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September 27, 1990 f1 MEMORANDUM FOR: Those on Attached List FROM:
Glen L. Sjoblom, Deputy Director i
' Division of Industrial and
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Medical Nuclear Safety, NMSS i'
SUBJECT:
FINAL NMSS NATIONAL PROGRAM REVIEW REPORTS FDR 1990 i
The NMSS reports providing final documentation of the results of the
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National Program Review for 1990 have t,een completed, following incorporation of suggestions from the Regions.
The results had been shared by the NMSS teams during their earlier visits to the Regions. This report is for information and record purposes and a response is thus not necessary, l
Glen L. Sjoblom, Deputy Director Division of Industrial and j
Medical Nuclear Safety, NMS
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Enclosure:
As stated DISTRIBUTION:
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September 27, 1990 MEMORANDUM FOR: Those on Attached List FROM:
Glen L. Sjoblom, Deputy Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
FINAL NMSS NATIONAL PROGRAM REVIEli REPORTS FOR 1990 The HMSS reports providing final documentation of the results of the National Program Review for 1990 have been completed, following incorporation of suggestions from the Regions. The results had been shared by the NMSS teams during their earlier visits to the Regions. This report is for infonnation and record purposes and a response is thus not necessary.
y-G en L. Sjobl Deputy Director Division of In ustrial and Medical Nuclear Safety. NMS
Enclosure:
As stated e
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4 MEMORANDUM FOR THOSE ON THE ATTACHED LIST Dated: 9/27/90 Malcolm Knapp, Director Division of Radiation Safety and Safeguards, RI J. Philip Stohr, Director Division of Radiation Safety and Safeguards, RII Charles E. Norelius, Director Division of Radiation Safety and Safeguards, RIII Arthur B. Beach, Director Division of Radiation Safety and Safeguards, RIV Ross A. Scarano Director Division of Radiation Safety and Safeguards, RV
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REPORT OF NMSS 1990 NATIONAL PROGRAM REVIEW AT NRC REGION I, MARCH 13 - MARCH 14, 1990 1.
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety and Safeguards and Office of Enforcement review of materials programs that were under the responsibility of NRC Region I for 1990.
The National Program Review Manual dated December 11, 1987 outlines the concept and plan for the NMSS National Program Review (NPR) process, and was the basis for the review.
The Headquarters team participating in this review included individuals from each of the program areas under review.
The composition of the team is shown in
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The Regional activities related to materials programs are primarily under the responsibility of the Region I Division of Radiation Safety and Safeguards (DRSS).
A copy of the DRSS organizational chart is shown in Attachment 2.
The Region I responses to an information questionnaire are shown in Attachment 3.
The NPR is based not only on the visit to the Region, but also on the collective Regional / Headquarters interfaces throughout the year.
These interfaces include the review of selected licensing casework and inspection reports, enforcement i
data, the accompaniment of region based inspectors, the review of casework and inspection statistics and resource utilization, technical assistance and coor-
'j dination actions including conference calls, and the information questionnt. ire.
I The NPR precess is intended to provide a review of the effectiveness of both the Region and Headquarters activities insofar as they relate to Region I's activities, and to identify suggestions for improving the effectiveness of the
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collective efforts of NMSS, OE and Region I.
The NPR review emphasizes both numerical goals for licensing and inspection activities and the quality of licensing and inspections efforts, on the basis that both of these elements i
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contribute to assuring the safety of operations involving NRC licensed activities.
This report is organized so as to present an integrated summary of Region I activities in each of the following areas:
1.
Background and Purpose 2.
Licensing 3.
Inspection 4.
Enforcement 5.
Training 6.
Initiatives 7.
Interfaces of Region I and NMSS 8.
Resource Utilization 9.
Recommendations and Suggestions 2.
LICENSING a.
Materials Safety In FY89, the Region completed 87.2 percent and 102 percent of budgeted licensing actions for new licenses and license amendments respectively and 395 percent of the budgeted license renewals.
In total,'the Region completed 116 percent of its budgeted license casework.
The Region's overall performance in the licensing area was enhanced by the large number of renewals started in FY88 that were completed in FY90.
During the first part of FY90, Region I devoted its limited resources to licensing activities and completed about 90 percent of the actions for which it was budgeted through' January 27, 1990.
However, this was at the expense of the inspection program.
Region I has requested a significant change in its Operating Plan because of its staffing shortage and has proposed deferral of 260 licensing actions and 390 inspections.
The Office of Nuclear Material Safety and Safeguards (NMSS) is considering the Region's request.
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9 Region I has made an extensive effort to cross-train its licensing reviewers and inspectors into a single team.
This is extremely helpful if an indivi-dual is sick, injured, or on maternity leave in that it allows employees to return to work part-time to perform licensing casework.
The Region will achieve greater efficiency in licensing as more of its staff become fully qualified and can sign their own licenses without further review.
The senior reviewers seem overloaded with their own licenses and inspections as well as reviewing the licenses and proposed " Notices of Violations" for less-experienced staff.
Delays in reviewing the licensing work of the less-experienced staff deprive them of needed timely feedback and delay their achieving at least limited licensing authority.
Regional management should place high priority on timely review of trainees' licens-ing cases se as to increase, as quickly as possible (without sacrificing safety consicerations), the number of fully qualified staff as well as staff qualified to sign at least some types of licenses.
A select number of Region I licensees' cases were reviewed against NRC Regulations and Standard Review Plans.
The cases are complete; no errors noted. The new two-step nuclear cardiology licensing process seems to be working well, but does involve additional staff resources, and close coordination between the licensee and the staff.
A small sampling of docket files showed that the files were maintained well.
Routing and control of docket files is similar to that of Region IV.
Region I has an excellent system for tracking the status of licensing actions and inspections.
b.
Safecuards Licensing The 10 CFR 70.32 reviews performed by Region I were consistent with NRC guidance and policy. The case reviews were technically complete and performed in a sound mannet.
Region I completed 4' licensing case reviews in FY89 versus 4 receipts.
For the first quarter of FY90, one review has been completed versus one receipt.
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Additionally, the region performed licensing assistance to Headquarters on i
the UNC comparability review which included an onsite visit and a peer review meeting in Headquarters.
i 3.
INSPECTIONS i
a.
Materials In FY89, 1060 materials safety inspections were completed.
The budgeted goal for FY89 was 1073 inspections.
Thus far, through February 20, 1990, 186 inspections had been completed.
The budget mark for that time period is 451 inspections.
The planned number of inspections for the year is 1074.
A root cause for the deficit in the number completed appears to be chronic staffing shortages and the amount of resources expended on recruit-ing efforts and in training of new staff.
The FY 1990 Staffing Plan calls for 25 inspectors and licensing specialists, and as of April, 1990, the total number of on board staff was twenty (sixteen considered qualified).
Furthermore, a concerted effort was placed in the licensing area during the first quarter of this fiscal year to reduce that program's backlog.
Region I also has completed 16 escalated enforcement cases since the beginning of this fiscal year, further expending resources.
As a resolu-tion to the inspection deficit, Region I has prepared a modification to the FY90 Operating Plan.
This was submitted to NHSS as part of the NPR package.
If approved by NHSS, the inspection goal would be reduced from 1074 to 684.
Communications in the Region appear to e good.
The Division Director routinely (approximately once per h) meets with the Division to discuss goals and issues.
The Branch Chief also meets, at approximate one week intervals, with new hires to also discuss goals and general training per-taining to administrative issues, etc.
In addition, Section Chiefs also routinely meet with their respective staffs and in fact one of the Section Chiefs has implemented tecNnically oriented training during his routine meeting with members of his staff.
Section Chiefs' emphasis on inspection effort is currently geared to completion of overdues and inspections of problem licensees.
As of May 7,
l 1990, Region I had The Section A Section Chief has developed a system for scheduling inspections.
This system is updated at quarterly intervals and is developed with input from members of his staff.
Although not as formal, the other two sections also will schedule overdue inspections as the need arises.
For Region I major manufacturers an'd distribution licensees and some of the larger broadscope licensees, it appears that the inspection efforts are preplanned, with sufficient input and discussions with the Section Chief.
It also appears that debriefings are routinely conducted within a very short time after the inspector returns to the office.
Although the staff for the most part indicated good morale, there was some
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comment on the following issues:
I Members of the staff felt that too much time is spent by Section Chiefs briefing the Branch Chief and Division Director on issues, rather than performing Section Chief responsibilities.
Many times j
Section Chiefs are not available simply bcrause thev have spent the l
entire day in " briefings".
Inspectors feel that this is causing a i
" bottleneck" with regard to issuance of reports and license documents since Section Chiefs just do not have sufficient time.
It appears i
that this is especially true during notifications of potential jl enforcement cases. Many inspectors indicated that once a potential j
enforcement case arises, Section Chiefs and the inspector spend an f
extraordinary amount of time debriefing other management personnel at l
various times.
Many people expressed frustra tion regarding this I
matter not only due to the time involved with these briefings, but also from the fact that on occasion the plan of action may change as various managers are briefed.
There was an indication and obvious frustration from many that these briefings on enforcement cases and other significant issues has increased in fre quency and are relying
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heavily on input from*the Section Chiefs who have expertise in those I
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areas.
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On a similar issue, with regard to Section Chief responsibilities, many felt that the senior staff have been overburdened with the training of new staff.
They feel that this responsibility of training is that of the Section Chiefs but due to their inability to serve as such, this responsibility is being given to the Senior staff, thus increasing workload on them.
The staff felt that mandatory overtime, as was recommended by the Region, would not be a good idea at this time.
They felt that if in the future Section Chiefs would be relieved of some of their " briefing management responsibilities" and could get back into a supervisory role, overtime may help out.
With regard to recruiting of new staff, many staff members felt that an extraordinary amount of time was spent in this area by management personnel and thus far has not been that productive.
They further felt that when potential candidates are brought in for a " presentation" that this is a waste of time and also an increased pressure placed on the candidate. No one really demonstrated the benefit of having the candidate put on the " presentation".
b.
