ML20057A644
| ML20057A644 | |
| Person / Time | |
|---|---|
| Issue date: | 05/31/1991 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Strohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309150094 | |
| Download: ML20057A644 (30) | |
Text
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May 31, 1991 MEMORANDUM FOR:
J. Philip Stohr, Director Division of Radiation Safety and Safeguards, RII FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
1991 DRAFT NATIONAL PROGRAM REVIEW REPORT FOR REGION II Enclosed for your review and comment is the 1991 draft National Program Review report.
Please forward any comments your region wishes to make to Charles Haughney of ray staff within two weeks of your receipt of this memo.
Your comments will be factored into the final report, as appropriate.
Additional comments or criticisms of the program review process may also be made at this time.
Original Signed By Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
Draft National Program Review Report DISTRIBUTION w/ Encl.
NRC File Center INNS R/F NMSS R/F GDeegan JHictfey IMNS Central File RBangart RBurnett PMcLaughlin JShaffner 1
IMIF R/F JGlenn WFloyd GArlotto GCant NMSS R/F RWehde RMcDarby GBidinger WFisher, RIV IMSB R/F IM08 R/F GL bT.
MWangler RBernero j
EFlack FBrwon
[CH/1991 DRAFT NPRR FOR RII]
- SEE PREVIOUS CONCURRENCEJ
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- IMNS IMNS
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NAME :CHaughney:jc:
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1 DATE :5/24/91
- 5 91
- 5/ /91
- 5/3r/91
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OFFICIAL RECORD COPY l
9309150094 930830 PDR STPRG ESGGEN
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REPORT OF NMSS 1991 NATIONAL PROGRAM REVIEW AT NRC REGION II, MARCH 7 - MARCH 8, 1991 1.
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety and Safeguards (NMSS) and Office of Enforcement (OE) review of Region II programs under the Headquarters responsibility of NMSS.
The National Program Review Manual dated December 11, 1987, outlines the concept and plan for the HMSS 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 NPR is based not only on the visit to the Region, but on the collective Regional / Headquarters interfaces throughout the year.
These interfaces include the review of selected licensing casework and inspection reports, enforcement data, the accompaniment of region-based inspectors, the review of casework and inspection statistics and resource utilization, technical assistance and coordination efforts including conference calls, and the information questionnaire.
The NPR process is intended to provide a review of the effectiveness of both the Region and Headquarters activities insofar as they relate to Region II's activities, and to identify suggestions for improving safety and the effectiveness of the collective efforts of HMSS, OE, and Region II.
The NPR review emphasizes the technical quality of licensing, inspection and enforcement activities, and timely completion of licensing casework, inspections, and enforcement on the basis
- that these elements contribute to assuring the safety and safeguards of operations involving NRC-licensed activities.
This report is organized to present an integrated summary of Region II 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 / Headquarters
- 8. Resource Utilization
- 9. Recommendations and Suggestions l
l l
i l
NMSS FY91 NPR FOR REGION II 2.
LICENSING -
l 2.1 Materials Safety i
Region II regulates approximately 1000 byproduct material licensees.
In FY90, Region II completed 608 material licensing actions against a revised operating plan of 600 (101 percent).
The branch chief, section chiefs, and licensing reviewers were aware of licensing goals for FY91. As of January 31, 1991, Region II had completed 171 cases of the 193 cases received. Although they were somewhat behind projected completions at the time, Region II has now completed 353 cases through April 30, 1991, and is on schedule to meet the goal of 600 cases for FY91, Region II has three approximately, full-time license reviewers that handle most of the licensing workload.
However, over the last three years inspectors have been cross-trained in licensing reviews to provide backup and replace full-time reviewers.
Region II continues to have a stable core licensing review group that is capable of handling a wide variety of casework in an efficient and highly professional manner. During FY90, and as of the first 18 weeks of FY91, Region II is expending labor at a rate of about 1 Full-Time Equivalent (FTE) in excess of that budgeted. Managers suggested that some of the excess labor is due to the relative newness of some 1
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reviewers to material licensing.
However, Region II management and supervision requested that NMSS review current budget labor rates for adequacy.
Region II has developed an automated system for generating materials licenses using a Local Area Network.
