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MAY 3 0 1991 l-MEMORANDUM FOR: Thomas T. Martin, Regional Administrator Region I FROM:
Glen L. Sjoblom, Deputy Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
FINAL 1991 NATIONAL PROGRAM REVIEW REPORT REGION I Enclosed is the 1991 National Program Review (NPR) report for Region I.
This report covers the period between our last two NPR team visits (roughly April 1990 through March 1991).
For the second year, the report includes not only all regional activities under NMSS' oversight authority, but also the enforcement activities related to these licensees, as reviewed by the Office of Enforcement.
NMSS circulated a draft version of this report to the region's Division of Radiation Safety and Safeguards.
These comments have been incorporated into this final version of the NPR report, as appropriate.
As always, we appreciate the efforts of your regional staff throughout the year and we welcome any additional thoughts you might have that might lead to further improvements in our review process.
Glen L. Sjoblom, Deputy Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
As stated DISTRIBUTION:
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OFFICIAL RECORD COPY 8
NPR REPORT FINAL 1991 9309150078 930830
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n REPORT OF NHSS 1991 NATIONAL PROGRAM REVIEW AT NRC REGION I, FEBRUARY 20-21, 1991 1 BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear isaterial Safety and Safeguards (NMSS) and Office of Enforcement (OE) 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 Attachment 1.
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 data, the accompaniments of region-based inspectors, the review of casework and inspection statistics, resource utilization, technical assistance and coordination actions including conference calls, and the information questionnaire.
The NPR process is intended to provide a review of effectiveness of both the Region and Neadquarters activities insofar as they relate to Region I's activities, and to identify suggestions for improving the effectiveness of the collective efforts of HMSS, OE and Region I.
The NPR review emphasizes both numerical goals for licensing and inspection activities and quality of licensing, inspection, and enforcement efforts, on the basis that all of these elements contrib6te to i
assuring the safety and safeguards of operations involving NRC licensed activities.
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The report is organized so as to present an integrated sumary of Region I activitiesin}eachofthefollowingareas 1.
Background and Purpose 2.
Licensing 3.
Inspections 4.
Enforcement 5.
Training 6.
Initiatives 7.
Interfaces of Region / Headquarters 8.
Resource Utilization 9.
Recomendations/ Suggestions 2
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2 LICENSING a.
Materials Safety In FY90, the Region completed 103 percent and 92 percent of revised budgeted licensing actions for new licenses and license amendments respectively, and 168 percent of the budgeted license renewals.
In total, the Region completed 106 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 FY89 that were completed in FY90 as well as through extensive staff efforts in the second half of FY90.
During the first part of FY91, Region I primarily devoted its recently acquired staff resources to inspection and qualification activities, yet still managed to complete about 94 percent of the actions for which it was budgeted through February 28, 1991.
Region I was considering proposing a significant change in its Operating Plan because of its continuing shortage of fully qualified staff. [ Region I has decided not to propose a change due to improved performance and productivity experienc ed after the dates of the NPR.
In fact, based on data thru April 30, 1991, Region I was about 10% ahead of its FY91 Operating Plan goal.]
During the second half of FY90, several actions were undertaken to enhance the Region's overall performance in the licensing category.
Specifically: (1) considerable overtime was employed by the professional staff, (2) achievable
- goals, i.e., license applications not requiring complicated reviews or responses were identified, (3) several highly qualified individuals were added to the staff and (4) two individuals from Headquarters possessing substantial licensing experience spent considerable time in the Regional office to augment the licensing effort.
The Region was successful in acquiring several highly qualified individuals resulting in five professionals being qualified to perform Level 1/2 license reviews during FY90 and through January 31, 1991.
The Region will achieve greater efficiency in licensing as new professionals join its staff and become fully qualified to sign their own licenses.
The planned segregation of the medical licensing function under a dedicated Section Leader will greatly enhance this effort.
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'8 A select number of Region I licensing cases were reviewed against NRC Regulations and Standard Review Plans.
The cases were complete, no errors were noted.
In addition, several VA medical licenses were reviewed to determine that their program codes were correct for a limited versus broad medical institution.
This review was conducted as part of an ongoing Headquarters review of VA-licensed facilities.
No discrepanies were noted.
