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%AY $ 1 bfs1 MEMORANDUM FOR:
A. Bert Davis, Regional Administrator Region III FROM:
Glen L. Sjoblom, Deputy Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
FINAL 1991 NATIONAL PROGRAM REVIEW REPORT REGION III Enclosed is the 1991 National Program Review (NPR) report for Region III.
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.
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NMSS circulated a draft version of this report to the region's Division of Radiation Safety and Safeguards. These coments have been incorporated into this final version of the NPR report, as appropriate.
g As always, we appreciate the efforts of your regional staff throughout the j
year and we welcome any additional thoughts you might have that might lead to further improvements in our review process.
Original Signed By W L Sjoblom Glen L. Sjoblom, Deputy Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
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0 REPORT OF NMSS NATIONAL PROGRAM REVIEW AT NRC REGION III, MARCH 5-6, 1991 1 BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety and Safeguards (NHSS) review of Region III programs under the Headquarters respon-sibility of NMSS. The Headquarters team participating in this review consisted of three persons from the Division of Industrial and Medical Nuclear Safety of NMSS, one from the Division of Safeguards and Transportation, one from the Divi-sion of Low Level Waste and Decommissioning, one _ from the Program Management, Policy Development and Analysis Staff, and one from the Office of Enforcement.
One member of the team was from the Region I office.
(See Attachment 1).
Addi-tional input was received from other elements of NMSS.
The principal regional activities are primarily under the responsibility of the Region III Division of Radiation Safety and Safeguards (DRSS).
A January 25, 1991 memorandum from Richard Cunningham listed the areas to be covered and transmitted a questionnaire to the regions.
The National Program Review (NPR) is based not only on the visit to the Region, but also on the collective Regional / Headquarters interfaces throughout the year, through review of some licensing casework, inspection reports, accompaniments of region-based inspectors, review of casework and inspection statistics, resource utilization, technical assistance and coordination, and the question-naire.
It is intended to provide a review of effectiveness of both the Region and Headquarters activities insofar as they relate to Region III activities and to identify suggestions for improving safety and the effectiveness of the joint efforts of NMSS, OE, and Region III.
The emphasis relates to achieving two goals:
technical quality, and timely completion of licensing casework and inspections, on the basis that both elements contribute to assuring the safety and safeguards of operations involving NRC licensed activities.
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4 This report is organized so as to present an integrated sumary in each of the followingr areas:
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
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i 2 LICENSING 2.1 Materials Safety Region III regulates over 2,800 byproduct materials licensees. In FY90, Region III completed 2,152 materials licensing actions compared to its revised operating plan goal of 2,050 (105 percent).
The baseline goal was 2210 cases with the adjustments made in the renewals area, which is not part of the core program.
i During the same period, they received over 2,400 licensing actions, causing the number of pending reviews to rise to over 500, and causing the backlog to rise from 31 to 75.
Both of these increases were largely the result of the influx of casework received during the summer because of the decommissioning rule.
Until that time, the Region had the backlog very well under control.
Region III licensing personnel expect to reduce their backlog again over time.
Through February, Region III had received and completed over 800 cases, putting themonscheduletomeettheFY91OperatingPlangoalof2020bytheendofthe fiscal year.
They remain on schedule based upon more current data.
Prior to the visit, NMSS reviewed about 100 completed regional licensing actions to determine conformance to the Standard Review Plans and other Policy and Guidance Directives.
Overall, the completeness of the reviews and the quality of documents generated to support the licensing actions were excellent.
NMSS noted that the Region generally makes proper use of special (non-Standard) conditions to address a specific licensee's program weakness.
- However, Region III uses a generic condition for medical licensees to keep records of training for authorized users.
NMSS recommends that the Regions submit any proposed generic conditions to NMSS for consideration prior to use.
Region III has been cross-training its reviewers and inspectors.
They have monthly meetings in which they discuss technical licensing issues.
They have a new training plan for reviewers which is consistent with NMSS Policy and Guidance Directive 91-1.
(This Directive was prepared at the suggestion of 3
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Region III, and it includes several elements recommended by the Region).
They also use Individual Development Plans to maximize personnel growth.
It was plainly evident that the license reviewers, inspectors, and administrative support staff work very well as a group.
The Region employed a thorough (100 percent) quality control check on its completed licensing casework for a period of time.
This was dor.e by the Section Chief and two senior license reviewers. This served them well.