This system appears to have the potential to improve efficiency and timeliness.
License reviewers suggested that NMSS develop a PC-based listing of current Policy and Guidance Directives and other relevant guidance documents.
Region II has reduced the number of pending actions slightly during FY91 but has seen the backlog of overdue licensing actions hover at about 20 cases for the past few months.
License reviewers and section supervisors recommended continued opportunities for contact and discussion among NMSS and Regional reviewers.
In particular, a desire was expressed that workshops and counterpart meetings be held at least annually.
In this regard, a counterpart meeting for branch and section chiefs has been scheduled in September near the Headquarters office.
2.2 Safeguards Region II received nine IO CFR 70.32 case reviews in FY90.
Seven cases were completed and two cases were transferred to Headquarters.
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NMSS FY91 NPR FOR REGION II In the first quarter of FY91, Region II has received three licensing cases and completed all three. These 10 CFR 70.32 case reviews were performed in a sound technical manner.
Region II achieved a case turnaround average of one month.
It should be noted that receipts are down because all material control and accountability (MC8A) work has been consolidated in Headquarters.
3.
INSPECTIONS 3.1 Materials Safety Inspections In FY90, Region II completed 393 material inspections compared to a goal of 387 (101.5 percent).
Through January 31, 1991, the Region had completed 157 inspections. This rate is somewhat above the prorated operating plan target of 138 for this time period. More recent data indicated that the Region II was even further ahead of its projected goal.
The Region thus expects to meet its FY91 targets for total inspections. Region II has few inspections in the overdue category, and is generally completing inspections on or before the next inspection due date.
An April 30, 1991, Region II memorandum proposed a number of changes to the Operating Plan, one of which modifies the rxrter of core and flexible materials inspections to reflect actual available intpections from now to the end of the fiscal year.
Region II continues to complete transmittal of inspection documen-tation and enforcement actions in a timely manner.
Review of selected documents and observations during an inspector accompaniment indicated no significant problems in the areas of technical adequacy, accuracy, or quality.
Region II inspection staff demonstrated a good awcreness of inspection and enforcement policy and guidance. Region II recently completed a trial program of not acknowledging responses to Notices of Violation when the corrective actions were determined to be adequate.
Based on a survey of licensees, Region II has decided to reinstate the acknowledgement letter. Some Region II inspectors and supervisors expressed concern about the time and effort required to generate the letter. NMSS recommended that Region II consider ca!egation of signature authority and PC-based generation of form letters as a method to reduce processing time.
Region II supported rotational assignments with NMSS during FY90, ar.o additional rotational assignments in FY91 with NMSS, OE, and the Office of the Executive Director for Operations. NMSS and Region II agree that such assignments should continue.
Inspectors expressed a desire to participate in team inspections involving inspectors from more than one Region.
NMSS supports such efforts, particularly with respect to inspections of significant licensed programs of broad scope.
Region II inspectors expressed concern that some Information Notices and issues of the NMSS Newsletter were received by licensees before the inspectors.
Both NHSS and Region II agreed to review distribution practices to determine whether distribution to the regional offices could be made more extensive and timely. Region II inspectors requested that guidance and training be provided for implementation of the revised 10 CFR Part 20. HMSS had already initiated planning with the Office of Research to develop guidance documents and training outlines for this subject.
Regional inspectors are using Performance Evaluation Factors (PEF's) as a routine part of inspections.
Inspectors made favorable comments about the current PEF's based on fewer factors 'than in the trial program.
3.2 Fuel Facility Inspections The Radiation Safety Project Section of the Nuclear Materials Safety j
and Safeguards Program Branch has the project management responsi-bility for the fuel cycle inspection program. Other sections within the Division of Radiation Safety and Safeguards conduct specialized inspections at fuel cycle facilities. Quarterly status reports for each licensee provide management with the status of the inspection program.
This project management scheme appears to be functioning quite effectively and is supported by inspectors in other sections within the Division.
- During FY90, the fuel cycle inspection program was completed. To date, for FY91 the program is meeting or exceeding the Operating Plan in most areas.
