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NUCLEAR REGULATORY COMMISSION REGION V O
@Y 1450 MARIA LANE. SUITE 210 t"ALNUT CEEEK, CALIFORNIA M 5M e...o
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OCT 121989 MEMORANDUM FOR:
Emergency Preparedness Section Staff FROM:
Ray F. Fish, Chief Emergency Preparedness Section
SUBJECT:
DETERMINATION OF REPEAT VIOLATIONS During an October 10, 1989, on handling severity IV and V violationstraining session on the enforcement policy there was a discussion concerning documentation (auditable recor,d) by inspectors to confirm they had performed the appropriate review of prior violations, both cited and non-cited, required by Section E.7 of Region V Instruction No. 0201, Handling of Region V Enforcement Actions.
Paragraphs "c" through "f" of Section E.7 describe the inspector's responsibilities specifically.
in paragraph "f,"I have generated a form that can be used.In order to fa A copy of this new form is attached.
Because we expect Headquarters to audit the regional implementation of the enforcement program, including compliance with the requirements in familiar with your responsibilities delineated in Instruction 7
Ray F. Fish, Chief Emergency Preparedness Section
Enclosure:
as stated cc:
A. Johnson
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ENFORCEMENT REVIEW Severity IV and/or V violations identified during this in
" repeat" violations.
Licensee:
Inspection Report No.
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The violation (s) identified is not a repeat violation
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identified during a prior inspection.
/_/ The violation (s) is a repeat ** of a violation that occurred:
Inspection Report No.
Violation 1.
2.
3.
Reason escalated enforcement action not taken:
Signed:
Inspector period covering the last two (2) inspections which i
Include cited and non-cited violations.
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UNITED STATES
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g NUCLEAR REGULATORY COMMISSION 4
4l REGON V Y.@...~*./
mb*EcM2iENi2m JAN 191990 Docket No. 50-344 Portland General Electric company 121 SW Salmon Street, TB-17 Portland, Oregon 97204 Attention:
Mr. David W. Cockfield, Vice President, Nuclear Gentlemen:
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SUBJECT:
NRC INSPECTION TROJAN NUCLEAR PLANT December 18 through 22This refers to the inspection conducted by 1989 of activities authorized by NRC License No.
NPF-1 and to the discus,sion o,f our findings held by Mr. Russell with Mr.
and other members of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the enclosed report. Within these areas the inspection consisted of selective examinations of procedures a,nd representative records, interviews with personnel, and observations by the inspector.
Based on the results of this inspection it appears that some of your activities were not conducted in full co,mpliance with NRC requirements as forth in the Notice of Violation, enclosed herewith as Appendix A, and the Notice of Deviation, enclosed herewith as Appendix B.
Your response to these Notices is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in the Appendices.
We note that item A of Appendix A is a repeat of violation B. 3. in our lett to you dated March 15, 1989.
have to do with work control practices.Both violations are very similar in nature a on January 12, 1990, During the PGE/NRC management meeting plan and stressed steps being taken to improve maintenance.you pres analysis of the causative factors for these similar viola explanation of how your improvement plan should have or will preclude t
recurrence.
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In addition to the repetitive aspects of ites A, enclosed, we have concern of containment depressurizations via the hydrogen vent s enclosed inspection report describes your use of questionable sonitoring Page 4 of the to discount saecific statements of a worker which clearly imply that the train of the hydrogen vent s to mid-September time frame.ystem may have been monitored during the mid-July would also appreciate receiving your final conclusion on this p
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02/08/90 RANCHO SECD VIOLATIONS (01- 01/90) 05000312 PAGE 1 TERT 88004 4 581070 ACCESS CONTROL--PERSONNEL CONTRARY 10 SECil0N 1.7.1 0F THE APPROVED SECURITY PLAN THE LICENSEE FAILED TO DENY ACCESS TO UNAUT HORllED PERSONNEL.
88004 0 581070 ACCESS CONTROL.-PERSONNEL OCOM TO LICENSEE'S LETTER DATED JULY 29, 1987. TH E LICENSEE FAILED TO ADEQUAIELY REVALIDATE SECURIT Y BADGES EVERY 31 DAYS.
B8006 4 525565 iMI ACTION PLAN INSPECTION FOLLOWUP 10 Cf R 50, APPENulX B.-CRITERION V. REQUIRES THAT AClivillES AFFECilNG QUALITY SHALL BE PRESCRIBED B Y DOCUMENTED INSTRUCTIONS, PROCEDURES OR DRAWINGS AND SHALL BE ACCOMPLISHED IN ACCORDANCE WITH THESE INSTRUCTION
S. PROCEDURE
S, OR DRAWINGS. SMUD MATE RIALS MANAGEMENT PROCEDURE MMP-0025, " PRESERVATION
. STORAGE. AND MAINTENANCE OF ITEMS IN STORAGE." P ARAGRAPH 7.6.5, REQUIRES THAT ITEMS WHUSE SHELF LI IE HAS I APIRED SHALL BE REMOVED FROM THEIR STORAGE LOCATION AND PLACED IN A ' HOLD" LOCATION, RANCHO SECO MANAGEMtNI INFORMATION SYSTEM REPORT RSMM 03
- 30. DATED JANUARY 4,' 1988,10EhilflED MATERIALS WI TH EXPIRATION DAi[5 FOR THE FIRST QUARTER OF 1988.
