ML20057A332
| ML20057A332 | |
| Person / Time | |
|---|---|
| Issue date: | 08/04/1989 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309140028 | |
| Download: ML20057A332 (34) | |
Text
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AUG 0* %
8 MEMORANDUM FOR: John B. Martin Regional Administrator, Region V FROM:
Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
FINAL REGION V NATIONAL PROGRAM REVIEW REPORT By memorandum dated May 6,1989, from Carl J. Paperiello, then Acting Deputy Director, HMSS, the NHSS National Program Review (NPR) draft report, covering FY 1989 for Region V was transmitted to your office for comments. Region V coments were transmitted back to Headquarters by memorandum from Ross A. Scarano, dated May 22, 1989, and have been incorporated in the report.
The final NPR report is enclosed for Region V information. Since the NMSS_ team-approach was effective during this year's visit to the Regions, NMSS plans to continue this approach next year.
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C'kb'5 Robert M. BerneFo', Director Office of Nuclear Material Safety j
and Safeguards L
Enclosure:
As stated DISTRIBUTION:
N FWS NMSS R/F DD R/F NHSS Director R/F R. E. Cunningham
'J. Hickey R. Burnett J. Greeves i
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REPORT OF NMSS 1988 NATIONAL PROGRAM REVIEW AT NRC REGION V, FEBRUARY 21-22, 1989 1.
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material 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 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 on Attachment 3.
The National Program Review (NPR) 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 utilization, 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 NMSS 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 summary in each of the following areas:
1
)
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 Region V currently regulates approximately 300 byproduct materials licensees.
Ir. FY88, they completed 192 cases, as compared against an adjusted Operating Plan target of 180 (107 percent). They received 194 cases during this timeframe.
Through 1/31/89, the region had completed 52 cases, or 25 percent of the annual goal.
(In December, the lead reviewer spent much of the time training others, on annual leave, and in interacting with Agreement States). Since the time of the review, the Region is now slightly ahead of its FY89 licensing target.
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.
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The Region appears on track to meet the new NMSS timeliness goals by the end of FY89. 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-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 in accordance with Standard Review Plans, Inspection Manual Chapters and other guidance documents.
Region V staff has sought guidance via telephone or technical assistance request on matters that are technically complex or may have policy implications.
One particularly difficult Region V 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.
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 placa 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 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 FY88.
Region V completed six licensing reviews in FY88 versus five planned licensing reviews.
Region V has completed two of the four licensing reviews received to date in FYB9 versus the ten receipts and reviews that are projected.
Region V expects year end completions to be commensurate with actual receipts.
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-e Region Y utilizes the NMSS Operating Plan Casework Statistics Report #41 to-inform Headquarters of the licensing casework status on a monthly basis. The FY89 licensing r'eview completion dates have been extended because of other licensing and inspection priorities established by the Region.
3.
INSPECTIONS a.
Materials Inspections In FY88, even though a relatively large amount of resources were spent on the Finlay and US Testing cases,155 materials safety inspections were completed compared to a goal of 156. During the same time frame, Region V estimated that they assisted on 20-30 other inspections of the Department of Agriculture, U.S.
Air Force and U.S. Navy permittees. Through January 1989, the Region has completed 60 inspections. The annual goal is 127, so. Region V is well ahead
'of schedule.
NMSS performed three inspection accompaniments of materials inspections. NMSS staff accompanied one Region V 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 programmatic changes. There was also an awareness of NMSS guidance concerning the medical inspection frequency increase _ and recently issued information notices, indicating that Region V keeps its inspectors well informed.
In general, Region V is employing effective, well-trained inspectors.
b.
Safeguards Inspections Region V met the inspection goals established in the FY88 Operating Plan and in Manual Chapter 2681 for their physical security and MC&A inspections. Region V is current on their FY89 inspection program as outlined by Mr. Burnett's memorandum of August 15, 1988. Region V inspection schedules are forwarded quarterly to Headquarters-in a. timely manner.
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It should be noted that as of February 15, 1989, the MC&A inspection function of Region V 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, comprehensive, technically competent and professional manner.
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 FY88.
In addition, one route survey was performed at the request of Head-quarters. For FY89, Region V has conducted one safeguards transportation inspection of the three that are scheduled in FY89. Region V is therefore current for their FY89 schedule. 0ne route survey has also been conducted in FY89 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 FY88 program and in keeping the FY89 program on schedule. The Branch Management is attempting to recruit a new Fuel Facility Inspector to provide smooth transition with the retirement of the current 5
Fuel Facility Inspector. The new Branch Management should carefully monitor reduced levels of licensees' activities and adapt the scheduled application of inspection resou'rces to the reduced levels. Continued participation by NMSS staff in fuel cycle inspections is judged desirable by NMSS and the Region.
e.