A small sampling of docket files demonstrated that the files were maintained in an orderly manner.
Region I has an excellent system for tracking the status of licensing actions.
However, review of a report from the Licensing Management System (LMS) dated February 1,1991, revealed several licensing actions which had not been entered in a timely manner.
Such delays were caused by staff turnover, personnel absences, and lack of familiarization within the Licensing Assistance Section (LAS). This problem appears to be headed toward resolution under the direction of a new Section Leader who came aboard in July 1990.
The LAS Section Leader expressed concern regarding the staff's ability to process mail and all licensing actions in a timely manner, particularly in view of the expectation for increased licensing productivity when the medical licensing program is restructured.
Some attention to this area is needed in order to lessen the administrative bottleneck and enhance completion of licensing actions.
This problem has been somewhat alleviated by the hiring of a highly qualified Reference Assistant to fill a slot that has been vacant for eight months.
b.
Safeguards Licensing With the transfer of all NMSS Material Control and Accounting (MC&A) licensing and inspection activities to Headquarters completed, and with the decommissioning activities at UNC Montville, there was no independent licensing (70.32) casework
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during FY90.
However, five licensing actions were reviewed in conjunction with Headquarters for UNC Montville.
In addition, the Region participated in two licensing meetings at the UNC Montville facility and two licensing meetings at Headquarters regarding UNC Montville submittals.
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3 INSPECTI.
a.
Materials' inspections In FY90, 740 materials safety inspections were completed.
The revised budgeted goal for FY90 was 724 inspections.
Thus far, through March 31, 1991, 545 inspections had been completed.
The budget target for that time period is 573 inspections.
The planned number of inspections for the year is 1146.
Therefore, the Region should easily exceed last year's performance and is close to being on track to meet this year's Operating Plan goal.
Of the 320 inspections completed through January, 252 were with violations, 68 were without violations, and the average elapsed time to issue an inspection report was 46 days.
For January 1991 only, of 35 inspections reviewed, 21 had violations, with the average elapsed time to issue an inspection report of 46 days and 14 had no violations, with the average elapsed time to issue an inspection report of six days.
The Region has not yet achieved the numerical inspection goals due to the average level of inspector / reviewer qualification and due to the need for extensive training of the many newer people.
However, the rate at which the work is being accomplished is increasing and further improvements are expected as this year progresses.
As stated above, the Region is doing a much better job (numerically) than it was doing at a similar time last year.
Region I was considering modifying its Operating Plan to propose deferral of 140 inspections.
The reduction was being considered due to the level of effort necessary to train new inspectors coupled with ncompaniments by Section Leaders in order to expedite the qualification process. [ Region I has now decided not to change its Operating Plan due to improved performance and productivity after the dates of the NPR.]
Communications regarding licensing issues with the Region remains thorough. The DRSS Division Director routinely meets with the division staff to discuss goals and issues.
The Branch Chief also meets at approximate one week intervals, with new hires to discuss goals and general training pertaining to administrative issues etc.
In addition, Section Chiefs also routinely meet with their respective staffs to 5
discuss inspection schedules and related regional objectives.
In particular, a six month "look ahead" schedule has been developed to maintain CORE program objectives and prevent delays or oversights of scheduled inspections.
Section Chiefs' emphasis on inspection effort is currently geared to Operating Plan commitments and timely issuance of inspection reports.
The Regional staff is currently thinking of how to improve computer based tracking systems for scheduling and monitoring performance of inspections.
The systems identified as Materials Inspection Report Tracking System (MIRTS) and Inspection Report Tracking System (IRTS) represent a substantial undertaking by Regional management to track inspections.
However, the systems currently pose a number of problems which may be beyond the regional staff's ability to address in terms of information systems management and availability of management time to resolve these issues.
Consequently, Regional management may want to consider the use of outside expertise to accomplish this important objective in a timely manner.
HMSS financial assistance should be available.
Overall, materials staff morale and workload appeared good and improving, with no major complaints from those interviewed by NMSS team members.
Discussions indicate that inspectors are checking to determine if licensees receive Infora tion Notices.
There is a line on the inspection module that reminds the j
inspectors to check this item.
Inspectors do not always receive the NMSS newsletter and the inspectors sometimes 1
encounter licensee questions about specific articles before the inspector has had a chance to review the article.