Fuel Cycle Inspections The Effluents Radiation Protection Section of the Facilities Radiological
-Safety and Safeguards Branch has the primary responsibility for the fuel cycle inspection program, while HMSS Section B inspects other source material licensees.
During FY89 the fuel cycle inspection program was effectively completed.
To date for FY90, the program:is satisfactory in all areas.
However, it has been perturbed by the 3-month assignment of one inspector to other duties, and by the occurrence of leakage at Cintichem which required appreciable Region I resources.
HMSS licensing staff membeFs participated in several fuel cycle inspections during the past year and fnund the inspectors to be conscientious and thorough and well prepared for the inspections.
In addition, the inspec-tions were complete and consistent with NRC policy and guidance.
The NMSS 6
l participation in the inspections is considered to be beneficial and worthwhile.
A review of several inspection reports determined that the reports communicated well the results of the inspections and were in accordance with Manual Chapter 0610.
c.
Safeguards Inspections Region I performed 4 safeguards inspections and one team inspection in FY89.
One inspection has been completed during the first quarter of FY90.
Before the MC&A inspection function was consolidated to Headquarters on February 15,
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1989, Region I completed 5 MC&A inspections which included 3 team inspections with Headquarters personnel.
Region I staff provided valuable assistance during the MC&A transfer process.
I The safeguards and MC&A inspections were conducted in a thorough and technically competent manner.
The Region I reports were completed in a timely manner and submitted to Headquarters.
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I d.
Safeguards Transportation i
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Region I comnleted 2 safeguards transportation inspections versus the 4 R<
scheduled for FY89.
As in previous years, a number of shipments were can-l celled or postponed and consequently, the inspections also had to be can-celled.
Additionally, the spent fuel imports were put on hold by DOE pending environmental impact studies.
Two route surveys were performed l
at the request of Headquarters.
In FY90,:two safeguards transportation inspections have already been completed along with one route survey.
e.
Transportation Inspections Region I continues to cond6ct inspections of transportation activities at
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materials licensees using module 86740.
Although the Region could not pro-vide a convenient way of extracting the information requested ahead of the NPR, a review of 2 recent inspections (Lucius Pitkin and Washington l
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Metropolitan Area Transit Authority) revealed the transportation activities are not included in routine inspections.
According to staff, module 86740 is always used for materials inspections.
Although an exact number of violations regarding DLT issues was not available, staff indicated the majority of violations of DDT regulations pertained to shipping papers.
The gauge user licenses typically are those where violations are identified.
4.
ENFORCEMENT f
a.
Background and Purpose This report provides the results of the Office of Enforcement's (DE) participatinn in the NMSS National Program Review.
OE's review involved primarily the Region's treatment of recurring violations, exercise of discretion under V.G.I. of the Enforcement Policy and Severity Level V violations.
b.
Treatment of Recurring Violations In response to the Office of Inspector General (OIG) recommendations in a draft report in the enforcement process, the Director of Enforcement requested among other things in a memorandum dated August 2, 1989 and made final by memorandum dated August 30, 1989 (EGM 89-09) that each region prepare writtr..) instructions to assure that Severity Level IV and V viola-tions for maierial licensees are properly reviewed to determine whether they represent a significant management breakdown (Severity Level III problems) or are repttitions and, if so, appropriate enforcement actions are con-sidered.
The regional instructions were to be prepared and submitted to OE within 90 days along with plans for training of regional personnel within six month of issuance of the regional instructions.
Written instructions were prepared and submitted to OE within the 90 day time limit. These instructions were recently revised on January 9, 1990 (See
Enclosure:
Region I Instruction 1320.1, Revision 2 (RI 1320.1/2)).
Formal training has been given to the regional materials staff on repeat violations in the last year.
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Discussions with materials inspectors and Section Chiefs indicated that licensee's inspection history is reviewed prior to inspection.
Should repeat violations be identified during the inspection, they are emphasized and discussed with the licensee at the close of the inspection.
Upon return to the Region, the violation identified and any repeat violations are discussed with the Section Chief.
Repeat violations are documented in draft field notes or formal insp~ection reports.
Region I has had a long-standing policy to identify repeat violations in cover letters transmitting the NOV to the licensee.
The Nuclear Materials Branch maintains a computerized dBase file of outstanding (or open) items for each licensee.
Repetitive violations, non-cited violations and open items are tracked in this file.
Region I is the only region which uses such a computerized system.
Use of the dBase file allows an inspector to quickly review the licensee's enforcement history prior to inspection.
OE's review of approximately 50 inspection letters indicated that repeat violations are being identified.
Regional Instruction RI 1320.1/2 is being followed.
Region'I has issued civil penalties for repetitive Severity Level IV violations in the past, as part of an escalated enforcement (aggregate Severity Level III) and at Severity Level IV.
Enforcement Discussion V.G.1 and Severity Level V Violations c.
i Written instructions regarding this topic are found in Region I Instruction 1320.1, Revision 2.
At least four training sessions for the materials staff during the last year have covered this subject.
Discussions with the materials inspectors indicated they are aware of and have used enforcement discretion for non-cited violations (NCVs).
NCVs are documented in the inspsctor's field notes and placed in the computerized dBase file for the individual licensee.
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d.
Other Tonics Reviewed Audits of non-escalated action:
The Region has recently begun a peer review of inspection reports and violations.
Several reports and/or NOVs are selected and assigned to a Senior Health Physicist for review.
In addition, the Enforcement Officer was recently assigned the duty of auditing routine enforcement actions for proper citations, NCV's, repetitive violation documentation in cover letters and the classification of the violation at the correct Severity Level.
Proofreading Determination of qualifications of new physicians, physicists, R50's, radiographers, etc. during the inspection Model Citations 35.999 Transition Policy Communications Records Violations Report Writing Information Notices 5.
TRAINING a.
Materials The Region is continuing its efforts in the pursuit of trairiing for all technical staff.
The goal is for qualification of all starf for licensing and inspection in all areas.
IDP's are routinely used for all employees and qualification journals are also beingeused.
The training of new staff this fiscal year appears to have been conducted primarily by senior members of the staff.
This may be due in part to other responsibilitics of the Section Chiefs.
However, as an excellent initia-tive, the Branch Chief has' routinely met with the new hires.
In addition, one of the Section Chiefs has initiated, as part of section meetings, a technical issues type of training for all interested materials staff.
Feedback on this training is favorable.
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l The new hires appear to be routinely accompanying senior staff during inspection related activities and plans are in place to have these indivi-duals conduct independent inspections with direct observation by their respective Section Chief.
If the audit is deemed favorable by the Section Chief, the individuals will be given " interim authorization" to conduct some independent inspections prior to completing their qualification journal.
The team was unable to review records of the actual training of inspectors and reviewers due to a problem with the computer system in the Region which maintains that information.
Therefore, the Region was not able to provide a matrix showing courses attended by each technical staff member.
Interviews with the staff indicated that, due to their Section Leaders' heavy workload, their requests for courses are not always processed in a timely manner and they sometimes learn of courses too late to request attendance.
The Region should consider the appointment of a Divisional I
training coordinator who could keep current on course offerings, match courses with staff members through their 10Ps, and ensure that administrative procedures are completed so that staff can attend desired Courses.
b.
Fuel Facility The fuel cycle inspectors expressed a wish for greater access to training in specialized areas such as criticality.
They also indicated thet accom-panying fuel cycle facility inspections in other regions would broaocc !%ir experience and give them a needed opportunity to exchange ideas with the other members of HRC's small group with expertise in this area.
It was also recommended that further training beeprovided for dealing with the submittals of financial assurance for decommissioning due July 27, 1990.
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c.
S_afeguards l
The Region I safeguards inspectors attended the Physical Protection System l
(PPS) courses at Sandia Laboratory.
Additionally, Region I provided train-ing to one inspector with his participation on the HMSS Team Inspections.
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This training helped the inspector receive his safeguards certification in FY89.
Finally, four members of the safeguards staff attended the Security Training Symposium sponsored by NMSS in the first quarter of FY90.
C.
Initiatives Region I's use of the two-step license for radiopharmaceutical users (which was noted earlier and in the report on the March 1989 review) is valuable but should be refined to minimize impact on staff resources.
Region I reviewed the standard license conditions used by all license reviewers and has recommended additions and other changes.
Region I has developed a generic license for nuclear gauges and submitted it to NMSS for review.
If adopted, the generic license could reduce the number of amendments.
Region I conducted ten workshops at different locations in the Region to inform medical licensees of regulatory requirements and NRC's expectations of them.
The Region identified Safety Light as a licensee needing increased attention because of long standing contamination on site.
The Region is commended for its follow-up efforts in this case and its support during the on going hearing and negotiation process.
The Region is also commended for its prompt response to the unscheduled source received at Amersham _ Corporation and the participation of one of its section chiefs in the subsequent Incident Investigation Team.
The Region is further commended for the extensive efforts of technical staff to recruit new staff.
Although the Region has not yet filled all-vacancies, its new staff appear to be knowledgeable and enthusiastic.
The Division currently has a requirement that candidates make a 30-minute
" presentation" before a number of NRC staff during interviews.
The current staff members felt this process was scaring qualified professionals away from the Region. This staff perception deserves consideration.
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l Development of a more forman scheduling system for inspections (Limited to Section A thus far).
Development of additional training given by the Section Chief (Section A) on technical issues.
4 Region I is to be commended for its' support of the Headquarters led team inspections of the 3 Category I fuel facilities in FY89 with one inspector at each site.
Moreover, the region worked closely with Headquarters on the UNC comparability upgrade to insure a comprehensive and inspectable security plan.
Region I has increased the use of team inspections at fuel cycle facilities which have real or perceived problems (i.e., Combustion Engineering Inc.,
and Cintichem) to assure the best use of available manpower and expertise.
The Region responded commendably to the leakage event at Cintichem.
Region I is realigning the work of the Effluents Radiation Protection Section to include facility oversight of non power reactors.
