ML20057A719
| ML20057A719 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/1992 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309150205 | |
| Download: ML20057A719 (31) | |
Text
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c APR 2 71992 MEMORANDUM FOR: Charles E. Norelius Director Division of Radiation Safety and Safeguards, RIII FR0H:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
DRAFT NATIONAL PROGRAM REVIEW REPORT REGION III I have enclosed the National Program Review (NPR) report for Region III. This report covers the period between our last two NPR team visits (roughly April 1991 through March 1992).
As always, we appreciate the efforts of your regional staff throughout the year and we welcome any additional thoughts you have that might lead to further improvements in our review process. Should you have any comments on the draft report, please provide them to me by May 8, 1992.
rl C,
sr Ric ard E. Cu ningham, D re or Ulvision of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
Draft NPR Report DISTRIBUTION:
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REPORT OF NMSS NATIONAL PROGRAM REVIEW (NPR)
AT NRC REGION III, FEBRUARY 27-28, 1992 1.
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety and Safeguards (NMSS) review of materials programs that were under the responsibility of NRC Region III 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 III Division of Radiation Safety and Safeguards (DRSS). A copy of the DRSS organizational chart is shown in Attachment 2.
The Region III responses to an information questionnaire are shown in.
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 include the review of selected licensing casework and inspection reports, the accompaniments of region-based inspectors, the review of casew g g g~
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 i
relate to Region III's activities, and to identify suggestions for improving the effectiveness of the collective efforts of NMSS, OE, and Region III. The NPR emphasizes both numerical goals for licensing and inspection activities and quality of licensfng, inspection, and enforcement efforts, en the Ucsis that all of these elemend contribute to assuring the safety and safeguards of operations involving NRC licensed activities.
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The report is organized so as to present an integrated summary of Region III 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.
Enforcement 9.
Recommendations / Suggestions c
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LICENSING a.
Materials Safety In FY91, the Region completed 73 percent and 115 percent of its budgeted licensing actions for new licenses and license amendments respectively, and 82 percent of its budgeted license renewals.
In total, the Region completed 104 percent of its budgeted casework. This equates to 2,093 completed actions.
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Completions approximately equalled receipts in all categories of licensing actions during the year.
t During the first five months of FY92, Region III managed to complete 868 cases, or 45% of the actions for which it is budgeted throughout the entire year. Region III's continued success in controlling the backlog (37 cases in March) has resulted in an outstanding record of timeliness for all types of licensing actions, including renewals.
l A select number of Region III licensing cases were reviewed against NRC regulations and Standard Review Plans.
The cases were complete, no significant 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 regions. This review was conducted as part of an ongoing Headquarters review of broad-scopes. Only minor variations were noted among the regions.
Region III undertook or strengthened its support of initiatives to improve the licensing process, particularly for licenses of broad-scope. These initiatives included increased supervisory involvement in case assignment, site visits and reviewer performance and oversight.
Region III established a Broad Scope License Review Board comprised of senior reviewers and inspectors to assure old problems are addressed and that new requirements are both inspectable and enforceable. The enhanced procedure for Broad Scope renewals includes early contact before the licensee begins preparation of the application, a pre-licensing meeting, and a site visit after the application is received.
In response to a Region V initiative to upgrade the NRC's overall regulation of broad scope programs, Region III personnel drafted an updated 3
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l Standard Review Plan (SRP) for broad scope licensees. The revised SRP stresses management authorities and responsibilities and clarifies the roles of the Radiation Safety Committee and Radiation Safety Officer.
Region III management suggested that NMSS look at the possibility of breaking out broad scope licensing and inspection programs in the budget to reflect the proper emphasis that should be given these programs in relation to simpler and smaller programs.
The licensing program is well supported by an experienced and highly-qualified staff. The staff has been able to handle unbudgeted and unplanned workloads resulting from the changes in the way NRC assesses fees as well as implementation of the financial and emergency planning rules.
During the past year, Region III rotated a Branch Chief and several Senior Health Physicists to NMSS. Both Offices felt the rotations had been useful and helped to improve communications and understanding of the overall materials program.
The Branch Chief rotation was particularly useful in helping the NMSS' staff draft its Action Plan for resolving the recommendations of the Materials Regulatory Review Task Force (NUREG-1324).
t b.
Site Decommissioning Management Plan (SDMP) and General Decommissioning A new section, Fuel Facilities and Contaminated Sites, was created in the Nuclear Materials Safety Branch. The new section is responsible for fuel facilities, the Site Decommissioning Management Program (SDMP), and other contaminated sites not listed in the SDMP. The section is staffed with experienced personnel and has helped focus regional management attention and resources on the effort to remediate and release the SDMP sites in a timely manner. A special training module has been developed for staff working on contaminated sites, of which SDMP sites may be considered a high profile subset. The training requirements for a " Contaminated Site Specialist Inspector" includes groundwater modeling and environmental regulations.