NMSS committed to address this problem.
b Fuel Cycle Safety Inspections The Effluents Radiation Protection Section of the Facilities Radiological Safety and Safeguards Branch has the primary responsibility for the fuel cycle safety inspection program.
During FY90, the fuel cycle safety inspection program was essentially completed.
It is noted, however, that inspectors not fully trained in fuel facility radiation safety, performed some of the radiation protection inspections at an operating facility.
This facility is also undergoing initial 6
stages of decommissioning which gives rise to potential radiation safety issues.
The Section is recruiting one additional staff member which should alleviate this staffing issue, t
During the past year, IMNS staff members participated in, or accompanied, inspectors on several fuel cycle inspections and found the inspectors to be conscientiously implementing the inspection program.
In all cases, the inspections were performed consistently with NRC policy and guidance.
The IMNS staff participation in the inspections was and is considered to be beneficial and worthwhile to both Region I and IMNS staff.
IMNS staff reviewed all safety inspection reports for Combustion Engineering and UNC, Inc., for the period of March 1990 to February 1991.
The IMNS staff rated the reports to be above average in clarity, recognition of issues, and appropriate enforcement actions.
Region I, however, required an average of 41 days to issue these same reports.
This significantly exceeds the goal of 20 days.
In December 17, 1990, memorandum to Richard E. Cunningham, Robert M. Bernero requested, in conjunction with the National Program Review, the staff to determine if there is still a "significant gap in our regulatory approach, our inspection methods, or our implementation" of findings for lessons learned.
The Region I fuel facility staff was queried on this issue.
The Branch Chief considered that, for Combustion Engineering (CE) inspections, the failure to use radiation protection specialists, as well as fuel facility inspectors, may have contributed to not finding the problems at CE in earlier inspections.
In later discussions, the Branch Chief recognized a similar pattern in the use of regional inspectors at an operating facilitybn the early stages of decommissioning.
There is now a recognized need for enhanced radiation protection inspections during the initial stages of decomissioning.
In response to an IMNS request, the Region I staff agreed to provide inspection trip reports to the West Valley project manager in NMSS for all West Valley interactions except for meetings which are attended by IMNS staff.
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The fuel cycle licenses are maintained current by the fuel facility inspector and are available for use by other inspectors.
Licen:ees' emergency plans are 7
also maintained by the fuel facility inspectors. Only one of two plans was located quickly by regional staff.
The other plan took five to ten minutes to locate. Data bases for outstanding items are maintained, and closure of such items is aggressively pursued by the Regional staff.
The Region I fuel cycle staff does not always have the opportunity to participate in preplanning for licensee meetings.
This has led to Region I management discussing non-relevant issues with licensee:.
c.
Safeguards Inspections Region I performed three safeguards inspections in FY90.
Fourth quarter inspection activities were devoted to licensing reviews with Headquarters for the transfer of all unencapsulated material from the UNC Montville facility.
One inspection per quarter is scheduled for FY91 unless there is a significant change in the security status of the facility (e.g., changing from a Category I facility to a Category II facility).
If and when these changes occur, additional inspections will be added to the schedule. One inspection had been completed during the first quarter of FY91.
It should be noted that the Region I staff is continuing to provide valuable assistance to Headquarters by constantly monitoring the UNC Montville deccanissioning activities, especially as related to the guard force status.
The Region I inspection reports were thorough and technically ccn4etent. The reports were con.pleted in a timely manner and submitted to Headquarters.
In related inspection activities, Region I staff provided valuable input to Headquarters on a number of issues related to the inspection activities at Category I facilities during FY90.
Specifically, staff attended three separate nieetings at Headquarters related to the inspection test kit, new perfori..ance inspettiti prctedures, and a Category I counterpart nieetir.9 with stafi fruta Legion II ario all the Category I licensees.
It should be noted that significant input was provided by the Region to Headquarters staff related to the new performance procedures.
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Additionally, the Region had attended two meetings at Headquarters during the first quarter of FY91.
d.
Safeguards Transportation Inspection Programs Region I completed two safeguards transportation inspections versus the four scheduled for FY90.
As in previous years, a number of shipments either were cancelled or never materialized.
