ML20057A706

From kanterella
Jump to navigation Jump to search
Forwards Final 1992 Natl Program Review Rept for Region I. Rept Covers Period Between Last Two Team Visits & Includes All Regional Activities Under NMSS Oversight Authority
ML20057A706
Person / Time
Issue date: 06/12/1992
From: Cunningham R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20055C202 List: ... further results
References
NUDOCS 9309150179
Download: ML20057A706 (22)


Text

y e-4 June 12, 1992 NEMORANDUM FOR: Thomas T. Martin Regional Administr6 tor, Region I FROM:

Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, HMSS

SUBJECT:

1992 FINAL NATIONAL PROGRAM REVIEW REPORT FOR REGION I Enclosed is the 1992 National Program Review (NPR) report for Region I.

This report covers the period between our last two NPR team visits (roughly April 1991 through March 1992). The report includes all regional activities under NMSS' oversight authority.

NMSS circulated a draft version of this report to the region's Division of Radiation Safety and Safeguards. Their comments have been inco*porated into this final version of the NPR report, as appropriate.

As always, we appreciate the efforts of your regional staff throughout the year and we welcome any additional thoughts you might have that might lead to further improvements in our review process.

ORIGINhl. SIGNED BY

\\

John T. Greevesy Richard E. Cunningham, Director Divisto~n of Industrial and Medical Nuclear Safety, NMSS

Enclosure:

As stated M

b0 DISTRIBUTION:

~

IM0B r/f RCunningham"'

RBernero IMMS r/f RBangart GArlotto -

CCQ, KING CTen j

NMSS r/f JCook GDeegan R8ernett GPangburn JKenne#

FCoug4 DFauver JGlenn UlcDarby JHickey LJ8aynard CHaughney JGreeves 1

0FC :IMDB

IMOB
I
IMN5
IMN3 r.....:..

g...:..

N"~ :G an/11

GPangburn
Fi o
J ev un gham:
............:.f..........:

f.

6/ 9 /92

6f /0/92

/2./92 ff//2/92

~

0FFICIAL RECORD COPY FINAL NATIONAL 9309130179 930830 i

.(

PDR STPRO ESGG f 7 {/

j s

REPORT OF NMSS NATIONAL PROGRAM REVIEW AT NRC REGION I, MARCH 10-11, 1992 1.

BACKGROUND AND PURPOSE l

This report provides the results of the Office of Nuclear Material Safety and Safeguards (NHSS) review of materials programs that were under the responsibility of NRC Region I for FY91 and the first several months of FY92.

The Headquarters team participating in this review included individuals from each of the program areas under review. The composition of the team is shown in Attachment 1.

The Regional activities related to materials programs are primarily under the responsibility of the Region I Division of Radiation Safety and Safeguards (DRSS). A copy of the DRSS organizational chart is shown in Attachment 2.

i The NPR is based not only on the visit to the Region, but also on the collective Regional / Headquarters interfaces throughout the year. These interfaces includa the review of selected licensing casework and inspection reports, the accompaniments of region-based inspectors, the review of casework and inspection statistics, resource utilization, technical assistance and coordination actions including conference calls, and the information questionnaire. The NPR process is intended to provide a review of effectiveness of both the Region and Headquarters activities insofar as they relate to Region l's activities, and to identify suggestions for improving the effectiveness of the collective efforts of HMSS and Region I.

The NPR emphasizes both numerical goals for licensing and inspection activities and quality of licensing and inspection efforts, on the basis that all of these elements contribute to assuring the safety and safeguards of operations involving NRC licensed activities.

1

4 The report is organized so as to present an integrated sumary of Region I activities in each of the following areas:

1.

. Background and Purpose 2.

Licensing 3.

Inspections 4.

Training 5.

Initiatives 6.

Interfaces of Region / Headquarters 7.

Resource Utilization 8.

Recommendations / Suggestions i

~

i l

's*18 i.

-. i.Q tf.. ;g 4 re

, 2 st s e r q

' ~ -4 1

6 2

2.

LICENSING liit erials Safety t

a.

In FY91, the Region completed 70 percent and 123 percent of its budgeted licensing actions for new licenses and license amendments respectively, and 73 percent of its budgeted license renewals.

