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Cobby H. Faulkenberry, Deputy Regional Administrator, Region V FR0f'.
Carl J. Paperiello, Acting Deputy Director Office cf Nuclear Material Saf ety and Safeguards SbfsJECT :
DRAFT EMSS NAT10f4AL PROGRAM REVIEW REPORT The NMSS National Program Review report is enclosed in draft form for Regioral comment.
The report provides the results of the Office of Nuclear Materiel Safety anc Safeguards' review of 1988 programs under the Headquarters' respcosibility as related to your Region.
The Headquarters' teams participating in the review were comprised of individuals from each of the four elements of NitSS that are involved in Regional activities.
The National Progran Review Marual cateo December 11, 1987, was the basis for the review. The National Program Review is based not only on the visit to the Region, but on the collective Regional / Headquarters interfaces throughout the year, through review of licensing casework, ins p ction reports, accompaniment of Regional inspectors, review of casework, and inspection statistics, technical assistance and coordirition, and coordination and Regional respcoses to an NMSS questionnaire.
The report is ittended 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 thi.t both elements contribute towards assuring the safety of operations involving TJ.C 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 flay 23, 1989.
Following incorporation of Regional comments, the final report will be transmittea to the Regions by the flMSS Director.
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Carl J. Paperiello, Acting Deputy Director Office of Nuclear Material Safety and Safeguards
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REPORT OF HMSS 1988 NATIONAL PROGRAM REVIEW AT NRC REGION V, FEBRUARY 21-22, 1989 1.
BACKGROUND AhD 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 V and under the responsibility of NRC Region V.
The Head-quarters Team participating in this review was comprised of individuals from each of the four elements of NMSS that are involved in regional activities. The NMSS i
team is shown on Attachment 1.
The principal regional activities are primarily under the responsibility of the Region V Division of Radiation Safety and Safe-guards (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. A February 6,1989 memorandum from Richard Cunningham listed the areas to be covered and transmitted a questionnaire to the regions. Region V responses to the questionnaire are shown 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 some licensing casework, inspection reports, accompaniments of region-based inspectors, review of casework and inspection statistics, resource utili-zation, and technical assistance and coordination, and the questionnaire.
It is intended to provide a review of effectiveness of both the region and head-quarters activities insofar as they relate to Region V activities and to iden-tify suggestions for improving the effectiveness of the joint efforts of HMSS and Region V.
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 sunnary in each of the following areas:
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1.
Background and Purpose 2.
Licensing 3.
Inspections 4
Training 5.
Initiatives 6.
Interfaces of Region /NMSS 7.
Resource Utilization 8.
F.econnendations/ Suggestions
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2.
LICENSING a.
Materials Safety Region V currently regulates approximately 300 byproduct materials licensees.
In FY88, they completed 192 cases, as compared against an adjusted Operating Plan target of 180 (107%). They received 194 cases during this timeframe.
Through 1/31/89, the region had completet 52 cases, or 25% of the annual goal.
They expect to catch up by the end of the fiscal year.
(In December, the lead reviewer spent much of the time training others, on annual leave, and in interacting with Agreement States).
The region has recently begun cross qualifying two reviewers to support the materials licensing program. These individuals should strengthen the program, and provide more flexibility for the Branch.
The region is aggressively taking actions to resolve old casework.
In early February, they had 12 such " backlogged" cases. More current data from the Branch Chief indicate that this number has been reduced.
The senior reviewer has been assigned many of these cases and is working on them as a high priority.
The Region appears on track to meet the new NMSS timeliness goals by the end of 3
FY 89.
This is requiring greater attention by more materials staff to licensing casework in the near term.
It was suggested that the Region may want to con-i sider the benefits of such broader involvement by more materials staff on a more extended basis.
In other Regions, there have been recognized benefits to the organization with improvements in both licensing and inspection activities through greater involvement by personnel in both activities, and benefits toward broadening the staff as well.
Headquarters staff reviews a fraction of completed materials licensing actions and inspection reports.
Both licensing and inspection actions are generally in accordance with standard review plans, Inspection Manual Chapters and other guidance documents.
Region V staff has sought guidance via telephone or techni-cal assistance request on matters that are technically complex or may have policy implications.
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m One particularly difficult RV case reviewed required extensive negotiations with VA San Francisco Hospital. The licensee had a history of lack of manage-ment support for the radiation safety program. As a result of RV guidance and
- negotiations, the radiation safety program was revised by the hospital manage-ment.