Region I's existing dBase tracking system is used to track repetitive violations and NCV, for each licensee.
Region I has instituted an audit program both in the NMSS Branch and at the Enforcement Officer level to review non-escalated enforcement actions.
7.
NMSS/ REGION I INTERACTION Interaction between Headquarters and the Region has been very good.
The counterpart meetings and workshops and inspection accompaniments scheduled during FY90 should foster this interaction.
4 Region I has made many excellent generic contributions to the national program in the materials safety area.
For example, Josephine Piccone is participating in the Pilot Program on Medical QA and John Miller is assisting with the review 13
of guides being developed to support the new 10 CFR Part 20.
When Region I is fully staffed, we hope that even greater use can be made of Region I expertise in developing contributions to the national program.
In general, communications have been good between Headquarters and the Region in the fuel cycle area.
The Region expressed a wish for quicker turnaround in response to Requests for Technical Assistance, and failing that, a more accurate projection of the expected time to the response.
Headquarters expressed the need for a written trip report on inspector reviews of activities at the West Valley Demonstration Project.
a.
NMSS/ Regional Interface The Region has requested that Headquarters keep them appraised and updated of the NMSS long range plans / goals on a more frequent basis.
This would conceivably be done by conference meetings or calls.
HMSS needs to address:
1.
RI's comment that additional lead time is needed for Materials Conference Calls Material Conference Calls are the 1st Tuesday of every month; IMAB secretary queries Regions for agenda topics 7-10d in advance of call, which should be sufficient.
2.
RI requested a TAR tracking system for quarterly status report.
This will be provided.
3.
RI's desire for a system to account for time spent by supervisors /
managers on escalated enforcement actions - PMDA respond (?)
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8.
RESOURCE UTILIZATION a.
Expenditures and Staffina The attached table shows FTE allocations and expenditures for the review period.
Region I has no program support funds in the HMSS mission areas.
Overall, resources for FY 1989 were slightly underexpended due Region I to being understaffed.
This same trend is continuing in FY 1990 for the In January, resources are underexpended by approximately 15 same reason.
percent.
The Region has initiated extensive recruiting efforts to hire staf f in the materials area.
Region I suggested in the material submitted for the National Program Review and by memorandum dated April 18, 1990 that a revision would be made to the resource allocation effort in materials licensing and inspections due to the severe shortage of staff.
Beginning in FY 1990, Region I staffing for the Nuclear Materials Safety Branch (HMSB) was 21 technical versus a budget of 26.1 FTE funded by NHSS.
In an effort to fully staff the Division, starting with FY 1990, Regional and Division management detailed a NMSB Section Chief and two staff members, one from each section, to work full-time for three months recruiting.
A senior health physicist in HMSB was detailed to replace the Section Chief.
In essence, NMSB lost two experienced staff from their normal inspection /
licensing duties, and also lost the services of an experienced Section Chief.
In November, two individuals recruited in FY 1983 joined the staff at Grade 11.
During the month of December, a Grade 12 individual joined the staff and one qualified, experienced member transferred to Region II.
In January 1990, another individual joined the staff and in February, one inspector transferred from the Facilities Radiation Protection Section to HMSB and two qualified experienced inspectors transferred from NMSB to Region II and USDA, respectively.
A highly qualified and experienced staff member died in February.
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Recruiting since the beginning of FY 1990 has been moderately successful.
Recently, two offers for positions in the Branch were accepted.
Several excellent candidates declined job offers.
NMSB is approximately 20 percent understaffed.
Thus, as of mid-February, the staff projection for the near future (i.e., once all new hires are on board) remains at about the same level as at the beginning of FY 1990.
A GG-13 Health Physicist (HP) is currently doing filing work in the Docket Rocm.
Approximately one-fifth of the HP's time per week is used for this effort.
This effort should be converted to licensing and inspection.
NMSS recommended that Region I continue to aggressively recruit and hire due to the increase of projected materials inspections in FY 1991.
b.
Administrative Support Feedback from materials staff indicates that:
The typing pool support is quite good.
The travel support is quite good.
The administrative staff support to recruiting has been poor in the past but has improved.
c.
Support From Headquarters Region I staff would like additional training for travel staff (specifically offer Division of Contract course on "Small Purchase").
Region I staff suggested that the imprest fund be replenished sooner than current turnaround time (currently takes a week to 10 days).
To allow inspectors to receive the advance more efficiently.
Region I staff suggested improved turnaround time for travel checks issued (usually takes about 10 days) to improve efficiency and more timely issuance of travel checks.
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RECOMMENDATIONS The Region should continue aggressive recruiting for the foreseeable future, as planned.
The Region should streamline its operations to allow overloaded senior reviewers and Section Chiefs more time to work with less-experienced staff (e.g., hold fewer one-on-one briefings; to allow decisions to be made at the lowest possible level).
Additional administrative / clerical staff should be directed to maintaining docket files, rather than using 6-8 hours a week of a GS-13 technical staff member's time.
As positions become vacant in the materials area, the Region should attempt to promote from within.
This would aid in rising expectations by the technical staff.
The Region should continue to acquire additional personal computers for each of the materials' technical staff and provide computer training, as needed, in order to improve licensing as well as inspection efficiency.
One person within the Division should be assigned to serve as a-training coordinator to assist in the planning and prioritization of training and maintain a Division tracking system for completed training.
A training completion matrix should be developed for the MC 1245 required and supplemental courses.
The Region should consider developing a procedure for-the scheduling of inspections which would be used consistently throughout the materials sections.
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A formal waiver document should be used for those inspectors given authorization to conduct inspections prior to completion of their i
qualification journal.
The Region should consider developing and implement a system to eliminate many of the debriefings with regard to enforcement actions.
Also, consider the use of an enforcement board to brief all necessary staff and Division members at the same time.
NMSS and Region I concluded that the fuel facility safety and safeguards staff will need to direct more time and effort to adequately monitor the
" phase-out" of the UNC operation.
It is conceivable that the licensee's safeguards and safety program will be changing on a frequent basis.
This will then necessitate expenditure of resources for site visits to evaluate potential security plan changes in addition to the normal safety and safeguards inspection activities.
Region I recommended that OE should issue Model Citations which have been approved by OGC as acceptable / legal to reduce editing of citations.
OE should continue to review non escalated actions and develop a more formal review to give feedback to the Regions.
The Region requests some generic, specific feedback on enforcement package revisions made by OE.
The Region feels somewhat frustrated and considers that they produce acceptable enforcement packages which should not need extensive revisions.
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REGION I RESOURCE UTILIZATION The following table shows FTE allocations and expenditures for the review period FY90 FY89 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDEO BUDGET OCT-JAN OCT-JAN. %
Fuel Facility Licensing 0.12 0
0.04 0.01 0
0 Event Evaluation 1.5 1.8 120 1.9 0.6 0.83 138 Materials Licensing 6.0 9.8 163 7.7 2.6 4.4 169 Materials Inspection 17.3 11.3 65 15.5 5.2 1.9 37 Fuel Facility Insp.
3.9 2.5 64 3.0 1.0 0.8 80 SG Fuel Facility Lic.
0.1 0.4 400 0.06 0.02 0.1 500 SG Fuel Facility Insp.
0.8 0.5 63 0.4 0.1 0.1 100 SG Transportation Insp.
0.2 0.1 50 0.2 0.06 0
0 LLW Inspection 0.25 0
0.25 0.08 0
0 Reactor Decomm.
0.1 0.1 100 0.2 0.07 0
0 Materials Decomm.
0.5 0
0.5 0.2 0
0 NMS Section Supv.
3.4 3.5 103 3.5 1.2 1.3 108 NMTS Section Supv.
0.2 0.1 50 0.1 0.03 0.03 100 TOTAL 34.4 30.1 88 33.4 11.2 9.5 15 NOTE:
FYB9 expenditures from Regional input provided in response to FYP/ Green Book update in 12/89.
.g.
/
1 Rec'A 3/7/90 c
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REGION I
NMSS PROGRAM i
I N FO R M ATIO N FOR 1990 N ATIO NAL l
PROGRAM R EVI EW 4
r 1 a u-
~ -
.i Q U ESTIO N 1
SPECIFY PERCENTAGE OF TIME STAFF SPENDS ON N M SS ACTIVITIES.
TABLES FOLLOW FOR:
- MANAGERS AND SUPERVISORS
- NUCLEAR MATERIALS STAFF
- SAFEGUARDS STAFF
- FUEL CYCLE STAFF
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w-REGION I FEBRUARY 1990 DIVIS10010F RADIATiest SAFETY AhD SAFE 00AltDS Malcolm R.
Mnepp. Di rector - 5283 Richard W. Cooper, 11. Deputy Division Director - 5281 (eff 4/1/90)
Jones H. Joyner. Olvision Project Manager - $370 Constance M. Yueko, Secretary - 5274 FActLITIES RADIOLOCfCAL SAFETY AleD SAFE 93.*_"3" *=_" w nonald R. Selleay - Chier - 5200 Sha ron Law Johnson - secretary - 5395 Michele Kirkner - Office Assistant 5072 SAFE 0MARDS SECTiGE W. 8.azerwe, Chief - $208 R. seres. Chier - 5213 W. Pesclek, Chier - 52S8 R. Nelsig, Chier - SESS C. Amste = $394 M. Austin - 5390 D. Chewege - 5082 R. Athert - 5268 C. Conktle - $342 J. Furia - 5041 T. Dragoon - 5373 A. Dette Retta - $273 E. Fox - SO44 J. Jong - 5220
- m. Nimitz - 5267 T. Dexter - 5374 C. Garden - S372 J. Motten - 5214 P. O'Connel8 - 5054 W. Lancaster - 3074 F
F. Lepreett - 5391 st. McNamare - 5337
- s. Shortlns - 5259
- 0. Smith - 5263 R. Summers - 5083 J. Roth - 5205 D. Vlte - 5323 R. Struchmeyer - 5300 i
ItWCLEAR MATERIALS SAFETY RfWueCH Lee M. Dettenhausen - Chler = $251' I
CePro8I Armstrong - Seeretery - 5244 mA MS IntSS C LICERSIMIB ASSISTAME SECT.