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Subjects such as teletherapy and brachytherapy have been eliminated as basic certification requirements for contaminated site specialists.
t A detailed project plan has been developed for the cleanup of each Region III SDMP site which allows for more systematic tracking of milestones and projection of future resource needs. The project plans include scheduled site inspections. The emphasis of the inspections is on material control and compliance with license conditions or other licensee commitments. Material control has proven to be a problem during previous extended decommissioning actions and the focus on this area is a commendable strategy.
The new Fuel Facilities and Contaminated Sites Section is also responsible for decommissioning projects that are not on the SDMP but require some sort of extended cleanup involving the submission of a decontamination plan, detailed site characterization, etc.
Region III recognized that these extended decommissioning actions require the same expertise as SDMP site cleanup. The new organization assures that the expertise gained and lessons learned during the SDMP site cleanups will be applied to future, non-SDMP, decommissioning actions and that contaminated sites meeting the criteria for inclusion in the 1
SDMP will be identified in a timely manner.
Communications between Region III and NMSS on decommissioning issues, for SDMP sites in particular, has been very good. Monthly teleconferences are scheduled to update Headquarters on progress at SDMP sites. The region agreed to further improve communications on SDMP issues by putting Headquarters on copy for all significant correspondence related to SDMP sites.
To improve regional i
awareness of evolving generic issues in decommissioning, Headquarters will put j
all regions on copy for policy guidance provided to anyone of the five regions. Region III made two recommendations to Headquarters in the area of decommissioning:
- 1) develop a formal inspection procedure for contaminated sites, and 2) lieadquarters project managers for SDMP sites should accompany regional inspectors at least annually.
Headquarters recommended that contaminated site specialists be trained in pathway analysis / dose assessment.
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1 c.
Financial Assurance (FA)
Following the July 27, 1990 deadline for the submittal of a decommissioning funding plan or certification of financial assurance, Region III has received 161 FA submittals. As of March 12, 1992, licensing action has been completed for 134 FA submittals. This represents significant progress towards full compliance with the decommissioning rule.
i FA submittals are tracked in the LTS system as license amendments. Any FA submittal pending over 90 days is flagged on the region's Management Information Status Report. The region's goal for the number of amendments pending greater than 90 days, including FA submittals, is 47.
FA submittals under review by Headquarters are excepted from timeliness statistics but continue to be tracked under another category.
There are currently no FA submittals which have been pending over 90 days.
Regional staff has an acceptable understanding of financial assurance issues.
However, licensing staff remains somewhat uncomfortable with the review of financial assurance submittals due to lack of expertise in this area. Of particular concern is the need for license reviewers to paraphrase recommendations made in Headquarters' responses to the region's requests for guidance on non-routine FA submittals when the reviewers do not totally understand the recommendations.
9 To reduce the level of discomfort with the process in place to review FA submittals, Headquarters will set up a program to provide periodic forums, such as conference calls anc workshops, to discuss financial assurance licensing issues. Also, Regional licensing staff should increase communication with Headquarters to clarify any comments on non-routine submittals that are not fully understood. This will enable license reviewers to be in better position to respond to licensees' questions. Finally, Headquarters will review FA training, procedures, and guidance, and the system for handling non-routine submittals to identify areas where the process can be streamlined and improved.
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3.
INSPECTIONS a.
Materials Safety Inspections In FY91, 1,045 materials safety inspections were completed. The budgeted goal for FY91 was 1,056 inspections.
Thus far, through February 29, 1992, 335-inspections have been completed. The budget target for this time period is 440 inspections. Due to the loss of four experienced staff members from the inspection program, RIII is concerned about its ability to meet its FY92 inspection goal.
It is experiencing significant improvement in productivity as new staff and interns become qualified and it will evaluate its program and propose any changes it feels are necessary within the next month or so.
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Planning and scheduling of inspection activities is well-coordinated as evidenced by the steady decline of overdue inspections since February 1991.
Region III inspectors made several comments regarding possible improvements to the inspection program. Although the recent trial program for field-cited violations for radiographers was perceived to have been only minimally successful due to the cumbersome process, inspectors felt that efficiencies t
could be achieved by delegating more responsibility to inspectors to issue findings either in the field or from the office.
Region III has established excellent planning and tracking procedures for managing the inspection program. Deviations from the operating plan are noted and approved on the basis of safety priorities.
Regional management is directly involved with selected inspections and normally attends exit meetings for significant inspections.
Inspections at major licensee facilities now utilize two or three inspectors and a cognizant license reviewer.
Region III has formalized its systems for tracking the status of expired licenses to assure prompt identification and resolution of safety problems.
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b.
Fuel Cycle Safety Inspections l
During FY91, three inspections were performed at Allied-Signal and seven inspections at C.E. Hematite. NMSS staff participated in some of the inspections, and there continues to be'a cooperative relationship between Headquarters and the Region. The completed inspections met the requirements of Manual Chapter 2600.