New radiation safety staff were acquired and a supplemental training program was developed.
Th'e RSO now reports directly to administration rathe'r than through the nuclear medicine chief.
The program was recently reinspected and the improvements are still in place and working.
b.
Safeguards Licensing Region V maintains a complete set of Regional guidance documents, Standard Review Plans, and Region V supplementary instructions related to the safeguards licensing process. The 10 CFR 70.32 case reviews were performed in 6 sound technical manner.
The reviews were complete and consistent with NRC policy and guidance.
Region V achieved an average case turnaround of 41 days in FY 88.
Region V completed 6 licensing reviews in FY 88 versus five planned licensing reviews. Region V has completed two licensing reviews to date for FY 89 versus the 10 licensing reviews that are projected.
The projections are on target for FY 89.
Region V utilizes the NMSS Operating Plan Casework Statistics Report #41 to inform Headquarters of the licensing casework status on a monthly basis. The FY 89 licensing review completion dates have been extended because of other licensing and inspection priorities established by the Region.
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INSPECTIONS a.
Materials Inspections In FY 88,155 materials safety inspections were completed compared to a goal of 156. During the same time frame, RV estimated that they assisted on 20-30 other inspections of the Dept. of Agriculture, U.S. Air Force and U.S. Navy permit-tees. Through Jan. 1989, the region has completed 60 inspections.
The annual goal is 127, so Region V is well ahead of schedule.
NMSS performed 3 inspection accompaniments of materials inspections.
NMSS staff accompanied one RV materials inspector, and found him to be conscientious and thorough, with a professional rapport with licensee personnel and with effective use of exit meetings with licensee management to initiate needed pro-gramatic changes. There was also an awareness of NMSS guidance concerning the medical inspection frequency increase and recently issued information notices, indicating that RV keeps its inspectors well informed.
In general, RV is employing effective, well-trained inspectors.
b.
Safeguards Inspections Region V met the inspection goals established in the FY 88 Operating Plan and in Manual Chapter 2681 for their physical security and MC&A inspections.
Region V is current on their FY 89 inspection program as outlined by Mr. Burnett's memorandum of August 15, 1988.
Region V inspection schedules are forwarded quarterTy to Headquarters in a timely manner.
It should be noted that as of February 15, 1989, the MC&A inspection function of Region V has been transferred to Headquarters.
Region Y personnel contri-buted valuable information to this transfer and one of their inspectors has been assigned to Headquarters. A member of the Division of Safeguards and Transportation staff accompanied a Region V inspector on a physical security inspection at GA Technologies in February 1989. The inspection was performed in a thorough, comprehensive, technically competent and professional manner.
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Region V has a policy of a 30-day turnaround on all inspection reports. These are tracked by an internal system, Management Information Report #6, and the inspectors are kept informed of their deadlines. Copies of the inspection reports are sent to Headquarters. Review of these reports show that they are thorough and technically competent.
c.
Safeguards Transportation Inspection Program Region V completed the three safeguards transportation inspections scheduled for FY 88.
In addition, one route survey was performed at the request of head-quarters.
For FY 89, Region V has conducted one safeguards transportation l
inspection of the three that are scheduled in FY 89. Region V is therefore current for their FY 89 schedule. One route survey has also been conducted in FY 89 at the request of headquarters.
d.
Fuel Cycle Inspection Management responsibility for the fuel cycle inspection program has been trans-ferred to the Emergency Preparedness and Radiological Protection Branch. The new management and the use of radiation protection inspectors from this Branch have resulted in an aggressive and evaluative inspection effort at Region V fuel facilities. The control of available inspection resources resulted in effectively completing the FY 88 program and in keeping the FY 89 program on schedule. The Branch Management is attempting to recruit a new Fuel Facility Inspector to provide smooth transition prior to the retirement of the current Fuel Facility Inspector.
The new Branch Management should carefully monitor i
reduced levels of licensees' activities and adapt the scheduled application of inspection resources to the reduced levels. Continued participation by NMSS staff in fuel cycle inspections, is judged desirable by NMSS and the Region.
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Transportation Inspections There was good regional inspection coverage of radioactive material transporta-tion safety at fuels, materials, and reactors. Materials inspection field notes reviewed were consistent with the Manual Chapter and thorough. The inspection reports were of technically good quality and adequate, identifying 34 violations
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of NRC requirements in 108 inspections during FY 88.