St. shentnehar, Chief = 5809 J. Minnemen, Chler - 5252 -
J. Wtite. Cheer - 5102
- c. Fester, Chief - 3839
- s. cour+====aane - S$7S F. Coste le - 5275 J. Owyer - $309 R. erown - 5260 T.. careen - S245 C. Eckert - 5364 A. Mirkweed - SOSO C. eureateer - 3093 J. Orosi ete - 53e3 T. Otserg - 5202 R. Ladun - $375
- m. Junod - 5117 l
J. Jewette -
7 C. Retter - 5276 -
J. Mi l te r. - 5304 E. Watts - 5398 J. Picoene - $169 E. Ull rich - 5040 C. Roberts - 5272 M. Wolsenberger - 5313 i
- c. schultaphomp - 3078 M. Taylor - 5311 J. Stanheugh - 6904 W. Thomas - 5043 l
L. Tripp - $471 T. Theepson - 5303 l
l omss ConruTut noon #Nies - 6910 oms 3 FAK 346-S369 eras coser noen - 5367 m
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NMSS 1990 REGIONAL QUESTIONNAIRE Q1-NMSB-R1 STAFFING PLAN - PERCENTAGES OF TIME SPENT IN MATERIALS AND FUEL CYCLE LICENSING AND INSPECTION (FOR MANAGERS AND SUPERVISORS)
NAME TITLE
%NMSS TIME M. R. Knapp Director, DRSS 60 l
J. H. Joyner Div. Project Manager 90
{
i R. R. Bellamy Branch Chief 30 l
L. H. Bettenhausen Branch Chief 100 l
J. D. Kinneman Section Chief 100 M. S. Shanbaky Section Chief 100 J. R. White Section Chief 100 D. J. Foster Section Chief 100 R. J. Bores Section Chief 40 W. J. Pasciak Section Chief 20 R. R. Keimig Section Chief 40 W. J. Lazarus Section Chief 0
l l
L l
I
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NMSS 1990 REGIONAL QUESTIONNAIRE Q1-NMSB-R1 STAFFING PLAN - PERCENTAGES OF TIME SPENT IN MATERIALS LICENSING AND INSPECTION (FOR TECHNICAL STAFF ONLY):
NAME
% INSPECTION
% LICENSING Section A Piccone, J. M.
20 80 Gresick-Schugsta 60 40 Darden, T. H.
15 85 Courtemanche, S. R.
60 40 Joustra, J. A.
20 80 Tripp, L. M.
10 90 Schulingkamp, C. M.
20 80 Stambaugh, J. V.
20 80 vacant vacant [FTE hire]
Section B Costello, F. M.
45 55 Davis, J.
S.+
0 100 Oberg, C. T.
25 75 vacant Ullrich. E.
50 50 Eckert, C. (11/12/89) 15 85 Reber,E.(11/20/89) 80 20 vacant Section C Miller, J. J.
85 15 Thompson, T. K.
40 60 Ladun, R. H.
100 0
Collins, O. J. (to RII) 70 30 Taylor, M. J.
70 30 Kirkwood, A. S.
60 40 Dwyer, J. (12/18/89) 40 60 G. (1/14/90) 0 100 Roberts (FTEhire]
vacant We do not have a detailed breakdown of the time spent inspecting decomissioned facilities, because this time is mixed with action on the new decomissioning rule. While this is an important activity it consumes less than 5% of our resources.
NMSS 1990 REGIONAL QUESTIONNAIRE Q1-FRSSB-R1 STAFFING PLAN - PERCENTAGES OF TIME SPENT IN FUEL CYCLE LICENSING AND INSPECTION (FOR TECHNICAL STAFF ONLY):
NAME AREA
%IN FY 89
%FY 90 Mike Austin Project 61.3 9.0 Don Caphton QA 5.1 3.3 Craig Conklin EP 3.0 Art Della Ratta '
MCA/P.S.
40.2 8.1 Tom Dexter P.S.
13.8 Tom Dragoun HP 4.8 Pete Drysdale Operations 4.3 4.8 Joe Furia HP 2.3 Craig Gordon EP 1.5 1.5 Jason Jang HP 29.4 Jim Joyner Project 17.8 17.1 Herb Kaplan Welding 5.3 4.5 Bill Lancaster P.S.
5.3 Nancy McNamara HP 8.4 Ron Nimitz HP 2.9 Peter O'Connell HP 6.7 Mike Oliveri Welding 3.8 Jerry Roth Project 100 100 Greg Smith P.S.
18.1 22.8 Jim Trapp Operations 7.5
'e Q U ESTIO N 2
PROVIDE
SUMMARY
OF ACTUAL EXPENDITURES AND ACCOMPLISHMENTS COMPARED TO PLAN N ED EXPENDITURES AND ACCOMPLISHMENTS FOR FY89 AND FY90 TO DATE a
w e
REGION I FTE EXPENDITURES BUDGET VERSUS ACTUAL FY 89 FY 89 FY 90*
FY 90*
Budget Actual Budget Actual (FTE)
(FTE)
(FTE)
(FTE)
Materials Licensing 6.60 11.16 2.67 4.36 Materials Deconmissioning 0.50 0.18 0.17 0.00 Total 7.10 11.34 2.84 4.36 Materials Inspections 18.8 14.88 6.03 2.69 Fuel Fac Health & Safety 2.20 1.93 0.47 0.67 Fuel Facility Licensing 0.30 0.04 0.02 0.04 Safeguards Inspections 1.04 0.44 0.26 0.08 West Valley 1.000 0.95 0.33 0.17 Total 4.54 3.36 1.08 0.96 FY 89 FY 89 FY 90*
FY 90*
Budget Actual Budget Actual (number)
(number)
(number)
(number)
Materials Inspections 1,073 1,060 374 133 Fuel Facility Inspections 31 42 11 12 Materials Licensing New Applications 250 218 81 49 Amendments 1,110 1,131 384 341 Renewals 83 328 140 165 Total 1,443 1,677 614 555 Safeguards Amendments 8
4 1
0
- EXPENDITURES THROUGH JANUARY 27, 1990
L FUEL CYCLE &
MATERIALS LICENSING FY 1989 EXPENDITURES FOR NMSS PROGRAMS LEGEND ACTUAL THRU 09/23 so--
_ BUDGET== 7.22 FTE is--
14- -
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FUEL CYCLE &
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__ BUDGET = 23.99 FTE 88"~
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C MATERIALS NSo EC T ONS FY 1989 THRU OCTOBER 1,
1989 (LESS 591'S)
'[1 FINDINGS:
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VIOLATIONS i
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_ L OCT DEC FEB APR JUN AUG NOV JAN MAR MAY JUL SEP MAM MONTH
MATERIALS LICENSING ACTIONS FY 1989 THRU OCTOBER 1,
1989 LEGEND:
voo-638 BACKLOG 638 595 soo 555
,9 goo..
NEW/ AMEND 54s /
eso
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o g<4co-s2a FY 89 COMPLET10NS s14 sos 330 30,
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FUEL CYCLE &
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,/
ACTUAL THRU 1/27 s- -
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_ BUDGET== 8.32 FTE 7--
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h MATERIALS LICENSING ACTIONS FY 1990 THRU FEBRUARY 1,
1990 LEGEND:
ACKLOG foo..
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_ NEW/ AMEND 655 eoo--
M COMPLETIONS NEW/ AMEND g
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inh 309 310 300 o 3oo.
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o OCT DEC FEB APR JUN AUG NOV JAN MAR MAY JUL SEP MATLLIC MONTH
MATERIALS INSPECTIONS FY 1990 TH RU FEBRUARY 1,
1990 (LESS 591'S) 2 FINDINGS:
NONE 1so- -
169
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__..___ AVG DAYS VIOLATIONS 3 140-l l
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1 OCT DEC FEB APR JUN AUG NOV JAN MAR MAY JUL SEP MATLS MONTH
MATERIALS INSPECTIONS FY 1990 THRU FEBRUARY 1,
1990 INSP TYPE:
p; 591 33 I
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Q 1990 National Program Review Safeguards Activities Number of Inspections FY1990'(1stQtrl FY 1989 Material Control Physical Material Control Physical
& Accounting Security & Accounting Security Facility 3
2 0
1 UNC-NPD,Montville I
1 0
0 Cintichem, Inc.
1 0
0 1
Combustion Engineering, Inc.
1 0
0 1
Eastman Kodak 0
1 1
0 SUNY, Buffalo 1
0_
0 MIT Cambridge J.
6 1
2 Total 7
Regional Initiatives /
Special Team Inspections 1
0 0
1 NFS, West Valley 1
0 0
0 UNC-NPD, Montville 1
0 0
0 NFS, Erwin Total 1
3 0
0 FY 1989 FY1990(1stQtrl Transportation Inspections _
2 0
Worcester Polytechnic Institute 1
0 Route Survey-Limerick /8&W, Lynchburg 1
0 Route Survey-Calvert Cliffs Chalk River Total 4
0 T
1990 National Program Review Safeguards Activities Fuel Faciltty Licensing Activity FY 1990'(1st Qtr)
FY 1989_
Facility Date Received Date Closed Date Received Date Closed 2/27/89 3/3/89 0
0 Cintichem. Inc.
Withdrawn Opened 12/31/89 UNC-NPD, Montville 12/28/88 9/14/89
- 11/21/89 Closed 1/31/90 9/22/88 12/22/88 Comparability Upgrade Plan Change
- Closed by Headquarter's Letter dated 1/31/90.
ROI expended resources to review plan in the Regional Office, to partic a peer review in Headquarters and to perform a review onsite.
4
. ~ -
e' W
Q L' ESTlO N 3
l ARE ANY CHANGES NEEDED IN PROJECTIONS I
FOR THE CURRENT FISCAL YEAR?