One minor problem exists with respect to the Region's review of returned mail.
This has been slowed due to the heavy workload.
2.2 Fuel Cycle Licensino All resource-intensive licensing actions for fuel cycle facilities and contaminated site decommissioning are either performed by NMSS or directed by1 NHSS; thus, fuel cycle facility licensing is a small part of Region III work-load.
The Region provided adequate input to NMSS in licensing actions.
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3 INSPECTIONS 3.1 Materials Safety Inspections Region III completed 802 materials inspections in FY90 versus a revised goal of 775 (103 percent).
The baseline goal of 991 inspections was adjusted in mid year to allow for the unbudgeted expenditure of regional resources on allegations, escalated enforcement activities and response to events.
Through March 1991, Region III completed 458 materials inspections versus a goal of 528 (87 percent).
The concept of the core program is fully acceptable to the Region and is working very well.
The Region indicated they are planning to complete all of the program (core and non-core) for the fiscal year.
The Region has a number of excellent systems in place, including the Management Information Status Report (MISRE), to track overdue inspections, completed inspections, and to list the inspections which each inspector is required to complete.
SomeareusedthroughouttheRegion,whileothersareprogram-speckfic.
Also, they have an individual who does about 50 percent of the telephone contacts, completes expired and terminated license tasks and completes FOIA matters, which relieves inspectors and licensing reviewers from this effort.
(For training purposes, some of the new inspectors will pull and review license files and contact licensees as necessary.) At the time of the review, about 30 inspections were past-due.
This figure excludes the community hospitals whose inspection intervals had just been revised.
This represents a significant improvement for Region III over their figures for past years.
NMSS reviewed about 30 inspection reports and related 766 data.
Region III's reports are concise and focus on problem areas, while excluding extraneous back-ground material.
The program strikes an excellent balance on performing quality safety-related inspections while attending to the quantitative Operating Plan performance goals.
It is obvious that safety issues come first, and this message has been passed along to the staff.
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During the year, one NMSS employee performed 17 accompaniments of various Region III inspectors as part of a rotational assignment.
He observed that the inspectors interacted with licensees in a professional manner and that they demonstrated thorough inspection techniques that included confirmatory surveys, licensee demonstrations of radiation-related tasks, observations of actual licensee operations, and routine document reviews.
The inspectors also displayed technical proficiency among a variety of different types of materials licensees.
The inspectors prepared well for their inspections, had clearly reviewed the past inspection histories, and were familiar with the licensees' programs, authorized users, and licensed activities before arriving on site.
Region III does a thorough job analyzing and critiquing itself.
These internal audits cover administration issues, as well as technical issues.
A recent example in which a lessons-learned evaluation was performed involved the University of Cincinnati inspection.
A Region III continues to emphasize the use of performance evaluation factors in their inspection program.
They believe that PEFs have helped them assess license performance and helped identify problems at about a dozen licensee facilities.
They also continue to search for the root causes of identified problems at Region III facilities.
Other ongoing initiatives demonstrate the Region's commitment to observe licensee operations, perform more field audits, and to review licensee QA programs for medical therapeutic licensees.
Allegations are tracked by a dedicated full-time individual on the enforcement staff, who also handles all Office of Investigations contacts and referrals.
He also handles most contacts with allegers, while the Division of Radiation Safety and Safeguards handles all licensee contacts.
This system appears to work well.
The allegation files are neat, orderly, and current.
The system for assigning allegation followup, the allegation action plan use and the Monday Allegation Panel Boards also appear to work well.
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4 3.2 Fuel Cycle Inspections In order to better utilize resources and focus attention on fuel facilities and contaminated sites, in November 1989, the responsibility for fuel facilities and contaminated sites was transferred from the Nuclear Materials Safety Section 1 to the Project for Fuel Facilities and Contaminated Sites group.
This group consists of a manager, and a fuel facility inspector.
In the near future, an additional individual is expected to be added to this group to deal with contaminated sites.
The formation of this group is considered to be a positive initiative.
During this review period, considerable regional resources were expended for special inspections, meetings, and incident follow-up.
During FY90, the Region performed six inspections at Allied-Signal, Inc. (ASI).
These inspections included an augmented team inspection, an emergency preparedness inspection, a reactive inspection, and three routine safety inspections.
Theaugmentedteak inspection, addressed high temperatures and pressures in a cold trap.
During FY90, five inspections were performed at the Combustion Engineering Hematite Facility (CEHF).