It was suggested that the past regional practice of having the materials section chief accompany regional inspectors each year be resumed. Reactor inspection reports continue to be of excellent quality.
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Low-Level Waste Inspections The Region has conducted inspections at material facilities, fuel facilities and reactors in accordance with operating plan objectives. The Region's inspectors are knowledgeable with the requirements of 10 CFR Part 61 and all have had the course, "H-308 Transportation of Radioactive Materials," this course covers waste generator requirements for 10 CFR Part 61.
The impact of the "New Core Inspection Program" on waste inspections at reactor facilities appears to be minimal at present. The supplementary inspection procedure, IP84850, has been credited at 11 material facilities.
Examination of the Region V material inspection files indicates that inspector field notes are complete and conclusions in the field notes are reflected in the final inspection reports.
Both field notes and inspection reports are of excellent quality.
Inspection of the special nuclear materials license at the Richland, Wa, low-level waste disposal facility is the responsibility of the Nuclear Materials Section. The materials section conducted on inspection and also accompanied the Washington State inspector on an inspection during this review period. The i
1 license for the Richland site has been renewed during this review period and
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the materials section has worked with NMSS headquarters staff during this renewal.
l The Region should be commended on its resource management techniques which have apparently helped reduce any negative impact which instituting the "New Core Inspection Program" might have had on low-level waste and transportation inspections. The full impact of the Core Inspection Program can probably not be determined before most plants have gone through the ful! SALP cycle.
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Ecth Region V and Headquarters recommend that Inspection Procedure 88035 be revised to reflect the current guidance contained in the Supplementary inspection Module (IP84850). The Region should provide low-level inspection training to the two new staff who will perform waste inspections.
4 TRAINING Nearly all inspectors have completed the transportation /LLW training.
NMSS suggested that three inspectors of the ED/AP branch receive the transportation training course, H-308, if they will be inspecting transportation and LLW at fuel facilities.
The necessary Regional staff is participating in the OSHA-sponsored training pursuant to the Memorandum of Understanding with OSHA.
The Regional Enforcement coordinator has given several training sessions to staff on the recent changes to the 10 CFR Part 2 enforcement policy.
The Region has trained all but two of the new inspectors who are responsible for inspecting radioactive waste activities, in the applicable requirements.
Region V physical security inspectors and their supervisors are attending the NMSS sponsored Technology Transfer Course presented by Sandia Laboratories.
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5.
INITIATIVES BY THE REdION In Region V, the performance evaluation factors (PEF) program is being pursued and is perceived as an effort very beneficial toward improving the focus on material safety and underlying causes of non-compliance.
The Region also believes that the improved recognition of underlying causes of licensee problems may be resulting in Regional management decisions to take more escalated enforce-ment actions, for example, where a judgment to aggregate several level IV and V violations is involved, and where the underlying cause has not yet resulted in level III violations. Thus, it appears the PEF program thus far is having the desired effect on the Region V inspection program.
The Region should be able to contribute valuable lessons to the national program from this experience.
For all licensing cases, RV has a cover summary sheet that explains the nature of the action, the considerations of the reviewer, and how these considerations were handled. Difficult cases are identified by the reviewer and aiscussed with the secticn chief, who initials the summary sheet.
For all inspections, RV attempts to spend time discussing NRC's regulatory program with the licensees to ensure there is a full understanding of the regu-latory policy and practice, new regulations, and interpretations. The region believes that this encourages development of a cooperative interaction between the NRC and the licensee, rather than a relationship characterized by contention. The region has recently documented the lessons learned from two problem radiography cases.
This new documentation should upgrade the radiography licensing and inspection programs.
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RV conducts prelicensing visits on difficult cases. Two examples are the renewals to University of Hawaii and the sole Hawaii nuclear pharmacy.
The university is a very large program with the potential for insufficient manage-ment support. The' pharmacy is a very small program that generated many items of noncompliance when one individual left the licensee's program.
RV has found that a two-man team is very effective in such meetings; the license reviewer can discuss technical matters with the RSO while an NRC management representative can meet with licensee management to discuss resource allocation and the need for more visible support of the radiation safety program.
The Region V Safeguards Section initiated in the first quarter of FY 89, a goal of training an alternate inspector for the fuel facility physical security inspections.
In the past, there has been an alternate but the alternate never performed an inspection at a fuel facility.
In December 1988, the alternate accompanied the principal inspector on an inspection of the Catecory I fuel, facility.
