ML20057A666
| ML20057A666 | |
| Person / Time | |
|---|---|
| Issue date: | 06/14/1991 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309150120 | |
| Download: ML20057A666 (7) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
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101 MARIETTA STREET,N.W.
ATLANTA, GEoRot A 30323
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JUN 141991 MEMORANDUM FOR:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS FROM:
J. Philip Stohr, Director Division of Radiation Safety and Safeguards S'UBJECT:
1991 DRAFT NATIONAL PROGRAM REVIEW PLAN Enclosed are our comments on the draft subject report submitted to us with your May 31, 1991 memorandum.
We appreciate the thoroughness of the review and the real interest on the part of the team in the area of review.
Several comments should be quite useful to us as we continue to work together to further improve these program areas.
One general suggestion is that, for perspective, the amount of narrative in the -
report better reflect the amount of effort (FTE) allocated to the program areas.
For example, the report contains four pages of assessment for low-level waste, an area for which the region is budgeted 0.4 FTE.
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Enclosure:
Conanents on Draft Report 9309150120 930830
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JUN 141991 ENCLOSURE Region II Comments on Draft 1991 National Program Review Report 1.
Item 2.1., Materials Safety (Licensing), page 3, paragraph 2:
Consider modifying this section on completed licensing cases to compare the total number of cases completed with the budgeted rather than the receipts, since that is how the FTEs are-allotted.
For example, through January 31, 1991, the Region was budgeted to complete 200 cases and completed 171 of those.
As of April 30, 1991, the region was budgeted to complete 350 and completed 321 cases or 92 percent and is on schedule to complete the goal of 600 cases for FY91.
Consider factoring in the core concept established in November 1990 to show the region has completed 107 percent of new and amendment cases (265 versus 248 budgeted) through April 1991, which shows the region is properly prioritizing the workload.
2.
Item 2.1., page 4, paragraph 3:
Consider expansion to characterize the type pending backlog and whether the cases are excepted from the operating plan timeliness goals.
For example, the region had a backlog of eight cases as of the end of February, with three of them in NMSS on technical assistance requests (i.e., excepted from goal).
This number increased to 20 as of the end of March and is still at 21 as of the end of May.
However, of these 21, ten of them are in categories excepted from the timeliness goals (e.g.,
licensing actions awaiting resolution of financial assurance reviews and sealed source and device reviews in NMSS).
Followup Action:
In an effort to eliminate this backlog, the region assigned an additional materials inspector to perform full time license reviews as of April 1991.
This individual is experienced in performing license reviews. This action sill cause the region to expend FTEs for this program in excess of those oudgeted.
3.
Item 3.1., Materials Safety Inspections, page 5, paragraph 1:
The assessment indicates the region has few inspections in the overdue category.
Consider expanding to clarify that the region expends effort and assigns cases to ensure there are zero inspections in the overdue category.
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2 of the computer system.During fiscal year 1991, a few overdue These were completed as of the end of Aprilw 4
Item 3.1., page 6, paragraph 1:
letters and this time can be reduced by delThis se e
generating acknowledgement PC - based generation of form letters egating signature authority and followup Action:
The region generated the acknowledgement lett as a form letter at the time of the programers via the IBM 5520 syste converts to a PC based system, we plan to have review.
about June 1991.
As the region a form letter on the PC The region maintains the signature level are reviewed by staff, supervisor and management lat Branch Chief 5.
Item 3.1., page 7, paragraph 1:
evels.
The recommendation was made practices for timely distribution of InformatiII review regional office that Region Newsletter.
on Notices and the NMSS followup Action:
Although there have been occasional dela s notices and the NMSS newsletter are distribut din general, informati y,
Radiation Safety and Safeguards and from th e
staff within one week of arrival 'in the region to the Division of copy may not reach an inspector for several w However, due to some region is exploring having copies of Informati ng out of the o
, in some cases.ffice, division level and, if appropriate The on Notices screened at the applicable sections.
, copies made for each inspector in Ah:--==m-The re region.gion also reviewed timeliness for these docume
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f of receipt of the division's copy in the regionInforma Newsletter took over two months from issuan of issuance to date The latest HMSS office.
ce to arrival in the regional 6.
Item 3.2., Fuel Facility Inspections
, page 8, paragraph 1:
Two recommendations were made in this parag management to review reporting of non-inspectise raph.
One was for Region II input during the inspection process The on Reports (SER) as 1
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3 Followup Action:
The Section Chief reviews and signs off on all forms completed by inspectors to document all their time.
This review includes how non-inspection time is reported.
The Deputy Division Director held a meeting last Fell with all inspectors to discuss consistency in reporting and will continue to hold these type meetings.
For the SER use, the Section Chief plans to meet with the staff in the section to explain how the SERs are to be used and follow that meeting with a memorandum to the staff.
7.
Item 3.2., page 8 last paragraph and page 9, first paragraph:
The recommendation was made that NMSS needs more information in fuel facility inspection reports in order to draw conclusions as to how safety issues are being addressed and how the facility is operating.
Followup Action:
On May 22, 1991, NMSS sent a memorandum to the region with exerpts from inspection reports that either did not contain sufficient information, did not contain conclusions regarding the adequacy of programs (other than no violations) or contained superfluous information regarding regulatory requirements.
The region has distributed this memorandum to all its fuel-facility inspectors and plans to provide further guidance to them in this area.
Regional managers met on June 12, 1991, to review these comments and a sampling of regional inspection reports to note any other areas where improvements may be necessary.
During the assessment we were informed that in addition to the examples of reports needing improvement, we were told that we would be providad axamnlae nf non ' vanorts.
We will review these examples with out' staff when received.