CONTRARY TO THE STATED REQUIIREMENTS, ON FEBRUAR Y 4, 1988, lHREE SAFETY-RELATED RSWI 0330 GASKET L INE liEMS (9 PIECES), WITH EXPIRED SHELF LIVES. HA D NOT BEEN TAGGED OR PLACLD IN A HOLD LOCATIDN.
88012 4 571710 ENGINEERLD SAFETY FEATURE WALK DOWN DURING AM NRC INSPECTION CONDUCIED ON MARCH 30 IHR 00GH MAY 2, 1988, A VIOLATION OF NRC REQUIREMENTS WAS IDENilFIED.
IN ACCORDANCE WITH THE ' GENERAL-S TATEMENT OF POLICY AND PROCEDURE FOR NRC ENFORCEME NT ACTIONS.* 10 CFR PART 2, APPENDIX C, THE VIOLAT 10N IS LISTED BELOW:
10 CFR 50.72 (B)(2) II STAT
"(8) NON-EMERGENCY EVENTS -(...).(2) i ES, IN PART:
FOUR-HOUR REPORIS.
...THE LICENSEE SHALL NOTIFY T HE NRC AS 500N AS PRACilCAL AND IN ALL CASES WITH-IN FOUR HOURS OF THE OCCURRENCE OF ANY OF THE FOLL
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ENFORCEMENT REVIEM This confirms my review of prior
- fnspections to determine whether the Sever 1ty IV and/or Y y1olations identifled during this inspection are
- repeat" violations.
Licensee:
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Inspection Report No. 5s-ra/vy-f y
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identified during a prior inspection.
/_/ The violation (s) is a repeat ** of a violation that occurred:
Inspection Report No.
Violation 1.
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3.
Reason escalated enforcement action not taken:
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prior means inspections performed within the last two perfod covering the last two (2) inspections whichever(is longer.2) years or th Include cited and non-cited violations, j
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ATTACHMENT 3 8
1 UNTTED STATES
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1460 MARIA LANE. SUITE 210 WALNUT CREEK, CAUFORNIA 94596-6308 FEB1s 1990 MEMORANDUM FOR:
Richard W. Cunningham, Director Division of Indust. rial and Medical Nuclear Safety, NMSS FROM:
Ross A. Scarano, Director Division of Radiation Safety and Safeguards
SUBJECT:
1990 NATIONAL PROGRAM REVIEW (MATERIALS),
RESPONSE TO QUESTIONNAIRE Enclosed is our response to the questionnaire forwarded in y and 23, 1990 National Program Review visit to Region V during Febr your staffs' r
, 1990.
helpful in your previsit review of our activitiesWe lo nclosed information is Dean Chaney of my staff at FTSIf you have any questions co 463-3763.
, please contact f; r Ross A. Scarano. Director Division of Radiation Safety and Safeguards Attachments: As Stated cc:
J. Martin B. Faulkenberry R. Pate G. Yuhas Section Chiefs. DRSS D. Bond Central Files, RV b y># L. 3
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NMSS program, specify the approximate percenta individual spends on the following activities:
fuel cycle inspection, materials licensing, materials inspectionfuel cycle li safeguards activities, and inspections of decommissioned facilities and reactors. (See Table I for percentage of time spent and Table II for organization structure).
2.
Provide a summary of actual expenditures and accomplishments as to operating plan / budgeted expenditure and accomplishments, for FY 89 and FY 90 to date. (See Tables III-V) 3.
Are there any changes needed in the estimate of year? If so Are there any, foreseeable barriers to completing insp accordance with Manual Chapters 2600 and 2800?
Fuel Cycle Inspection No changes are needed for FY 90 fuel fabrication inspection program However, due to lack of activities at Atomics International and Gereral Atomics only a minimum of time will be spent completing the program There are no foreseeable barriers to completing the MC 2600 inspect modules for FY 90.
Materials Inspection Yes, changes are needed for FY 90.
will be completed in accordance with MC 2800.The new estimate of 99 inspecti Scarano to Cunningham, NMSS, dated FebruarySee attached memorandum 16, 1990.
Materials Licensing The estimated case workload projection may need to be adjusted due the increased effort necessary to complete the "old" cases and the
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escalated enforcement activities by reviewers - Skov and Montgomer The primary licensing person has had to devote considerable time to position of Acting Section Chief during the first quarter of FY 9J.