In total, the Region completed 105 percent of its budgeted casework.

This equates to 1,726 completed actions.

The Region's overall performance in the licensing area was enhanced by 11% in comparison to the previous year. This is probably because the levels of staffing and experience have improved.

During the first five months of FY92, Region I managed to complete 938 cases, or slightly more than 50 percent of the actions for which it is budgeted throughout the entire year.

This fine performance had already brought about a reduction in the number of pending i

cases from 1,500 to 1,235, and " backlogged" cases from 411 to 390.

By the end of April, these figures continued to drop, with 1178 pending cases, and 322 backlogged. A Region I proposed Operating Plan revision submitted in April would place additional emphasis on licensing casework, in order to reduce the backlog still further. The reprogramming comes from the materials inspection area.

It should be noted that the backlog problem was largely the result of the unexpected rash of receipts from the 100% fee recovery rule, and receipt of many licensee financial assurance amendments.

In addition, FY90 and FY91 attrition resulted in the loss of qualified license r'eviewers and created a lag time for training and qualifying new staff as reviewers. Since the last program review, the Region has been very successful in filling vacant positions with highly qualified individuals. The region will achieve greater efficiency in licensing as these new professionals become fully qualified to sign their own licenses. A dedicated medical licensing section in the new organization has enhanced licensing activities.

A select number of Region I licensing cases were reviewed against NRC regulations and Standard Review Plans.

The cases were complete, no errors were noted.

In addition, several medical licenses of broad scope were reviewed to note any non-uniform practices in the review process among the 3

- - ~

regions.

This review was conducted as part of an ongoing Headquarters review of broad-scopes.

No discrepancies were noted.

1 The Region has initiated a plan to complete the review for renewals of broad-scope licenses on a priority basis.

NMSS participants concurred that these renewals were a priority but emphasized the need to continue to complete action on new applications and amendment requests as promptly as possible.

Regional personnel recommended improved access to information on sealed source and device reviews. They noted the progress made in the last year in automating certain information contained in the source and device certifications. However, license reviewers indicated that certain information was still only available through members of the Sealed Source Safety Section.

During the past year, Region I rotated a Branch Chief and Senior Health Physicist to NHSS and NMSS rotated a Project Manager to Region I.

Both Offices felt the rotations had been useful and helped to improve communications and understanding of the overall materials program.

j 1

License reviewers recommended that HMSS guidance provided in response to Technical Assistance Requests (TAR's) be shared more widely and completely.

Specifically, the incoming request from the originating Region should be included in the distribution to the other Regions.

In addition, the availability of AUTOS, the agency's computer network, makes possible the use of a TAR index natntained by MSS but accessible to all reviewers in the Regions. Administratively, Region I reviewers requested that the TAR responses refer to the control number of any licensing action involved.

b.

Site Decommissionina Manaoement Plan (SDMP) and General Decommissionino Region I fonned a task group in January 1992 in the Nuclear Materials Safety Branch to address 50MP sites, other contaminated sites, and " difficult" licensing issues not related to decommissioning. The existence of the task 4

T group has increased regional management awareness of the SDMP and focused regional efforts to more effectively resolve the unique problems associated with SDMP sites.

In February 1992 the task group completed all necessary actions leading to the decomissioning of the Allied Signal site and its removal from the SDMP list.

The task force is currently planned to remain in place until June 1992. However, the DRSS/NMSB Chief acknowledged that the task force appears to be needed beyond June 1992.

The task group has been allocated 4.5 FTE for 199f, four of which were allocated by the Division of low-Level Waste Management and Decommissioning (LLW1) for the SDMP.

The remaining 0.5 FTE was extracted froin other Region I programs. Regional staff estimated that approximately half of the task force resources have been devoted to SDMP activities to date.

If this trend continues, the full four FTE allocated for the task force would not be utilized on SDMP activities.

Region I should make every effort to use the full four FTE allocated on SDMP-related activities.

c.

Financial Assurance (FA)

Following the July 27, 1990 deadline for the submittal of a decommissioning funding plan or certification of financial assurance, Region I has received approximately 450 FA submittals. However, after regional review it was l

determined that only 320 of the FA submittals were subject to the rule. As of March 12, 1992, licensing action has been completed for 109 FA submittals.