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During the 1991 program review, Headquarters made suggestions to the Regions i
regarding the need for improvement of inspection reports. This was followed by distributing written examples illustrating strong points ana weak points.
Headquarters has observed improvements in Region III inspection reports, and i
has no further concerns. The fuel cycle inspection reports were prepared, on average, in 34 days--an improvement compared to last year's 39 days.
In late 1989, Region III made organizational changes which brought more resources to the fuel cycle program.
There are now clearly observed benefits from that initiative.
Region III aggressively pursued problems at Allied-Signal associated with cylinders which did not meet specifications, and worked closely with Headquarters regarding concerns with the proposed I
1 expansion of the C-E Hematite plant.
i c.
Transportation Safeguards Inspections i
Region III conducted three transportation safeguards inspections in FY91 using inspection module 81310. During these inspections, one significant generic issue was identified related to Appendix D to Part 73 and was referred to Headquarters for resolution. The reviewer observed that the inspection i
reports were very detailed and technically sound.
It should be noted that the FY91 program scheduled only one spent fuel inspection and that Region III exceeded that level of effort by conducting two additional inspections.
In addition, two route surveys were conducted by Region III at the request of t
Headquarters. These surveys were requested on short notice with the region i
responding in a very timely manner with a thorough and detailed report.
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1 d.
Transportation Safety Inspections The region inspects licensee transportation safety programs as part its materials, reactor and fuel facility inspection programs. There are approximately 2,600 facilities and material licensees in Region III.
In FY91, Region III conducted a total of 375 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 indicated that violations were properly cited against NRC and Department of Transportation regulations.
e.
Low-Level Waste (LLW) Inspections Low-Level waste reactor inspections are performed in the Radiological Controls Section and Radiological Controls and Chemistry Section. The Region dedicates approximately 0.6 FTE for the direct inspection of solid waste functions at reactor facilities.
During the last National Program Review, Region III was in the process of converting to a core inspection module for LLW inspections.
Reactor LLW inspections in Region III now include the core inspection module IP 86750.
During the last SALP cycle, this module was scheduled for use on all operating nuclear power plants in the Region.
In a new initiative, the Region has instituted additional LLW inspections above the core inspection program.
Within the next year, this will result in the inspection of one-solid waste inspection module, IP 84850. The remaining two-thirds will be inspected using this module over the next two years.
Prior to the National Program Review, the Region requested assistance from NMSS' Division of Low-Level Waste Management and Decommissioning (LLWM) on how to use this module to inspect for the proper use of solidification agents not certified under the Headquarters topical report certification program. Through LLWM and Regional coordination, a training session on inspection of waste form requirements was held for regional inspectors. The region is commended for initiating this activity.
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The reviewer examined the Region's coverage of waste storage at operating reactors in an effort to assess the impact of the loss of disposal capacity by Michigan utilities.
Following this examination, a repart was prepared which described the storage situation at 19 regional utilities.
This report indicates that no storage problems needing immediate attention have yet been identified at these utilities. The Region plans to assess this situation and to note any changes.
The inspection function for fuel facilities is now located in the Fuel Facilities and Contaminated Sites Section of the Division of Nuclear Materials Safety and Safeguards. Only two operating facilities generate low-level waste in this Region. Senior inspection staff members indicated that the region is continuing to work with these licensees to effect the cleanup and removal of large quantities of soil and deteriorated, empty containers at these facilities. Fuel facilities inspectors in the Region are very knowledgeable about low-level waste issues.
Thirty percent of-the material facilities in the Region generate low-level waste which is shipped for disposal. Most of this waste is collected by a waste broker licensed by the State of Illinois.
The checklist used for material inspections contains specific information and procedures on the inspection of low-level waste. The thirty percent of materials licensees in the Region who are LLW generators use vendor services for processing waste for disposal. Much of this processing involved compaction services for volume reduction for preparation and shipment for disposal.
Inspection reports in this crea appear to be more than adequate in their coverage of waste issues and seldom if at all does this waste exceed Class A.
4.
TRAINING a.
Materials Region III has shown strong commitment to the recruitment of a highly educated multidisiplinary staff. Management has in place the mechanism to track and 10
schedule appropriate training. Region III has strongly supported the intern program both through recruitment of outstanding candidates and planning of meaningful work experiences.
It has also established a strong recruiting bond with some of the major universities in the region, especially Purdue.
b.
Fuel Cycle The Region has implemented a program to broaden experiences and training.for its fuel facility inspectors. Specialists from various disciplines (maintenance, mechanical engineering, emergency planning, etc.) are being involved in the annual inspection program at fuel facilities. The Region is j
interested in more criticality training, which is being developed by NMSS and theTechnicalTrainingCenter(TTC).
c.