ARE THERE FORESEEABLE BARRIERS TO COMPLETING INSPECTION MODULES IN ACCORDANCE WITH MC2600 AND MC2800?
_ = _ -
NMSS 1990 REGIONAL QUESTIONNAIRE Q3-NMSB-RI MATERIALS Chronic staffing shortages caused by transfer and turnover, combined with considerable diffi:ulty in recruiting health physicists, result in failure to meet budgeted goals in both licensing and inspection for FY90. A concerted effort was made in the first quarter of FY90 to keep abreast of licensing; this was done, but at ',he expense of inspection completions. A realistic projection of staff resources shows that only about 60% of the licensing and inspection goals can be met. The analysis which follows summarizes the original FY90 goals, discusses the present staffing concerns and projections, and proposes revisions to the FY90 goals that reflect the staffing projections.
Table I lists the budgeted goals and tne FTE allocated in accordance with the Labor rates used in the budget projections. These work product goals were very similar to the results achieved in FY89. The FY89 goals were achieved with a staff which remained relatively stable until two staff members left in June and then two more in September. These staff losses and several others made known, along with difficulty in recruiting, caused Division and Regional management to devote considerable resources to recruiting at the expense of licensing and inspection in order to obtain the needed numbers of new staff.
These resources were committed early in the Fiscal Year.
Table II summarizes the staff deficits. These deficits result from unfilled positions, recruiting efforts, and the new staff training along with its impact upon current staff. These deficits are estimated in a different way later in this analysis. The result of the analysis of staffing and staff deficits is shown in Table III. Table III lists the achievable goals for FY90 as well as those actions that will not be completed. The achievable goals require a proposed FTE of 17.7.
This will require nearly 1 FTE of overtime to achieve the listed goals.
The analysis now ores on to discuss the staffing situation in detail, the staff deficit in terms of productive hours, and the reasons for selecting the reductions of efforts as shown in Table III.
First, the staffing situation should be understood. The Nuclear Materials Safety Branch (NMSB) began FY90 with 21 technical staff members filling the 25.6 positions funded by NMSS.
In an effort to fully staff the Division, in October 1989, Regional and Division management detailed a NMSB Section Chief and two staff members, one from each Branch, to work full-time for three months recruiting. A senior HP in NMSB was detailed to replace the Section Chief.
Thus, NMSB lost two experienced staff from their normal inspection / licensing duties, and lost the services of an experienced Section Chief. Subsequently, in November,1989, 2 individuals recruited in the summer of 1989 joined the
4 s
TABLE I BUDGETED G0ALS LICENSING' ACTIONS NUMBER FTE ALLOCATED New 235 1.2 Renew 430 3.0 Amend 1110 3.3 T775 7.T INSPECTIONS Priority 1 240 3.2 Priority 2 75 1.0 Priority 3 240 3.1 Priority 4 175 2.2 Priority 5, 6, 7 200 2.6 New Licenses, Reactive 144 1.9 1.7 Military, radiography, etc.
1574 1U ALLi.GATIONS, INVESTIGATIONS 0.7 ENFORCEMENT 0.9 NATIONAL PROGRAM REVIEW 0.3 DECOMMISSIONING 0.5 2G t
n h
TABLE II
SUMMARY
OF STAFF DEFICITS B UD G ETE D FT E.................................... 2 5. 6 DEFICITS New S ta f f Trai ni ng.......................... 3.0 Current Staff Giving Training............... 0.9 Inef fi ci ency of New Staff................... 0.5 Recruiting.................................. 1.5 Unfilled FTE................................ 2.8
- BT7 FTE AVAILABLE FOR PRODUCT IVE E FF0RT............................... 16. 9 l
i
)
i 1
l 4
i
- These deficit figures are not comparable to those used in the readjustment of goals; these are estimates for the fiscal year, whereas the hour estimates j
start from the situation in March, 1990.
)
1
t TABLE III ACHIEVABLE G0ALS TO BE DONE DEFERRED LICENSING ACTIONS NUMBER NUMBER FTE PROPOSED New 200 35 1.0 Renew 200 230 1.4 Amend 810 30-0 3.3 Tff5 li6!i U
INSPECTIONS Priority 1 240 3.1 Priority 2 75 0.9 Priority 3 152 74 2.0 Priority 4 80 96 1.0 Priority 5, 6, 7 20 180 0.3 New Licenses, Reactive 115 20 1.5 1.5 Military, radiography, etc.
lie 2 375 1D EVENTS, ALLEGATIONS, ENFORCEMENT 1.5 DECOMMISSIONING 0.2 177
)
i
2 Q3 staff at Grade 11. In December, a Grade 12 individual joined the staff and a qualified, experienced member transferred to Region II.
In January, 1990, a grade 7 individual joined the staff.
In February one inspector was transferred from the Facilities Radiation Protection Section to Materials Safety Section C, and two qualified, experienced inspectors transferred to other offices, one to Region II and one to USDA. A highly qualified and experienced staff member died the same month.
Recruiting since October,1989, has been moderately successful. Two offers for positions in the Branch recently were accepted, but the process of clearing and bringing them on board is lengthy.
Four excellent candidates declined job offers. Thus, as of mid-February, the staff projection for the near future (i.e., once all new hires are on board) remains at about the same level as at the beginning of the fiscal year. A major difference is that the five new individuals on board and two expected are considerably less experienced in the materials areas than the individuals lost from the Branch.
(See numerical analyses provided under Readjustment of Program Goals).
For licensing, a concerted effort made in the first quarter of FY90, partic-ularly on renewals and older actions, resulted in 543 completions through the first third of the fiscal year. To acknowledge the loss of experienced staff and the inefficiency of unqualified replacement personnel it is necessary to project that 95% of the renewal backlog will not be performed; and about 300 license amendments will not be completed. This results in a total loss of 565 actions, ie., 31% of the FY90 goal of 1775. Thus, we estimate that only 1210 licensing actions will be accomplished in FY90 (See numerical analysis provided under Readjustment of Program Goals).
The consequence of concentration on licensing for the first quarter was a significant shortfall in completed inspections. The number of completed inspections as of February 20, 1990 was 163.
It can be seen from early FY90 perfonnance by the Nuclear Materials staff in Region I that:
1.
Licensing actions were completed at a rate which kept the backlog from increasing. Further, many of the completed actions (30%) were backlog renewals.
2.
Experienced staff losses were substantive.
3.
Considerable staff resources were expended in recruiting, escalated enforcement and response to the Safety Light case.
4.
The completion rate for inspections was significantly reduced in order to keep the rate of licensing actions up and to obtain additional staff.
3-Q3 As a result, is necessary to reduce the licensing and inspection goals for FY90 to realistically reflect the reduction in number and experience of the staff in the Nuclear Materials Safety Branch. These goals should become:
Licensing Action Completions 1210 682 Inspections per MC 2800 All priority one and two inspections will be performed. Other changes are discussed, along with the reasons for change, with the reconciliation of available staff which follows.
These proposed revised goals assume that the staffing estimates for the balance of the fiscal year can be met and that productivity from new staff members follows that of previous experience.
(See numerical analyses provided under Readjustment of Program Goals).
Readjustment of Program Goals The FY 1990 staffing plan for NMSB provides for twenty-five Inspectors and Licensing Specialists. At the present time the total number of on board inspection and licensing technical staff is nineteen, a deficit of six. After careful examination of program scope and goals to be achieved, in both licensing and inspection, for FY 1990 vis a vis the understaffing problem, loss of experienced inspectors, the significant eTTort spent in training and qualifying new staff, the significant effort spent in recruiting, and decrease in efficiency in both inspection and licensing due to new inexperienced staff, it was concluded that significant readjustment in projected goals for licensing and inspection must be made. This analysis is for Direct Effort Hours; some of the results have been modified for the FTE estimates of the previous tables.
Based on the total number of licensing and inspection staff (25),
the total number of Direct Effort Hours (licensing and inspection) budgeted for FY 1990 is:
37,440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br /> 25 x 2080 x 0.72
=
Deficit calculations:
number of staff:
6 FTE 8,986 hours0.0114 days <br />0.274 hours <br />0.00163 weeks <br />3.75173e-4 months <br /> training of new staff:
3 FTE 4,493 hours0.00571 days <br />0.137 hours <br />8.151455e-4 weeks <br />1.875865e-4 months <br /> training & review by experienced staff:
1.2 FTE 1,797 hours0.00922 days <br />0.221 hours <br />0.00132 weeks <br />3.032585e-4 months <br /> inexperience of new staff 1.0 FTE 1,498 hours0.00576 days <br />0.138 hours <br />8.234127e-4 weeks <br />1.89489e-4 months <br /> Total deficit:
16,774 hours0.00896 days <br />0.215 hours <br />0.00128 weeks <br />2.94507e-4 months <br /> i
4 Q3
~
Tnis deficit is 45% of the total of the Direct Effort Hours (DEH) budgeted. A deficit of this magnitude necessitates considerable change in the program goals. Accordingly, the following adjustments in FY 1990 program goals are proposed:
1.
25% of Medical Group licensees (Program Code (PC) 2120) (Priority 3) inspections will not be performed.
Instead, telephone calls will be made to the licensee to verify basic program status. Only licensees with good prior enforcement history will be included in this category. The following DEH reduction will be achieved:
483 licenses x 1/3 years x 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> / inspection x 25% = 1047 hours0.0121 days <br />0.291 hours <br />0.00173 weeks <br />3.983835e-4 months <br /> 2.
The following licensees will not be inspected this year:
a.
Medical Private-Limited (PC 2201) (Priority 5)
These are usually very small programs. Only those with prior escalated enforcement history will be inspected. Thus, the saving is:
77 licensees x 1/5 year x 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> / inspection = 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> b.
Measurement System Fixed Gauges (PC 3120) (Priority 5)
Inspection of these on a routine 5-year basis is a recent change to MC 2800.
It was on a 7 year frequency, so the deferral is not a significant change.
