ML20057A331
| ML20057A331 | |
| Person / Time | |
|---|---|
| Issue date: | 05/22/1989 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Sjoblom G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309140025 | |
| Download: ML20057A331 (7) | |
Text
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MEMORANDUM FOR:
Glen L. Sjoblom, Deputy Director Division of Industrial & Medical Nuclear Safety Office of Nuclear Material Safety & Safeguards FROM:
Ross A. Scarano, Director Division of Radiation Safety & Safeguards, RV
SUBJECT:
COMMENTS ON DRAFT NMSS NATIONAL PROGRAM REVIEW REPORT Enclosed are pages 3, 4, 5, 8, 10, and 12 of the draft NMSS National Program Review Report, which contain our coments. We look forward to receiving the final report in the near future.
Ps& W"For P
Ross A. Scarano, Director Division of Radiation Safety & Safeguards Enclosures as stated 9309140025 930830 ry PDR STPRG ESGG
o 2.
LICENSING y
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 completed 52 cases, or 25% of the annual goal. They expect to catch up by the end of the fiscal year.
(InDecember, 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 HMSS timeliness goals by the end of FY 89.
This is requiring greater attention by more materials staff to licensing i
casework in the near term.
It was suggested that the Region may want to con-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 la both licensing and inspection activities through greater involvement by gersonnel in both activities, and benefits toward broadening the staff as well.
Headquarters staff reviews a fraction of completed materials licensing actions g and inspection reports.
Both licensing and inspection actions are g @ _ W l in accordance with standard review plans, Inspection Manual Chapters and other guidance documents. Region Y staff has sought guidance via telephone or techni-cal assistance request on matters that are technically complex o'r may have policy implications.
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o One particularly difficult RV case reviewed required extensive negotiations with VA San Francisco Hospital.
The Itcensee 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. The RSO now reports directly to administration rather 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 perfonned in a 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 Y completed 6 licensing reviews in FY 88 versus five planned licensing reviews. 4:ghn Y ha ccyleted twe licissir.g reviews te dcte fcr FY S9 ver4us the 10 liccasiaa raviews tha+ =ce arejected. # @ V M h N
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The-projections crc en terget fcr TY ah Region Y utilizes the NMSS Operating Plan Casework Statistics Report f41 to inform Headquarters of the licensing "y -
casework status on a monthly basis. The FY.89 licensing review completion i
dates have been extended because of other licensing and inspection priorities j
established by the Region.
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INSPECTIONS a.
Materials Inspections g
In FY 88,iS5 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.
WSS performed 3 inspection accompaniments of materials inspections. NHSS 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-grannatic changes. There was also an awareness of NHSS guidance concerning the medical inspection frequency increase and recently issued information noticen indicating that RV keeps its inspectors well idormed.
In general, RV is employing effective, well-trained inspectors.
b.
Safeguards Inspections Region Y 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 i
memorandum of August 15, 1988,'
Region V inspection schedules are forwarded
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quarterly to Headquarters in a timely manner.
It should be noted that as of February 15, 1989, the MC&A inspection function of Region Y has been transferred to Headquarters.
Region V 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, comprebensive, technically competent and professional manner.
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1 po #[v Both Region V and Headquarters recomend that Inspection Procedure 88035 be revised to reflect the current guidance contained in the Supplementary InspectionModule(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.
HMSS s
suggested that three inspectors of the ED/AP branch receive the transportation i
training course, H-308, if they will be inspecting transportation and LLW at j'
fuel facilities.
The necessary Regional staff is participating in the OSHA-sponsored training pursuant to the Memorandum of Understanding with OSHA.
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The Regional Enforcement coordinator has given several training sessions to
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staff on the reAchanges to the 10 CfA ear.LZ_gInforcement_ Dolicy.
y-T The Region has trained all-het.-twoWh inspectors,who are responsible 7
for inspecting radioactive waste activities, in the applicable requirement <
Region V physical security inspectors and their supervisors are attending the ESS sponsored Technolo Transfer Course presented by Sandia Laboratories.
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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 Safguards Section initiated in the first quarter of FY 89, a goal of D#47x[anjalteNte inspector for the fuel facility physical security j
inspections.
In the past, there has been an alternate but the alternate-never/Wr; performed an inspection at a fuel facilitym smUn' Deces6er 1988, the alternate g
accompanied the principal inspector on an inspection of the Category I fuel facili ty.
i In view of the minimal effort which could be directed to transportation inspec-tions using new Core Inspection Program, (CIP) Region.V has programed the performance of the supplemental module (86740) during FY 89 at all operating reactors using the 0.2 FTE additionally provided by NHSS/LLWM.
Region V is to be comended for this very wise use of this idded 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 form is completed by the assigned inspector after an inspection.
It quantifies the status of completion of the various elements of each CIP procedure.
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a RV conducts prelicensing visits on difficult cases. Two examples are the renewals to University of Hawaii and the sole Hawail nuclear pharmacy.
The university is a very large program with the potential for insufficient manage-ment support. The'pharinacy 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.
i l
The Region V Safeguards Section initiated in the first quarter of FY 89, a goal p
M altwwe of ntag an alternate inspector for the fuel facility physical security j
j inspections.
In the past, there has been an alternate but the alternate.never/she {
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performed an inspection at a fuel facilitya In December 1988, the alternate accompanied the principal inspector on an inspection of the Category I fuel f acility.
l In view of the minimal effort which could be directed to transportation inspec-tions using new Core Inspection Program, (CIP) Region.V has programed 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 form is completed by the assigned inspector after an inspection.
It quantifies the status of completion of the various elements of each CIP procedure.
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