One route survey and one port survey was performed at the request of Headquarters during FY90.
During the route survey, training was provided by the Region to a new Headquarters employee.
During the first quarter of FY91, one safeguards transportation inspection had been completed.
e.
Transportation Inspections Region I continues to conduct inspecticns of transportation activities as part of materials license programs and reactor radwaste program activities.
The appropriate inspection modules are used by the inspectors.
The review of Region I's program shows that transportation inspections are being generally conducted by inspectors who are knowledgeable of and experienced in the transportation regulations.
It was noted during the review that inspectors had available current copies of Parts 100-177 of Title 49 of the Code of Federal Regulations, Transportation.
Specific questions can be and have been directed to the transportation specialist at NHSS.
Additional reference material will be sent by NMSS to the Region as these materials become available Transportation inspections of materials are part of the materials safety inspections.
As a result, reports and numbers cannot be specifically separated from other aspects i
of the inspection.
For materials licensees, inspectors use the field note format.
This format is a complete facility inspection report form that contains section 7A related to transportation.
Section 7A was mostly consistent with 86740.
- However, subtle differences will be reviewed by Headquarters to ensure complete compatibility.
A review of several inspection reports showed that section 7A had been completed as appropriate for the inspection.
Documented violations included failures in properly completing shipping papers, failure in surveying packages and failures in adequately blocking and bracing packages during transport.
Followup was adequate.
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Transportatiog(inspections at reactor facilities are part of radwaste program inspections.{Inspectionsofradwastetransportationprogramswerefoundtobe consistent with procedure 86750.
The frequency of inspections coincides with the SALP cycle for the facility.
Two violations have been noted.
These violations were related to failure to use appropriate packaging and excessive external radiation levels on a package.
The transportation program in this area demonstrates a high rate of compliance with the DOT and NRC regulations.
Currently, there is one experienced transportation inspector in the Region I program.
This individual's expertise is laudable.
He is training other inspectors to perform the transportation inspection at radwaste facilities, f.
Low-Level Waste Inspections Region I continued to conduct inspections of low-level waste activities and procedures at reactor, materials and fuel cycle facilities during FY90.
All reactor facilities received at least one low-level waste inspection during normal SALP activities and two escalated enforcement actions were undertaken.
The enforcement actions were timely and follow-up corrective actions were taken.
Inspection of radwaste at reactor facilities has recently been delegated to a new section and a senior staffer conducts 100 percent of low-level waste inspections.
More accompaniments should help provide a cadre of people fully capable of conducting transportation-radwaste inspections.
Region I has provided valuable feedback to Headquarters on the usefulness of new core inspection procedure 86750.
This included the identification of important reference material and the need for definitive guidance in the waste form waste classification area.
Radwaste materials inspections are currently performed by inspectors who perform the entire realm of materials inspections.
Current section chiefs work loads precluded detailed involvement of those supervisors in staff inspection activities.
No escalated enforcement actions were identified.
Region I should continue its efforts to conduct supervisory inspections in the materials area.
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4 ENFORCEMENT a.
Background and Purpose This section provides the results of participation by the Office of Enforcement (DE) in the HMSS National Program Review conducted at Region I, February 1991.
Issues Discussed:
For Severity Level III enforcement cases to be issued by the Region under the Delegation of Authority, concern that OE be informed of the facts of the case and have opportunity to provide verbal input (e.g., via conference call) early in the decision process.
Need to include a statement of the " regulatory concern" in the letter that accompanies a Notice of Violation at Severity Level IV or V.
Region I's experience with the dBase tracking system that inspectors use to track open items, repetitive violations, and non-cited violations.
i Maximizing the use of Form 591.
Experience with non-cited violations.
Results of the audits performed at the Division Level on Notices of Violation at Severity Level IV or V.
Adequacy of licensees' responses to Notices of Violation at Severity Level IV and V.
Use of Personal Computers (PC) and standard paragraphs for the preparation of Notices of Violations and related enforcement documents.
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b.
Discussion of Enforcement At the outset of this program review, there was some lack of agreement between Region I and OE concerning the Delegation of Authority to issue certain escalated enforcement actions.
OE believes that it should be fully informed concerning the facts of the case and have opportunity for verbal input early in the process of considering escalated enforcement action.