Safeguards Fuel Facility Licensing Program Our experience for FY 89 reveals that while 10 casework receipts were projected, we actually received only 3 cases, had a backlog of 2 cases and 5 were completed.
one case has been received.The casework projection for FY 90 is 6 cases, and Safeguards Fuel Facility Inspection Program There are no foreseeable barriers to completing the inspection module for FY 90 in accordance with MC 2681.
needed for Part 95 inspections.
Additional resources will be
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Are regional administrative support functions performed in a timely manner?
Are changes needed in the manner in which these support functio are performed?
If so, please be prepared to discuss the changes needed which would result in optimal administrative support for the programs Regional Support functions are perfonned in a timely manner.
continually working to improve performance in this area.
We are 5.
Please provide your comments on the programs for interaction of Headquarters with your Region.
Please include your coments on the usefulness of the conference calls, licensing workshops, executive management seminars, inspection accompaniments, telephone calls on case reviews.
review plans, guides, etc. Technical assistance provided on a day-to-day recomendations for modifications, changes improvements,
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interaction program.
Materials Licensing and Inspection The conference calls have continued to be useful.
The licensing and of problems common to all Regions and Headquar continued.
understanding of regional activities. Inspection accompaniments ar license conditions, and model licenses should be upgraded. Reviewer applications prepared relative to Part 39. guidance is neede Also, final Safeguards Licensing and Inspection reviewer and their NMSS counterparts has been ef interaction is conducted on an as needed basis.
call sponsored by the NRR Safeguards Branch.NMSS shou effective means of comunicating generic type safeguards issues.This ap Telephone calls on case reviews are made on an "as needed" basis.
generic issues may be involved; or where a potential p In all the region and the headquarters cognizant program o Fuel Cycle Inspection The fuel cycle counterpart calls have been helpful.
and Atomics International.have been excellent, particularly in suppor
. been most beneficial and we encourage continued The fire protection and project management support at Advanced Nuclear Fuels have been most helpful.
We continue to support fuel facility counterpart meetings in Headquar 6.
Summarize regional initiatives to improve the quality of inspections and license reviews, particularly those aimed toward preventing licensee activities in a safe manner. safety problems, or those aimed at licens Materials Licensing and Inspection The following initiatives have been implemented or continued:
New Initives Inspector's are being encouraged to spend more time on performance inspection activities while at licensee's place of business or operatio We are initiating development of a questionnaire to be issued durin review of license renewals that require the radiography and portable and procedures for conducting transportation activities.
Continued Initiatives More time is spent with the licensees in discussing the license conditi and the associeted regulations.
Performance factors are still being utilized to identify weaknesses in licensed programs.
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Problem licensees have reduced inspection frequencies and manage Medical work shops'have been used as a forum for interaction and inspection issues.
Transportation module 86740 is reviewed during each inspection where applicable.
Safeguards Licensing and Inspection The goal of training an alternate inspector for fuel facility physical i
security inspections was accomplished.
It is intended to rotate these familiar with each fuel facility site and to be experi n
cycle physical security inspections.
. Fuel Cycle Inspection Regional management visited each fuel fabrication facility during the last year.
The Fuel Facility Inspector is doing an excellent job of surfacing safety issues.
For example, fire protection and bioassay issues at ANF.
Two inspectors attended training on transportation requirements du the last year.
Reactor Radiation Specialist and Emergency preparedness Analysts and Headquarters experts are being used to support the Fuel Facility Inspector.
7.
Summarize the total number of inspections of transportation activities at MC 2800 program licensed facilities, including average staff hours per inspection and brief summary of most typically observed violations including any escalated enforcement actions.
(Procedure 86740).
Summarize the number of referrals (from Regions II and V) which were processed by your region regarding enforcement action against licensee shippers in your region who made errant shipments to either of the thre commercial low level waste burial sites.
Summarize the completion status if the annual inspections of transportation activities at MC 2600 licensed fuel facilities and a brief summary of findings.
whether transportation activities were included on any of the major team Describe inspections of fuel facilities.
inspections of transportation activities at MCSuninarize the completion status licensed reactor facilities.
(MC procedures 2500 (2515 and 2545)
Please provide your evaluation of whether Core Inspection Procedure 8 83750 has been adequate in providing sufficient effort in the inspectio of transportation as a percent of the staff hours expended against Procedure 83750.
Material Licensees (MC 2800)
The region performed Inspection Procedure 87640 at 97 Docket Type licensees in FY 89.
Each inspection averaged approximatel Nineteen similar inspections have been conducted to date (y 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
for FY 90.
were associated with lack of shipping papers, labe available copies of Special Fonns and DOT Certifications.
cases involving escalated enforcement.
There were no We have not had any referrals waste burial site requirements during FY 89 or to da HMS Section inspectors have completed TTC Course H-308 All of Radioactive Materials", and attend refresher courses, when offered.