The overall inspection program remains at an effective level. Management meetings continue to be effective in obtaining improved performance at several fuel cycle licensees, l
Several inspectors commented that they believed more time wan needed to prepare for, and to report on, inspections.
In addition, voluntary overtime is not being reported in a uniform manner.
Region II manage-ment should review reporting of time and the use of non-inspection time for preparing for and reporting on inspections.
Inspectors reported that Safety Evaluation Reports (SER) were used by some, but not all, inspectors.
No suggestions for changes to the SER content were offered by the regional inspectors.
The Region II inspectors and managers noted the need to revise regulatory guides and inspection procedures which are out-of-date s
and compliance-oriented.
Regional staff suggested that the Operational Safety Team Assessments effort be streamlined or that other Federal agencies be dropped from the program.
NMSS resources to effect these changes are lacking because of staffing levels and emphasis on license renewals.
i l
Extensive discussions were held with the inspectors, supervisors, and managers concerning an NftSS request for more safety information in the inspection reports.
The inspectors and supervisors requested
guidance because of management controls on the report format and content. Some of the Division managers resisted the request because of requirements in Manual Chapter (MC) 0610 and the Region II Peer Review Comittee. The NPR team member, who read all inspection reports for the last year, noted that Region II's interpretation of MC 0610 was unique.
In the closecut meeting, the Regional Administrator re-cognized the problem and agreed he had seen examples of reports that lacked substantive discussion.
NMSS agreed to review MC 0610 and to provide examples of useful inspection reports as well as examples of less useful reports.
Fuel Facility Safeguards Inspections The FY90 physical security inspection program met its goals as established ty the FY90 Operating Plan, MC 2681 and Mr. Burnett's 1
memorandum of August 28, 1989.
In FY90 Region II completed seven safeguards inspections at B&W Lynchburg.
Three of these inspections were accompanied by headquarters personnel and one inspection was performed at the request of headquarters.
The reviewer observed that the inspections were very detailed and technically sound.
The reports were completed in a timely manner and covered all areas of the inspec-tions. The NPR team noted that Region II provided available assistance with the consolidation of the MC&A inspection program to Headquarters.
Two regional inspectors provided approximately 420 inspection hours to assist Headquarters with numerous MC&A inspections.
During the
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NMSS FY91 NPR FOR REGION II first' quarter of FY91, Region II has conducted two team inspections (one at each Category I facility). This effort is in accord with their FY91 Operating Plan.
3.3 Transportation Inspections 3.3.1 Transportation Safeguards Region II performed eight safeguards transportation inspections in accordance with their FY90 Operating Plan, the third consecutive fiscal year that this goal was met or exceeded. All transportation-reports were technically sound and submitted in a timely manner. The transportation goal for FY91 has been increased to twelve inspections.
During the first quarter of FY91, four inspections were completed.
Three route surveys were conducted in FY90 at the request of Head-quarters.
One survey has been completed during the first quarter of FY91.
3.3.2 Transportation Safety Region II conducts inspections of transportation activities as part of its materials, reactor, and fuel cycle program activities.
Review of Regions II's program shows that transportation inspection activities are generally being conducted by inspectors who are knowledgeable of and experienced in the transportation regulations.
Regional inspectors i
NMSS FY91 NPR FOR REGION II use the appropriate inspection modules.
During the review, it was noted that inspectors generally had available appropriate reference material. The exception was current copies of Title 49 of the Code of Federal Regulations Parts 100-177, Transportation.
The Region should obtain the appropriate number of copies of this document for its staff.
Other new reference materials will be sent to Region II i
1 as these materials become available.
Materials Inspection During FY90, approximately 280 inspections were conducted in which transportation activities were reviewed. Nine items of noncompliance were indicated of which six Severity Level IV and three Severity evel V items were noted.
The total number of violations found in Region II's materials transportation is low compared to other regions. Documented violations included failure to maintain Type A package evaluation documents, failure to perform external radiation levels and contamination surveys, failure to label packages properly, and failure to place shipping papers in the appropriate place in tiie vehicle.
For materials safety inspections, the field note format was used.
These field notes had a section addressing transportation activities.
The notes were consistent with core inspection procedure (IP) 86740.