This represents significant progress towards full compliance with the decouaissioning rule.

FA submittals are tracked in the LTS as license amendments with a unique reviewer code. The backlog of 200 submittals is scheduled to be reduced by 100/ year. Over 100 submittals were processed in 1991 and the Region is on schedule for 1992.

If this rate continues, the backlog should be eliminated by the end of 1993. The 0.5 FTE allocated for FA submittal reviews appears to be adequate to meet the Region's goal. Region I staff is taking full advantage of the current LLWM procedure for processing non-routine FA submittals by 5

making an effort to fully understand the guidance and comments contained in LLWH response to the Region's request for assistance.

The guidance and recommendations provided by LLWM are also used as a training tool for license reviewers. Non-routine FA submittals of a type previously encountered are processed by the Region without again seeking LLWM assistance. Overall, Region I staff has made an excellent effort to incorporate FA submittals reviews into the routine licensing process.

d.

Safeguards Licensina Region I expended extensive licensing efforts in support of HMSS in coordinating physical security plan changes and approvals related to decommissioning of United Nuclear Corporation (UNC) Montville. Some of this effort required site visits by an inspector before approvals or recommendations could be fonvarded to HMSS. Work performed by the Region I inspector and other regional support was effective and resulted in an orderly shutdown of the facility within the planned schedule.

3.

INSPECTIONS

a. Materials Safety Insoections In FY91, 1,168 materials safety inspections were completed. The budgeted goal for FY91 was 1,146 inspections. Thus far, through February 29, 1992, 439 inspections had been completed. The revised target for that time period is 382 inspections, based on the proposed goals requested in April. Once agreement is reached on this new goal, the Region will be in a good position to meet or exceed both its licensing and inspection objectives. The planning and scheduling of inspection activities is well-coordinated as evidenced by the fact that there were only 4 licensees overdue for inspection as of early March. This is a remarkable figure for a region with about 2,700 licensees.

As a result of changes made in the documentation of the granting of reciprocity pursuant to 10 CFR Part 150 and the policy decision to require submission of Form 241 only once per year, Region I developed a comprehensive program to improve tracking of reciprocity notifications. As a result of 6

better controls in this area, Region I has performed more field inspections of licensees operating under reciprocity and has made significant findings regarding licensee performance under reciprocity.

NMSS plans to share the Region program as a model for other Regions.

Region I inspectors and management made several coments regarding possible improvements to the inspection program. Although the recent trial program for field-cited violations for radiographers was perceived to have been minimally successful due to the cumbersome process, inspectors felt that efficiencies could be achieved by delegating more responsibility to inspectors to issue findings either in the field or from the office.

Specific recomendations were made relating to better access to information and communications.

For example, Region I inspectors believe the ability to access the General License Database would aid in the tracking of sources and devices found at scrapyards, landfills or other locations. They also recommended that the monthly conference calls be expanded to always include participation by LLWH personnel. This would help snsure that Regional inspectors were aware of any new developments, particularly i.9 LLW storage, and that Headquarters LLWM personnel would be better informed regarding storage issues at licensee sites.

Further, the conference calls should include more discussion of enforcement actions. A manager suggested that NHSS should participate more frequently in enforcement conferences and also perfom more accompaniments of regional inspectors.

b.

E nl Cycle Safety Insoections 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 FY92 from the Effluents Radiation Section to lighten the load on that Section Chief, who is heavily involved with planning for the 1993 Federal Field exercise. During FY91, six fuel cycle inspections were performed at CE-Windsor and four inspections at UNC. All required inspections were completed in accordance with Manual Chapter 2600 and the quality of the inspection reports was superior. During the past year, fuel cycle inspection report 7

l I

l turnaround time improved. On average, reports were prepared in 38 days vs. an average of 41 days a year ago. Thus far in FY92, the average time to issue fuel cycle reports has been less than 22 days. NMSS staff accompanied the Region on several inspections, and there continues to be close cooperation between Headquarters and the Region reijarding fuel cycle facilities.