In view of the minimal effort which could be directed to transportation inspec-tions using new Core Inspection Program, (CIP) Region V has programmed the performance of the supplemental module (86740) during FY 89 at all operating reactors using the 0.2 FTE additionally provided by NMSS/LLWM.
Region V is to be comended for this very wise use of this added resource, and further, for recognizing that the existing level of effort on transportation /LLW could potentially be diminished with the CIP modules above.
The Acting Section Chief has devised and implemented in January 1989 a " Core Inspection Program Tracking Form." This fonn is completed by the assigned inspector after an inspection.
It quantifies the status of completion of the l
various elements of each CIP procedure.
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E.
NMSS/ REGION V INTERACTIONS Both NMSS and Region V believe that interactions have been useful and effective in all the areas in inspection and licensing.
Region V has been very responsive to HMSS requests for information or short term requests for special inspections and responsive to new initiatives from NMSS, such as in the medical inspection area.
In the U.S. Testing and Finlay cases, there was extensive cooperation not only with NMSS, but with other regions as well.
Region V suggested that the new Materials Branch Chief participate in an NMSS rotational assignnent.
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7.
RESOURCE UTILIZATION The table on page 13 shows Full Time Equivalent (FTE) allocations and expenditures during FY 1988 and FY 1989 through January 1989.
In FY 88, 0.65 FTEs were reprogrammed f rom the fuel f acility inspection activity to materials inspec-tions. With this action, expenditures closely matched the budget allocations.
The region also expended almost 3 additional FTEs on overhead activities.
In FY 89, the region has reprogrammed 1.2 FTE from the safeguards inspection pro-gram to the material areas to increase the licensing effort (0.6) and to imple-ment centralization of MC&A licensing and inspection in HQ (0.6). To date, they are slightly overexpending resources on the materials inspection program (+.21) and slightly unoerexpending on materials licensing (.21).
Since the Region does not plan to conduct an operational safety team assessment in FY 1989, it appears that the 0.3 FTE budgeted for that activity may be reprogrammed.
The regional staffing levels line up closely with the budget allocations. The Facilities Radiological protection Section is understaffed by one, but the rest of the Division of Radiation Safety and Safeguards is fully staffed at 30.5 FTEs for FY 89.
Because of the small size of the various programs, the Sections include only 4-6 people.
The region has good clerical support and the Licensing Assistant supports both the inspection and licensing programs.
RV has made recommendations to HQ to improve the Licensing Management System, but was not aware of a recent HQ trans-mittal on inspection / licensing fees. The review identified some instances where correspondence issued by HQ to provide guidance, information or action to the Region had not reached appropriate staff members.
It seems that the flow of such information from HQ to the appropriate staff members could be improved.
The region makes effective use of computer support systems. Some inspectors generate draft reports themselves at their personal computers.
Increased com-puter usage is underway, which should continue to improve efficiency of the operations.
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- d FY 88 FY 89 Projected Actua13 Original Revised Actuall Original Current expenditures expenditures budget budget expenditure %
budget budget thru 1/89 thru 1/89 Fuel facility licensing 0.0 0.0
.2162 NA 0.0 0.0
- 0. 0
- 0. 0 NA Fuel facility inspections 2.3 1.653 1.551 94 2.3 2.3 0.77 0.64 83 Materials licensing 1.2 1.2 1.421 118 1.5 2.14 0.70 0.49 70 Materials inspections 2.48 3.133 3.219 103 3.5 3.5 1.17 1.38 118 Event evaluation 0.0 0.0 0.003 NA 0.3 0.3 0.10 0.08 80 Transportation inspections 0.18 0.18
.039 22 0.2 0.2 0.07 0.01 14 SG-Fuel facility licensing 0.18 0.18
.317 176 0.2 0.2 0.07 0.02 29 SG-Fuel facility 1.0 1.0
.860 86 2.0 0.84 0.27 0.37 137 Low level waste
- 0. 0 0.0 0.0 NA
- 0. 2 0.2 0.07 0.00 0
Decommissioning 0.0 0.0 0.0 NA 0.1 0.25 0.07 0.00 0
7.34 7.34 7.626 104 10.3 9.8 3.27 2.99 91 2 Based on regional supplied RWAT data.
2 Includes effort on allegations and investigations.
30.65 FTE reprogrammed from fuel inspections to materials inspections.
41.2 FTE reprogrammed from safeguards and transportation inspections to materials inspections and MC & A centralization at HQ.