Specific guidance will be provided to inspectors in the area of inspection report preparation and content.
T 8.
Item 3.2., Fuel Facility Safeguards Inspections, page 9:
Consider mentioning the region's support for headquarters programs and attendance at meetings to foster a joint approach to the resolution of upgrades at these facilities.
Examples include participation in meetings at headquarters on the status of upgrades and participation in special reviews such as the diversion path analysis at Nuclear Fuel Services, Inc.
9.
Item 3.3.2., Transportation Safety, page 10, last paragraph:
This section states Region II's program for transportation inspection activities is generally being conducted by inspectors knowledgeable and experienced in the transportation regulations.
During the period assessed, all inspectors performing transportation inspections (FRP Section) were fully trained and qualified in transportation.
The
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transfer of this function to REC was scheduled for April 1991, based on an understanding that the Transportation course would be givem in April 1991.
The courses will be given in July and August 1991.
REC inspectors will not close 86750 (transportation procedure) until they have completed this course.
It should be noted that the delay in this training has been due to the unavailability of the course from the TTC.
The region has 10 inspectors scheduled for the courses in July and August.
10.
Item 3.3.2., page 11, paragraph 1:
The recommendation was made that the region should obtain current copies of Title 49 CFR, Parts 100-177, for its staff.
Followup Action The region had one current copy at the time of the program review and agrees this is not sufficient.
The region has ordered copies for its staff and will maintain at least one current copy per section and for each.
fuel facility resident.
11.
Item 3.3.2., Materials (Transportation) Inspection, page 12 first paragraph:
This section has a comment that the record for one inspection of a specific license for transportation activities indicated little time spent on IP 86740.
The region looked into this and discovered that the items in Inspection Procedure No. 86740 were reviewed; hcwever, the time spent in this area was charged to the Inspection Pro.cedure for materials programs (IP 87100).
The Section Chief plans to meet with the staff to clarify when to charge time to 86740 versus 87100 for all type materials licensees.
The region recommends NMSS consider providing guidance to all regions in this area.
12.
Item 3.4., Low-Level Waste Inspections, pages 13-16:
The region recommends this section be modified in several areas as follows:
a.
Paragraphs should clarify whether the action is for NMSS or the region.
Examples of NMSS actions are field notes not referencing 10 CFR Part 61 requirements in paragraph one on page 13, field notes not referencing 10 CFR Part 20 requirements in paragraph two on page 13, and the concern that disposal records are not being kept by licensees in paragraph four on page 13.
b.
There are several places where statements are included, but do not appear to be an assessment of the region's program.
For example, the statement that actual site cleanups are chargeable directly to licensees or that licensees hold LLW for decay and other solid waste 1
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5 is being transferred to brokers on page 13.
c.
In Section 3.4.1., should the state inspection documentation be included in the NRC Barnwell inspection file for a complete record?
The region believes only items applicable to the NRC license portion of the program should be maintained in the file, d.
If worth mentioning, the last paragraph in Section 3.4.2 on page 15 should clarify what the recommendation was.
13.
Item 3.4.3., Low-Level Waste Inspections of Reactors, page 15:
The region has made plans to transfer this function, but will not allow or expect inspectors to independently complete inspections using this procedure until they have been trained and qualified.
The delay in this training has been due to unavailability of the transportation course (which also includes training on 10 CFR 61) from the NRC Technical Training Center.
The region does have 10 inspectors scheduled for the
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transportation courses in July and August 1991.
14 Item 4.2., Enforcement Findings, page 18, last paragraph:
This section contains a recommendation for the region to provide additional training to make inspectors aware of the enforcement manual as a resource.
Followup Action:
The region has had training sessions in selected areas from the enforcement manual, such as addressing similar and non-cited violations.
The region plans to schedule a training session specifically to " walk through" the enforcement manual between now and the end of the fiscal year.
15.
Item 5.1., Training, Fuel Facilities, page 19:
The correct number for the referenced tank event at NFS is 704/705 and not 703/704 as written.
In the last paragraph on the page, it is suggested that an NMSS representative accompany the new resident inspectors for a week of effort.
Consider expanding to recognize that this effort was already included in the training plan schedule for these inspectors.
16.
Item 5.3., Transportation Safety, page 20:
Consider expanding to clarify, as stated in Item 14, that the region has endeavored to enroll those who need the transportation training and has 10 inspectors scheduled for the next courses.
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Item 6.3., Initiatives, Fuel Facilities, page 21:
Consider expanding to recognize the region's efforts in (1) holding semi-annual plant review sessions to review past efforts and plan for future inspections at fuel facilities, (2) holding management meetings at the facilities to review operational. safety assessment, and (3) in developing information notices to address generic issues (e.g., beta dose extremity monitoring at fuel facilities and the potential for contamina-tion of non-contaminated liquid systems).
18.
Item 9.,
Recommendation, pages 26-28:
The only recommendations not previously addressed in our comments are those dealing with rotational assignments (Item 9.1, paragraph 1), hosting and assisting inter-regional team inspections of significant broad-scope materials programs (Item 9.1, paragraph 2) and coordinating SNM inspections with State inspections of Barnwell (Item 9.3, paragraph 3).
Followup Action:
The region continues to schedule other rotational assignments.
For example, Larry Camper and Chuck Hosey completed assignments in April 1991.
In an effort to improve broad-scope inspections, Region II has scheduled two expanded inspections for June and August 1991 at broad-scope facilities in. Region II.
These inspections will include in-depth reviews of multiple operational safety programs at these licensees.
All things considered, there may not be an overall advantage to making a special effort to perform inspections at the same time as the State.
The region does notify and coordinate with the State of South Carolina when NRC inspections are planned at Barnwell.
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