During the review, several inspection reports were examined. The
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NMSS FY91 NPR FOR REGION II inspections were generally thorough and the quality of the inspections appeared to be satisfactory. However, the record of an inspection of a specific license for transportation activities indicated that little time had actually been spent on IP 86740.
Fuel Facilities Transportation inspections were completed for all fuel facilities in Region II using IP 86750. During these inspections, three items of noncompliance were noted.
Reactors During FY90, transportation activities at power reactors were performed according to the SALP inspection frequency for the plant.
The core program has implemented the use of IP 86750 related to solid radwaste and transportation. This procedure is often supplemented with the use of IP 86740 for the transportation inspection.
Few items of noncompliance were noted.
3.4 Low-Level Waste Inspections Field notes have been developed and recently updated for various types of materials inspections.
Low-level waste (LLW) inspections are covered to varying degrees in the modules.
In several cases,
field notes do not include explicit reference to 10 CFR Part 61 waste generator requirements. Experienced inspectors are inspecting against requirements due to personal knowledge of requirements, but a new materials inspector may not know to do so.
In most instances, licensees hold LLW for decay, and exempt quantities are being disposed of per Part 20. Other solid waste is being transferred to brokers. However, if the broker is coming on-site to process waste for disposal, Part 61 generator requirements apply to the licensee.
Therefore, materials inspections involving solid waste which will be disposed of should include Section 20.311 requirements as well as Sections 61.55, 61.56, and 61.57 requirements.
The reviewer noted that a temporary storage element was added to many of the materials checklists. This addition is to accommodate Puerto Rico which is currently storing LLW.
The reviewer raised a concern about Section 20.304 disposal records.
The regional staff is aware that a number of such disposals took place particularly at academic institutions and that records and institutional memory of such disposals are eroding.
i The reviewer noted that all of the decommissioning FTEs are being expended in processing the financial assurance verifications required by the decommissioning rule. Actual site cleanups are chargeable directly to the licensee, i
i NMSS FY91 NPR FOR REGION II 3.4.1 Low-Level Waste Inspections of Materials Safety Licensees Barnwell Special Nuclear Material (SNM)
Region II most recently inspected the Barnwell facility in February 1990. This inspection focused primarily on criticality issues which is the major inspection increment over the South Carolina source and byproduct license. Many items were not inspected because the items were considered to be in South Carolina's jurisdiction.
In fact, many of these areas are important to each license.
Efforts should be made to coordinate NRC and state source and byproduct inspections. Also, to the extent practicable, the state inspection documentation should be incorporated into the NRC's Barnwell inspection file for a complete record of facility inspection.
The Barnwell SNM license is in timely renewal. The new license has been drafted but not promulgated.
Regional inspectors should be afforded opportunity to comment on the "inspectability" of the proposed license.
An SNM inspection is currently due and scheduled as a priority 1.
3.4.2 Low-Level Waste Inspections of Fuel Facilities LLW inspections at fuel facilities include inspection against Part 61 reporting, manifest, classification, characterization and labelling requirements.
Typical waste streams include large volutes of single
NHSS FY91 NPR FOR REGION II.
isotope material, generally class A.
Violations against LLW requirements are limited.
However, because large volumes of waste are stored for long periods of time, licensees have been cited against storage requirements.
Fuel facility LLW aspects are inspected approximately once a year.
The reviewer examined one inspection report and LLW discussion was comprehensive. One minor reconnendation was discussed with the inspector.
3.4.3 Low-Level Waste Inspections of Reactors Reactor LLW is being inspected once per SALP cycle.
Inspectors are knowledgablebutseemsomewhatoverworked(seebelow).
Inspectors have a good working knowledge of LLW generator requirements. Licensees are also knowledgable as evidenced by a drop in violations.
Responsibility for the LLW module has been transferred to the Radiological Chemical Section which has no inspectors trained in the module -- this is resulting in work overload for current inspectors.
i NMSS FY91 NPR FOR REGION II -
Inspectors are spending appropriate amounts of time in LLW inspections.
One inspector suggested more time would be of use to understand
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programmatic aspects of LLW program.
4.