50.1 FTE transferred from NRR to NMSS to conduct decommissioning inspections on reactors.
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E.
RECOMMENDATIONS / SUGGESTIONS NMSS recommended that Region V consider the benefits of spreading materials licensing caseload to more Regional staff on a permanent basis.
(see Section 2a.).
NMSS recommends that Region V identify areas into which it intends to reprogram the 0.3 FTEs budgeted for operational team assessments (see Section 7) and monitor fuel cycle inspection resource requirements commensurate with licensee operations (see Section 3d).
NMSS shoulc revise the 766 system or in some way arrange that Region V receive credit for assist inspections of Navy and Air Force broad scope programs, that are administered by Regions II and IV.
NMSS agrees that credit should be given for these and will discuss this item with Region II and IV.
NMSS would also appreciate if Region V would share with NMSS any general views provided to Region II and IV from these assist inspections.
The Regional and Headquarters staff reconnends that inspection procedure 88035 be incorporated into other inspection procedure guidance or revised to reflect current low-level waste inspection procedure requirements.
Region V recommends that the safeguards licensing workshop should be reinstituted on the staff level.
Region V considers these to have been one of the most valuable mediums for exchange by all regions with the headquarters staff.
The Policy and Guidance Directive system is unwieldy. The recently published subject index is helpful, but the entire system may be more workable if it is sorted into subject areas such as medical, pharmacy, academic, radiography, and general applicability (such as license issuance and termination, licensee name changes, and abandonment).
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ATTACHMENT 1 Glen Sjoblom, Division of Industrial and Medical Nuclear Safety, Team Leader Pete McLaughlin, Program Management, Policy Development and Analysis Staff George Deegan, Program Management, Policy Development and Analysis Staff George Bidinger, Division of Industrial and Medical Nuclear Safety Norman McElroy, Division of Industrial and Medical Nuclear Safety Al Grella, Division of Safeguards and Transportation William Floyd, Division of Safeguards and Transportation Leroy Person, Division of Low Level Waste Management and Decommissioning 4
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ATTACEMENT 2 REGION Y DIVISION OF RADIATION SAFETY AND SAFEGUARDS Director - Ross A Scarano Regional State Liaison Officer - Dean Kunihiro Health Physicist - State Agreement - Jack Hornor Emergency Preparedness & Radiation Protection Branch - Gregory Yuhas, Chief
- Facilities Radiation Protection Section - Chief (vacant)
- Emergency Preparedness Section - Raymond Fish, Chief Nuclear Materials Safety & Safeguards Branch - Robert Pate, Chief
- Nuclear Materials Safety Section - Robert Thomas, Chief
- Safeguards Section
- Douglas Shuster, Chief 4
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ATTACRMENT 3 REGION V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE 1.
Using the current version of your regional staffing plan related to the NMSS program, specify the approximate percentage of time that each individual spends on the following activities: fuel cycle licensng, fuel cycle NEeo2tiod; materials licensing, materials inspection, safeguards activities, and inspections of decommissioned facilities and reactors.
See attached chart s
Activities (1)
(% of Tirne Spent by each Individual)
Chart for Question 1 Fuel Cycle Materials Materials Safeguards Safeguards Name-Inspection Licensing Inspection Licensing Insp. & other Decommissioning R. Fish, Chief EP Section 5
-B. Brock Inspector 100 Other Fuel Cycle Inspection Support (Various Inscpectors) 1 FTE
- 11. florth, Act. Chief EP&RP Branch 5
M. Cillis Sr, Rad. Spec.
20 R. Thomas, Chief HMS Section 50 50 J. Montgomery Sr. Matls. Spec.
40 60 B. Riedlinger
-Health Physicist (Lic.)
98 2
i F. Pang Rad. Spec.
100 D. Skov Rad. Spec.
10 90 P. Zurakowski Rad. $pec.
75
t Chart for Question 1 l
l Fuel Cycle Materials Materials Safeguards Safeguards Name Inspection Licensing Inspection Licensing Insp. & other Decommissioning F. Browne Lic. Asst.
50 50 E. Garcia I/R Coord.
5 Schuster, Chief SG Section 10 30 L. Norderhaug Sr. M/C Analyst 40 A. McQueen Phy. Sec. Spec.
30 D. Schaefer Security Inspec.
15 G. Nelson MC&A Insp.
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(1) Fuel Cycle Licensing is not done in Region V f
REGION Y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONAIRE 2.