In particular, the Region has provided valuable input on decomissioning the B&W Apollo facility.

The lead fuel cycle inspector, Jerry Roth, is highly regarded by the HMSS staff and was a valued contributor to a number of special assignments.

Specifically, he was a key participant in developing the Materials Regulatory Review Task Force (NUREG-1324) report. The Region I Division Director also rendered a valuable contribution in preparing management comments to go with this task force report.

The Region provided on-site monitoring of numerous operational activities at the West Valley Demonstration Project on a continuing basis. These activities included concrete placement and quality assurance of shield walls of vitrification cell, site transportation, and process and procedures related to the evaporator in the Integrated Radwaste Treatment System. The Region also continued their TLD monitoring at the site.

c.

Fuel Cycle Safeouards Insoections The FY91 safeguards inspection program was devoted to safety and compliance inspections of UNC, Montville as the transfer of all unencapsulated material was finally completed during the first quarter of FY92. Region I successfully monitored and inspected the transition of UNC, Montville from a Category I facility tera Category II/III facility. Four safeguards inspections were conducted after each major physical security plan change was approved by Headquarters. The Region I inspection reports for these transitional inspections were thorough and technically competent. The reports were completed in a timely manner and submitted to Headquarters.

d.

Transoortation Safety Insoections 8

I The Region inspects licensee transportation safety programs as part of its materials, reactor and fuel facility inspection programs.

There are j

approximately 2,700 facilities and material licensees in Region I.

In FY91, Region I conducted a total of 310 transportation safety inspections, using Inspection Procedures 86740, 867408 and 86750.

Eighteen violations (all Severity Level IV and V were identified durir" these inspections. A review of selected inspection reports indicates inspection procedure subjects were

]

addressed and that the inspections were effective in identifying violations.

i Violations were properly cited against NRC and Department of Transportation regulations.

e e.

Transoortation Safeauards Insoections Region I completed their safeguards transportation program by inspecting three spent fuel shipments and one Category II shipment in FY91. The inspections were thorough and effective. As in previous years, a number of shipments either were canceled or never materialized.

Presently, an additional regional inspector is being trained to perfone thase inspections.

f.

Low-level Waste (LtW) Inso9etions Region I continued its programs for inspection of LLW at its licensees. Most of its efforts are devoted to inspection at nuclear powe reactors using inspection module 86750.

Inspections of materials licensees are performed using the broad guidance given in inspection procedure 87100 which covers many areas in addition to waste.

With respect to the power reactor inspections, Region I continues to inspect its licensees once each SALP cycle. One of the recommendations from the last national. program review was that the Region qualify more personnel to perform these inspections. At that time, one Npector was fully qualified.

In the last year, the Region has made substori al progress. Three inspectors have been qualified and several others ut b th process of being qualified to 9

one r--

perform these inspections. The staff recommends that RI continue with its successful program of qualifying additional inspectors for power reactor low-level waste inspections.

In discussions with the Regional inspectors involved in power reactor LLW inspections, they pointed out several areas that could be improved in the i

inspection program.

First, a number of RI personnel had taken the new LLW inspection course given at the TTC (H-202). They recommended that it be reviewed to determine if it can be improved to better qualify LLW inspectors.

j Specific areas they felt needed attention were the insufficient time devoted to 10 CFR Part 61 LLW criteria for waste form and classification, and inappropriate references in the course to materials and technologies which are not being used by licensees, such as certain stabilization media.

4.

TRAINING

a. Materiah j

The Region continues extensive efforts in training of new Itaff in the materials area.

Since a number of new staff has been addad, licensing and inspection efficiency should improve as a result of this training program.

Individual Development Plans (IDP) are in place for the majority of the staff.

Qual'fication journals are also being used effectively; however several staff men i sre not adequately informed about the inspection qualification procm 4 allowup discussions with the WSB Branch Chief indicate that this problem was corrected by the end of March 1992. Other staff members stated a perception that criteria used by qualification boards differs based upon the members constituting the board. MSS suggested that regional management review its procedures to assure maximus uniformity.

b.