Safeguards and Transportation In FY91, 28 Region III inspectors conducted transportation safety inspections. Of these, 26 have taken NRC's Transportation of Radioactive Material course (H-308). Region III supports training and has an active program to provide training for those who need it.
d.
Low-Level Waste Training The team was made aware of three inspectors in the Reactor Programs Branch who need low-level waste training within the next year as part of their training and assimulation program.
The Region recommended that 11RC Headquarters investigate enhancement of the Radwaste Management course (currently taught at the TTC by Weston Associates) to include information on up-to-date regulatory policy and issues such as the status of topical report material certifications and new guidance on storage.
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5.
INITIATIVES BY THE REGION The following Region III initiatives were underway throughout the year.
The Region initiated pre-licensing contacts, management meetings, and site visits as part of the renewal process for licenses of Broad Scope.
Regional staff wrote a new draft Standard Review Plan for Broad Scope Licenses.
The Region has initiated in-depth team inspections of licenses of Broad Scope.
The Region continued to support rotations with NMSS.
The Region reorganized its staff functions to create a new section able to concentrate on fuel facilities and contaminated sites.
The Region has initiated additional LLWM inspections above the core program.
i 6.
NMSS/ REGION III INTERACTIONS Interactions between NMSS 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.
Management briefings by NMSS af ter accompaniments would be helpful.
There have been several beneficial rotations between Region III and NMSS in the past year.
For example Jack Grobe served as Acting Chief for the l
Operations Branch for about a month last winter.
Robert Gattone participated in a review of the policy and guidance available for mobile imaging vans, and c
Colleen Casey helped prepare guidance about remote af terloading brachytherapy.
James Cameron completed a rotation with the Office of Enforcement.
In addition, Roy Caniano worked in the Office of the Executive Director for Operations.
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NMSS noted that ' Region III is extremely diligent in keeping NMSS informed of incidents and significant inspection findings.
i Region III appreciated the support from various Headquarters' offices in providing participants for the medical workshops held in the summer.
7.
RESOURCE UTILIZATION i
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 FY91, Region III expended approximately 102 percent of the amount budgeted for the NMSS program.
In the Nuclear Materials Safety Branch (NMSB),
two sections were added. The Nuclear Materials Support Section was created'to centralize the administrative support for the materials program and improve the oversight of both the administrative staff as well as the Nuclear Materials i
Licensing Section where the majority of the administrative staff was previously assigned.
The Fuel Facilities and Contaminated Sites Section was created with three additional Contaminated Sites Specialists to significantly expand their oversight of site remediation and strengthen the oversight of fuel facilities.
i Region III was responsive to a Headquarters' request to establish two intern positions. Their interr. positions have been fully staffed with new hires in the two Nuclear Materials Inspection Sections. An NRR intern has been assigned in the Fuel Facilities and Contaminated Sites Section.
The Region has undertaken an extensive broad scope rencwal initiative aimed at increasing the quality and safety of these complex licensing issues.
In order to perform this initiative, they are expending more resources than budgeted to work with the licensee to develop a comprehensive broad scope license which matches the actual program, staffing needs and safety hazard. As the Region i
reviewed the proposed labor rates for the FY 1994 Budget, they provided information to Headquarters concerning this effort.
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'In FY91, Region III completed 2,093 materials licensing actions against a budgeted goal of 2,020 and 1,045 materials inspections against a budgeted goal of 1,056. Resource expenditures through February were underexpended, primarily in the materials inspections effort. Through February, Region III conducted 335 materials inspections versus a projected goal of 440. Although the Region is running approximately 20 percent behind in materials inspections. As stated in Section 3.A of this report, this is largely due to the loss of four experienced inspectors and the region is considering the need to revise its inspection goal. Nonetheless, they are conducting the core inspections and have very few backlogged cases.
Region III is providing assistance to Headquarters in the threat assessment area. Currently, there are no resources in the budget for this effort.
DRSS exchange and interaction with the DRMA staff is outstanding.
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REGION III RESOURCE UTILIZATION The following table shows FTE allocations and expenditures for the review period FY92 FY91 ANNUAL BUDGET EXPENDEO PROGRAM ACTIVITY BODGET EXPENDE0 BUDGET OCT-FEB.
OCT-FEB.
Fuel Facility Licensing 0.05 0.3 600 0.02 0.01 0.02 Fuel Facility Insp.
1.9 1.1 58 1.8 0.75 0.5 Materials Licensing 8.3 8.5 102 8.0 3.33 3.7 Materials Inspection 15.2 14.8 97 17.6 7.33 4.6 Event Evaluation 3.0 3.3 110 3.3 1.4 1.1 NMS Section Super.
3.5 3.3 94 3.9 1.6 0.1 NMS Subtotal 31 75 3T I T
T4 62 14.42 10 62 SG Fuel Facility Lic.
