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i June 12, 1992
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MEMORANDUM FOR: Stewart D. Ebneter Regional Administrator, Region II FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NHSS
SUBJECT:
1992 FINAL NATIONAL PROGRAM REVIEW REPORT FOR REGION II Enclosed is the 1992 National Program Review (NPR) report for Region II. 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.
HMSS circulated a draft version of this report to the region's Division of Radiation Safety and Safeguards. Their comments have been incorporated into this final version of the NPR report, as approp*iate.
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.
ORIGINAL. SIGMED BY John T. Greeves h/
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
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OFFICIAL RECORD COPY l
FINAL NATIONAL 9309150200 930830 f [g. ;_ f PDR STPRG ESGGEN r
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REPORT OF NMSS NATIONAL PROGRAM REVIEW (NPR)
AT NRC REGION II, MARCH 12-13, 1992 1.
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety and Safeguards (NMSS) review of Region II programs under the Headquarters responsibility of HMSS for FY1991 and the first several months of FY1992.
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.
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The Regional activities related to materials programs are primarily under the responsibility of the Region II Division of Radiation Safety and Safeguards (DRSS). A copy of the DRSS organization chart is shown in Attachment 2.
The NPR is based not only on the visit to the Region, but on the collective Regional / Headquarters interfaces throughout the year.
These interfaces include the review of selected licensing casework and inspection reports, the accompaniment of region-based inspectors, the review of casework and inspection statistics and resource utilization, technical assistance and coordination efforts including conference calls, and the information questionnaire from the Region. The NPR process is intended to provide a review of the effectiveness of both the Region and Headquarters activities insofar as they relate to Region II's activities, and to identify suggestions for improving safety and the effectiveness of the collective efforts of HMSS and Region II. The NPR emphasizes both numerical goals for licensing and inspection activities and the technical quality of licensing casework and inspections, on the basis that these elements contribute to assuring the safety and safeguards of operations involving NRC-licensed activities. This report is organized to present an integrated summary of Region II activities in each of the following areas:
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1.
Background and Purpose 2.
Licensing 3.
Inspections i
4.
Training 5.
Initiatives 6.
Interfaces of Region / Headquarters 7.
Resource Utilization 8.
Recommendations and Suggestions 2.
LICENSING 2.1 Materis1's Safety Region II regulates approximately 940 byproduct material licensees.
In FY91, Region 11 completed 634 material licensing actions against an operating plan goal of 600 (106 percent).
The branch chief, section chiefs, and licensing reviewers were aware of licensing goals for FY92. As of February 28, 1992, Region II had completed 266 cases, which compares favorably to the budgeted projection of 246 for that period of time.
Data available through April 30 show 357 completed cases, keeping Region II on schedule to complete or exceed the goal of 590 cases for FY92.
Region II has three approximately full-time license reviewers that handle most of the licensing workload. However, over the last several years inspectors have been cross-trained in licensing reviews to provide backup and replace full-time reviewers.
Region II continues to have a stable core licensing review group that is capable of handling a wide variety of casework in an efficient and highly professional manner.
Unlike most of the other regions, Region II was able to mitigate the effects of the large influx in casework related to the fee rule.
In fact, in the 12-month period between March 1991 and February 1992, 2
the inventory of pending casework dropped to 147 cases, and the backlog also dropped slightly to 19; nearly all of which were renewals.
Region II has coordinated its approach to the Navy Master Material license with NHSS and the other regions.
Region II was the driving force behind the scheduling of a workshop at Rockville to discuss issues regarding licensing and inspection of Master Materials Licensees. Region II has made a special. effort to communicate regulatory requirements to its licensees in Puerto Rico.
is planned for this summer.
A workshop 2.2 Safeauards Region II received eleven 10 CFR 70.32' case reviews in FY91.
Eight cases were completed with the remaining cases transferred to Headquarters.
The case reviews were extensive in nature, dealing with the physical security upgrade construction at the CAT I Fuel Facilities.
In some instances these reviews required site visits and attendance at Headquarters meetings.
These 10 CFR 70.32 case reviews were performed in a sound technical manner.
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3.
INSPECTIONS
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3.1 Materials Safety Insoections In FY91, Region II completed 540 material inspections compared goal of 413 (131 percent). Through February 1992, the Region had completed 181 inspections.
This rate compares favorably with the prorated operating plan target of 172 for this time period.
The Region thus expects to meet its FY92 target for total inspections In addition, team inspections were completed at two universities during 1991.
Region II had very few inspections in the overdue category throughout the year because of the effort they expended planning, assigning, and completing inspections on or before the next inspection due date.
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Region II continues to complete transmittal of inspection document-ation and enforcement actions in a timely manner.
