ML20057A702
| ML20057A702 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1992 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309150174 | |
| Download: ML20057A702 (5) | |
Text
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KING OF PRUSS' A, PENNSYLVANIA 19406-1415 MAY111g MEMORANDUM FOR:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS FROM:
Richard W. Cooper, II, Director Division of Radiation Safety and Safeguards, RI
SUBJECT:
DRAFT NATIONAL PROGRAM RF'litiW REPORT This is in response to your memorandum, same subject, which requested comments on or before May 8,1992. This date was extended until May 11, 1992 in a telephone conversation between John Greeves and Jacque Durr. We appreciate the opportunity to comment on the subject document and are available for any other assistance we can provide regarding this matter.
Ri oo II, Director Division of Radiation Safety and Safeguards Ecciosure:
As stated 9309150174 930830 G. - f) s PDR STPRO ESCGEN
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COMMENTS ON THE DRAFT NATIONAL PROGRAM REVIEW REPORT REGION I Page 3, Section 2.a. Materials Safety, second paragraph,
.. It should be noted that the backlog problem was largely the result of the unexpected rash... "
Comment:
... as well as the result of FY 90 and FY 91 attrition, that resulted in the loss of qualified license reviewers and the lag time for -
training and qualifying new staff as license reviewers. In addition, the receipts budgeted were exceeded by those actually received in FY 90 and FY 91 by 293 and 464, respectively.
Page 5, Section 2.b. Site Decommissioning Management Plan and General Decommissioning, Comment:
Mention that Region I succeeded in getting the first SDMP site off the SDMP list (Allied Signal).
Comment:
Concerning the statement that only half of the SDMP Task Force resources have been devoted to SDMP activities to date, we agree but note that one individual was not available to the branch until March due to SLO commitments, one individual is in extensive training, and the Safety Light hearing has severely impacted SDMP Task Force activities.
Page 6, Section 2.d. Safeguards Licensing, Comment:
The paragraph consists of factual statements without any assessment.
Page 6, Section 3.a. Materials Safety Inspections, first paragraph,
" As discussed above, the Region is developing a revised inspection goal to help reduce the licensing backlog."
Comment:
This is already done.
4 Page 7, Section 3.b. Fuel Cycle Safety Inspections, first paragraph,
" The Effluents Radiation Protection Section of the Facilities Radiological Safety and -
Safeguards Branch..."
Comment:
Change to read:" The Facilities Radiological Protection Section of the Facilities Radiological Safety and Safeguards Branch now has the responsibility for the fuel cycle safety inspection program. This program was transferred at the beginning of FY 92 from the Effluents Radiation Section to lighten the load on that section I
chief, who is heavily involved with planning for the 1993 Federal Field Exercise."
"On average, reports were prepared in 28 days vs.an average of 41 days a year ago."
Comment:
Add the following:" Thus far during FY 92, the average time to issue fuel cycle repo ts has been less than 22 days."
"The Region reviewed and inspected numerous operational activities at the West Valley Demonstration Project on a continuing basis."
Comment:
Change to read:" Th Region provided on-site monitoring of '
numerous operational.tctivities..." We do not inspect West Valley.
Page 8, Section 3.c. Fuel Cycle Safeguards Inspections, "The FY 91 safeguards inspection program was devoted to compliance inspections..."
Comment:
Change to read:" The FY 91 Safeguards inspection program was devoted to safety and compliance inspections..."
Page 8, Section 3.d. Transportation Safety Inspections, Comment:
This paragraph lacks any assessment and is focused on compliance in lieu of safety or how effectively the inspections were conducted.
There should be a message other than apparently stressing the ratio -
of violations to inspections.
Page 8, Section c. Transportation Safeguards Inspections, Comment:
Add to the end of the paragraph, " An additional trained inspector will contribute to both inspector availability and increase the opportunities to provide inspection coverage for these shipments since they are often on short notice and subject to frequent-schedule changes." Also, this paragraph does not.contain any assessment.
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Page 10, Section 4.a. Materials,
" Qualification journals are also being used effectively; however several staff were not adequately informed about the inspection qualification process."
Comment:
Add: " Followup discussions with the NMSB branch chiefindicate that this problem was corrected by the end of March 1992."
" Individual Development Plans are in place for all staff."
Comment:
Change "all" to" the majority of".
Page 10, Section 4.e. Decommissioning,
" Region I staff should evaluate the need for additional procedures and training to address those aspects of decommissioning not covered by current procedures."
Comment:
Region I will make greater efforts to identify and document needs in these areas. However, we need NMSS staff to be active in initiating, developing and giving guidance and training in the rapidly evolving and difficult aspects of decommissioning policy.
Page 11, Section 5. Initiatives by the Region, "The following Region I initiatives were underway throughout the past year "
Comment: What time period does "the past year" cover?
"* The Region initiated an effort to seek staff..."
Comment:
Change to read:
- DRSS initiated an effort to seek...
Comment:
Add the following initiatives,
- 1. SDMP task group
- 2. Upgrade of LA's in LAS
- 3. Licensing process improvement program
- 4. Voice mail for NMSB
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'The Region continued to support rotations with NMSS."
Comment:
This is too narrow, the region also supported NRR, Region III and Region V.
Change to read:"The Region continued to support rotations and inspector exchanges with headquarters and other regions.
Page 12, Section 6. NMSS/ Region Interactions,
" Monthly conference calls are scheduled to update LLWM on progress at SDMP sites."
Comment:
Scheduled, but we are not aware that they are routinely happening.
We recommend that the need for these conference calls be revisited and a decision by HQ made to either continue them and take charge to assure their success, or do away with them.
Page 14, Section 7. Resource Utilization,
" A revised Operating Plan for FY 92 is expected to be submitted in the near future..."
Comment:
At the time of the final NPR report, this will have been issued.
Page 15, Section 8. Recommendations / Suggestions
" Improve timeliness of enforcement packages provided to NMSS for enforcement conferences."
Comment:
On page 12, NMSS has action to discuss this issue with OE, since NMSS looks to OE for distribution of the proposed enforcement action for review. Thus, we believe that the recommendation for Region I action is incorrect; this item requires action by NMSS.
Also, the comment should be rewritten to not sound as though escalated enforcement timeliness needs improvement.
" Evaluate whether inspector qualification boards are using consistent criteria to evaluate new inspectors."
Comment:
Unless this is supported in the text of the report, so that we can understand its basis, we believe that it should be deleted as a recommended Region I action.
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