Provide a sunnary of actual expenditures and accomplishments as, compared to operating plan / budgeted expenditures and accomplishments, for FY 88 and FY 89 to date.
See attached charts.
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REGION Y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONAIRE 2.
Provide a sunnary of actual expenditures and accomplishments as compared to operating plan / budgeted expenditures and accomplishments, for FY 88 and FY 89 to date.
See attached charts.
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r REGION V HATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE 3.
Are there any changes needed in the estimate of workload prcjection (licensing actions and inspections conducted) for the current riscal 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 Fuel Cycle Inspection No changes are needed for FY 89 fuel fabrication inspection program.
If Atomics International and/or General Atomics become involved in decontamination / decommissioning of their facilities, some changes may be neces sa ry.
There are no foreseeable barriers to completing the MC 2600 inspection modules for FY 89.
Materials Inspection No changes are needed for FY 89. The estimated 120 inspecticas will be completed in accordance with MC 2800.
Materials Licensing The estimated case workload projection may need to be adjusted due to the increased effort necessary to complete the "old" cases and the escalated enforcement activities by reviewers - Skov and Montgomery.
Safeguards Fuel Facility Licensing Program Our experiece for FY 88 reveals that while 3 casework estimated receipts were projected; actual receipts were 6 cases.
The fuel facilities regional safeguards 'icensing casework estimated receipts for FY 89 is projected as 8 cases, and two cases were received in the first quarter.
The projections are therefore, at present, right on for FY 89.
Safeguards Fuel Facility Inspection Program No changes are needed for FY 89.
There are no foreseeable barriers to completing the inspection modules in accordance with NC 2681.
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REGION V KATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE 4.
Are regional administrative support functions performed in a timely manner? Are changes needed in the manner in which these support functins are performed?
If so, please be perepared to discuss the changes needed which would result in optimal administrative support for the programs.
Regional support functions appear adequate to support the NMSS programs in Region V.
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REGION Y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989
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EEGIONAL QUESTI0hhAIRE S.
Please provide coments on the programs for interaction of Headquarters with your Region.
Please include your comments on the usefulness of the i
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., in the interaction programs.
Materials Licensing and Inspection Interaction with headquarters has improved over the recent months.
The conference calls have become more useful since topics are being assigned to individuals for resolution. The licensing workshops are still important for the resolution of problems common to all regions and headquarters.
Inspection accompaniments are valuable to the headquarters staff in that a better understanding of regional activities is obtained.
Reviewer's guides and review plans should be upgraded.
Radiography guides do not address the transportation requirements, the R50 requirement, and the quality assurance program. The medical review plan has disagreement between RG 10.8, Rev. 2 (Aug. 87) Appendix P and RG 8.20 relative to a bicassay requirement for I-131 capsules. Also, final guidance is needed for well-logging applications prepared relative to Part 39.
How do we handle Part 39.41 for well-logging devices which do not meet new criteria after July 14, 19897 Should we expand the type of cases which require technical assistance, i.e., 5 half lives vs. ten half lives for decay in storage?
Safeguards Licensing and Inspection Interaction between the regional safeguards inspector and the licensing reviewer and their NMSS counterparts has been effective and such interaction is conducted on an as needed basis.
The monthly safeguards inspection conference call sponsored by the NRR Safeguards Branch, and has been participated in by NMSS, appear to be an effective means of communicating generic type safeguards issues, problems, and program changes. We recommend they continue and that NMSS continue to participate when top cs also appear to reflect on NMSS programs.
There have been no safeguards licensing workshops (formerly sponsored by NMSS) since the reorganization splitting materials and reactor safeguards licensing and inspection functions. This was a disappointment as these were considered to have been one of the most valuable mediums for interchange by all regions with the various headquarters elements managing or administrating regional safeguards program activities. They should be reinstituted, whether on a joint basis by NMSS and NRR or on a separate basis by each.
The joint workshops would appear to be most desirable and efficient based on experience of the previous workshops.
FY 89 NMSS PROGRAM ACCOMPLISHMENTS Program Budget Current FTE Activity Allocation Allocation Expenditures Accomplishment)
LLW, Lic. Inspection
.20
.20 0.00 (3)
Decommissioning (Non-Power) 0.10 0.10 0.00 Section Chief 1.00 1.00 0.46 (3) RITS data incorrect
a Question 5 Cont'd.