Review of selected documents and observations during an inspector accompaniment indicated no significant problems in the areas of techoical adequacy, accuracy, or quality.
Region II inspection staff demonstrated a good awareness of inspection and enforcement policy and guidance.
Region II continues to support rotational assignments with Headquarters. During the review period, a Region II Section Chief switched jobs with an NMSS Section Leader for about a month, and a materials inspector worked in the Office of Enforcement.
Inspectors expressed a desire to participate in team inspections involving inspectors from more than one region.
Region II has focused on problems experienced by its licensees in Puerto Rico. The Region has been proactive in focusing on waste and storage issues which may develop.
Region II has initiated team inspections for larger broad-scope licensees. The ir.spection at the University of Virginia uas coordinated with NE S and. involved HMSS participation.
The Region has also been very supportive of NMSS' initiative to examine use of the Gamma Knife through a contractor.
3.2 Fuel Facility Safety Insoectioni The Radiation Safety Project Section of the Nuclear Materials Safety and Safeguards Program Branch has the project management responsibility for the fuel cycle inspection program. Other sections within the Division of Radiation Safety and Safoguards conduct specialized inspections at fuel cycle facilities.
Quarterly reports fcr each licensee provide management with the status of the inspection program. This project managerent scheme appears to be functioning quite effectively and is supported by inspectors in other sections within the Division.
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During FY91, the fuel cycle inspection program was completed.
During this period, 56 fuel cycle inspections were conducted. On average, reports were issued in 34 days, a performance standard typical of the national average. To date, for FY92 the program is meeting or exceeding the Operating Plan in most areas.
The overall inspection program remains at an effective level. Management meetings continue to be effective in obtaining improved performance at several fuel cycle licensees. The Region is to be commended for the effectiveness of Performance Improvement Programs, which are substantially improving safety at NFS and GE.- Also, the Headquarters staff believes that the resident inspectors are doing an excellent job.
~As in 1991, the Region II inspectors and managers noted the need to revise regulatory guides and inspection procedures which are out-of-date and compliance-oriented. Headquarters is assigning more resources to such improved guidance.
In 1991, Headquarters recommended that inspection reports should contain more safety information. Headquarters noted improvement over the last year, and this is no longer an issue.
Regional management indicated that they are still making further improvements in their reports.
3.3 Fuel Facility Safeauards Inspections
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Region II completed their scheduled safeguards inspection program in accordance with their Operating Plan. Special emphasis was placed in the inspections of all Tactical Response Team (TRT) exercises conducted by both Category I facilities. Also, Region II inspectors participated in the NRC observed TRT exercises. Valuable data has been provided to Headquarters on the TRT program because of these regional inspections.
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Region II has been very responsive in attending the quarterly interface meetings with Headquarters staff and Category I licensees.
Their participation helped make these meetings a success.
3.4 Transoortation Safety Insoections The Region inspects licensee transportation safety programs as part of its materials, reactor and fuel facility inspection programs.
There are over 900 facilities and materials licensees in Region II.
In FY91, Region II conducted a total of 317 transportation safety inspections, using Inspection Procedures 86740, 86740B and 86750.
Twenty-seven violations (all Severity Level IV and V) were identified during these inspections. A review of selected inspection reports indicates that violations were properly cited against NRC and Department of Transportation regulations.
3.5 Transoortation Safeauards Insoections Region II conducted the required transportation safeguards inspections in accordance with their FY91 Operating Plan. As happened in other regions, a number of shipments either were cancelled or never materialized which lowered the total number of inspections that were possible.
Region II exceeded their FTE allocation for Route Surveys by conducting four route surveys at the request of Headquarters.
In addition, a special inspection of a transportation carrier was requested by Headquarters because of a training problem associated with Appendix D of 10CFR Part 73.
The special inspection was conducted in a very timely manner with a detailed report which enabled Headquarters to resolve the training issue.
3.6 Decommissionina The Headquarters staff reviewed decommissioning activities in Region II for which fiMSS has lead programmatic responsibilities.
In the 6
~ area of financial assurance, the staff's review was keyed to c
tracking and managernt of financial assurance submittals, the backlog of financial.s.urance submittals, timeliness goals, Headquarters guidance, policy issues, and resource utilization.
In Region II, financial assurance matters are assigned to a staff member and managed by a Section Chief.
The Section Chief maintains a manual tracking system that includes all sites that require financial assurance instruments. Oversight of financial assurance issues as implemented in the Region is working.
In Region II, there are approximately 50 sites that require financial assurance instruments. As of March.1992, only one site requiring financial assurance instruments had been brought to closure.
The Region is aware of, and follows Headquarters guidance related to transmitting non-routine submittals to Headquarters for resolution.