Fuel Facilities Region I has a small, but experienced fuel cycle staff. The Region I fuel cycle staff training during the last FY was sufficient. Due to the reduction 10 l

l

in the fuel cycle activities in the Region, there is no need to expand training for additional staff in this area. _The lead fuel cycle inspector should attend the fuel cycle workshop and criticality trairing session planned for later this fiscal year.

c.

Safeauards Region I took the initiative to begin training an additional safeguards inspector on transportation inspections, d.

Transoortation l

In FY91, 31 Region I inspectors conducted transportation safety inspections.

Of these, 16 have taken NRC's Transportation of Radioactive Material course (H-308). Region I has scheduled the transportation course for 13 inspectors in FY92 and FY93.

e.

Decomissionino Training, inspection, and licensing procedures currently in place for routine licensing actions are applied to extended decommissioning and SOMP activities.

Region I staff should evaluate the need for additional procedures and training to address those aspects of decommissioning not covered by current procedures, such as residual contamination criteria, sampling plan design, review of site characterization and decomeissioning plans, and termination survey criteria.

LLWM will work with the Region to ensure that adequate guidance and procedures exist for decossissioning activities.

11

4 5.

INITIATIVES BY THE REGION The following Region I initiatives were underway since the 1991 program review.

DRSS initiated an effort to seek staff feedback on areas of possible improvement for its activities.

The Region developed new, comprehensive procedures to handle reciprocity notifications based upon new guidance for processing of Form 241.

The Region began and completed a comprehensive program to resolve outstanding licensing and inspections issues regarding licensees in the State of Maine prior to Maine becoming an Agreement State this year.

The Region continued to support rotations and inspector exchanges with Headquarters and other regions.

The Region formed a Task Group to address SDMP sites and other non-routine contaminated sites.

The Region initiated a plan to complete the review for renewals of broad-scope licenses on a priority basis.

The Region recently issued guidance on its own initiative for its staff reviewers concerning licensing of storage of LLW. This initiative will help to ensure that licensees are prepared to safely store LLW after disposal sites close down on January 1,1993.

6.

HMSS/RE8Mit I INTERACTIONS Interactions between MSS and the Region have been excellent. The counterpart meetings, workshops and inspection accompaniments have been very productive.

Routine telephone calls and periodic meetings have also been very effective.

12

~

There have been several beneficial rotations between Region I and NMSS in the past year.

For example, Ron Bellamy served as Acting Chief for the Medical, Academic and Commercial Use Safety Branch for about a month last Spring and Judy Joustra participated in a review of the policy and guidance available for mobile imaging vans. Sally Merchant of NMSS gained valuable field experience at Region I during the past year.

Region I recomended that HMSS staff should attend significant enforcement activities that are conducted in the Region or participate with the Office of Enforcement (CE) on a conference call.

Headquarters has requested more lead-time on the schu' ale for these enforcement actions. NMSS will discuss this issue with OE to improve communication on future enforcement actions.

Region I took the lead for NRC in the response to the Springfield, MA fresh fuel transportation accident, and contributed to satisfying NRC responsibilities under the policy statenent on NRC response to Accidents j

Occurring During Transportation of Radioactive Material. Communications between Region I and Headquarters were excellent during this event, and throughout the year.

Comunications between Region I and LLW on SDMP issues have been good.

During 1991, monthly conference calls were scheduled to update LLW on progress at SDNP sites.

In early 1992, each SDMP site, for which project management responsibility lies outside of LLW, was assigned a LLW member to monitor the progress of ongoing activities. This serves to replace the j

monthly conference calls. The Region agreed to further improve communications on SDHP issues by putting LLW on copy for all significant correspondence related to SDMP sites. To improve regional awareness of evolving generic issues in decommissioning, LLW will put all Regions on copy for policy guidance provided to any one of the five Regions. The Region also noted that NHSS should coordinate all approvals of 20.302 disposals with NRR and the Regions.

Region I SDNP activities are currently being tracked with a "next action" list which is issued monthly to the LLW/LLDR and DRSS/WSB branch chiefs. This tracking system reflects the Region's proactive approach to SDMP site cleanup, 13

(..

l lj..