222 licensees x 1/5 yr. x 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> / inspection = 1154 hours0.0134 days <br />0.321 hours <br />0.00191 weeks <br />4.39097e-4 months <br /> Measurement System Portable (PC 3121) (Priority 4) c.
These are routinely inspected every four years, but were formerly on a 5-year frequency. Not inspecting a year represents little change in inspection frequency.
385 licensees x 1/4 year x 26 = 2503 hours0.029 days <br />0.695 hours <br />0.00414 weeks <br />9.523915e-4 months <br /> d.
Manufacturing and distribution (M&D) (PC 3214) (Priority 5)
This delays 20 of the lowest priority M&D inspections for a year, but problem facilities will be inspected.
95 x 1/5 years x 26 = 494 hours0.00572 days <br />0.137 hours <br />8.167989e-4 weeks <br />1.87967e-4 months <br /> e.
Irradiator-SS (PC 3510) (Priority 3)
These are self-shielded irradiators which are inherently safe.
893 hours0.0103 days <br />0.248 hours <br />0.00148 weeks <br />3.397865e-4 months <br /> 103 x 1/3 years x 26
=
i 5
Q3 i
l f.
RandD(PC3620)
This delays 63 inspections of the lowest priority R&D for a year, but problem facilities will be inspected.
1648 hours0.0191 days <br />0.458 hours <br />0.00272 weeks <br />6.27064e-4 months <br /> 317 x 1/5 years x 26
=
3.
95% of the backlogged license renewalt will not be performed this year.
4172 hours0.0483 days <br />1.159 hours <br />0.0069 weeks <br />0.00159 months <br /> 366 renewals in backlog x 0.95 x 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> / renewal
=
4.
300 license amendments will not be performed this year.
300 amendments x 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> / amendment = 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> The total number of DEH savings as a result of these adjustments is 13,511 hours0.00591 days <br />0.142 hours <br />8.449074e-4 weeks <br />1.944355e-4 months <br />.
Actual deficit - proposed program adjustment = Net deficit 2,814 hours0.00942 days <br />0.226 hours <br />0.00135 weeks <br />3.09727e-4 months <br /> 16,325 - 13,511
=
It is expected that the net deficit will be compensated by planning overtime work for all members of the staff. This averages 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per pay period (12.5% OT) for each of the 20-22 staff members for the balance of the fiscal year. Barring changes in the amount of reactive' inspections, followup on allegations, enforcement cases, and decrease in the staff, all other program areas will be performed as planned for FY 1990.
SAFEGUARDS
\\'
We currently foresee the FTE budget for Safeguards licensing activities (0.2) to be low. This is due primarily to already expended and anticipated resources needed for UNC-NPD up-grade rule review activities, which include review of TI's, meetings with NMSS etc. These types of activities were apparently not considered when the FTE was budgeted. We anticipate that at least twice the budgeted FTE will be expended.
It is possible that the additional resources needed could be derived from the budgeted inspection FTE since the activities in that area may be less for FY '90 than originally estimated. Otherwise, inspections and licensing actions are expected to be completed in accordance with budget projections and inspections in accordance with inspection modules.
FUEL CYCLE We do not forsee the need to change the projections for fuel facility licensing actions or inspections, nor to completing required inspection modules.
l 2
Q5 For future National Program Reviews, we encourage review of the NMSS 1990 Regional Questionnaire (Enclosure 3 to Mr. Cunningham's memorandum sent to us J
by 5520 on January 23,1990) to eliminate infonnation requests that could be answered through existing management information systems, such as RITS. We recognize some of the difficulties inherent in obtaining meaningful information from RITS and systems related (such as deciding whether the hours charged to i
decommissioning activities, for example, should include " inspections of decomissioned f"111 ties" or only activities related to implementing the decomissioning rule.) However, we encourage review and modification, if needed, of RITS and similar systems (MIPS, etc.) in order to assure that the infonnation needed by the Program Office to manage assigned programs is available. Questions 1, 2, 7 and 8 in the questionnaire appear amenable to this approach.
4 4
Q U ESTIO N 4
ARE REGIONAL ADMINISTRATIVE SUPPORT FU NCTIONS PERFORMED IN A TIMELY MANNER?
ARE CHANGES NEEDED IN MANNER OF PERFORMANCE OF SUPPORT FUNCTIONS?
4 NMSS 1990 REGIONAL QUESTIONNAIRE Q4-NMSB-R1 This response addresses various regional administrative support functions for materials licensing and inspection activities. To understand administrative support, it is useful to explain briefly how the support is supplied. The Materials Docket Room is staffed by a Reference Assistant. Materials license and inspection paperwork is largely handled by two Processing Assistants. An Office Assistant provides inspection typing services. A recently assigned Licensing Assistant spends 75% of her time on materials and 25% of her time on safeguards licensing work. This direct support staff is supervised by the Licensing Assistance Section (LSA) Chief and assigned to the Nuclear Materials Safety Branch. Licensing typing and computer data entry services are provided, respectively, by staff and contractors of the Division of Resource Management and Administration (DRMA).
Licensing typing support was a problem late in the summer and fall of 1989 when the Word Processing Center (WPC) encountered staffing shortages. Since the hiring of new personnel, productivity of license typing has been good. One method used to deal with occasional delays has been to have the NMSB Office Assistant type license corrections while continuing to use the WPC staff for routine typing.
Internal paperwork handling, tracking, and docket filing is a resource consuming and continuing task. The LAS staff have worked overtime (20-30 hours / pay period) to keep up with the task, particularly when one or more of the direct staff have been on sick or annual leave. Data entry into the Licensing Tracking System by DRMA contractors has been satisfactory.
Inspection typing is largely done by the NMSB Office Assistant, although several staff members do much of their own draft typing on available personal computers. So far the Office Assistant has been able to keep up with the typing volume for routine reports, correspondence and escalated enforcement actions.
Internal paperwork for inspections is somewhat cumbersome. The regional computer system used for tracking inspections is difficult to maintain. Errors have been corrected and the system remains useable, but a less cumbersome i
system with ready feedback to inspectors and supervisors would reduce j
inspector frustration and improve productivity.
l The Licensing Tracking System has been a useful tracking and work a? location tool. The standard management reports available are helpful to supervisors. The addition of comment fields is proving useful. One suggestion for further help would be the addition of appropriate measures of licensing action timeliness to gauge performance against timeliness goals.
2 Q4
~
Travel support has remained unchanged.
In order to travel, an inspector fills out a handwritten trairel request with trip details. The DRMA Travel Section types a Travel Authorization (TA). The DRSS Branch Chief and DRMA Administrative Chief sign the authorization. The traveller then picks up the signed TA, tickets, and advance money from the Travel Section. Upon return, the traveller hand writes a travel expense claim.
The claim is processed and the claim is reconciled 3-4 weeks after completion.
The Travel Section tracks delinquent claims and notifies supervision of claims not submitted in 60 days. Preparing the paperwork requires notable effort by the inspector and is an occasional source of frustration and friction.
Personnel support has been greatly stressed in the sizeable effort to recruit health physicists. The DRSS professional staff has taken over the entire recruiting process, from developing leads to designing brochures to conducting reference checks and the other tasks needed to successfully recruit replacement staff members. The DRSS administrative staff arranges travel and interview schedules, as well. This has led to a significant diversion of resources for both the technical and administrative staff.
However, the staffing shortages would be worse without this effort because the usual means of recruiting health physicists were not producing the numbers and experience mix needed.
It is also becoming more difficult to compete in the health physics marketplace with present salary and benefits. A considerable recruiting effort remains to be done. Effective February 26, 1990, DRMA provided assistance in the form of a temporary Personnel Specialist to assist with recruiting. We are hopeful this will reduce the load on the DRSS staff while maintaining an effective recruiting effort.
As the staff becomes more computer literate, additional computer hardware and access to the regional LAN would improve productivity. We believe that readily available hardware, with proper support, could allow the technical staff to issue finished licenses a short time (hours) after the technical review is complete. Access to additional computer support personnel to help us improve the use and effectiveness of personal computers would also be helpful.
There are no apparent significant problems related to administrative support of fuel cycle licensing or inspection functions in Region I.
A computerized open item tracking system has been generated for the fuel cycle inspection and licensing functions. The Project Engineer (Fuel Facilities) is responsible for the system, and uses the Office Assistant (Typing) in the Facilities Radiological Safety and Safeguards Branch for administrative assistance.
We believe that a significant increase in discretionary time for first line managers is necessary if we are to have a well managed Division. We intend to explore the possibility of additional secretaries, or administrative assistants as a way of providing this time.
i Q U ESTIO N 5
PROVIDE COMMENTS ON HEADQUARTERS INTERACTIONS WITH REGION FOR:
CONFERENCE CALLS, WORKSHOPS, SEMINARS, INSPECTION ACCOMPANIMENTS, CASE-REVIEWS, TECHNICAL ASSISTANCE, STANDARD REVIEW PLANS AND GUIDANCE.
NMSS 1990 REGIONAL QUESTIONNAIRE QS-DRSS-RI MATERIALS AND FUEL FACILITIES Region I believes that conference calls, workshops, seminars and accompaniments are a useful method of providing information exchanges between NMSS and Regional personnel. The fuel facility counterpart conference calls should be modified slightly to reduce the emphasis from a discussion of individual cases to a discussion of generic issues (i.e., training, assurance that inspection activities are comparable from region to region, etc.). The materials conference calls upon occasion have not had sufficient lead time to develop an agenda and prepare for the call. The recent national materials workshop is regarded as a highly useful and productive meeting.
An area which makes planning and scheduling difficult is the uncertain completion dates often associated with Technical Assistance Requests. While it is recognized that changing priorities will affect these completions, it is difficult to explain this to licensees who are awaiting a licensing action.
Some mechanism such as a TAR tracking system or a quarterly status report should be developed.
There should be additional contact between the Regional Division Directors and senior NMSS management. We suggest a brief quarterly conference call involving these individuals.