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 of NRC requirements in 108 inspections during FY88.
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.
f.
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 miniral 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.
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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 an inspection and also accompanied the Washington State inspector on an inspection during this review period. The license for the Richland site has been renewed during this review period and the naterials section has worked with NHSS Headquarters staff-during this renewal.
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 full SALP cycle.
BLth 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.
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The Region has trained all inspectors who are responsible for inspecting radioactive wast,e activities, in the applicable requirements. As new vacancies are filled, the selectees will diso need low-level waste inspection training.
Region V physical security inspectors and their supervisors are attending the NMSS sponsored Technology Transfer Course presented by Sandia Laboratories.
5.
INITIATIVES BY THE REGION 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 Y violations is involved, and where the underlying cause has not yet resulted in level III violatiuns. 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, Region V 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 discussed with the Section Chief, who initials the summary sheet.
l For all inspections, Region V 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 j
believes that this encourages development of a cooperative interaction between tne NRC and the licensee, rather than a relationship characterized by i
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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i 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 j
that a two-man team is very effective in such meetings; the license reviewer can discuss technical matters with the R50 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.
In the first quarter of FY89, the Region V Safeguards Section initiated a goal of providing an effective alternate inspector for the fuel facility physical security inspections.
In the past, there has been an alternate but the alternate had not performed an inspection at a fuel facility for three years.
In December 1988, the alternate accompanied the principal inspector on an inspection of the Category 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 programed the performance of the supplemental module (86740) during FY89 at all operating reactors using the 0.2 FTE additionally provided by NMSS/LLWM.
Region V is to be commended 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, i
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6.
NMSS/ REGION V INTERACTIONS Both NMSS and Region Y believe that interactions have been useful and effective in all the areas in inspection and licensing.
Region V has been very responsive to NMSS 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 assignment. This has since beeen completed.
In addition, one NMSS Section Leader participated in a rotational assignment in Region V.
7.
RESOURCE UTILIZATION The table on page 13 shows Full Time Equivalent (FTE) allocations and expenditures during FY88 and FY89 through January 1989.
In FY88, 0.65 FTEs were reprogrammed from the feel facility inspection activity to materials inspections.
With this action, expenditures closely matched the budget allocations.
In FY89, the Region has reprogrammee 1.2 FTE from the safeguards inspection program. Also, 0.6 FTE was repre;- rad to the material areas to increase the licensing effort and 0.6 FTE was transferred to Headquarter's to implement centralization of MC&A licensing and inspection in Headquarters. To date, they are slightly overexpending resources on the materials inspection program (+.21) and slightly underexpending on materials licensing (.21).
Since the Region does not plan to conduct an operational safety team assessment in FY89, it appears that the 0.3 FTE budgeted for that activity may be reprogrammed.
The regional staffing levels line up closely with the budget allocaticns. The Facilities Radiological Protection Section is understaffed by one, but the rest of the DRSS is fully staffed at 30.5 FTEs for FY89. Because of the small size of the various programs, the Sections include only four to six people.
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The Region has good clerical support and the Licensing Assistant supports both the inspection and licensing programs.
Region V has made recommendations to Headquarters to improve the Licensing Management System, but was not aware of a recent Headquarters transmittal on inspection / licensing fees. The review identified some instances where correspondence issued by Headquarters to provide guidance, information, or action to the Region had not reached appropriate staff members.
It seems that the flow of such information from Headquarters to the appropriate staff members could be improved.
The Region makes effective use of computer support systems. Some inspectors generate draf t reports themselves at their personal computers.
Increased com-puter usage is underway, which should continue to improve efficiency of the operations.
8.
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 should revise the 766 system or in some way arrange that Region V receive credit for assisting 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.
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The Regional and Headquarters staff recommends 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.
Region Y believes that 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, pharmaqy, academic, radiography, and general applicability (such as license issuance and termination, licensee name changes, and abandonment).