1 which is commendable. However, tha system does not effectively track the milestones for the SDMP site cleanup projects. Milestone tracking is crucial for planning future resource needs, determining the cause of cleanup schedule delays, and developing strategies for minimizing future delays. DRSS staff agreed to work with LLWM staff to develop a milestone tracking system to accomodate the needs of both divisions.

7.

RESOURCE UTILIZATION Expenc!itures and Staffina fl21 The region's NMSS resources for FY91 were underexpended by 12 percent due to staffing shortages. However, this was a significant improvement over FY90.

Despite this staffing shortfall, materials licensing and inspection goals were exceeded with 1726 licensing cases completed against a goal of 1650, and 1168 materials inspections completed against a goal of 1146.

E191

\\

In order to address the need to devote time to recruitment efforts, training of new staff, and the backlog of licensing cases, the region submitted a revised FY92 Operating Plan a few weeks after the NPR visits. The materials licencing goal was increased by 100 in an effort to eliminate the backlog of new applications and amendments; and reduce the backlog of renewals. The inspection goal was reduced by 170.

Resources were reallocated to devote 1.9 FTE to training and 1.2 FTE to recruitment efforts.

The recruitment efforts have been successful and the ragion is now staffed at close to its FY92 FTE level. This puts the region in good position to use its full allocation of FY92 resources. The review team noted that the Nuclear Materials Safety Branch has an FY92 staffing allotment of 43 FTE. This includes 37 FTE of direct staff and 6 FTE of overhead. This makes it the 14

largest Branch of its kind in all of the regions. The Branch has five Sections, with full responibility for materials licensing, inspection, deconsissioning and clerical support activities.

It has grown in size as its budget has increased, and interns have been added. There is some potential for the span-of-control to become unwieldy in a Branch this size.

This situation should be monitored to assure the program continues to function efficiently.

As of the end of February 1992, the regior, had exceeded.its licensing goal by approximately 20 percent. The region will also be in good position to exceed its revised inspection goal, once it is approved by NMSS.

One of the workload issues that the DRSS managers highlighted was the increased effort being devoted to review of enforcement issues and allegations. Much of this effort is spent on reviewing the Office of Enforcement's (OE) assessment of the region's Level 4 and 5 enforcement actions for " lessons learned". Although the region is not formally required to do this review, it is something they feel compelled to do. The NPR team promised to discuss this with OE, because it was felt that OE did not intend for their report to become a resource intensive effort for the region.

19

ie following table shows FTE allocations and expenditures for the review period.

REGION I RESOURCE UTILIZATION FY91 FY92 REVISED ANNUAL BUDGET BUDGET EXPENDED

-PROGRAM ACTIVITY BUDGET EXPENDED % BUDGET (9/91) OCT-JAN OCT-JAN Fuel facility Licensing 0.04 0

0 0

0 0

Event Evaluation 3.5 1.8 51 3.3 1.5 0.5 1.1 Materials Licensing 7.5 10.2 136 7.4 10.2 3.4 4.2 Materials Inspection 16.4 13.2 80 17.8 14.1 4.7 5.3 Fuel Facility Insp.

2.9 1.7 59 2.9 2.9 1.0 0.4 SG Fuel Facility Lic.

0.02 0.05 250 0.02 0.02 0.01 0.01 SG Fuel Facility Insp.

0.5 0.2 40 0.5 0.5 0.2 0.8

^

SG Trans. Insp./ Plans 0.4 0.01 2

0.4 0.4 0.13 0

Reactor LLW Insp.

0.25 0

0 0.25 0.1 0.03 0

Reactor Decomm. Insp.

0.2 0.03 15 0.2 0.1

'0.07 0.01 Materials Decomm.

0.5 0.8 160 0.5 0.4 1.3 0.5 SDMP 0

0 0

3.5 0.8 0.6 0

NMS Section Supv.

3.5 3.4 97 4.0 4.0 1.3 1.6 ITS Section Supv.

0.1 0.03 30 0.1 0.1 0.03

-0.01 W Section Supv.

0.2

_9d_

_59_. _9.1. _Ql_

_Q.J._

0.07 iOTAL 36.01 31.51 88 41.47 36.42 12.14

  • 2412 1.03' 39.52 13.17 13.28 100.8 Unprogrammed:

1.95

  • Reflects 1.9 FTE allocated for training and 1.2 FTE for recruitment efforts.