0.02 0.04 200 0.02 0.01 0.01 SG Fuel Facility Insp.
0.2 0.04 20 0.2 0.08 0
SG Transp. Insp. & Plans 0.2 0.04 20 0.44 0.18 0.02 NMTS Section Super.
0.1 0.04 50 0.1 0.04 0.1 SG Subtotal 0.52 0.16 31 0 76 0.31 0.13 Reactor LLW Insp.
0.25 0.1 40 0.25 0.1 0.03 Reactor Decomm. Insp.
0.3 0
0 0.3 0.13 0
Materials Decomm.
0.5 1.6 320 0.5 0.21 1.0 S0MP 0
0.8 800 1.6 0.67 0.2 LLW Section Super.
0.1 0.3 300 0.3 0.12 0.1 LLW Subtotal 0.95 2.8 755 2.95 1.23 1.33 NMSS Total 33.62 34.26 102 38.33 15.96 11.48 72 NOTE:
FY91 expenditures from regional input provided in response to FYP/ Green Book update in 11/91.
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8.
ENFORCEMENT The Office of Enforcement (0E) explored three issues during the review.
First, OE has completed two audits of enforcement actions issued by the Regions at Severity Level IV and V in the materials area. These audits cover the time period July 1991 through December 1991 and involved a detailed review of apprcximately 50% of the actions issued during that period.
The audits found no serious problems but did identliy areas where increased attention to boilerplate format and better feedback to inspectors who prepare the actions could improve the quality of the product.
OE wanted to determine whether the audits had been used by the regions as a tool for strengthening their own review of nonescalated enforcement actions and if so, how.
Second, OE wanted to determine whether standard boilerplate paragraphs and standard citations were readily available to inspectors in electronic form and how they were being utilized in the preparation of nonescalated enforcement actions.
Third, OE wanted to determine the status of the use of a trial format, known as " Form 592" for the issuance of a Notice of Violation (NOV) at Severity Levels IV and V to radiography licensees by inspectors in the field at the time of the inspection.
8.1 Audits At the time of this program review, the first audit of Severity Level IV and V enforcement actions had been extensively reviewed by the staff of the Region III Enforcement Coordinator.
Each NOV was retrieved and compared to the comments in the audit to determine whether there was a pattern or commonality associated with a particular inspection area or inspector. None was found.
The audit was then routed to DRSS and had reached the Chief of the Nuclear Material Safety Branch. Neither of the two audits had yet reached the Section Chiefs of the Nuclear Materials Inspection Sections.
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As part of this program review, the audits were discussed with the Section Chiefs, who believed that the audits would be helpful in identifying areas that required closer attention on their parts and/or additional training for inspectors. At the exit interview, the Branch Chief indicated that he had planned training for the inspectors as a result of the audit findings, i
The Enforcement Coordinator's staff conducted an audit of Severity Level IV and V enforcement actions in mid-year 1991 and intends to contir.ue periodic auditing; however, there appears to be no established plan or format for conducting such audits.
8.2 Standard Boilerplate/ Standard Citations Standard citations are available to inspectors via computer discs prepared by.
Region III.
In order to assure uniformity, the discs were prepared in such a manner that the information on them cannot be altered. One Section Chief expressed concern that the discs contain some errors, such as punctuation errors, that cannot be corrected because of the manner in which the discs were prepared. Computers will be connected via local area network (LAN) within the coming months.
Inspectors expressed concern thut verbatim use of the standard citations was being required, even when such use did not exactly fit the circumstances.
Also, because there are difficulties transferring information from Wordperfect to IBM 5520, Secretaries frequently retype a document from scratch, even after the inspector has prepared it electronically. Finally, the emphasis on obtaining computers for the Licensing Section has left the two Inspection Sections short on machines.
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" Form 592" Trial Inspectors found the process of issuing NOV's in the field on the trial " Form 592" to be difficult and unworkable and have discontinued the trial. The.
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number of pages that had to be carried on inspections and the lack of 1
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reproduction facilities at some licensees' facilities were cited as the major problems.
In order to avoid such problems in the future, inspectors strongly believe that inspector input should be obtained at the outset of any such trials.
8.4 Additional Enforcement Concerns Raised by Region III Some license reviewers are allowed to sign out their own licensing actions without review and concurrence from their supervisors. There would be a resource savings if qualified inspectors were similarly allowed to sign out NOV's at Severity Level IV and V without supervisory review.
Headquarters is not fully aware of the impact on resources when violations-such as radiographer's f ailure to survey are recategorized at a higher Severity Level.
If such violations were not recategorized, the more egregious cases could always be assigned a higher Severity Level as appropriate. At the minimum, it may be appropriate to have the enforcement conferences for such violations conducted at the Branch Chief level, i
9.
RECOMMENDATIONS / SUGGESTIONS For Region III:
a.
Continue efforts to identify training needs and schedules as far in l
advance as possible.
b.