ENFORCEMENT l
4.1 Issues Discussed Maximizing the use of Form 591 Experience with non-cited violations
' Receipt by inspectors of Information Notices and NMSS News-letters and inspection findings related to those documents Use of personal computers (PCs) and standard paragraphs for the preparation of Notices of Violations and related enforce-ment documents Training conducted on the Enforcement Manual Use of Performance Evaluation Factors (PEFs)
4.2 Findings
Statistical data indicates that Form 591 is being used in 72 percent of the materials inspections in Region II. This extensive use is confirmed by inspectors and their Section Chiefs who are almost unanimously satisfied with the use of the form.
The Region has a Branch Guidance Memorandum concerning the use of the Form 591. The Memorandum contains examples of permitted use, and limits use of Form 591 to i
NMSS FY91 NPR FOR REGION II cases with not more than four violations.
Personnel contacted considered the guidance useful.
Discussions indicate that inspectors are checking to determine if licensees receive Information Notices and HMSS Newsletters. Another reviewer cited instances of receipt of these documents by the inspectors after licensees.
Discussions indicate that inspectors understand the non-cited violation (NCV) process and use it when possible, with documentation in the inspector's field notes. Section chiefs are comfortable with the process now that implementation difficulties have been overcome. While one inspector objects to treating the NCY as a first " violation" if it recurs, he does consider the option useful overall.
One inspector commented that use of an NCY gets the right message across as to our greater concern with safety issues rather than recordkeeping, and the process encourages both openness by the licensee and greater internal scrutiny.
Regional personnel are making increasing use of PCs in preparation of inspectio6 and enforcement documents, and most welcome this development, although the " cut and paste" method is still preferred by some.
Inspectors and managers are making extensive use of standard citations in preparing Notices of Violations, although minor quibbles arise about wording in a few instances. Many of the persons interviewed are eager to start using the new disk containing the standard citations. Management noted the need for fully approved citations for Part 35.
The Enforcement and Investigation Coordination Staff-(EICS) has prepared and the Regional Administrator promulgated extensive guidance on the preparation of enforcement documents. This guidance is of excellent quality; and Regional Office Instructions cover such items as NCVs, repeat violations, and drafting of enforcement actions.
As Enforcement Guidance Memoranda are received from headquarters, they are disseminated within the Region by Regional Notice.
This was done for the recent Delegation of Authority for Severity Level III materials cases, even though that delegation cannot be implemented in Region II until a Regional Counsel is in place.
Training on appropriate enforcement topics is conducted by the EICS.
The Enforcement Manual is held by the section chiefs.
Not all inspectors were aware of the manual. While they will seldom need to use it, additional training would make them aware of it as a resource.
- As noted above, the Delegation of Authority for Severity Level III materials cases has not been implemented in Region II pending assignment of a Regional Counsel; therefore, implementation of the delegation was not discussed with Region personnel.
5.
TRAINING 5.1 Fuel Facilities The acute need for supplemental training of Fuel Facility Inspectors (both Resident and Region-based) in nuclear criticality safety was discussed by inspectors and their supervisor.
The slow recognition of the significance of the Nuclear Fuel Service, Inc. (NFS) 703/704 Tank event highlights this need.
NMSS staff agrees with the need but does not have the resources, given the curient licensing priorities, to provide the supplemental training on a near-term basis.
The Regional staff has prepared and is executing a training program for two newly selected Resident Inspectors.
The f.' MSS staff agreed to a request to provide part of a 1-week Headquarters training assignment for the two residents, and this training was conducted during the week of April 15, 1991.
In addition, the NMSS representative suggested that an NMSS safety staff member accompany the new inspectors for a week of inspection
- effort, preferably at NFS. The EDO has requested a staff action plan to develop in-house resources in nuclear criticality safety.
NMSS is developing a plan to establish a pyramid structure for experts, analysts, and inspectors.
In this structure, the experts would serve as mentors for the training and development of inspectors.
5.2 Safeguards Region II sent four inspectors and the section chief to the Training Symposium conducted at Headquarters in the first quarter of FY90.
5.3 Transportation Safety Several of the regional inspectors had not received training in transportation. When the TTC offers the H-308 transportation course, the region should endeavor to enroll those who need the training.