" Transportation
. Fuel Cycle Facility Licensee's (MC 2500 and 2600)
The region performed Inspection Procedure 87640 at 19 Docket Type 50 and 70 licensee's during FY 89.
Each inspection averaged approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Five similar inspections have'been conducted to date (9/24/89-2/13/90) in FY 90.
During FY 90 the average number of hours per inspection is five.
One minor violation involving waste classification was identified.
(See Table VI)
Procedure 83750 provides a sufficient level of effort. No changes should be proposed.
Precise data does not exist to give an actually measured percentage for 83750.
General expenditure would be 15% to 20%.
8.
Provide a training summary for each inspector and reviewer in tabular form.
For each inspector, state which courses listed in Manual a.
Chapter 1245 have been completed, when oral boards were completed, what types of inspections the inspector is certified for, and which courses were waived and the reason, b.
For each license reviewer, state which courses listed in Manual Chapter 1245 have been completed, and which types of licenses the reviewer is authorized tc. sign.
Inspector qualification training files are maintained for each Division inspector.
Because of the effort that would be required to consolidate the requested training data, we believe the desired information can be most efficiently evaluated by examining information which is documented in the qualification training files.
As discussed with John Hickey on February 13, 1990, he agreed that this information would be reviewed during the actual visit.
Table I Page 1 of 2 RESPONSE TO ITEM NO. 1. HMSS 1990 REGIONAL QUESTIONNAIR Percentage of Time Spent by Each Individual
- Name Fuel Cycle Materials Materials Safeguards Safeguards Inspection Licensing Inspection Licensing Insp.& other Decommissioning Supervision Section FPRP Branch G. Yuhas, Chief **
EPRP Branch C. Hocker 25 90 Other Inspection support 10 (Various Inspectors) 10 NMSS Branch 10 H. Chaney, Acting Chief **
NMS Section 5
10 J. Montgomery 85 Sr. Matls. Spec.
5 95 B. Riedlincer Heal.th Physicist (Lic.)
98 F. Pang 2
Radiation Specialist 100 D. Skov 5
95 P. Zurakowski Radiation Specialist 100 I
Table I Page 2 of 2 RESPONSE TO ITEM NO. 1. NMSS 1990 REGIONAL QUESTIONNA Percentage of Time Spent by Each Individual
- Name Fuel Cycle Materials Materials Safeguards Safeguards Inspection Licensing Inspection Licensing Insp. & other Decommissioning Supervision Section F. Browne **
Licensing Assistant 50 50 Schuster, Chief **
Section 5
5 L. Norderhaug 10 Sr. M/C Analyst 5
10 A. McQueen Phy. Sec. Spec.
D. Schaefer 10 Security Inspector 10
-0 Fuel Cycle Licensing is not done in Region V o
Involved in the inspection process but not dedicated to performing a t c ual inspections.
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i Table II Organ 1zation Structure DIVISION OF RADIATION SAFETY AND SAFEGUARDS i
DIRECTOR - Ross Scorono S.or. tory - chree sorreg.
STATE AND 00VERNMENT L
AFTMRS STAFF EMEROENCY PREPAREDNESS AND MADIOLOGICAL Tnsic.,insN BRANCH NUCLEAR MATB41ALS SAFETY State Agreement Officer AND SAFEQUARDS BRANCH Jock Homer CHIEF - Oreg Yuhoe CHIEF - Bob Pete State Uoleon Officer Sooretory - Gene Moller-Dusk e
Deon Kunihiro t^ -i - Chris Serv 4 Senior Watertois ". a:^_ge jim : ". _.af
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Response to Item No. 2 NMSS Regional Questionnaire Budgeted and Actual Expenditures & Accomplishments, FY89 Table III Prograe FTE Activity Allocation Encenditures
...........................................................................Accesplishaents FUEL FACILITIES (FF)
Licensing 0.00 0.00 None planned Inspections 2.30 1.25 The inspection prograa was completed MATERIALS Licensing 1.80 1.50 Budgeted Cospletions 206 Actual Cospletions 217 Technical Assistance to Agrereent States 0.30 0.08 Inspection 2.70 3.31 Budgeted Cospletions 127 Actual Cospletions 180 National Progras Revieu 0.10 0.52 Perforsance Evaluation 0.20 0.05 Support for Allegations and Investigations 0.00 0.05 Support for Enforcesent 0.00 0.21 Medical Prograe leprovements - Inspect.