Keep NMSS/LLWD informed on SDMP 1ssues.
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c.
Consider cross-regional training assignments for team inspections of broad-scope licensees.
d.
Assure that at least one of the contaminated site specialists receives training in pathway analysis / dose assessment, e.
Determine the need to request FY92 Operating Plan revision for materials inspection goal.
f.
Establish a frequency schedule and audit plan for Severity Level IV j
and V enforcement actions.
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E g.
Make available the audits of non-escalated enforcement actions to the Inspection Section Chiefs so that findings may be used to improve the quality of future enforcement actions.
h.
Make standard paragraphs and citations available to inspectors via the LAN as soon as that system is installed.
If the information is write-protected, there should be a simplified process to effect designated changes such as text corrections (OE and RIII).
4 For NMSS:
Strive to do better still in developing guidance and training for a.
inspectors and reviewers as part of rulemakings.
b.
Reconsider the budget allocations for' broad-scope programs in oraer-to emphasize the different requirements for these programs.
c.
Support efforts to establish or develop new courses such as the Fundamentals of Inspection Refresher Training course, Fuel Cycle Technology, and Criticality Safety.
2 d.
Consider using informal inspector-generated violations which require licensee response or delegating signature-authority for minor violations (NMSS/0E).
Re-examine the enforcement policy severity level categorizations e.
j (NMSS/0E).
t f.
Change LMS data files for the Quality Management Program tracking to allow later determination of receipt and approval dates, g.
Use program codes rather than docket numbers for tracking manpower utilization.
h.
Send proposed draft documents and " boiler-plates" to the regions via electronic medium.
i.
Re-examine licensing labor rates for renewals.
Region III recommends a rate of.009 per renewal.
J.
Work with contactor to prepare questions on financial assurance in better form and review FA training, procedures, and guidance to identify ways to streamline the process.
k.
Clarify policy.regarding states taking title to waste..
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Provide guidance to permit modification of standard citations as-necessary to fit the circumstances of each case.
b.
Consider allowing individuals at the Branch Chief level to conduct enforcement conferences on appropriate delegated enforcement cases or allow regions to decide the appropriate level of NRC representation.
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ATTACHMENT 1 REVIEW TEAM 1.
John E. Glenn, Chief, Medical, Academic and Commercial Use Safety Branch, Division of Industrial and Medical Nuclear Safety, NMSS
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2.
Edward L. Halman, Acting Chief, Program Management, Policy Development and Analysis Staff, NMSS 3.
Douglas M. Collins, Chief, Nuclear Materials Safety and Safeguards Branch, Region II a
4.
Leroy S. Person, Project Manager, Division of Low-Level Waste Management and Decommissioning, NMSS 5.
David N. Fauver, Project Manager, Division of Low-Level Waste Management 5
and Decommissioning, NMSS 6.
Joseph R. Delmedico, Senior Enforcement Specialist, Office of Enforcement 2
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January 23, 1992:1s DIVISION OF RADIATION SAFETY AMD SAFEGUARDS Director C. E. Morellus -
Deputy Directory W. L. Axelson Secretary M. Meenan Co-op W. H. Radcliffe 4
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Reactor Programs Nuclear Materials Nuclear Material Safety Branch Support Section Branch bJ.Pearson,Cblef L. R. Greger Chief J. A. Grobe Chief C. F. Gill Sr. Rx. Prj. Spel.
J. E. Loser Secretary J. Puscas Secretary I. R. Bell I. P. Detloff Radiological Controls K. E. Andre D. A. Hersey Nuclear Materials J. L. Caseron and Che=1stry Section A. G. Januska R. M. Pankratz Inspection Section 1 D. R. Gibbons M. A. Kunowski R. V. Rozhon M. C. Schumacher Chief R. A. Paul J. R. Mu11auer
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W. H. Schultz Chief W. P. Reichhold N. Shah T. L. Simmons W. J. Slawinski S. Wagner T. F. Young I
Radiological Controla J. E. House
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Section T. J. Kozak Nuclear Materials C. C. Casey P. L. Louden Inspection Section 2
- 8. L. Hamriek i
W. G. Snell Chief A. W. Markley M. F. Kurth D. L. Nelson G. L. Shear Chief J. L. Lynch E. R. Matson l
M. W. Mitchell S. J. Mulay M. F. Weber VACANT Emergency Preparedness C. R. Cox Section
.J. E. Foster
- S. K. Orth J. M:Cormick-Barger Chf T. J. Ploski Nuclear Materials C. F. Frazier H. J. Simons Licensing Section R. G. Gattone L. J. Hueter G. M. McCann Chief J. D. Jones P. J. Lee J. R. Madera Safeguards J. L. Belanger K. G. Null Section G. M. Christoffer P. J. Pelke J. R. Kniceley D. Piskura r
J. R. Creed Chief T. J. Madeda P. M. Vacherlon G. L. Ptrtle Fuel Facilities and G. M. France
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Contaminated Sites R. L. 611nskt K. J. Lambert i
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R. J. Cantano Chief D. J. Srentavski l
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Response to 1992 NPR Questionnaire Question A. 1 Submit a current staffing plan for the Division of Radiation Safety and Safeguards.