We do have some frustration in our contacts with and feedback from OE. We consider that we should be able to produce an acceptable enforcement package most of the time, but our products are often revised. We as yet do not see a clear pattern in the changes that we can use to improve our perfonnance. We receive excellent assistance and support in this area from the Regional Enforcement Officer / Coordinator, but believe some generic, specific feedback would be helpful. We are arranging rotational assignments for OE personnel and may propose a meeting between the senior managers.
Escalated enforcement for materials licensees in particular has consumed major resources due to the number and complexity of cases. While staff effort can be accounted for in RITS, it is more difficult to assess the impact with supervisors and managers. A more useful system of budgeting and accounting for escalated enforcement activity should be developed.
SAFEGUARDS We continue to experience requests to participate in NMSS/SGTR - initiated activities on what for us is short notice. Our inspection planning process requires development of schedules in four month increments. The receipt of unexpected inspection requests from SGTR has degraded our ability to accomodate previously scheduled inspections. We need to develop more timely communications between NMSS and Region I management on anticipated inspection resource requirements.
2 QS For future National Program Reviews, we encourage review of the HMSS 1990 Regional Questionnaire (Enclosure 3 to Mr. Cunningham's memorandum sent to us by 5520 on January 23,1990) to eliminate information requests that could be
)
answered through existing management information systems, such as RITS. We recognize some of the difficulties inherent in obtaining meaningful information from RITS and systems related (such as deciding whether the hours charged to decommissioning activities, for example, should include " inspections of decommissioned facilities" or only activities related to implementing the decomissioning rule.) However, we encourage review and modification, if needed, of RITS and similar systems (MIPS, etc.) in order to assure that the information needed by the Program Office to manage assigned programs is available. Questions 1, 2, 7 and 8 in the questionnaire appear amenable to this approach.
6
(
Q U ESTIO N 6
SUMMARIZE REGIONAL INITIATIVES TO IMPROVE QUALITY OF INSPECTIONS AND LICENSE REVIEWS, PARTICULARLY THOSE AIMED AT PREVENTING SAFETY PROB.LEMS OR CONDUCTING SAFE TRANSPORTATION.
4 HMSS 1990 REGIONAL QUESTIONNAIRE Q6-DRSS-RI With current resource constraints, it has been difficult to develop and implement initiatives. However, the following are examples of recent efforts to improve the quality of NMSS programs.
FUEL CYCLE Region I has increased the use of team inspections at fuel cycle facilities which have real or perceived problems (i.e., Combustion Engineering Inc.
and Cintichem) to assure the best use of available manpower and expertise.
HQ should strongly consider providing the Regions with FTE to cover MCA quantity facilities (such as universities and small laboratories)gnificant and Physical Security inspections at nonpower reactors and low si and physical security inspection at Cat 2 or 3 fuel cycle facilities (such as Cintichem and Combustion Engineering).
MATERIALS Licensing Initiatives:
Employment of a two-step license for new users of radiopharmaceuticals insures that procedures and instruments are in place prior to issuance of the full license to obtain and use radiopharmaceuticals.
Review and update of standard license conditions for use by all NRC license reviewers.
Development of a generic license for nuclear gauges to reduce the need for amendment just for buying a gauge from a different supplier.
Inspection Initiatives:
None.
Other Initiatives:
Conduct of ten workshops at different locations in the Region for medical licensees to inform them of NRC expectations and regulatory requirements.
SAFEGUARDS There were no licensing or inspection initiatives in this area.
I
i s
b Q U ESTIO N 7
SUMMARIZE TRANSPORTATION INSPECTIONS:
@ MATERIALS FACILITIES (lP86740)
@ FUEL FACILITIES (MC2600)
@ REACTOR FACILITIES (IP86721,86740,83750)
INCLUDE STAFF TIME USED, TYPICAL VIOLATIONS, TRANSPORTATION-AS PART OF TEAMS, EVALUATION OF ADEQUACY OF IP83750 FOR TRANSPORT ACTIVITIES.
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l NMSS 1990 REGIONAL QUESTIONNAIRE Q7-FRSSB-RI We do not have a convenient way of extracting the detailed inspection information requested. However, records of individual inspections are available for review, and the 766 system may contain certain of the information requested.
No significant problems were identified during our inspections of transportation activities in FY 1989 or thus far in FY 1990.
Transportation inspections were conducted at each operating fuel facility during FY 1989, and transportation was routinely reviewed during inspections of the cited procedures at power reactors. For materials facilities, transpor--
tation was routinely reviewed when required.
In particular, transportation inspections of broad scope licensees consumed about 15% of the staff hours expended.
Review of enforcement records revealed no recent instances of referrals by Regions II or V of low level waste transportation violations that required Region I enforcement action.
One major team inspection was conducted at a fuel facility during the period under review. That inspection, at Combustion Engineering, Windsor, Connecticut, late in FY 1989, included a review of the licensee's program for preparing and transporting radioactive' waste. No problems were identified.
We will provide our assessment on the adequacy of. Core Inspection Procedure
^
83750 for inspecting transportation activities during the course of the team visit.
3 1
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Q U ESTIO N 8
PROVIDE A TRAINING S U M M ARY FOR.
EACH INSPECTOR AND R EVI EWER.
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NMSS 1990 REGIONAL QUESTIONNAIRE Q8-FRSSB-RI MATERIALS The Agency Training System was queried for training given to materials reviewers and inspectors. The database contained too many errors to develop the requested matrix.
Individual records of training will be available for review during the team visit.
The status of qualification of each inspector / license reviewer is shown in the attached tables.
FUEL CYCLE Roth - trained in team leader activities, Probabilistic Risk Assessment, and OSHA Fire training.
i Austin - Completed Inspector Qualification Program.
SAFEGUARDS Arthur Della Ratta Attended the NRC Physical Protection System (PPS) Session 3. at Albuquerque.
N.M. on 2/13-17/89.
~
Accompanied G. Smith on a Transportation Inspection of non-power reactor fuel at Worcester Polytechnic Institute on 5/15-16/89.
Accompanied a HQ led team inspection of a Category I fuel facility in Region I and Region II during 5/21-26/89 and 7/9-14/89.
Accompanied G. Smith for the Regulatory Effectiveness Review (RER) conducted at Susquehanna on 6/19-23/89.
Accompanied G. Salth on a route survey for a shipment of reactor fuel -
i Limerick /B&W, Lynchburg on 8/1-2/89.
Accompanied G. Smith on a Physical Security inspection of UNC-NPD on i
9/11-15/89.
Attended the course " Transportation of Radioactive Materials" at Chattanooga, Tenn. on 10/17-20/89.
Attended the Security Training Symposium in Bethesda, Maryland on 11/27-30/89.
Completed the Region I Inspector Qualification Program for Physical Security Inspector at Fuel Facilities and Power Reactors and was certified on 11/8/89.
i Thomas W. Dexter Attended the NRC Physical Protection System (PPS) course at Albuquerque, N.M.
on 6/12-16/89.
Completed the Region 1 Inspector Qualification Program for Physical Security Inspector at Power Reactors and was certified on 10/2/89.
Accompanied G. Smith on a Physical Security inspection of UNC-NPD on 12/18-21/89.
Gregory C. Smith Participated in a HQ NMSS meeting for the Category I fuel facilities upgrade on 11/3-4/88.
Participated in a HQ Regional Meeting to develop inspector Test Kits for fuel facilities on 1/18/89.
Attended the NRC Physical Protection System (PPS) courses at Albuquerque, N.M.
on 3/12-17/89 and 6/12-16/89.
Attended the Security Training Symposium in Bethesda, Maryland on 11/27-30/89.
Richard R. Keimig Attended the NRC Physical Protection System (PPS) course at Albuquerque, N.M.
on 6/12-16/89.
Attended the Security Training Symposium in Bethesda, Maryland on 11/27-30/89.
Ernest D. Sylvester Attended the NRC Physical Protection System (PPS) course at Albuquerque, N.M.
during FY 1989.
Completed the Region I Inspector Qualification Program for Physical Security Inspector at Power Reactors and was certified on 11/21/89.
Attended the Security Training Symposium in Bethesda, Maryland on 11/27-30/89.
Ron Albert Accompanied G. Smith on a transportation inspection of a Category II shipment of SNM at JFK Airport on February 14, 1990.
._~
QUALIFICATION STATUS - MATERIALS SECTION A 22 - FEB,
REPORT TO INSPECTOR ORAL LIMITED FULL IDP NAME REGION I JOURNAL BOARD LICENSING LICENSING J. GRESICK COMPLETED PASSED APPROVED ECD IN SENIOR HP JUL-88 01/31/89 01/11/89 03/26/90 PLACE J. PICCONE COMPLETED PASSED APPROVED APPROVED IN SENIOR HP MAR-87 12/22/88 10/22/87 PLACE S. COURTENANCHE COMPLETED PASSED APPROVED ECD IN HEALTH PHYS JAN-86 02/15/89 05/10/89-06/22/90 PLACE T. DARDEN ECD ECD APPROVED ECD IN HEALTH PHYS MAY-82 03/01/90 03/09/90 05/10/89. 06/04/90.
PLACE J. JOUSTRA COMPLETED PASSED APPROVED APPROVED IN HEALTH. PHYS APR-84 05/01/88 02/17/87 01/11/89 PLACE C. SCHULINGKAMP ECD ECD ama TBD IN HEALTH PHYS Nov-87 03/26/90 04/30/90 PLACE J. STAMBAUGH ECD ECD ECD TBD IN HEALTH PHYS JAN-89 04/25/90 04/29/90 02/28/90 PLACE L. TRIPP ECD ECD APPROVED ECD IN HEALTH PHYS JAN-88 05/18/90 05/25/90 01/11/89 06/04/90 PLACE VACANT OVERHIRE t
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QUALIFICATION STATUS - MATERIALS SECTION B 22-FEB-90 REPORT TO INSPECTOR ORAL LIMITED FULL IDP-NAME REGION I JOURNAL BOARD LICENSING LICENSING F. COSTELLO COMPLETED PASSED APPROVED APPROVED IN SENIOR HP JAN-77 02/27/78 04/04/86 PLACE i
VACANT SENIOR HP C. ECKHART NEWLY ECD ECD ECD IN HEALTH PHYS Nov-89 ASSIGNED 12/01/90 06/01/90 03/01/91 PLACE r
VACANT HEALTH PHYS E. REBER NEWLY ECD ECD ECD IN HEALTH PHYS Nov-89 ASSIGNED.