0.60 0.41 Budgeted Cospletions 8
Actual Completions 11 SAFE 6UARDS Safeguards FF Licensing 0.24 0.07 Budgeted Cospletions 10 Attual Receipts 3
Actual Cospletions 5
Safeguards FF Inspections 0.70 0.93 Budgeted Completions NA ActualCcapletions 9
Transport. Inspections 0.18 0.01 Budgeted Cosoletions 3
Actual Completions 3
Route Surveys 0.08 0.07 National Progras Reviews 0.00 0.06 LCu LEVEL WASTE 8 LLW Disposal, Licensing, and Inspection 0.20 0.02 Decessissioning 0.10 0.00 SECT!DM SUPERvlSIDM 1.00 1.29 l
TOTAL 10.70 9.83 8 RITS data charged to wrong ccdes - See Table V
Response to Item No. 2 NMSS Re Budgeted and Actual Expenditures &gional. Questionnaire Accomplishments, FY90 Table IV Periarte Budget Projected 8 8 FIE
(
y Allocation Espenditures Espenditures Accesplishaents FUEL FACILITIES IFF)
Licensing 0.00 0.00 0.00 None planned Inspections 2.00 0.69 0.40 1r6 g: tion progras on target to RATERIALS etnplete all sedules at all facilities Licensing 1.70 0.39 0.57 Budgeted Cosp!rtions 210 ProjectedCospletions 74 TechnicalAssistance Actual Completions 64 to Agreesent States 0.30 0.10 0.02 laspection 2.90 1.00 0.66 Budgeted Cospletions 125 ProjectedCompletions 43 National Progras Revies 0.10 0.03 0.18 Actual Cospletions 31 Performance Evaluation 0.20 0.07 0.03 Support for Allegations and investigations 0.20 0.07 0.01 Support for Enforcesent 0.20 0.07 0.60 Medical Prograe leprovements 0.20 0.07 0.01
,RDS Safeguards FF Licensing 0.12 0.04 0.01 Budgeted Cospletions 6
Pending Cases 1
Actual Cospletions 0
Safeguards FF Inspections 0.20 0.07 0.11 Budgeted Cospletions 3
Actual Cospletions 2
Transportation inspections 0.18 0.06 0.00 Budgeted Cospletions 3
Actual Cospletions 1
Route Surveys 0.08 0.03 0.00 LOW LEVEL NASTE LLW Disposal, Licensing, and Inspection 0.20 0.07 0.04 Deceseissioning Paterials 0.10 0.03 0.01 Decosalssioning Reactor 0.20 0.07 0.01
'ECTION SUPERVISlDN 1.12 0.39 0.40 TOTAL 10.00 3.46 3.08 t 8atarepresents18weets A
l Table V i
RESPONSE TO ITEM NO. 2, NMSS 1990 REGIONAL QUESTIONNAIR TIME SPENT ON LOW LEVEL WASTE ACTIVITIES FRPS Inspection Resources to NMSS - FY 89 Actual Modules Reported: 86721, 86740 and 84850 Research Reactors Module 86740 (hours)
Washington State NTR 1
GA 2
1 UC Berkeley Aerotest 5
1 Reed College 3
UC Irvine 2
Total TE-~
Power Reactors Module 86721 Module 86740 Module 84850 SONGS 16 Diablo Canyon 14 12 3
12 12 Rancho Seco 0
23 13 Trojan WNP-2 11 0
7 0
0 15 Palo Verde 41 12 110 (two inspectors)
Totals 7T ET 17T Total FRPS hours to NMSS =
15 71 61 171 ITE hours HMSS FTE a 318 2080 hrs x 32% =.48'FTE in FY 89 Data Source: 766 Data System
Attachment for
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Question 3
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UNmED STATIES
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E NUCLEAR REGULATORY COMMISSION a
REGON V f
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1450 MARIA LANE. SufTE 210 WALNUT CREEK. CAUPORNIA 94508 5300 FEB 16 1990 MEMORANDUM FOR: Richard E. Cunningham, Director Division of Industrial and Medical Nuclear: Safety, NMSS FROM:
Ross A. Scarano, Director Division of Radiation Safety and Safeguards
SUBJECT:
AFFECT OF U. S. TESTING ENFORCEMENT ON MATERIALS PROGRAM GOALS
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As you know Region V has been involved in protracted escalated enfo actions with U. S. Testing which involves the issuance of proposed Civil Penalties of $280,000, and $5,000. and their response denying most o violations.
our staff who have expended approximately 580 man this effort.
Redirecting such a large portion of our resources to this unplanned area has decreased our ability to do the budget numb cases and inspections.
scheduled to spend 20% of their effort on materia on inspections, we request our program goals be adjusted as follows:
5 FY 1990
- FY 1990 Revised Number of Materials Licensing Cases 210 190 Number of Materials Inspections 125 99 i
- See attached calculations The settlement of the U. S. Testing actions appears near, so additional adjustment for this effort should not be necessary.
Thank you for your consideration in this matter.