Response A.I. contains the current Division of Radiation Safety and Safeguards (DRSS) Staffing Plan and Enclosure 3 contains the current Division Organizational Chart.
You should note that both branches have undergone reorganizations at the beginning of FY92. A section was added to the RPB to strengthen the oversight of reactor health physics, chemistry, and emergency preparedness programs.
In the NMSB, two sections were added. The Nuclear Materials Support Section was created to centralize the administrative support for the materials program and improve the oversight of both the administrative staff as well as the Nuclear Materials Licensing Section where the majority ei the administrative staff were previously assigned. The Fuel Facilities and Contaminated Sites Section (FF&CS) was created with three additional contaminated sites specialists to significantly expand our oversight of site remediation and strengthen our oversight of fuel facilities.
You should also note that our HMSS intern positions have been fully staff with new hires in the two Nuclear Materials Inspection Sections (S. Wagner and M. Weber) and we have an NRR Intern assigned in the FF&CS Section (G. Smith).
Questions A.2 Provide any comments and recommended changes regarding the effectiveness of Headquarters support to regional activities and the Region / Headquarters interface.
Identify any regional interaction with Headquarters and licensees to improve the quality of your licensing and/or inspection programs.
(Safety and Safeguards)
Response A.2 We have found the interaction between the Headquarters offices and Region III to be strong in support of the NRC safety mission. Of particular note is the coordination and communication developed at all levels in the contaminated site program area and the Headquarters support of regional activities and team inspections in the fuel facilities and materials program areas. We have also found value in the NMSS inspection accompaniments and would appreciate continuation of that activity. When accompaniments are conducted, brief telephone entrance and exit interview at the Branch Chief level would enhance communications.
i The Headquarters support of Region III's medical workshop was valuable and training in 10 CFR Part 20 and the Quality Management Rule will enhance staff j
development. Guidance for 10 CFR Part 20, the Quality Management Rule and the l
revised broad scope licensing initiatives should have been completed on a more timely basis to support regional staff efforts.
Regional interaction with Headquarters has been significantly enhanced this year through several rotational assignments at the staff and management level.
We have an aggressive program to continue those rotations through this calendar year to further enhance staff and program development and Region / Headquarters interface.
Further initiatives are described under Question B.2.
Question A.3 Provide a summary of actual expenditures and accomplishments as compared to operating plan / budgeted expenditures and accomplishments for FY92 to date.
Discuss reprogramming changes or diversion of resources for items unbudgeted.
(Provide a copy of end-of-year expenditures / accomplishments for FY91, if already available.
If not already available, do not prepare.)
Response A.3 Program status and expenditures for FY91 and FY92 through the first quarter are described in Enclosures 4, 5, 6, and 7.
Due to the reorganization in the Nuclear Materials Safety Branch (NMSB), the resignation of one inspector, and the transfer of another inspector to Region II, the inspection staff has been temporarily impacted. To lessen this impact, while new staff are becoming qualified, reprogramming of certain qualified staff from contaminated sites and licensing to inspection responsibilities has occurred as described in Enclosure 8.
This will continue as necessary to support the inspection program and could result in up to 0.375 FTE being reprogrammed from both contaminated sites and licensing to inspection during FY92.
Reactive efforts in inspection (allegations, event response, and enforcement) continue to be a significant impact on the expenditure of inspection progran FTE. Decommissioning financial assurance and fees rules as well as support to the revision to Part 20 guidance have impacted on both the inspection and licensing staffs.
Question B.1 Describe any changes you currently anticipate making in licensing and inspection program completion goals and the basis for those changes.
Response B.1 We anticipate fully meeting our operating plan goals for productivity, timeliness and quality of licensing actions in FY92, i
Due to either termination, reassignment, or reorganization, four qualified staff were lost from the inspection program.
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Gary Shear was promoted to Section Chief to replace R. Caniano who was transferred to the Fuel Facilities and Contaminated Sites Section (FFCS).
K. Lambert was transferred to FFCS and was replaced with T. Young, a new hire due on board April 5, 1992.
B. Parker transferred to the Region II Reactor Programs Branch (RPB) and was replaced with B. Hamrick from the Region III RPB who was not qualified to perform materials inspections.
J. Patterson resigned.
In addition, we dedicated two inspection FTE to the NMSS Intern Program.