NOTE:

FY91 expenditures frar regional input provided in response to FYP/ Green Book update in 11/91.

16 T

P-"

"m--

er

+

s.

..-w

8.

RECOMMENDATIONS / SUGGESTIONS a.

For Recion I:

Complete analysis of FY92 Operating Plan goals and propose recomended changes for formal NMSS review and approval.

(COMPLETED APRIL 6).

Review the adequacy of LLW storage guidance in Information Notice 90-09 and recomend changes to NHSS/LLWD.

Ensure that new staff members are informed of inspection qualification process and requirements.

(COMPLETED BY NMSB CHIEF IN LATE MARCH).

Make full use of budgeted 50HP resources.

Improve timeliness of enforcement packages provided to HMSS for enforcement conferences.

Evaluate whether inspector qualification boards are using consistent criteria to evaluate new inspectors.

b.

For NHSS Include LLWH personnel in the conthly conference calls because of the increasing attention to LLW storage issues.

Increase the level of NHSS participation in significant enforcassat activities.

Develop a technical assistance request index to broaden access to this information across Regions and refer to license control numbers as appropriate.

9 Work with the Region.to develop an SDMP milestone tracking system.

]

17

A Develop improved access for reviewers to sealed source and device review information.

Review and update the Radwaste Management course (H-202) and also improve core inspection procedure 86750 for LLW inspections at nuclear power reactors.

Provide training to regions on SDMP type activities especially issues associated with groundwater contamination.

Continue to participate in OE counterpart meetings, and discuss the level of effort OE expects each region to dedicate to " lessons learned" from Severity Level 4 and 5 enforcement actions.

Conduct a counterpart meeting for license reviewers.

Coordinate 20.302 reviews with NRR and regions.

Share the Region I program for reciprocity inspections with other regions as a model.

i 18

~

ATTACHMENT 1 REVIEW TEAM 1.

John Greeves, Deputy. Director, Division of Industrial and Medical Nuclear Safety, (INNS) 2.

John Glenn, Chief, Medical, Academic, and Commercial Use Safety Branch, INNS 3.

John Cook, Sr. Transportation Specialist, Transportation Branch, Division of Safeguards and Transportation, SGTR 4.

William Floyd, Security Specialist, Division of Safeguards and Transportation, SGTR 5.

James Kennedy, Section Leader, Licensing and Coordination Section, Low-Level Waste Management Branch, Division of Low-Level Waste Management and Decosmissioning, (LLW) 6.

Dave Fauver, Health Physicist, Decommissioning and Regulatory Issues Branch, LLW 7.

Kathleen McDarby, Program Analyst, Program Management, Policy Development and Analysis Staff, MSS

-)

19

e RI:G.

I DIV.

OF RADI ATIO N SAFETY

.AFE (.a.! Ald )

., W. '

DR. MALCOLM H.

- K N APF',

Dire. t cir GlQHARD W.

COOPER, ll, D-p u t y l

DIV. OF RADIATION SAFETY & SAFEGUARDS, I______.._________-..__.

FACILITIE S RAD. SAFETr N UC Lt. AR tvtA Il i<lal

& SAFEGUARDS [9 RANCH sal-l lY BfMAI Eli Jarries H. Joyner, Chief Ror iald R.

Uellan :iy,

i 1it.

_ Fac. Rod. Protection Medit a l Irisi, - li ii Walter Pasciok M o h o rned

' lior itsol y Ef fluents Rod. Pr otect.

R& D Do. c.n.rriir i..ru n.;

Rot >ert Bores J.:l io Kininou.in Linct gency Pr e p.2 redrieve Iru it ial s ic il /1,j.li,. il i.i :

E t,u Minit>o l a.it

.w,-i l i r i,1 3

  • i t i f m.

ii i ri in M i <ti. iil I ii

.-ri

iri )

}

l< ii.! ;. ;; :' Keli r sig

.l.*: s i i i.

.1. + 1 i. it c o i Y

R

.l s,

l i.. ti.n i. : A

.i. l. n.

i..i s e in. i.

.