W Ross A. Scarano, Director Division of Radiation Safety and Safeguards
Attachment:
As Stated 437)<6OU1
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I. Activities were budgeted as follows:
a) 1.7 FTE O 74% for Licensing = 2617 hours0.0303 days <br />0.727 hours <br />0.00433 weeks <br />9.957685e-4 months <br /> = 12.46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> pe 2T6 cases b) 2.g FTE 9 27% for inspection = 1628 hours0.0188 days <br />0.452 hours <br />0.00269 weeks <br />6.19454e-4 months <br /> = 13.02 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />
~I25 inspections on II. a)
Dave Skov did 315 hours0.00365 days <br />0.0875 hours <br />5.208333e-4 weeks <br />1.198575e-4 months <br /> of Enforcement.
according to his original program goals, If he had been working been spent in inspection, and 10% (31.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) would ha 90% (283.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> would have in licensing.
n b)
Jim Montgomery did 265 hours0.00307 days <br />0.0736 hours <br />4.381614e-4 weeks <br />1.008325e-4 months <br /> of Enforcement working according to his original program go. If he had been have been spent in licensing.would have been spent in III.
Licensing
_ Inspection.
Budget 2617 Skov 1628 31.5 Montgomery
- 212
- 283.5 2373.5 53 1291.5 0 12.46 hrs. per case 190 cases 0 13.02 hrs per insp.
99 inspections 9
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i Table VI RESPONSE TO ITEM NO. 7, NMSS 1990 REGIONAL QUESTIONNAIR TRANSPORTATION INSPECTIONS Date Module Name Operations 86740 Last Docket No.
Class Performed Aerotest 50-228 11 General Atomics (Mark 1)50-089 11 3/27-30/89 General Atomics (Mark F 10/11-14/88 General Electric (NTR) )
50-163 II 10/11-14/88 50-073 11 Oregon State University 50-243 II 11/13-21/89 Reed College 5/22-25/89 50-288 II University of Arizona 8/1-4/89 50-113 II University of California 50-224 1/8-12/90 at Berkeley 7/1/89 University of California 50-326 II at Irvine 8/28-31/89 University of Washington 50-139 III Washington State 1/8-9/90 University 50-027 II 5/24-26/89
- under decommissioning order MODULES 86721, 86740 AND 83750 COMPLETIONS AT OPERATING POWE 83750 86721 FY 89 FY 90 FY 89 FY 90 FY 89 FY 90 86740 WNP-2 5/18/89 7/14/89 TROJAN 12/22/89 9/15/89 R.S.
11/09/89 1/26/90 8/30/89 D.C.
7/14/89 2/89 SONGS 11/08/89 4/03/89 4/03/89 PV 9/01/89 12/88 12/01/89 12/88 GA 3/3/89 ANF 12/16/88 and 9/29/89 GE-VAL 8/14/89
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WALNUT CREEK, CAUFORNIA 90006 53N 1400 MARIA LANE. SUTTE 210 j
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FEB 2 8 1990 MEMORANDUM FOR: Richard W. Cunningham, Director Division of Industrial and t
Medical Nuclear Safety, NMSS FROM:
Ross A. Scarano, Director Division of Radiation Safety and Safeguards
SUBJECT:
1990NATIONALPROGRAMREVIEW(MATERIALS),
ADDITIONAL RESPONSE TO QUESTIONNAIRE Enclosed is our response to the Office of Enforcement questions forwarded on February 21, 1990, as Enclosure 4 to the January 23, 1990, memorandum concerning the schedule and agenda for your staff's National Program Review.
Dean Chaney of my staff at FTSIf you have any questions concerning 463-3763.
d~~
Ross A. 'Scarano, Director Division of Radiation Safety and Safeguards
Enclosure:
As Stated cc:
J. Martin B. Faulkenberry R. Pate G. Yuhas Section Chiefs. DRSS Central Files, RV h
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1990 NATIONAL PROGRAM REVIEW REGION V INPUT TO 0FFICE OF ENFORCEMENT QUEST ENCLOSURE 4 1.
a)
What types and frequency of training is conducted by the regions in enforcement matters?
Formal enforcement training sessions conducted by the Enforcement Officer are scheduled once or twice a year (with makeup sessions policy, practice or procedures.as necessary), and whenever signi occurs in conjunction with resident inspector meetings.Nomall b)
Training for new employees and regional personnel?
The Enforcement Officer reviews enforcement policy and procedures with new employees after the employees have read the materials in their self-study program.
c)
How is enforcement guidance / instructions given out to regional personnel?
Whenever EGMs are received in the Region, copies are distributed to all the members of the technical staff as appropriate, d)
Has training been given especially on repetitive violations, enforcement discretion under V.G.1 and Severity Level V violations?
Training was given to all members of the technical staff in October discretion (V.G.1 of App.C), and Severity Level V 2.
Are repetitive violations being identified?
a) to licensee during close out b) to section chief during discussion of inspectors' findings SAFEGUARDS SECTION Yes, to all questions FUEL FACILITY SECTION during close out of inspection (exit interview).Yes, they are discussed with the section chief by the inspector following theThey are be inspection.
MATERIALS SECTION Yes, to all questions
. 3.
How are repetitive violations being documented?
a)
Is there a paragraph in cover letter
- 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?