These inspections included one safety team inspection with representatives from OSHA and NMSS, one routine inspection with a fire safety specialist, one routine emergency preparedness inspection, and an emergency exercise / drill.
As a result of the safety team assessment, several concerns and 13 unresolved items were identified involving program improvements.
The other fuel facilities in Region III are operating either in a limited mode or are undergoing decontamination / decommissioning.
General Electric Morris Operations and Battelle Columbus Laboratories operations included only maintenance and radiological surveillance.
No change in their status is expected in the near 7
j
w future.
Consequently, Region III plans to inspect these facilities only on an annual basis.
The Kerr McGee Cimarron uranium and plutonium facilities have been shutdown since 1975 and only decontamination / decommissioning activities are taking place.
During the review period, NMSS staff members and a staff member from Region I participated in five inspections, whereby, the regional inspectors were found s"*
to be conscientious and well prepared for the inspections.
Both NMSS and Regional staff consider NMSS inspection participation to be beneficial.
A review of inspection reports determined the need for some improvement in content.
Examples of inspection reports considered needing improvement and also considered good reports were provided to the Region.
The average inspection report issuance time was 39 days compared to the goal of 21 calendar days after the inspection has been completed (30 calendar days for major team inspections) as stated in NRC Inspection Manual Chapter 0610-11 dated January 14, 1991.
The longest issuance time was 76 days and the shortest time was 13 days.
RegionIIIrequestedthatNMSSprovidepromptfeedbackoninspectionreportsfn which concerns were identified.
A review of the files determined that the license application for ASI and CEHF are not up-to-date.
It is recommended that the Reofon maintain an up-to-date license application for these facilities.
During the review period, Region III's fuel cycle inspection program met the requirements of Manual Chapter 2600.
The Region's immediate response to several incidents during the review period is considered a program strength.
3.3 Low-Level Waste Inspections In assessing the status of the Low-level Waste (LLW) program in Region III, NMSS had discussions with individuals, as noted below, in the fuel facilities program, the materials program and the reactor program.
NMSS performed a very limited review of selected inspection reports that included the low-level waste module.
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Overall, RMSS found Region III management and staff to be knowledgeable in the aspects of 10 CFR Part 61 and 10 CFR 20 that pertain to LLW generators.
Inspectors appear to be diligent in assuring that licensees comply with classification requirements, waste form and packaging requirements, and reporting and manifest requirements.
Licensees also seem to have a good understanding of requirements as evidenced by the lack of violations against Part 61 requirements.
Inspectors in all three areas appear to be spending the appropriate amount of time on LLW inspections and have an appreciation for the importance of good LLW practices.
An area that was identified as a possible area for more resources is documenting old 20.304 burial sites.
Because recordkeeping for these old sites was poor, and specific knowledge of them is dependent on personal recollection and whatever records were retained, without some initiative on the part of the regulator, these sources of information could be lost. NMSSandRegionIIIahe working cooperatively to assess the scope and magnitude of this potential problem and implement a plan of action.
l 3.3.1 Low-Level Waste Inspections of Fuel Facilities Contaminated Sites NMSS discussed with staff the LLW aspects of inspections of waste at major I
regional fuel facilities.
Licensees have a good understanding of LLW requirements.
However, storage of large quantities of material and related deterioration of l
containers is sometimes a problem -- LLW sometimes requires repackaging to meet l
shipping and disposal requirements.
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NMSS also discussed the large volumes of low specific activity bulk waste at fuel facilities and problems with disposition.
Inspectors noted that licensees sometimes took an "out of sight, out of mind" viewpoint about this waste and occasionally had to be reminded to manage it properly.
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4 Regarding the Site Decommissioning Management Plan (SDMP) program, there seems to be a need for better communication between the Region and NHSS.
NMSS needs to keep the Region current on HMSS Project Manager contacts and any Headquarters initiatives regarding SDMP.
Additional resources would help the Region become more proactive in assuring responsible parties implement appropriate actions.
During the FY1993 budget formulation process, resources were allocated for project management of SDMP sites for Region III.
3.3.2 Low-Level Waste Inspections of Materials Safety Licensees Inspectors are using checklist procedures for material inspections tailored to the specific program.
Checklists include specific procedures for LLW.
Approximately 30 percent of all materials licensees in the region are LLW generators.
They use vendor services for processing for disposal. The materials inspection Section Chief was knowledgeable in LLW requirements as they pertained to materials licensees.