Region I was of the opinion that it should exercise its delegated authority relatively independently, with primarily a retrospective audit by OE, followed by any policy direction that may be necessary as a result of the handling of the case.
At the conclusion of the program review, Region I agreed to include OE early in the process of formulating escalated enforcement action.
The NPR review team does not believe that the weekly Wednesday meetings at the Division Director level have fully implemented the recommendation made last year that Region I consider the use of an enforcement board to determine the need for escalated enforcement action.
For cases that may require escalated enforcement action, individual debriefings are still held successively between the inspector
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and the Section Chief, and then among the inspector, Section Chief and Branch Chief.
In addition, the inspector may also be called into the Wednesday meeting where the final decision concerning the need for escalated action will be made.
At the conclusion of the program review, Region I agreed to give further consideration to implementing the use of an enforcement board.
Region I personnel planned to review Region III's enforcement board process as it participated in the Region III program review.
Discussions indicate that inspectors understand the non-cited violation process and use it when it is possible to do so.
There is a preference for documenting the NCV in the inspectors' field notes.
Discussions indicate that problems noted as a result of the audit program at the Division Director level for Notices of Violation at Severity Level IV and V generally involve instances where the wording could have been clearer but is not legally incorrect.
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l Discussions with Section Chiefs indicate that licensee responses to Severity Level IV and V violations are carefully rhviewed in the Region. As many as 20% of the initial licensee responses require additional information before they can be closed out.
Most frequently, these are handled by telephone calls to the licensees.
When an inspection results in escalated action, the " clock" on the action starts immediately even though the inspector may have to spend several more days on the road.
The inspector could have the Notice of Violation and associated documents drafted in his or her absence by calling in from the road with 1
numbered boilerplate paragraphs and numbered standard citations.
Discussions, as well as the attached data (attachment 4), indicate that Form 591 is being used extensively in Region I.
Inspectors and their Section Chiefs are satisfied with the current form and did not recommend any changes.
The medical Section Chief estimates that the use of this form approached 50% of his inspections.
Normally, the Form 591 is issued by the inspector in the field.
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1 5 TRAINING i
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a.
Materials l
The Region continues extensive efforts in training of new staff in the materials A considerable effort is required and therefore Region I is not yet reaching area.
the licensing and inspection efficiency that should be reached in the reasonable future.
However, good progress is being made.
Individual Development Plans (IDP) are routinely used for all employees and qualification journals are also being used effectively.
At the last NPR, NMSS requested that a training completion matrix be developed 4
to show the required and supplemental courses taken by for each inspector.
In response to a similar request in the NMSS questionnaire this year, some information was provided.
However, following the NPR visit a subsequent review determined l
it only shows when the Region qualified staff at various levels.
The more detailed information has been found useful in other regions to assist in planning and ensuring that necessary and ongoing training is carried out.
The new hires appear to be routinely accompanying senior staff during inspection related activities and plans are in place to have these individuals conduct independent inspections with direct observation by their respective Section Chiefs.
If the audit is deemed favorable by the Section Chief, the individuals will be given formal documented " interim authorization" requested by the Section Chiefs and approved by the Branch Chief to conduct some independent inspections prior to completing their qualification journals.
This allows the earliest effective use of new staff.
b.
Fuel Facility The Region I fuel cycle staff again expressed the need for training.
The experienced i
Region I staff believes that attendance at professional and technical meetings should fall into the training category.
Specialized training for new staff hires should be l
provided.
Participation at counter part meetings should include the Section Chief and 14
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inspectors with fuel facility inspection responsibilities.
The Region I staff feels that, because of limited training opportunities and small staff, participation by the Section Leader as well as all involved inspectors should be encouraged.
At the time of the review, the Region I fuel cycle staff was not aware of the fire safety training program to be given in May 1991, just prior to the Fuel Cycle Seminar.
The Region I staff commented that the fuel cycle technology training course which is under development might be too elementary for some fuel cycle staff.
c.
Safeguards All seven members of the safeguards staff attended the Security Training Symposium sponsored by NMSS in FY90.
In addition, training of one inspector in safeguards transportation inspections and route surveys has already been initiated with plans to train two other inspectors.
d.
