven 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.
j 4
l y
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. This short-term disadvantage of the transfer should be overcome in large measure through conduct of the required team safety assessment in FY89.
With the completion of enforcement action stemming from the SFC accident in 1986, and the continued satisfactory performance of the licensee, the level of effort expended on the SFC inspection program will be budgeted at 0.8 FTE in FY90 (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 nours) appears appropriate and adequate for the annual routine inspection program; however, additional effort may be required in FY89 and FY90 for Regional inspection initiatives.
HMSS 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.
The NMSS team informed the Region that available NMSS staffing did not permit work on revision of inspection modules for UF1 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.
5
d.
Transportation Safety inspections Based on the on-going Headquarters review of inspection reports, they continue to be of excellent quality. Transportation activities were inspected at all operating nuclear power stations at least once in FY88 except f or 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.
Section Chiefs had accompanied their inspectors at least once during FY88.
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.
3 In the materials program 61 violations were noted during the 184 inspections which covered transportation module 86740.
This is a significant increase over the 29 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 revised 10 CFR Part 2 Enforce 5ent 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).
6
1 The Region IV low-Level waste generator inspection program for the power reactors covbred six of nine 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.
The discussions with the reactor inspection management indicated that the Region agreed that the core modules did not fully cover waste generator requirenents 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 Region IV Reactor Programs Branch intends to continue performing, as initiatives, the basic /supplementai modules (84722/84850) in addition to the core modules at all operating power reacters.
4.
TRAINING Two new materials inspectors and a one 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 transportation training (course H-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 i
Nuclear Materials Inspection Section Chief (D. Powers) has not yet taken this course.
l l
7 i
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 materie'!s licensing and inspection area to improve safety and efficienqy, such as:
Implementation of the performance evaluation factor (PEF) program.
The effort to upgrade licenses through better and more frequent communication.
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.
8
URF0 and LLWM development of a management position on interpreting requirements on erosion protection.
I URF0 and LLWM joint sponsoring of a workshop on alternate concentration limits as one option for ueeting the uranium milling groundwater standards in 10 CFR Part 40.
8 The FRPS is planning to perform the supplemental transportation module 86740 at each operating reactor in FY89 as a supplement to Core Inspection Procedure 83750. This initiative is apparently in response to their general feeling that the degree of coverage of transportation offered by 83750 is ger.erally insufficient. The Region has done an excellent job in preparing new field notes for the low-level nste core inspection program.
The Chief, Nuclear Materials Licensing Section, has taken an initiative to editorially update on old information notice No. 82-47,
" Transportation 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 licensee 2.
The Region is commended for its efforts to contribute to improved agency processes to ensure sound regulatory decisions.
6.
HEADQUARTERS / REGIONAL INTERACTION Interaction between the Headquarters and Regional staffs has been excellent. URF0 and HMSS staff interact and coordinate on a regular basis.
URF0/HQ staff are planning a workshop in June 1989 on erosion protection.
There.have also been two very succesfoi interchanges between the Region and NMSS at the Division Director levr' H
- par. The interaction between the offices has been very good and has brin w oving.
9
7.
RESOURCE UTILIZATION Tne Table on page 13 shows FTE allocations and expenditures for the review period.
In FY88, expenditure for materials licensing, materials inspection, and fuel facility inspection closely approximated the budget allocation.
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 materials licensing than budgeted (0.86 vs. 0.43) while 40 percent fewer FTE were being expended 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 UAF0 had expended 2.3 fewer FTE (20 percent) than budgeted in FY88 for uranium recovery activities (8.9 vs 11.2).
However, upon closer examination of the Region IV 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 percent fewer than budgeted.
The first quarter FY89 URF0 FTE expended were slightly low, but understandable in view of the recent holidays and current vacancies.
URF0 has two recent vacancies, one Branch Chief and ri s Project Manager, which reduces the URF0 staff to 15, 10 direct staff e
- erhead.
The URF0 Director 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. Region IV should include overtime in the FTE expenditure numbers in the Operating Plan report.
The Region IV DRMA staff agreed with the'se two recommendations.
10
4 URF0 currently has two technical assistance contracts, one of which will be completed the end of April 1989.
The $100K of FY89 funds had not yet beer:
obligated but will be in March 1989 to ORNL for assistance in analyzing inspection samples.
Region IV's staffing plan lines up closely with the budget, but a vacancy does exist in materials inspections.
The staffing situation at URF0 shows an underutilization of resources provided, as the budget assigned 12.3 direct FTE of work in FY89, but URF0 only has 11.0 direct staff in its curretc staffing plan and 10 direct staff on board.
Region IV has recently acquired two very promising licensing and inspection staff persons with medical backgrounds which should put the Region in a good position to accomplish the NRC mission in the medical area.
8.
RECOMMENDATIONS Continue to closely monitor materials inspection completions, training and overtime, to see whether goals are being met and overtime is being reduced.
(Mandatory overtime has been discontinued since the time of the program review).
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 computer equipment can be made available.
The cross-training of licensing and inspection personnel has improved communication between sections. This should be expanded to include senfor personnel.
The Region requested additional training as a refresher course on low-level waste issues and waste classification packaging and waste forms for reactor inspectors and some additional limited training for materials inspectors.
11
.\\
9 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. 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 Deconnissioning 0
0 0
0.1 0.03 0
0 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 %
BUDGET OBLIGATED %
Ur.. lum Rec. Lic.