Additionally, the region noted that periodic refresher seminars would
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be beneficial to inspectors previously trained.
Headquarters will
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provide these refresher seminars.
6.
REGIONAL INITIATIVES 6.1 Materials Region II took the lead in developing Information Notices regarding l
the effective use of Radiation Safety Committees and the safe use of
HMSS FY91 NPR FOR REGION II SR-90. Eye Applicators.
In the licensing area, Region II has improved efficiency by developing a Local Area Network for generating-licensing documents. The Region has initiated a program of cross-training in-spectors to develop a cadre of qualified license reviewers.
6.2 Safeguards Region II provided two inspectors to assist two Headquarters staff members in testing newly developed performance inspection procedures in a special inspection at NFS Erwin. Additional time was spent providing written comments on these procedures and attending a peer.
review meeting at Headquarters to finalize these procedures. Also, the region has been very responsive in attending Headquarters upgrade licensing meetings with the Category I licensees. Besides the time allocated for the meetings, effort was expended in providing detailed comments on numerous upgrade licensing issues.
6.3 Fuel Facilities The Region hosted a Fuel Cycle Seminar in May 1991. The Seminar was well organized and managed and helped maintain the dialogue between NMSS, the regions, and the licensed community.
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Regional management participated in frequent meetings with NFS concerning their Performance Improvement Plan for nuclear criticality safety as well as a program to reconstruct the safety basis for the facility.
Region II developed and is implementing a training program for two newly selected Resident Inspectors.
7.
HEADQUARTERS / REGION II INTERACTIONS 7.1 Materials Region II noted that the monthly materials inspection and licensing conference calls have been helpful. The Region recommended that a workshop or counterpart meeting be held in FY91.
Subsequently, a counterpart meeting has been scheduled for mid-September at Headquarters.
NMSS and Region II felt that day-to-day communication is good and responses are generally timely. The Region noted that turnaround-time on formal technical assistance requests has improved in the last year.
7.2 Safeguards The interface has continued to be cooperative and constructive in FY 1990. Region II has responded constructively to suggestions and, as mentioned previously, has provided valuable assistance on important headquarters projects. Region II has offered suggestions for improving the program and has provided its expertise whenever requested. Finally, NMSS has arranged quarterly interface meetings between HMSS/ Region / Category I licensees and quarterly interface meetings between NMSS and Region II. The Region has attended all meetings and has provided constructive suggestions.
8.
RESOURCE UTILIZATION During FY 1990, Region II completed 608 materials licensing actions against an Operating Plan goal of 600--101 percent of the target. The Region expended 1.3 FTE more than budgeted in order to accomplish this.
The Region completed 393 materials inspections against an Operating Plan goal of 387--101.5 percent of the target. This was accomplished using 1.3 FTE less than budgeted.
In FY 1991, as of the end of January, the Region was slightly behind its target for materials licensing completions.
There were 17I completions against receipts of 193 for this period; the FTE expended for this effort
was slightly higher than projected. However, as stated in Section 2.1, the Region has subsequently caught up and is now on schedule to meet its ifcensing goal for the year.
As of the end of January,1991, the Region was exceeding its goal for materials inspection completions. Overall, 157 inspections were completed against a target of 138. The FTE expended for the materials inspection effort is slightly lower than budgeted.
The reviewers raised the issue of the imbalance between the number of core and flexible inspections completed and the pro-rated Operating Plan target as possibly indicating a need for a revision to the FY 1991 Operating Plan.
Region II staff will review this, but indicated that the probable cause for the imbalance is that more core inspections are planned for the latter part of the fiscal year than occurred early in the fiscal year. An April 30, 1991, memorandum from the Region proposed a number of revisions to the Operating Plan. One of the revisions modifies the core and flexible materials inspections to reflect actual available inspections from now until the end of the fiscal year.
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REGION II RESOURCE UTILIZATION The'following table shows FTE allocations and expenditures for the review period FY91 FY90 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED %
BUDGET OCT-JAN OCT-JAN' Fuel Facility Licensing 0
0.08 0
0 0
0 Event Evaluation 0.8 1.3 163 1.2 0.4
.6 Materials Licensing 3.1 4.4 142 3.1 1.0 1.5 i
Materials Inspection 5.9 4.6 78 6.7 2.2 1.9 Fuel Facility Insp.