I 3.3.3 Low-Level Waste Inspections of Reactors Region III is still in the process of converting to a core inspection procedure for LLW.
The new procedure is conditioned on the SALP cycle for individual sites.
Reactor facilities are inspected against the LLW module once per SALP cycle -- in general approximately 12 inspector hours are spent on the LLW specific aspects of each module.
Licensees generally use vendor services to process waste.
This has led to fewer problems and violations.
Inspectors are knowledgeable in requirements of LLW modules.
Some training may be appropriate regarding the recent developments in waste form and possible long-term waste st<> rage by reactor sites, particularly in Michigan.
Region III follows up on transportation violations identified at LLW sites out i
of the Region.
Notices of Violation (NOVs) and penalties are issued as appropriate.
It may be beneficial for Headquarters to consider a tracking system to allow quantification of all such interregional interactions [NMSS will raise this issue in a meeting with all regions in June].
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3.4 Transportation Safety Inspection Program Region III conducts inspections of transportation activities as part of its materials, reactor, and fuel cycle program activities.
Review of Region III's program shows that transportation inspection activities are being conducted generally by inspectors who are knowledgeable of and experienced in the transportation regulations.
Regional inspectors use the oppropriate inspection modules.
During the review, it was noted that inspectors generally had available appropriate reference material, including current copies of Title 49 of the Code of Federal Regulations Parts 100-177, Transportation.
Other new reference materials will be sent to the Region III as these materials become available.
3.4.1 Materials Inspection During FY90, approximately 190 inspections were conducted in which transportation activities were reviewed. On the average 1.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per inspection were spent on transportation inspection activities.
32 violations were indicated of A
which 1 Severity Level III, 27 Severity Level IV, and 4 Severity Level V items were noted.
The total number of violations found in Region III's material transportation is average when compared to other regions.
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 module 86740.
During the review, several inspection reports were examined.
The inspections were generally thorough and the quality of the inspections appears to be safisfactory.
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 the vehicle.
3.4.2 Fuel Facilities Eight transportation inspections at five sites were completed for fuel facilities in Region III using inspection module 86750.
During these inspections, one violation was noted.
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i 3.4.3 Reactors During FY90, transportation activities at power reactors were performed I
according to the SALP inspection frequency for the plant.
The core program has implemented the use of procedure 86750 related to solid radwaste and transportation.
This procedure is often supplemented with the use of 86740 for the transportation inspection.
Three items of noncompliance were noted.
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4 ENFORCEMENT The following-items were discussed related to enforcement activities:
For Severity Level III enforcement cases to be issued by the Region under the Delegation of Authority, the process that is being used to coordinate as the action is being developed, including the roles of the technical and EICS staffs.
Use of a statement to indicate the " regulatory concern" in the letters that accompany a Notice of Violation of Severity Level IV or V.
Maximizing the use of Form 591.
Experience with non-cited violations.
Training conducted on the Enforcement Manual.
I Receipt by inspectors of Information Notices and the NHSS Newsletter and inspection findings as to those documents.
Use of Personal Computers (PC's) and standard paragraphs for the preparation of Notices of Violations and related enforcement documents.
For these discussions, the Office of Enforement found the following:
In almost all instances, the inspectors use the standard citations that have been promulgated, although noting that sometimes they believe they can improve on the citations.
Most deliver the draft Notice of Violation (NOV) on disk to administrative typing, reducing typing support requirements.
At the time of the review, the standard citations had been put on disks and copies provided to two inspectors, but the fact that instructions on use of the disks would be forthcoming following approval did not come out in interviews with inspectors.
The Region advises that the instructions have been approved and the disks are 13
now in full use.
It is expected that they will further expedite the process, as PCs are increasingly available for inspectors and most of them are using computers to prepare documents.
Region III has updated two Regional Procedures to reflect the Delegation of Authority for Severity Level III cases and other changes, such as promulgation of the Enforcement Manual.
The Delegation of Authority, changes in personnel in key positions within the past year, and direction to emphasize the expression of points that are most important to the technical staff have all resulted in greater involvement by the technical staff in the preparation of enforcement packages.
Some inspectors are not yet comfortable with their greater roles in that process and the need for extensive drafting prior to the Enforcement Board.
The managers involved are aware of these unsettled feelings and are endeavoring to make the new procedures work effectively.