Transportation With respect to transportation, additional refresher training of personnel is needed.
About one-half of the inspectors have been trained in transportation inspections and at least 1 inspector has training that dates back to 1982.
The TTC at Chattanooga is revising H-308 on transportation.
This course will be conducted in July 1991 in Columbia, SC.
Region I is encouraged to send appropriate staff to the course.
Region I has requested that this training be presented in the regional office to save significant time and resources.
However, the Columbia site was selected because the prime contractor is located near the Barnwell low-level waste site.
It is planned that refresher training will be offered frequently in each region.
Training needs in low-level waste transportation have been identified for four
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staff members in the material area and one staff member in the fuel facilities area and potentially two staff members in the reactor areas.
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6 INITIATIVES BY THE REGION The following Region I initiatives wore underway throughout the past year:
The Region has made progress in reducing somewhat the load on Section Chiefs, but more attention would be useful.
The region is creating another materials section.
A recently completed internal A 'it has documented several problems with the inspection tracking system edT nistration.
This audit report appears to have several useful recommendations and NHSS has no additions to make.
NHSS is willing to provide assistance as needed in resolving this problem.
Similar audits have been useful in other regions, such as in reviewing the adequacy of responses to enforcement actions and adherence to MC610.
Allegation backlog and level of effort are well managed and properly prioritized.
The Region is assigning a formal allegation coordinator.
Core inspection backlog is well managed and inspectors are scheduled based on the CORE priority (1, 2, and 3).
The Region is using some stay-in-school staff to help out with the administrative burden.
The Region continued many good initiatives that were listed in last year's report.
Region I has reduced the average time to issue a materials Notice of Violation at Severity Level IV or V from 62 days in FY90 to 47 days for FY91 to date.
As of February 7,1991, there were no late inspection reports within the Nuclear Materials Safety Branch and the Branch Chief predicted that the average time to issue a report will drop further as the year continues.
Region I has initiated a weekly meeting at the Division Director / Branch Chief level to track the status of escalated enforcement actions.
Region I estimates that this meeting is reducing the average time that an escalated enforcement package spends in Region I to approximately 25 days.
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7 NMSS/ REGION I INTERACTION Interactions between NMSS and the Region have been very good.
The counterpart meetings and workshops and inspection accompaniments scheduled 1
during FY91 should foster this interaction.
Routine telephone discussions and periodic meetings on ongoing and emergent issues are also effective.
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Region I has made excellent generic contributions to the national program in the materials safety and safeguards areas.
We hope that even greater use can be made of Region I expertise in developing contributions to the materials 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.
NHSS will improve its responsiveness in this area.
Headquarters again expressed the need for a written trip report on inspector reviews of activities at the West Valley Demonstration Project.
The Region has requested more lead-time from Headquarters in scheduling meetings, route surveys and safeguards transportation inspections.
This will be discussed with the Headquarters personnel and a solution to the problem will be found.
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8 RESOURCE UTILIZATION a.
Expenditures and Staffina The attached table show FTE allocations and expenditures for the review period.
Region I has no program support funds in the NMSS mission areas.
The resources for FY90 were underexpended by 14 percent due to staffing shortages.
In FY90, materials licensing completions were 1549 versus a revised goal of 1475.
In materials inspections, Region I completed 740 inspections versus a revised goal of 724.
Through January 1991, resources are underexpended by approximately 11 percent.
At the time of the review, materials licensing and inspections were slightly behind due to vacancies and extensive time required for recruiting and training new staff.
Also, a number of significant and highly visible activities (e.g.,
RTI, Stanford Mining, Consolidated NDE, Site Decommissioning Management Plan etc.) impacted Region I's ability to perform routine licensing actions and j
inspections.
During the review, Region I had prepared a proposed revised Operating Plan for materials licensing and inspection activities.
- However, based upon improved performance and troductivity in March and April, both NMSS and Region I now agree that such a ra"ision is no longer necessary.
i The Safeguards and Transportation effort appears to be performing on schedule.
Transportation inspections are being completed on timely basis.
Resources are underexpended through January due to the lack of opportunities for transportation inspections and the lack of physical security activities at UNC Montville.
The Low-Level Waste resources were being slightly underexpended through January.
However, the program seems to be running smoothly.