SAFEGUARDS SECTION Yes, to all the questions FUEL FACILITY SECTION a)
Yes a) No specific boiler plate b)
No c)
Case by case basis MATERIALS SECTION Yes, to all the questions. The need for enforcement or management The safety significance of the violations are certainly cons reaching a decision.
4.
When a violation is repeated a third time, what action should be taken?
Region policy dictates that an enforcement conference be held and civil penalty evaluated.
The safety significance of the violations and their Severity Level are factored into this decision making process.
5.
Have inspectors had cases of repeat violations in inspections since new i
guidance was issued by Office of Enforcement?
SAFEGUARDS, FUEL FACILITY AND MATERIALS SECTIONS Yes 6.
How have inspectors exercised discretion under VG.1 during inspections of licensees?
SAFEGUARDS, FUEL FACILITY AND MATERIALS SECTIONS Followed guidance in Region V Policy 0201 and 10 CFR Part 2. Appendix C, paragraph V.G.1
4 7.
When and for what types of violations are 591's being issued?
MATERIALS SECTION Level IV and V violations, including repetitive vi safety significance.
violations on 591s so the licensee will have a written B.
How are repetitive violations, non-cited violations, and open items tracked?
_ SAFEGUARDS AND FUEL FACILITY SECTIONS Region's outstanding item tracking systems.By the inspe MATERIALS SECTION There is currently no formal tracking system being used.
enforcement for a licensee, these items (repetitiv violations) are examined and noted. The Materials Section is regarding repetitive and non-cited violations. implement 9.
inspection, and closeout old violations and flag rep SLF GJARDS AND FUEL FACILITY SECTIONS 1
Yes MATERIALS SECTION i
No formal tracking system used 10.
Could Office of Enforcement have copy of tracking system output of example license?
Yes, see attachment t
11.
Who does audit on tracking systems to assure input by?
Some source and tracking system output verification is done by DRMA next inspection preparation. staff, otherwise each inspector reviews O
)
. 12.
How many Severity Level IV and V violations were disputed by the licensee during the current FY?
SAFEGUARDS SECTION None FUEL FACILITY SECTION None MATERIALS SECTION One violation was disputed.
13.
How many Severity Level IV and V violations were withdrawn during the current FY?
SAFEGUARDS SECTION None FUEL FACILITY SECTION None MATERIALS SECTION One
.14 Do the regions perform internal audits, other than the normal concurrenc process, of inspection reports and Severity Level IV and V violations?
SAFEGUARDS, AND MATERIALS SECTIONS No FUEL FACILITY'SECTION Yes, very informal 1
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WALNUT CREEX, CALIFORNIA M500 OCT 121989 h
MEMORANDUM FOR:
Emergency Preparedness Section Staff FROM:
Ray F. Fish, Chief Emergency Preparedness Section.
SUBJECT:
DETERMINATION OF REPEAT VIOLATIONS During an October 10, 1989, on handling severity IV and V violations, there was a discussiontrainin concerning documentation (auditable record) by inspectors to confirm they had performed the appropriate review of prior violations, both No. 0201, Handling of Region V Enforcement Actions. cited an Paragraphs "c" through "f" of Section E.7 describe the inspector's responsibilities specifically.
in paragraph "f,"I have generated a form that can be used.In order to f this new form is attached.
A copy of Because we expect Headquarters to audit the regional implementation of the enforcement program, including compliance with the requirements in Regional Instruction No. 0201, I suggest you read again and become very familiar with your responsibilities delineated in Instruction No. 0201.
[
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Ray. Fish, Chief Emergency Preparedness Section
Enclosure:
as stated cc:
A. Johnson i
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ENFORCEMENT REVIEW Severity IV and/or V violations identified during this in
" repeat" violations.
Licensee:
Inspection Report No.
//
The violation (s) identified is not a repeat violation
~-
identified during a prior inspection.
/_/ The violation (s) is a repeat ** of a violation that occurred:
Inspection Report No.
Violation 1.
2.
3.
Reason escalated enforcement action not taken:
Signed:
Inspector period covering the last two (2) inspections whiche Include cited and non-cited violations.
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JAN 191990 Docket No. 50-344 Portland General Electric Company 121 SW Salmon Street, TB-17 Portland, Oregon 97204 Attention:
Mr. David W. Cockfield, Vice President, Nuclear Gentlemen:
SUBJECT:
HRC INSPECTION TROJAN NUCLEAR PLANT December 18 through 22This refers to the inspection conducted by M 1989 of activities authorized b NPF-1 and to the discus,sion o,f our findings held by Mr. y NRC License No.
and other members of your staff at the conclusion of the inspection. Russell with
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Areas examined d&ing this inspection are described in the enclosed ins report. Withir. these areas the inspection consisted of selective examinations 4 procedures a,nd representative records, interviews with personnel, and observations by the inspector.