An NMSS/SG0B representative accompanied a Region V inspector during a Category I Fuel Facility safeguards inspection in February 1988.
The interchange between the two during this inspection was considered to have been outstanding by the regional inspector.
Recommend consideration be given to documenting these accompaniments in a manner to preserve the positive and/or problem areas encountered during the inspection.
This could also serve as educational feedback for other regions as well as the one involveo.
Telephone calls on case reviews are made on an "as needed" basis.
In all cases where a licensee change appears unacceptable; where policy or generic issues may be involved; or where a potential problem is identified or perceived; the case is telephonically discussed between region and the headquarters cognizant program office.
Safeguards licensing reviews are based en guidance contained in the NMSS provided "Safeguaras Regional Guidance" Manual.
Fuel Cycle Inspection There presently are no scheduled interactions between the Region and Headquarters in the area of fuel fabrication facilities.
Contacts on an "as needed" basis have been satisfactory and responsive.
In the past Headquarters accompaniments on our fuel fabrication inspections have been most beneficial and we encourage continued support in this area.
We believe the Region (Fuel Facility Inspector) should be informed in a timely manner of the results of discussions between the licensee and NRC licensing on matters related to fuel fabrication license renewal or major modification.
We suggest a fuel facility counterpart meeting in Headquarters, possibly in connection with the Fuel Cycle Workshop being scheduled for April /May 1989.
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REGION Y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NHSS-1989 REGIONAL OUESTIONNAIRE 6.
Summarize regional initiatives to improve the quality of inspections and license reviews, particularly those aimed toward preventing licensee safety problems, or those aimed at licensee's performing their transportation activities in a safe manner.
Materials Licensing and Inspection The following initiatives have been implemented:
More time is spent with the licensees in discussing the license conditions and the associated regulations.
Inspections are more in depth using performance factors.
Problem licensees have reduced inspection frequencies and management meetings.
Transportation module 86740 is reviewed during each inspection where applicable.
Safeguards, Licensing and Inspection The Region V Safeguards Section initiated in the first quarter of FY 89, a goal of training an alternate inspector for fuel facility physical security inspections. For the past three years, fuel facilities had been inspected by one principal safeguards inspector. While an alternate had been designated for the same time period, the alternate performed no inspections or accompaniments at fuel facilities. A second inspector accompanied the principal inspector on an inspection of General Atomics, a Category I Fuel Facility, during December 1988.
This allowed accomplishment of all semiannual program goals in one trip, instead of the usual two trips per semiannual inspection cycle at this f a cili ty.
It is intended to rotate these two inspectors in the future in a manner which will allow both to remain familiar with each fuel facility site and to be experienced in fuel cycle physical security inspections.
Fuel Cycle Inspection Regional management expects to visit each fuel fabrication facility each year.
The Fuel Facility Inspector attended an OSHA training course in FY 88.
I Additional inspectors are scheduled to attend OSHA training courses (Hazardous Materials and Fire Protection) during FY 89.
Additional inspector training on transportation requirements is expected to be accomplished during FY 89.
Reactor Radiation Specialist and Emergency Preparedness Analysts are being used to support the Fuel Facility Inspector.
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REGION Y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSSu1989 REGIONAL QUESTIONNAIRE 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 brief summary of the most typically observed violations. Summarize (Regions II and V) referrals to other regions of state identified violations on shipments by NRC licensees to commercial burial sites.
Summarize the completion status of inspections of transportation activities at 2600 (#86740) and 2500 (#86740) and
(#86721) program facilities. Please provide early observations on the impact of the Core Inspection Procedure #83750 on the inspection of transportation activities at 2500 program facilities.
Material Licensing and Inspection Thetransportationactivitiesunderthe(Procedure 86740)MC2800has involved a total of 108 inspections (10/1/87 to 12/31/88) for 30, 40, and 70 docket type of licensees. A total of 148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br /> was expended.
A-total of 34 violations was identified. The majority of the violations were associated with shipping paper requirements, labelling, and the Special Form and DOT 7A certifications. We have not had any regional referrals of NRC licensees with violations at the burial sites during FY 88.
Activities associated with Inspection Procedure 84850 have been as follows: 030 and 070 Dockets Number of inspections 16 Number of inspection hours 40 Number of violations 0
Safeguards Licensing and Inspection As provided for in the letter from the Director, Division of Safeguards and Transportation, NMSS, to all regional Directors, Divisions of Radiation Safety and Safeguards,
Subject:
SAFETY / SAFEGUARDS TRANSPORTATION INSPECTIONS, dated November 4, 1987; three transportation safeguards inspections were conducted in FY 88 and one to date in FY 89.