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REGION I RESOURCE UTILIZATION The following table shows FTE allocations and expenditures for the review period FY91 FY90 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDEO 8UDGET OCT-JAN OCT-JAN %
Fuel Facility Licensing 0.04 0
0.04 0.01 0.0 Event Evaluation
- 1. 9 2.1 111 3.5 1.2
- 0. 8 Materials Licensing
- 7. 7 11.5 149 7.5 2.5 3.9 Materials Inspections 15.5 9.5 61 16.4 5.5 4, 0 Fuel Facility Insp.
3.0
- 1. 8 60 2.9 1.0
- 0. 5 SG Fuel Facility Lic.
0.02 0.1 500 0.02 0.01 0.01 SG Fuel Facility Insp.
0.5 0.3 60 0.5 0.2 0.04 SG Transportation Insp.
0.4 0.1 25 0.4 0.1 0
& Plans LLW Inspection 0.25 0
0.25 0.08 0
Reactor Decomm.
0.2 0
0.2 0.07 0.01 Materials Decomm.
0.5 0.3 60
- 0. 5 0.2
- 0. 3 NHS Section Supr.
3.5 3.1 55 3.5
- 1. 2
- 1. 2 NMT Section Sup.
0.2 0.1 50 0.1 0.03 0.01 LLW Section Supr.
0.1 0.04 40 0.2 0.07 0.04 TOTAL 33.81 29.0 86 36.01 12.17 15751 89 NOTE:
FY90 expenditures from regional input provided in response to FYP/ Green Book update in January 1991.
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9 RECOMMENDATIONS The Region should continue aggressive r?cruiting for the foreseeable future, as planned.
The Regian should seek reasonable ways to 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).
As positions become vacant in the materials area, the Region should continue its attempts to promote from within.
This would aid in raising expectations by the technical staff.
Several such actions in the past year have been beneficial.
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.
HMSS has made this recommendation to IRM as well and is willing to make its views known again if requested by the region.
A training completion matrix should be developed for the MC 1245 required and supplemental courses.
(Please see training section).
Regional Section Chiefs should accompany each inspector each year.
Region I should assure that inspectors qualified in radiation safety are used to perform the fuel cycle radiation safety inspection program.
Region I should identify causes for the delays in issuing fuel cycle inspection reports and take appropriate actions to minimi?e the delays.
20
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i Radiological Contingency Plans should be maintained in a well-known unique location for use by inspectors and response center personnel.
Region I should recognize and encourage attendance at technical and professional society meetings as appropriate training for experienced inspectors of fuel cycle licensees.
Because of the small size of the fuel cycle staff and limited training opportunities, the Section Chief and involved inspectors should be encouraged to attend counterpart and fuel cycle training.
NMSS should sponsor development of training programs for new health physicists performing radiation protection inspections at fuel facilities.
NHSS should sponsor development of training programs for inspectors performing nuclear criticality safety inspections.
The Region has made the suggestion that the Spent Fuel and Category II transportation inspection modules be revised.
It also suggested the need for new guidance criteria regarding port surveys and dock surveys to incorporate lessons learned to date.
The Region should continue to address the efforts needed to solve the administrative problems in the materials licensing and inspection area, such as through improving tracking and mail handling staffing levels, and more efficient computers usage.
Region I should implement a system to create Notices of Violation and related cover letters through the use of numbered boilerplate paragraphs and numbered standard citations that are being provided by OE.
The appropriate numbers would be provided by the inspector to a secretary or used via PC to create the draft document.
A recurring comment at the Section Chief level is that not every letter that accompanies a Notice of Violation at Severity Level IV or V needs to 21
describe a specific regulatory concern in the standard cover letter format as the Enforcement Manual calls for.
There is a preference to save a description of regulatory concern for the more significant cases so that the impact is preserved and licensees are not desensitized through the over use of this message.
Subsequently, OE agreed to modify the format for the Severity Level IV and V cover letter to indicate that a statement of the regulatory concern should be included, if applicable.