They need to monitor the interaction between the technical and.EICS staffs closely and continue to explain the reasons for the procedures and fine-tune them.
1 Discussions indicate that Form 591 is being used extensively in Region III.
The Branch Chief reports 50% use of this form in his inspections and encourages greater use.
A Section Chief suggested that additional guidance might increase usage. Normally, the Form 591 is issued by the inspector in the field.
Discussions indicate that inspectors are checking to determine if licensees receive Information Notices and the NMSS Newsletter.
However, inspectors do not always receive these items from NMSS before the licensees and the inspectors sometimes encounter licensee questions about specific articles before the inspectors have had a chance to review the articles.
Inspectors report very favorable response to the Newsletter, with considerable interest in enforcement actions taken against other licensees.
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Discussions indicate that inspectors understand the non-cited violation (NCV) process and use it when it is possible to do so, particularly now that the required standard language has been reduced to manageable size.
l Several inspectors deplored the paper burden, such as the number of documents that must be filled out with often repetitive data, e.g., licensee and its address, to support the administrative process, such as 766 reports, travelers, etc.
Concerning the Enforcement Manual, some inspectors were familiar with it, and I
one inspector has his own copy.
The Section Chiefs have copies of the manual.
Other inspectors were unaware of the Enforcement Manual and felt that they had not received training concerning it.
General training to create awareness of this resource document is recommended.
The materials staff and the Director, EICS, noted the need for additional 1
guidance on the definition of " supervision" for application of 10 CFR 35.25.
It is recommended that NMSS address this issue.
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1 5 TRAINING The Region has a strong commitment to training and qualifying its staff.
In fact, based upon a suggestion from the Region III Deputy Regional Administrator to NHSS, Policy and Guidance Directive 91-1 was issued in March which outlines the new training requirements for license reviewers.
They also make effective use of the Individual Development Plan process.
Region III continues to cross-train its reviewers and inspectors and is beginning quarterly rotations of its staff so that reviewers and inspectors can gain new perspectives.
They have also participated in rotations to and from NMSS.
The Region conducts periodic in-house training.
Technical and administrative topics are discussed and the training is open to all staff members.
NMSS noted that because of the recent unavailability of the course, several of the regional inspectors had not received training in transportation.
When the 1
Technical Training Center (TTC) offers the H-308 Transportation course in July, the region should endeavor to enroll those who need the training.
Additionally, the region noted that periodic refresher seminars would be beneficial to inspectors previously trained.
Headquarters will provide these refresher seminars.
NMSS noted that inspections of facilities using new technologies and new types of equipment could be conducted more efficiently if inspectors were familiar with the technology in advance of the site visits.
This would allow them to focus the time they normally spend on becoming familiar with the new technologies to the assessment of the licensees' health and safety programs.
While it is difficult to have every inspector familiar with all new technologies, a new training course is being developed through TTC to fill this void.
The course would deal with current health physics associated with new technologies. Once it is available, all materials inspectors, including those in Region III will be encouraged to attend.
This issue, of making efficient use of our inspectors' time, will become even more important once the new 100% Fee Recovery Rule becomes effective.
The Region also felt more could be done concerning training on the revisions to 10 CFR 20.
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6 REGIONAL INITIATIVES The Region continues to pursue a number of initiatives to maintain the quality of its programs.
Examples include:
Region III continues to use the Performance Evaluation Factors Program j
during the conduct of materials safety inspections.
'j Region III continues to search for root causes of identified problems at ifcensee facilities.
The Region continues to emphasize the observance of licensee operations during inspections.
To this end, they are conducting more field inspections of radiographers and gauge licensees and are increasing the emphasis on QA inspections of major licensees engaged in therapeutic procedures.
Theyarecontinuingtousepre-inspectionplanningforbroad-scopelicedees to focus on prior safety issues and previous unresolved or open items.
They are planning inspections based on the NMSS core inspection program, and are progressing to reduce the number of overdues in Priorities
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1, 2, and 3.
The Division Director met with counterparts in EPA Region V and EPA Region VII to establish interface regarding contaminated sites.
They are making effective use of rotational assignments within the Region j
and with NHSS.
The HMS branch has undertaken a methodical process of procuring computer i
hardware and software, establishing standard practices and procedures and providing training to expand the use of these resources and improve efficiency.
The Region is moving to provide ADP equipment to all of its license reviewers and for two of every three inspectors.