Two more are programmed for FY 89, if the appropriate transport activities become available for inspection.
1 In FY 88, the three inspections indicated for Region V in the "FY 1988 NMSS Inspection Schedule" were one each for: Spent Fuel Imports, Category II Shipments, and Domestic Spent Fuel Shipments.
One each was conducted for Category II Shipments and Domestic Spent Fuel Shipments;
)
however, since no Spent Fuel Imports were reported, a Spent Fuel Export was substituted.
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l Question 7 Cont'd.
The FY 89 inspection pertained to a Category II shipment being exported through the Port of Oakland.
Inspection Modules used during Safety / Safeguards Transportation Inspections were 81335, 85301, and 86740.
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No transportation activity has been available for inspection at 2500 program facilities; therefore no safeguards experience exists to date to gauge the impact of the Core Inspection Program on the inspection of I
transportation activity at those facilities.
Fuel Cycle Inspection i
Transportation activities have been inspected (Procedure 86740) at all fuel fabrication facilities within the last year.
Reactor Faciliti_e_s (MC 2500) 1 Procedure 86740 has been completed at two Region V facilities (Diablo l
Canyon and Palo Verde).
Procedure 86721 has been completed at one Region V facility (Palo Verde).
Not enough of the Core Inspection Program has been completed to assess the impact of procedure 83750.
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FY 89 NMSS PROGRAM ACCOMPLISHMENTS Program Budget Current FTE Activity Allocation Allocation Expenditures Accomplishments FC Licensing 0.00 0.00 0.00 None planned FC laspactions 2.30 2.30 0.64 Inspection program on target to complete all modules at all facilities.
Materials Licensing 1.60 2.10 0.49 Planned license cases 206 Completed cases 52 Materials Inspection 2.60 2.70 1.38 Planned inspections 120 Completed inspections 60 Medical Program Improvement
.80
.80 0.00 (2)
Loma Linda VAMC team inspection. More frequent inspections of broad scope medical licensees.
Planned workshop on Part 35 for VA, Military and Agreement State Hospitals.
Safeguards 2.40 1.80 0.41 Planned license cases 10 Completed cases 2
Planned SG inspect.
Completed SG inspect. ~
6 2
(1)
Planned trans. insp.
3 Completed inspections 1
i Budget reduced due to General Atomics and Rockwell contract falling through (1) Two man weeks of inspection in one week.
(2) No charges have been made due to problem with RITS inputs.
Should be approximately 0.2 (3 man-weeks direct effort.)
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FY 88 NMSS PROGRAM ACCOMPLISHMENTS Program Budget Current FTE Activity Allocation Allocation Expenditures Accomplishments FC Licensing 0.00 0.00 0.00 II)
FC Inspections 2.30 1.65 1.77 The inspection program was completed at all Fuel Facilities with minor exceptions.
Materials Licensing 1.38 1.38 1.a2 Planned license cases 180 Completed cases 192 Materials Inspections 2.44 3.09 3.22 Planned inspections 156 Completed inspections 155 Increased workload due to U. $7 Testing and Finlay Testing Laboratories Safeguards 1.36 1.36 1.22 Planned license cases 5
Completed cases 6
All planned security inspections were completed. "ransportation inspections planned and completed 3
Route survey completed 1
Section Chief 0.60 0.60 1.19 Totals:
8.08 8.08 1/ Includes.22 for FC, 01 and Allegation Support
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FY 89 NHSS PROGRAM ACCOMPLISHMENTS r
l Program Budget Current FTE j
Activity Allocation Allocation Expenditures Accomplishments I
LLW, Lic. Inspection
.20
.20 0.00 (3)
Decomissioning i
(Non-Power) 0.10 0.10 0.00 l
Section Chief 1.00 1.00 0.46 l
(3) RITS data incorrect i
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FY 89 NMSS PROGRAM ACCOMPLISitMENTS Program Budget Current FTE Activity Allocation Allocation Expenditures Accomplishments LLW, Lic. Inspection
.20
.20 0.00 (3)
Decommissioning (Non-Power) 0.10
.10 0.00 Section Chief 1.00 t 00 0.46 (3) RITS data incorrect
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