12/01/90 06/01/90 02/01/91 PLACE T.-0 BERG REG 111 GRAND ECD TBD IN HEALTH PHYS AUG-84 03/05/76 FATHERED 04/01/90 PLACE E. ULLRICH COMPLETED PASSED APPROVED ECD IN HEALTH PHYS MAR-87 02/16/89 04/10/89 03/01/90 PLACE VACANT Z
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1 OUALIFICATION STATUS - MATERIALS SECTION C 22-FEB-90 REPORT TO INSPECTOR ORAL LIMITED FULL IDP NAME REGION I JOURNAL BOARD LICENSING LICENSING J. MILLER COMPLETED PASSED APPROVED APPROVED IN SENIOR HP JUN-84 11/28/88 10/22/87 PLACE T. THOMPSON COMPLETED PASSED APPROVED APPROVED IN SENIOR HP JAN-84 06/01/89 10/22/87 PLACE D. COLLINS IN LEAVING LEAVING TBD IN HEALTH PHYS SEP-81 PROCESS 02/28/90 02/28/90 PLACE J. DWYER NEWLY ECD ECD ECD IN HEALTH PHYS DEC-89 ASSIGNED 01/31/91 06/30/90 01/31/91 PLACE A. KIRKWOOD COMPLETED PASSED ECD ECD IN HEALTH PHYS OCT-88 12/20/89 03/15/90 08/30/90 PLACE R. LADUN COMPLETED PASSED ECD ECD IN HEALTH PHYS OCT-82 07/19/89 09/30/90 03/30/91 PLACE M. TAYLOR COMPLETED PASSED ECD ECD IN HEALTH PHYS JAN-84 01/12/89 12/30/89 06/30/90-PLACE VACANT
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REGION I RESPONSE OE INPUT INTO NMSS NATIONAL PROGRAM REVIEW PROCESS 1.
What type and frequency of training is conducted by the region in enforcement 4
matters?
Training for new employees and regional personnel?
How is enforcement guidance / instructions given out to regional personnel? - Has training been given under V.G.1 and Severity. Level V violations?
Training for regional staff in enforcement matters is conducted on an as-needed basis.
When new guidance or instructions are received, the Enforcement Coordinator reviews them and either incorporates the information into the appropriate Regional Office Instruction (s) or circulates the original document to the staff.
Specific training sessions are held when the subject matter is significantly different from past practice. For example, the' subjects of non-cited violations, V.G.1, and Severity Level V violations have been reviewed in at least i
four training sessions for the materials staff during the past year. Enforcement policy is a specific area listed in the journals of new staff and is, of course, reviewed thoroughly with them by their Section Chief as they handle more work t
independently.
t 2.
Are repetitive violations being identified?
a) to licensee during close out b) to section chief during discussion of inspectors findings? -
Yes, it has long been Region I policy to do these things.
3.
How are repetitive violations being documented?
a)
Is there a paragraph in cover letter 1.
Standard boiler plate paragraph option in preparing?
b)
Are they identified in NOV as repeats c)
If other violations, is an enforcement conference held? Safety significance?
Repetitive violations are documented with a standard paragraph in the cover letter which is available to all inspectors as boiler plate (see attached). As a general rule we do not mark the violation in the NOV as a repeat, but the standard paragraph calls out each repeat by item letter. Enforcement conferences are held based on our evaluation of the safety significance of the identified violations and our best estimate of the " direction" (improving or deteriorating) the licensee is headed.
Repeat violations are considered in deciding whether to conduct a conference.
4.
When a violation is repeated a third time, what action should be taken?
DRAFT
OE INPUT 2
In keeping with current guidance, enforcement should be progressive and additional sanctions should be considered. Since violations vary in severity, it is not possible to absolutely spccify the sanction for a second repeat. In any case, the action should probably include additional attempts to improve program management and effectiveness of all corrective actions.
5.
Have inspectors had cases of repeat violations in inspections since new guidance issued by OE7 Yes, and we believe we have followed the guidance. We do not have an efficient way of recovering the cases.
6.
How have inspectors exercised discretion under V.G.1 during inspections of licensees?
With some reluctance, but after several training sessions and encouragement from supervision, we believe V.G.1 is being routinely and properly implemented in the field. All such actions are reviewed by supervision.
7.
When and for what types of violations are 591's being used?
See attached.
8.
How are repetitive violations, non-cited violations, and open items tracked?
The Region I Nuclear Materials Safety Branch maintains a dBase file of outstanding (or open) items for each licensee. All such items are entered into the file.
9.
If there is a tracking system, do inspectors preview output prior to inspection and closcout old violations and flag repeats.
Inspectors review both the outstanding items file and the docket file in preparation for inspections.
Violations and other open items are to be closed whenever possible during the current inspection. Thoses which are not closed, remain open for review during the next inspection.
10.
Could OE have copy of tracking system output of example license?
See attached.
11.
Who does audit on tracking systems to assure input by?
As part of the final approval of the inspection documentation, the Section Chief assures that a record of the input into the outstanding items list is present.
DRAFT
OE INPUT 3
12.
How many Severity L.evel IV and V violations were disputed by the licensee during the current FY?
While we can recall that several were disputed, we have no convenient way of recovering the cases. We believe the number is no more than five. Each received specific attention at least one level of management higher than that who signed the original violation.
13.
How many Severity level IV and V violations were withdrawn during the current FY?
A few of the disputed violations described in answer to question 12 were withdrawn. We have no convenient way of recovering the cases.
14.
Do the regions perform internal audits, other than the normal concurrence process, of inspection reports and Severity Level IV and V violations?
Region I has recently begun peer review of inspection reports and violations.
Each month several reports and/or NOV's are selected and assigned to a Senior Health Physicist who has not been previously involved with them for review and comment. The comments are provided to the inspector, the Section Chief and the Branch Chief.
1 l
r DRAFF
' NUCLEAR MATERIALS SAFETY SECTIONS A, B & C DOCUMENTATION LETTER
~#
.. p Docket No(s).
Licenso No(s).
a.
ATTN:
(Title):
Gentlemen:
Subject:
(Circle One) Routine or Special Inspection No.
(ex.87-001)
Circle Al for COMPLETE INSPECTION (if one license)
Circle A2 for COMPLETION INSPECTION (if more than one license)
. Circle B1 for LIMITED INSPECTION (if one license) l Circle B2 for LIMITED INSPECTION (if more than one license)
Circle any optional paragraphs desired.
Al or A2 Date(s):
- I Complete Inspection
)1 Only
-Inspector (s):
location of inspection:
)(ex."theabove address)"
B1 or B2 Date(s):
- l Limited Inspection
[l Only i
Inspector (s):
Location of inspection:
) (ex."The above address)"
Inspection limited to a review of:
C.
[Opti. anal] Dates of licensee correspondence reviewed during inspection:
D.
[ Required]
Licensee representative at exit:
Region I Fots 293 01/87
j(
E.'
[Opticnal)(copyofinspectienreportenclosed)_
F.
[ Optional)
Telephone conversation date:
Licensee representative:
NRC representative:
/
/ Custom Paragraph Attached Circle one of the following: IRequired]:
G.
(no violations identified)
H.
(one or more violations identified)
Circle or check as required: [ Optional)
I.
(Security violation downgrade) Item:
J.
(Single recurrent violation) Item:
Date of prior NOV K.
(Multiple recurrent violations) Item (s):
Date of prior NOV Closing: [ Required - Circle One)
L.
(Section A Chief Signature)
M.
(Section B Chief Signature)'
N.
(Section C Chief Signature) 0.'
(NMSS Branch Chief _ Signature)
P.
(DRSS Director Signature)
Enclosures:
[ Required]
/ / Appendix A, Notice of Violation
/ / NRC Region.I Inspection Report Number
/ / Combined NRC Region I Inspection Report Number
/ / None-cc w/ enclosure (s): [ Required]
/ / Commonwealth / State of
/ /
, Radiation Safety Officer -
// Other bec:
Region I Docket Room (w/ concurrences)
Management Assistant, DRMA (w/o enclosures)
// Other Indicate Concurrences: [ Required) 1 I
I I
I I
I I
I I
I I
Region I Form 293 01/87
-V Y
STANDARD PARAGRAPH J Item in the Notice of Violation enclosed with this letter was identified t
during a previous inspection of your licensed activities and documented in a Notice of Violation. enclosed with our letter dated From this inspection, it appears that your corrective actions were not effective since this item has recurred.
Recurrent and uncorrected violations are given additional weight in the consideration and selection of appropriate enforcement action. Therefore, in your response to this letter, you should
- give particular attention to those actions taken or planned to ensure that identified items of noncompliance will be completely corrected and will not recur.
STANDARD PARAGRAPH K l
Items
, and in the Notice of Violation enclosed with this letter was identified during a previous inspection of your licensed program and documented in a Notice of Violation enclosed with our lettar dated From this inspection it appears that your corrective actions were not effective since these items have recurred. Recurrent and uncorrected violations are given additional weight in the consideration and selection of appropriate enforcement action.
Therefore, in your response to this letter, you should give particular attention to those actions taken or planned to ensure that identified items of noncompliance will be completely corrected and will not recur.
STANDARD PARAGRAPH L Your cooperation with us is appreciated.
Sincerely,
' John D. Kinneman, Chief Nuclear Materials Safety Section A Division of Radiation Safety and Safeguards 4
CC' Public Document Room (PDR)
Nuclear Safety Information Center' (NSIC)
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