NMSS should ensure the regions are provided adequate copies of the HMSS 1
Newsletter and the Region should route them so as to ensure quick availability to the staff.
t 22 L
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i Review Team
- Glen L. Sjoblom, Deputy Director, Division of Industrial and Medical Nuclear Safety, NHSS William L. Axelson, Deputy Director, Region III, Division of Radiation Safety and Safeguards Larry W. Camper, Section Leader, Medical and Academic and Commercial Use Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS George H. Bidinger, Section Leader, Uranium Fuel Section, Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, NHSS Elizabeth Jacobs-Baynard, Sr. Program Analyst, Program Management and Policy Development Staff, NMSS Wil am C. Floyd, Security Specialist, Requirements Oversight Section, Division of Safeguards and Transportation, NMSS Michael Wangler, Sr. Transportation Specialist, Transportation Branch, Division of Safeguard and Transportation, NMSS Leroy S. Person, Project Manager, Operations Branch, Division of Low Level Waste Management and Decommissioning, NMSS Robert Hogg, Project Manager, Operations Branch, Division of Low Level Waste Management and Decommissioning, NMSS Joseph R. Delmedico, Sr. Enforcement Specialist, Office of Enforcement
- Team Leader 23
C question 1 Response REVISED NOVEMBER 1990 DIVISl0N Of RADIAllON SAFETY AND SAFEGUARDS
- INDICATES ADDITION /
Malcolm R. knapp, Director - 5283 Richard W. Cooper, ll, Deputy Director - $281 Constance M. Yusko, Secreta ry - 52 74 FAClllil[S RADIOLOGICAL SAFETY AND SAFEGUARDS BRANCH James H. Joyner. Chier - 5370 Sha ron Law Johnson, Secretary - 5395 Michele kirkner, Orrice Assistant 5072 LHERGENCY PREPAREDNESS EFFLU[NTS RADlAll0N PROILCJ t0N SLG110 i
{ACILM1 _ES_86DIAljoff SECilON j
PROIECil0N SLGD ON
$MLCUARDS SECTIOJi W. Lazarus. Chier - 5208 R. Oures. Chief - 5213 C. Amato - 5394 H. Austin - 5390 W. Pasciak, Chier - 5258 R. helmig, Chier - 5255 C. Conklin - 5083 T. Dragoun - 5373 D.
Chawaga - 5082 R.
Albert - $268
- C.
Cordon - 5372
- J. Turia - 5041 J.
Jang - 5220 A. Della Ratta - 5273 F.
Lopresti - 5391 J. kottan - 5214 R. tance - 5069 T. Dexter - 53 784 D. Mann - 5237 N. McNamara - 5317 R. Nimitz - 5267 E.
king - $178 S. Fiveash - 5101 L. Peluso - 5323 J.
Hoggle - 5063 D. Limroth - 5121 J. Roth - $205 P. O'Connell - 5056
- c. Smith - $263 R.
St ruckmeyer - 5380 S. Sherbini - 5259 h0CarAR MATERIALS SAFilY BRANCH
- Ronald R.
Bellamy. Chier - 5200 Carroll Armstrong. Secretary - 5248 NHSS A NMSS B NHSS C LICENSING ASSISTANCE SECT.
H. Shanbaky, Chier - 5209 J. kinneman, Chier - 5252 J.
White, Chier - 5102 S. Villar, Chier - 5239 M. Cahill - 51U9
- f. Costello - 5275 S. Courtemancho - 5075 C. rekert - 5364
- k. Brown - 5048 R. Brown - 5260 T. Darden - 5245 T. Oberg - 5202 J. Dwyer - $309 A. Kirkwood - 5050 C. Duracker - 5093 J. Cresick-Schugsta - 5382 E. Reber - 52T6
- T. Haverkamp - 5398 J. Joustra - $257 H. Roberts - 5094 R. Ladun - 5375
-S.
Minnick - 53t2 R. Junod - 5117 P. Nessen - 5169 E. Ullrich - 5040 C. Schulingkamp - 5078 C. Roberts - 5272 J.
Stambaugh - 6904 H.
Taylor - 5311 L.
Tripp - 5071 W.
Thomas - 5043 T.
Thompson - 5303 Ibn P
DRSS COMPUTER ROOM #1088 - 6910 DRSS FAX - 5269 PART-TIMr RIUDENIS.
O DRSS CONF ROOM - 5038 C.
Forgione - $313 D. Roseboro - 5313 4
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