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Region III has a good introspective process, which makes use of internal audits to cover both administrative and technical issues.
i Region III's quarterly " Master Activities Plan for Fuel Facilities" report is very useful to NHSS and has improved NMSS' understanding of issues at Region III's fuel facilities.
NHSS supports issuance of the rep,Jrt and believes it helps to improve the communications between NMSS and Region III.
The formation of a separate group responsible for fuel facilities and contaminated sites is another strong point.
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7 HEADQUARTERS / REGION III INTERACTIONS Region III felt that interaction between Headquarters and the Regional staff continues to be satisfactory regarding significant issues and events; however they felt that NMSS and Regional workloads and timeliness goals were causing the interaction levels to decline on more routine matters. Their concern relates to the potential for inconsistencies to develop between regions on the handling of routine matters.
Monthly conference calls help to a certain extent, but they are not adequate substitutes for periodic reviewer workshops, and section leader counterpart meetings.
HMSS found that interactions between the respective staffs of Region III and NMSS in such matters as licensing reviews, inspections, incidents, and enforcement actions have generally been good during the review period.
How-ever, there were a few fuel cycle incidents in which the interactions were not as good.
As a result of these incidents, both NMSS and Region III are con-sciously trying to improve.
Region III plans to routinely travel to Washington 3
to meet with NHSS and discuss mutual issues of concern.
In addition, Region III needs to be more proactive in identifying problems related to contaminated sikes and communicating these concerns to the licensees and NMSS.
In addition, several Regional staff members pointed out problems they have experienced in receiving the NMSS Newsletter on a timely basis.
NMSS has arranged for additional copies to be provided to the Region in a more timely manner.
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8 RESOURCE UTILIZATION The attached table shows FTE allocations and expenditures for the review period.
Region III has no program support funds in the NMSS mission areas.
During FY90, Region III expended approximately 89 percent of the budgeted resources for the NMSS programs.
The underexpenditure was attributed to attrition of staff, new staff not fully qualified, and the absence of two senior reviewers for a significant amount of time.
(Also, an FTE has been taken from the Nuclear Materials Safety r*,;csm and designated to the Enforcement and Investigation Coordination St_rf sad a Technical Assistant was also taken from that same program and assigned directly to the DRSS at the Division level, i
If these FTE were included in the count, the expenditure figure would be nearly 95%).
Region III has aggressively recruited personnel for the Nuclear Materials Safety program and was fully staffed at the time..of the review. A staffing r issue that should be reviewed concerns the number of GG-14s.
If more could be added, it could lend support to the overburdened Section Chiefs, i
In FY90, Region III completed 2152 materials licensing actions.
Resource expenditures through January were slightly more than budgeted (approximately 9 percent).
This appears to be attributed to more effort being devoted to the materials decommissioning effort.
The Region makes effective use of its ADP hardware and software and has moved ahead well with a well-thought out plan to procure additional hardware and software.
When completed, two of every three inspectors should have such equipment.
i Region III is providing assistance to Headquarters in the threat assessment Currently, there are no resources in the budget for this effort.
DRSS area.
exchange and interaction with the DRMA staff is outstanding.
The DRMA is thorough in preparing timely travel authorizations and typing of licensing and inspection correspondence is efficient.
Other administrative support also seems to be available, with about 3.5 FTE dedicated, and extra part-time support (about 0.3 FTE) from another Branch member.
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It was noted that training is needed in RITS and the license fees area for appropriate ORMA staff.
(NRR is tentatively planning such a training session; possibly NMSS;can participate in this session or come up with a training session at some time in the near future - preferably prior to the 100 percent Fee Recovery 1
deadline of September 30, 1991).
Also, NMSS should consider establishing a User's Manual for RITS (and more daily dialogue may also help).
REGION III RESOURCE UTILIZATION l
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 y
Fuel Facility Licensing 0.05 0.02 40 0.05 0.02 0.13 Fuel Facility Insp.
2.0 1.0 50 1.9 0.6 0.33 Materials Licensing
- 9. 8 8.8 90 8.3
- 2. 8 3.0 Materials Inspection 14.4 13.0 90 15.2 5.1 5.04 Event Evaluation
- 1. 9
- 2. 8 147 3.0
- 1. 0
- 1. 2 NMS Section Super.
3.5 3.2 91 3.5 1.2 1.3 NMS Subtotal 31.65 28.82 91 31.95 10.72 11.0 103 SG Fuel Facility Lic.