5.6 5.7 102 5.4 1.8 2.1 NMS Section Supy.
1.9 2.2 116 2.0 0.7
.8 NMS Subtotal ID ID IE ID E.I O
SG Fuel Facility Lic.
0.4 0.2 50 0.2 0.1
.2 SG Fuel Facility Insp.
3.8 2.4 63 1.6 0.5
.5 SG Transportation Insp.
0.5 0.1 20 0.8 0.3
.1 and Plans NMTS Section Supv.
0.4 0.4 100 0.3 0.1
.1 NMTS Subtotal T.T TI TI T9 D
-' f LLW Inspection 0.4 0
0 0.4 0.13 0
Materials Decomm.
0.1 0.1 100 0.2 0.07
.5 LLW Section-Supv.
0 0.02 0
0.1 0.03
.1 LLW Subtotal 7
.12 T4
-~7 7
.6 NMSS TOTAL 22.9 21.5 94 22.0 7.3 8.4 115 i
NOTE:
FY90 expenditures from regional input provided in response to FYP/ Green Book update in 01/91.
HMSS FY91 NPR FOR REGION II -
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9.
RECOMMENDATIONS / SUGGESTIONS 9.1 Materials Region II should continue its strong support for rotational assignments at all levels.
f Region II should both host and assist inter-regional team inspections of significant (broad-scope) materials programs.
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Region II should review the number of core inspections due or available to be done in FY91.
If sufficient inspections are not available in the core program, the Region should recommend changes,
to its operating plan.
(As previously noted, Region II, in a memo dated April 30, 1991, has proposed a number of revisions to its Operating Plan, one of which addresses the core and flexible inspections).
NMSS and Region II should review distribution procedures to assure that regional staff receive Information Notices and the NMSS l
Newsletter as early as licensees do.
NMSS should sponsor et least one workshop for the licensing staff and one counterpart meeting for materials supervisors each year.
NMSS should develop a PC-based index and text for Information Notices, Policy and Guidance Directives and applicable regulatory guides.
NMSS and the Office of Nuclear Regulatory Research should provide training for implementation of the revised 10 CFR Part 20.
NMSS should review work factors for materials licensing to determine if revisions are necessary.
9.2 Enforcement Conduct additional awareness training for inspectors on the availability and contents of the Enforcement Manual.
9.3 Low-Level Waste NMSS should incorporate explicit references to Part 61 requirements for labelling, waste classification, characterization, and manifest requirements in materials inspection procedures (e.g., Nuclear Medicine Field Notes).
LLWM needs to clarify and finalize guidance in regional responsibilities concerning decommissioning financial assurance in order to eliminate duplicate effort on the part of regional personnel.
Region II should attempt to coordinate SNM inspections with state inspections of Barnwell.
NMS55 should afford Region II inspectors an opportunity to comment on the proposed Barnwell license.
Training is suggested in the area of LLW inspection for all inspectors involved to:
Garner a better understanding of Part 61 requirements for inexperienced inspectors; and f
Upgrade inspectors capabilities concerning long-term storage-of LLW.
NMSS should consider additional FTEs for reactor intpto;ars to allow for clear understanding of integration of reactor LLW programs and allow for interaction with HMSS LLW personnel concerning potential problem areas, e.g., storage capacity.
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ATTACHMENT 1 1991 Region IT, Program Review - Team Members Atlanta, Georgir, March 7 - March 8, 1991 Charley Haughney, Division of Industrial and Medical Nuclear Safety, Team Leader George Bidinger, Division of Industrial and Medical Nuclear Safety John Glenn, Division of Industrial and Medical Nuclear Safety Peter McLaughlin, Program Management, Policy Development and Analysis Staff Kathleen McDarby, Program Management, Policy Development and Analysis Staff Mike Wangler, Division of Safeguards and Transportation Jim Shaffner, Division of Low-Level Waste Management and Decommissioning William Floyd, Division of Safeguards and Transportation Geoff Cant, Office of Enforcement Bill Fisher, NRC Region IV, Division of Radiation Safety and Safeguards
,