Based on the results of this inspection it appears that some of your activities were not conducted in full co,mpliance with NRC requirements as set forth in the Notice of Violation, enclosed herewith as Appendix A, and the Notice of Deviation, enclosed herewith as Appendix B.
Your response te these Notices is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in the Appendices.
We note that item A of Appendix A is a repeat of violation B. 3. in our letter to you dated March 15, 1989.
have to do with work control practices.Both violations are very similar in nature an on Janwy 12, 1990, During the PGE/NRC management meeting plan and stressed steps being taken to improve maintenance.you prese analysis of the causative factors for these similar violat explanation of how your improvement plan should have or will preclude 1
recurrence.
\\
In addition to the repetitive aspects of item A, enclosed, we have concern of containment depressurizations via the hydrogen vent sy enclosed in3pection report describes your use of questionable monitoring da Page 4 of the to discount s>ecific statements of a worker which clearly imply that the w train of the tydrogen vent s to mid-September time frame.ystem may have been monitored during the mid-July would also appreciate receiving your final conclusion on this po
-02/D8/90 RANCHO SECO VIOLATIONS (0101/90) t 05000312 PAGE 1 TEXT 88004 4 581070 ACCESS CONTROL--PERSONNEL-.._____._____...__...... __..__...._______.__._______
CONTRARY TO SECTION 1.7.1 0F THE APPROVED SECURITY PLAN. THE LICENSEE FAILED 10 DEMY ACCESS TO UNAUT HORilED PERSONNEL.
88004 D 581070' ACCESS CONTROL.. PERSONNEL OCOM TO LICENSEE'S ((TTER DATED JULY E LICENSEE FAILED TO ADEQUATELY REVALIDATE SECURIT29, 1987. TH Y BADGES EVERY 31 DAYS.
88006
'4
$25565 THI ACTION PLAN INSPECTION FOLLOWUP 10 CFR 50. APPENDIX B. CRITERION V. REQUIRES THAT ACilvillES AFFECilNG QUALITY SHALL BE PRESCRIBED 8 Y DOCUMENTED INSTRUCTIONS PROCEDURES OR DRAWINGS AND SHAtt SE ACCOMPLISHED IN ACCORDANCE WITH THESE INSTRUCTION
S. PROCEDURE
S. OR DRAWINGS.
SMUD MATE RIAL 5 MANAGEMENT PROCEDURE 704P.0025. ' PRESERVATION
. STORAGE. AND MAINTENANCE OF ITEMS IN STORAGE.* P ANAGRAPtt 7.6.5, REQUIRES THAT ITEMS WHUSE SHELF Ll iE HA5 f XPIRED $ HALL BE REMOVED FROM THEIR STORAGE 10LA110N AND PLACED IN A ' HOLD" LOCATION.
RANCHO SECO MANAGtMtNT INFORMATION SYSTEM REPORT R5MM 03
- 30. DATED JANUARY 4.1988.- IDENTIFIED MATERIALS WI IH EXPERATION DATES FOR THE FIRST QUARTER OF 1988.
CONTRARY TO THE STATED REQUllREMENTS ON FEBRUAR Y 4.1988, lHREE SAFETY-RELATED RSMM 0330 GASKET L INE ITEMS (9 PIECES. WITH EXPIRED SHELF LIVES. HA D MOT BIEN TAGGED PLACED IN A HOLD LOCATION.
88012 4 571710
[NGINEERLD SAFEIY FEATURE WALK DOWN DURING AM NRC INSPECTION CONDUCTED ON MARCH 30 THR OUGH MAY 2.1988. A VIOLATION OF NRC REQUIREMENTS WAS IDENTIFIED.
IN ACCORDANCE WiiH THE 'GENERAE 5 TATEMENT OF POLICY AND PROCEDURE FOR NRC ENFORCEME NT ACTIONS.* 10 CFR PART 2. APPENDIX C. THE VIOLAT ION 15 LISIED BELOW:
10 CFR 50.72 (B)(2)(II STAT
- (8) NON-EMERGENCY EVfMTS..)..(2)
E5. IN PART:
[00R-H00R REPORTS.
...THE LICENSEE SHALL NOTIFY T HE NRC AS 500N AS PRACTICAL AND IN ALL CASES. WITH IN FOUR HOURS OF THE OCCURRENCE OF ANY OF THE FOLL
f ENFORCEMENT REVIEW This confims my review of prior
- inspections to determine whether the Severity 1Y and/or Y violations identiffed during this inspection are
' repeat" violattons.
Licensee:
L._ l A.,u,./
Inspect 1on Repurt No. so sa/miy UMG hh<l' 8 The violation (s) identified Nnot a repeat violation identiffed during a prior inspecticn.
/_/ The violation (s) is a repeat ** of a violation that occurred:
Jnspection Report No.
Violation 1.
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2.
3.
Reason escalated enforcement action not taken:
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Include cited and non-cited violations.
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