Region II
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stated that the timing, resolution, and response from Headquarters on non-routine financial assurance submittals has been very good.
There is a need for the regional staff to be aware of expiration dates of financial instruments further in advance. There is a feature of the Licensing Tracking System (LTS) designed for this purpose. Region II should maks use of the automated tracking provisions of the LTS, especially the feature used to track financial instruments' expiration dates, so that the Regional staff can remain cognizant of the status of all financial assurance submittals. DuQngtheNPRinRegionIIonMarch 12, 1992, the Region did not have any data related to financial instruments entered into the LTS. As of May 8, 1992, the Region had completed entry of all Decommissioning Funding data into the LTS.
The Region II staff has established goals for approving all financial assurance submittals. The Region has an objective to bring to closure all but several (there are approximately six submittals currently under Headquarters review) of the problems by 1 ate summer of 1992.
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J Region II staff is uncomfortable with their level of in-depth understanding of financial instruments.
Headquarters staff suggested additional training, and emphasized that Headquarters would support the region's request for training.
To insure that Headquarters meets the Region's needs, Headquarters staff suggested that the Region, based on their financial assurance experience to-date, define the specific areas where training would yield the greatest benefits.
In addition, specific cases can be referred to Headquarters for technical assistance from Headquarters staff or a contractor.
Region II staff is aware of all existing guidance related to financial assurance, and do not feel that there is at present a need for additional guidance. The Regional staff suggested that a consolidation by the Headquarters staff of documents such as guidance, existing financial assurance tracking methods, and policy-related documents would go a long way toward enhancing both regional and Headquarters effective management of financial assurance, and other decomissioning requirements.
There are 0.2 FTE budgeted in FY92 for materials facilities decommissioning in Region II. Region II uses the RITS system to capture time charged against materials facilities decommissioning efforts. The RITS track at a level of detail that does not lend itself to defining the time spent on financial assurance issues.
Following the review, Region II established a special TAC number in RITS to track financial expenditures more closely. NMSS is now considering what steps to take to solve this issue on a nationwide basis.
Region II is aware of the listing criteria in SECY-91-096 used to evaluate problem contaminated sites that require non-routine cleanup. The Region has developed a list of potentially-8
contaminated sites.
Region II feels that one site, Nuclear Fuel Services, Inc., should be included in the Site Decommissioning Management Plan (SDMP).
In the near future, Region II anticipates meeting with the Director, LLW to discuss other sites on their potentially-contaminated list for inclusion in SDMP, and the necessary resources needed to support this effort.
In 1991, 97 license terminations were processed. Of these, two involved a site with a-decommissioning plan (A.H. Robbins and ITT).
During 1991, there were no technical policy decommissioning issues identified and forwarded to Headquarters for resolution. At present, there is not a need for guidance from Headquarters for the performance of routine license termination.
The Licensing Tracking System is used by the Region to track routine license terminations.
3.7 Low-Level Waste (LLW)
Because of the limited resources devoted to LLW, the positive interactions between Headquarters staff and Region II staff during the year, and the results of the 1991 review, Low-Level Waste Management Branch aff elected not to participate in the visit to the Region II offices this year. No issues have been identified in the routine interactions with the Region during the year.
4.
IB&INING Regional training is being or has been completed in accordance with the Inspection Manual Chapter 1245 and Headquarters guidance. The staff reported that regional management is very supportive of training. The Region continues to support rotational assignments between Headquarters and the Region.
The Region requested more fire protection training from 9
Headquarters, and this was completed in May. Headquarters has also initiated a broad effort to improve criticality training, and the Region will participate fully in this training.
In FY91, I4 Region II inspectors conducted transportation safety inspections. Of these, all have taken NRC's Transportation of Radioactive Material course (H-308).
Eleven other Region II inspectors have taken the H-308 course, for a total of 25 H-308 trained inspectors in Region II.
In addition, Region II has schedul'd three inspectors for H-308 in FY92.
e 5.
REGIONAL INITIATIVES The Region is to be commended for numerous initiatives over the past year, including the following:
Responding to the GE-Wilmington incident, including participation on the Incident Investigation Team.
Performance improvement programs at NFS and GE.
Hosting the Fuel Cycle Seminar.
Responding to the Surry transportation incident in Virginia.
Assisting Headquarters with the Division Path Analysis Study at NFS.
Proposing improved resident inspection procedures.
Improving the Incident Response Center and associated documents.
6.
HEAD 00ARTERS/ REGION II INTERACTIONS The Regional and Headquarters staffs agreed that communications were good, but could be improved.
Examples of good communications are the response to the GE event, coordination on the NFS renewal, and development of the resident inspection procedures.