0.02 0.01 50 0.02 0.01 0.03 SG Fuel Facility Insp.
- 0. 2 0
0 0.2 0.07 0
SG Transp. Insp. &
0.4 0.01 3
0.2 0.07 0.06 Plans NMTS Section Super.
0.1 0.01 1
0.1 0.03 0.01 SG Subtotal 0.72 0.03 4
0.52 0.18 0.1 56 LLW Inspection 0.25 0
0 0.25 0.08 0.003 Reactor Decons.
- 0. 2 0
100 0.3 0.07 0
Materials Decomm.
- 0. 5
- 0. 6 120 0.5
- 0. 2
- 1. 0 LLW Section Super.
0 0.08 0
0.1 0.03 0.13 s
LLW Subtotal 0.95 0.68 72 1.15 0.38 1.133 298 NMSS TOTAL 33.32 29.53 89 33.62 11.21 12.23 109 NOTE:
FY90 expenditures from regional input provided in response to FYP/ Green Book update in 01/91.
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\\
9 RECOMMENDATIONS / SUGGESTIONS For Region III:
Maintain an up-to-date license application for the two operating fuel facilties, Allied Signal, Inc., and Combustion Engineering Hematite far 111ty.
Assure that the inspection staff has a general knowledge of the content of the Enforcement Manual; also assure its availability.
Catch up on follow-up of returned mail.
Submit to NMSS requests for generic licensing conditions before using them regularly.
Interact more frequently with licensees and NHSS on issues related to thh low-level waste issues at contaminated sites.
Continue to implement a plan to improve records related to the old 20.304 burial sites.
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RECOMMENDATIONS FOR HEADQUARTERS i
Continuesto encourage rotational assignments to and from the Region.
Those coming to NMSS could be used to review the consistency of licensing actions or to. revise Standard Review Plans or Regulatory Guides.
Allow Regions to hire non reactor interns. (Note that this item was not funded by NMSS during the FY93 budget process).
Provide prompt comments / feedback on fuel cycle inspection reports.
Increase day-to-day communications and hold a materials workshop for inspectors and license reviewers and a Section Chief counterpart meeting.
(Note that the section meeting is scheduled for September at Headquarters).
Assure the Region has a current list of NMSS contacts in all technical areas -- the SDMP program was one example cited.
I Consider developing a refresher course for low-level waste inspectors particularly for storage for large quantities of low-level waste and the recent requirements on waste generacors related to waste form.
Assure a more timely distribution of the NHSS Newsletter to Regional personnel.
Discuss with all five regions the feasibility of installing a mechanism for tracking and following-up on out-of-rsgion, low-level waste issues - particularly those involving requests for follow-up by State low-level waste regulatory staff.
Assure that technical training evolves with the new technologies and assure that generic courses for NRC inspectors are not slanted too far toward reactor issues.
Provide additional guidance on the definition of " supervision" as used in 10 CFR 35.25.
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1 Continuetto update Standard Review Plans and Regulatory Guides in the following broad scope programs, portable and fixed gauges, licenses.*or laboratory areas:
and industrial uses of small quantities of byproduct material.
Re-evaluate guidance on issuing "as needed" possession limits, particularly on medical licensees, in light of the financial assurance rule.
Improve response timeliness on Technical Assistance Requests, specifically Sealed Source and Device Reviews.
(The Region indicated that other requests were generally acceptable).
Consider training for regions with respect to RITS, new license fees, and 10 CFR 20 revisions.
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Team Members.-i
- John W. N. Hickey, Chief, Operations Branch, Division of Industrial and Medical Nuclear Safety, NMSS Ronald R. Bella n, Chief, Nuclear Materials Safety Branch, Division of Radiation Safety and Safeguards, Region I Steven L. Baggett, Chief, Sealed Source Staff Section, Medical, Academic, and Commercial Use Safety Branch, Division of Industrial and Medical Nuclear Safety, NHSS Edwin D. Flack, Sr. Health Physicist, Fuel Cycle. Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS Michael Wangler, Sr. Transportation Specialist, Transportation Branch, Division of Safeguards and Transportation, NMSS James A. Shaffner, Project Manager, Operations Branch Division of Low-Level Waste and Decommissioning, NMSS Elizabeth Jacobs-Baynard, Sr. Program Analyst, Program Management and Policy Development Staff, NHSS Geoffrey D. Cant, Enforcement Specialist, Office of Enforcement
- Team Leader 25 i