100 100 100 100 0
0 F0TE: FY89 funds obligation as of 2/28/89 12
1989 Region IV Program Review - Team Menbers Arlington and Denver - February 27 - March 3,1989 Glen Sjoblom, 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 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 Hickey, Division of Industrial and Medical Nuclear Safety Robert Brown, Region II Myron Fliegel, Division of Low-Level Waste Management and Decommissioning ATTACHMENT 1
DIVISIOII Of IRAI )l A I It il I
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l 01 -l ICI Of iI il iIll 'l (: 1 ( sit lh cl ea r si i lloogiar 1 Ihr m. tor If arvion I i toll. 1Icgsoty I sie en_t os st p.se mnle..
2ir.cton Cor al A. Ilobe. Sec r itt a rr y 1
6 NUCt. EAR MATERIALS SAFETY BRANCit Dassine Mear r u r.
E.hief William L Fisher. Chief I angevee Outes, I seies queet y H e spos.s..
Carol Hill Secretary 4:nne dinot ne Stucey Poseenber g
- .iec s et or y NUCLEAR MATERIALS INSPECTION SECTION.
SECURIIY AND E Mt'RGL NCY Dale A.' Powers. Chief HUCLEA54 MAlf 841A1 S PHEPAHLONLSS SECilOr4 FActe sitLS RADsot OGacAs.
LICt;t4 SING SEC1tOH Radiation Specnolist R. Jerry Everett. Chief
. P"OIE_CilOH SEC'*"wa David B. Spitzberg. Senior nonw E n
.r. chi.e Anthony Gaines. Radi.
- ton James Kelly. Senior Physical Deon Cheney. S.ntor F (fon Security Specialist Fgaci381st Charles L Coin. Chief Ronald Caldwell. Phyalcol Blair Htchotos. Senior R.
.lon sp..
Wesley Holley. Rodi stion Vivion compt >eis. Heanth Physicist Security specionist sp.cir.
- necio'ist Jackie Whit t en. Iteoith Physicist A. Hrsace (~or rie s t. Physic ant 8 0"Y Hi'b *t **a. II*dlellan Lorenzo Wilborn. RodnU.>n Billie Grusynekt. Licensing Security Speclulist 5p.6 tuts.*
Speciatiet Assistant Heenen Terc. Ernerg enc y p,,,,,, g,,, g Gerald Vasquer. Rodlotion Preparedness Aenotyst 3,,,,,,,,
Speclotist
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Using the current version of your regional staffing plan related to the HMSS program, specify the approximate percentage of time that each individual spends on the following activities:
licensing, materials inspection, safeguards activities, and inspection decommissioned facilities and reactors.
PERCENT OF TIME SPENT ON INDIVIDUAL F. C.
F. C.
MATERIALS MATERIALS SAFEGUARDS DECOM. FAC LICENSING INSPECTION LICENSIM INSPECTION INSPECTION Fisher 20 75 5
Cain 95 5
Campbell 80 20 Gruszynski 100 Whitten 95 5
Powers 5
95 Gaines
~
Holley 100 Kasner 95 s
Y 80 Spitzberg 5
90 Vasquez 5
Vacancy 100 100 i
Jrfelenl.5
2.
Provide a summary of actual expenditures and accomplishments as compared to operating plan / budgeted expenditures and accomplishments, for FY88 and j
FY89 to date.
1 Licensing and inspection expenditures and accomplishments during FY88 and the first quarter of FY89 are summarized below and on the following pagas.
LICENSING Actions Budgeted Hours FY Licensing Actions Completed Goal Hours Expended (Direct Effort) 1988 A.
New Applications 71 60 795 615 8.
Renewals 153 189 2,010 938 C.
Amendments 336 300 795 1,094 Subtotal
~5IE~
3,600 2,647 560 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
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526 768 0.
Miscellaneous 113 516 (LA Direct, Info.
639 1,284 Req., Lic. Site Visits, etc. )
INSPECTION Inspections Budgeted Hours FY Haterials Inspections Completed Goal Hours Expended 1988 1.
Routine Inspection 2,754 2,086 2.
Reactive Inspection 150 427 Total 405
~III 2,904 2,513 1989 1.
Routine Inspection 55 931 503 (1st Q) 2.
Reactive Inspection 18 38 46 Total T
T 969 549
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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 28007 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.
w--.
5 Are regional administrative support functions performed in a timely 4.
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 ir rove 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 Heaoguarters 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 NMSS has been very good.
The HMSS 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.
NMSS 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 sight be avoided by going to an alternate year schedule.
Region IV strongly advocates inspection accompaniments to strengthen both the NHSS and Regional staffs and to improve rapport b2 tween thee.
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 NMSS 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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t 6.
Summarize regional initiatives to improve the quality of inspections and l
license reviews, particularly those aimed toward preventing licensee safety problems, or those aimed at licensee's transportation activities in a safe manner., performing their 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 NHSS.
The visits have been initiated.)
Improved feedback between licensing and inspection personnel.
c.
(Initiated) d.
More tutorial communication between licensing personnel and licenses / applicant.
(Initiated)
- 2.
Investigating bases for license denial.
Region IV has denied licenses in some case (s.) Referred to MMSS, but 3.
Identification of wrongdoers.
(Referred to NHSS) 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)
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7 Summarize the total number of inspections of Transportation activities at MC 2800 licensed program facilities (Procedure 86740) including average staff-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 staf f-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 Papers) 3 173.415(a) (Type A Packages) 16 173.476(a) (Special Form Approvals) 12 Others
__8 61 "In three cases, the transportation violations found contributed to an escalated enforcement NOV.
i Recommending (to NHSS) ways to increase the efficiency of processing 8.
(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 DMS 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 reauest regarding disposal of americium well-logging sources.
(See February 15, 1898, meno 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.)
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