The Region suggested that Headquarters renew periodic fuel cycle conference calls, and coordinate more closely emergency preparedness 10
issues and requests for comments on license amendments.
They also suggested that Headquarters may want to use inspectors to assist on the NHSS Regulatory Impact Survey, if the staff is directed to undertake this effort.
Region II coordinated with Headquarters on numerous other events, including the response to the Surry transportation incident in Virginia, GE fuel incident in Massachusetts, and the Browns Ferry waste shipment transportation accidents.
The Region coordinated with Headquarters during-each of the accidents, providing frequent status updates. Other communication with Region II on transportation matters has also been good.
7.
RESOURCE UTILIZATION The attached table shows FTE allocations and expenditures for the review period.
Region II has no program support funds in the NMSS mission areas.-s.
During FY91, Region. II expended approximately 106 percent of the amount budgeted for the NMSS programs.
Resource expenditures through February-align closely with projected expenditures for that time periode In FY91, Region II completed 634 materials licensing actions against a budgeted goal..of 600.and.540 materials inspections against a budgeted. goal.of 413. _They exceeded the goals by approximately six percent and 30 percent respectively. Through February, Region II conducted 181 materials inspections versus a projected goal of 172. They are completing the core program for both. licensing ande. inspection.
Resources have been reprogrammed in FY91 and FY92 to complete the materials licensing casework, oversee the Navy military broad license, review decommissioning casework, respond to fuel facility event 11
establish a resident inspector at Nuclear Fuel Services, Inc., (NFS), and decommissioning activities at NFS.
Although reprogramming has taken place, the Region has completed all the core budgeted casework for these areas.
REGION II RESOURCE UTILIZATION The following table shows FTE allocations and expenditures for the review period.
FY91 FY92 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT-FEB. OCT-FEB.
Fuel Facility Licensing 0 0
0 0
0 0
Event Evaluation 1.2 1.8 150 1.6 0.66 1.1 Materials Licensing 3.1 4.3 139 3.0 1.25 1.2 Materials Inspection 6.7 5.4 81 7.1 2.96 2.3 Fuel Facility Insp.
5.4 6.3 117 5.4 2.25 3.7 SG Fuel Facility Lic.
0.2 0.2 100 0.2 0.08 0.07 SG Fuel Facility Insp.
1.6 1.5 94 1.6 0.66 0.5 5G Transportation Insp. 0.8 0.2 25 0.7 0.29 0
& Plans Reactor LLW Insp.
0.4 0.2 50 0.4 0.17 0.07 Materials Decomm.
0.2 1.0 500 0.2 0.08 0.23 NMS Section Supv.
2.0 2.2 110 2.1 0.88 NA NMTS Section Supv.
0.3 0.2 67 0.3 0.13 NA W Section Supv.
0.1 Q21 100 Q1 Q291 0 0 "AL 22.0 23.4 106 22.7 9.45 9.17 97 NOTE: FY91 expenditures from regional input provided in response to FYP/ Green Book update in 11/91.
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RECOMMENDATIONS / SUGGESTIONS a.
For NMSS:
1.
Continue to issue guidance and revised inspection procedures, particularly in the fuel cycle and decommissioning areas.
2.
Define the Integrated Safety Analysis that we will expect from fuel cycle licensees, and communicate this information to licensees and the Regions.
3.
Consider re-establishing periodic fuel cycle conference calls among Headquarters and the Regions.
4.
Coordinate more closely with the. Region on emergency planning issues.
5.
Provide criticality training to the Regions.
6.
On requests for comments on major fuel cycle license amendments, provide specific information as to when-comments from the Region are due.
7.
Consider use of inspectors on the Regulatory Impact Survey, if one.
is undertaken.
b.
For Reaion II:
1.
Complete fuel cycle fire protection inspections, with Headquarters assistance.
- 2. Be sure that the Decommissioning Funding Plan data in the Licensing Tracking System are kept up-to-date.
(AS OF MAY 8, 1992, REGION 11 COMPLETED THE ENTRY OF ALL DEC0m ISSIONING FGW ING PLAN DATA INTO THE LTS. THE REGION PLANS TO CONTINUE UPDATES AS DATA BECOME AVAILABLE).
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o REGION II REVIEW TEAM John. Hickey, Fuel Cycle Safety Branch Chief, IMNS, NMSS*
William Axelson, Deputy Director, Division of Radiation Safety and Safeguards, RIII John Cook, Sr. Transportation Specialist, Division of Safeguards and Transportation, NMSS William Floyd, Security Specialist, Division of Safeguards and Transportation, NMSS Lawrence Bell, Project Manager, Division of Low-level Waste Management and Decommissioning, NMSS
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