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FY 88 FY 89 7
Projected Actuall l
Original Revised Actuall Original Current expenditures expenditures budget Budget exp.enditure 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
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Decomissioning 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 l
1 Based on regional supplied RWAT data.
2 Includes effort on allegations and investigations.
30.65 FTE reprogranned 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 decomissioning inspections on reactors.
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__._____--________'______n
e 1989 Region V Program Review - Team Members Walnut Creek - February 21-22, 1989 Glen Sjoblem, 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 ATTACHMENT 1 14
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i REGION 'I DIVISION OF RADIATION SAFETY AND SAFEGUARDS Director - Ross A Scarano Regional State Liaison Officer - oean Kunihiro Health Physicist - State Agreement - Jack Hornar Errergency 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
- Safeguarcs Section
- Douglas Shuster, Chief l
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ATTACHMENT 2 s
i REGION Y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPON nr.ul0hAL QUESTIONNAIRE 1.
Using the current version of your regional staffing plan related to the NMSS program, specify the approximate percentage of time that each individu gal s ends on the following activities: fuel cycle licensng, fuel cycle rneoctiofi., materials licensing, materials inspection, safeguards activities, and inspections of decommissioned facilities and reactors.
See attached chart ATTACHMENT 3
Activities (1)
(% of Time Spent by each Individual)
Chart for Question 1 Fuel Cycle Materials Materials Safeguards Safeguards Name Inspection Licensing Inspection L icens ing Insp. & other Decommissioning R. Fish, Chief EP Section 5
- 8. Br:ck Inspector 100 Other fuel Cycle Inspection S:tpport (Various Inscpectors) 1 FTE II. flurth, Act. Chief EPARP Branch 5
M. Cillis Sr. Rad. Spec.
20 R. Thomas, Chief MMS Section 50 50 J. Montgomery Sr. Matis. Spec.
40 60
- 8. Riedlinger Health Physicist (Lic.)
98 F. Parg 2
R d. Spec.
100
- 0. Skov Rid. Spec.
10 90 P. Zarakowski
- Red. $pec.
75
Chart for Question 1
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Fuel Cycle Materials Ma teria ls Safeguara_
Safeguards
-Name Inspection Licensing Inspection Licensing Insp. & other Decommissioning F. Browne t
Lic. Asst.
50 50 E. Garcia I/R Coord.
5 Schaster, Chief SG Section 10 30 I
L. Msrderhaug Sr. M/C Analyst 40 A. McQueen Phy. Sec.-Spec.
30 O. Schaefer Security inspec.
l 15 G. NeIson
.MCSA Insp.-
80 l
(1) Fuel Cycle Licensing is not done in Region V
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REGION Y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO REGIONAL QUESTIONAIRE 2.
Provide a sumary of actual expenditures and accomplishments as compared to operating plan / budgeted expenditures and accoriplishments, for FY 88 and FY 89 to date.
See attached charts.
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4 REGION Y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMS REGIONAL QUESTIONAIRE 2.
Provide a sumary of actual expenditures and accomplishments as compared to operating plan / budgeted expenditures and accomplisnments, for FY 88 and FY 89 to date.
See attached charts.
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REGION V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RE REGIONAL QUESTIONNAIRE 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 2800?
Fuel Cycle Inspection No changes are needed for FY 89 fuel fabrication inspection program.
Atomics International and/or General Atomics become involved in If decontamination / decommissioning of their facilities, some changes nay be There are no foreseeable barriers to completing the MC 2600 necessa ry.
inspection modules for FY 89.
Materials Inspection No changes are needed for FY 89. The estimated 120 inspections will be completed in accordance with MC 2800.
Materials Licensing The estimated case workload projection ray 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 case?.
The projections are therefore, at present, right on for FY 89.and t I
Safeguards Fuel Facility Inspection Program l
No changes are needed for FY 89.
There are no foreseeable barriers to completing the inspection modules in accordance with MC 2681.
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REGION V KATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-Ig89 FIGIONAL QUESTIONNAIRE 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.
REGION y MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NHSS-1989 REGIONAL QUESTIONNAIRE 5.
Please provide comments on the programs for interaction of Headquarters witn 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 guides, etc., in the interaction programs., standard review plans, 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 cosunon to all regions and headquarters.
Inspection accompaniments are valuable to the headquarters staff in that a better understanding of regional activities 1s obtained.
Reviewer's guides and review plans should be upgraded.
Radiography guides do not address the transportation requirements, the RSO 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 bioassay 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 af ter July 14, 1989? 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 connunicating generic type safeguards issues, problems, and program changes.
We recocunend they continue and that HMSS continue to participate when topics also appear to reflect on NMSS programs.
There have been no safeguards licensing workshops (formerly sponsored by HMSS) since the reorganization splitting materials and reactor safeguards licensing and inspection functions. This was a disappointment as these by 'all regions with the various headquarters elements m 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.
4 FY 89 NMSS PROGRAM ACCOMPLISHMENTS Prograrr Budget Current FTE Ac tiv1:y Allocation Allocation Expenditures Accomplish LLW, Lic. 'nspection
.20
.20 0.00 (3)
Deconni ssioning (Non-Power) 0.10 0.10 0.00 Section Chief 1.00 1.00 0.46 (3) RITS data incorrect
.l Guestion 5 Cont'd.
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An NMSS/SGOB 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 consiceration 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 involved.
Telephone calls on case reviews are nede 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 on guidance contained in the MMSS provided " Safeguards Regional Guidance" Hanual.
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 najor 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 V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSE REGIONAL QUESTIONNAIRE 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 Y Safeguards Section initiated in tne 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 Atontics, a Category I Fuel Facility during December 1988. This allowed accomplishment of all semiannual pro, gram goals in one trip, instead of the usual two trips per semiannual inspection cycle at this fa ci li ty.
It is intended to rotate these two inspectors in nie isture 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, Additional inspectors are scheduled to attend OSRA 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.
1 REGION V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-198g REGIONAL QUESTIONNAIRE 7
Summarize the total number of inspections of Transportation activities at J
MC 2800 licensed program facilities (Procedure 86740) including average staff-hours per inspection and brief sunnary 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. Sumarize 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 The transportation activities under the (Procedure 86740) MC 2800 has 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 DDT 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 O
Safeguards Licensing and Inspection As provided for in the letter from the Director, Division of Safeguards and Transportation, NHSS, 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.
In FY 88, the three inspections indicated for Region V in the "FY 1988 HMSS Inspection Schedule" were one each for: Spent Fuel Imports, Category 11 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.
4
-uestion 7 Cont'd.
The Fh 89 inspection pertained to a Category II shipment be through the Port of Oakland.
- nspection Modules used during Safety / Safeguards Transportation Inspections were 81335, 85301, and 86740.
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 transportation activity at those facilities.
Fuel Cycle Inspection Transportation activities have been inspected (Procedure 86740) at all fuel fabrication facilities within the last year.
Reactor Faciliti,es (MC 2500)
Procedure 86740 has been completed at two Region V facilities (Diablo Canyon and Palo Verde).
Region V facility (Palo Verde). Procedure 86721 has been completed at one Not enough of the Core Inspection Program has been completed to assess the impact of procedure 83750.
FY 89 NMSS PROGRAM ACCOMPLISilMINIS Program Budget Current FTE Activity Allocation Allocation Expenditures Accomgii_shmen ts FC Licensing 0.00 0.00 0.00 None planned FC Inspections 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 32 Materials inspection 2.60 2.70 1.38 Planned inspections 120 Completed inspections 60 Medical Program Improvement
.80
.80 0.00 (g)
Loma Linda VANC 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.
6 Completed SG inspect.
2 (1)
~~~~~
Planned trans. Insp.
3 Completed inspections 1
Budget reduced due to General Atomics and Rockwell contract falling through (1 j 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 ACCOMPLI 5ftMENTS Program Budget Current FIE Activity Allocation Allocation Expenditur_es Accomplishments FC Licensing 0.00 0.00 0.00 FC Inspections 2.30 1.65 1.77 (I}
The inspection program was completed at all fuel FaClitties with minor exceptions.
Materials Licensing 1.38 1.38 1.42 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. S~ 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.
Transportation inspections planned and completed 3
Route survey completed l_
Section Chief 0.60 0.60 1.19 Totals:
8.08 8.08 1/ Includes.22 for FC, 01 and Allegation Support
FY 89 NMSS PROGRAM ACCOMPLISiiHfMIS Program Budget Current FTE Activity Allocation Allocation Expenditures Accomplishments I3I LLW, Lic. Inspection
.20
.20 0.00 Decomiss loning (Mon-Power) 0.10 0.10 0.00 Secti:n Chief 1.00 1.00 0.46 (3) RITS data incorrect i
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FY 89 letSS PROGRAM ACCOMPLIsilMINTS f
Program Budget Current-FTE Activity Allocation Allocation Expenditures Accomphhments,_,
I3I LLW, Lic. Inspection
.20
.20 0.00 Decommissioning (Ison-Power 3 0.10 0.10 0.00 Srction Chief 1.00 1.00 0.46 t
(3) RITS data' incorrect i
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1 1990 NA TIONAL I
PROGRAM i
1 1
REVIEW i
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