S. Wagner on board in November 1991, M. Weber on board in February 1992, Due to these factors and the normal heavy vacation usage in the first quarter of the fiscal year, the inspection program was 36% under budget in completions as of January 31, 1992. We are experiencing significant improvement in productivity as a result of our inspection program enhancements (Enclosure 9) and anticipate continuing productivity increases as the new staff and interns become qualified, but we are concerned with our ability to meet our end of year goals. We will continue to evaluate our progress on a monthly basis and propose any changes needed in the operating plan goals before April 30, 1992.
Question B.2 Describe any initiatives your region has made to improve the safety of licensed programs and effectiveness of the regional program.
Response B.2 Several Region III initiatives implemented since the 1991 National Program Review are listed below.
Conducted a successful workshop for medical licensees from three Region III states.
Reorganized to strengthen administrative support and the contaminated sites and fuel facilities program areas.
Hired five new staff in the contaminated sites and inspection program areas.
Established and staffed the Region III HMSS Intern Program with specifically tailored position descriptions, individual development plans, and performance elements.
Initiated a proactive licensee coordination and communication program to enhance the broad scope renewal process and improve the safety of broad scope programs.
Initiated a revision to the broad scope license standard review plan.
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Reduced the backlog of old broad scope license renewals by a factor of 3.
The backlog will be eliminated in FY92.
Exceeded all inspection and licensing production and quality goals in FY91.
Upgraded the quality of the data on decomissioning financial assurance in the licensing tracking system.
Established a program to control returned mail and ensured that licensed programs are safely terminated.
Procured sufficient personal computers and software to meet the Region III goal of providing equipment for all license reviewere and two-thirds of the inspection staff.
Initiated a project plan to encourage licensees subject to the emergency preparedness rule to come into early compliance.
i Completed an effort to communicate with licensees subject to the Quality Management Rule revisions to ensure timely compliance.
Implemented a program to track licensee submittals of therapy quality management programs to assure compliance with that revision to the rule.
Substantially upgraded our analytical laboratory capability through the procurement of a new liquid scintillation counter with beta spectroscopy capability and a portable sodium iodide gama spectroscopy unit.
Initiated a program to upgrade portable survey instrumentation.
l Increased utilization of confirmatory measurements during inspections.
Assigned project responsibilities for all contaminated sites.
Developed inspection program for contaminated sites including evaluation and confirmation of characterization, analytical capability and remediation.
Established project plans for all contaminated sites to facilitate timely remediation and coordination with Headquarters and other regulatory bodies.
Initiated a study of low-level waste problems in the State of Michigan to ensure no safety issues existed.
Implemented inspection followup to ensure lessons learned from GE-Wilimington are factored into Region III fuel facilities.
Initiated a program at Combustion Engineering to significantly upgrade their controlling maintenance activities.
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Question C.1 Please verify the inspection information in Table 1, " Transportation Safety Inspections-FY1992"(Source: 766SystemDataOnly).
Inspection information for FY 1990 is provided for reference in Table 2.
Table 2 is based on 766 system data as revised by the regions.
Response C.2 We have initiated our review of the transportation inspection data you enclosed with your February 11, 1992 memorandum. The data appears low for materials transportation inspections. When we conclude our analysis, we will forward the information to you.
Questions C.2 Please provide the number of inspectors who conducted transportation safety inspections in FY 1991; the number of inspectors who have taken NRC Technical Training Center Course H-308, " Transportation of Radioactive Material" and estimate the number of inspectors who will need to take H-308 in FY 1993.
Response C.2 All inspectors in the Nuclear Materials Inspection Sections 1 and 2, Radiological Control and Chemistry Section and Radiological Controls Section perform transportation inspections. Enclosure 9 includes a summary of those individuals in need of H-308 transportation training.
Question C.3 Please provide a copy of any regionally-generated field notes for conducting transportation safety inspections.
Response C.3 We have no regionally initiated transportation field notes.
Question C.4 Please provide status of findings concerning radiographer transportation quality assurance program approvals (see memo from Robert f. Burnett to Directors, Division of Radiation Safety and Safeguards, Region I-V, dated September 26,1991).
Response C.4 The license files for all affected radiographers have been tagged to assure I
that the transportation quality assurance program issue is addressed during the next inspection. The detailed status of those inspections will be available during the review.
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c O-A Question D.1 What problems in licensee waste form and waste classification programs have been identified during low-level waste inspections?
Response D.1 We have not identified any significant problems in this area.
Question D.2 What steps are being taken to identify problems associated with low-level waste generator storage?
Response D.2 Because of our concern with low-level waste disposal problems in the State of flichigan, we have been closely monitoring the reactor and materials licensees to ensure no safety issues are caused by the inaccessibility of low-level waste disposal facilities to Michigan licensees. Several materials licensees are expanding their capability for interim storage. Enclosure 10 includes a briefing paper on this issue. A current summary of low-level waste storage capabilities at reactor sites is available in the region.
Question E.1 Identify any revisions or modifications necessary to improve the safeguards inspection program at Category I fuel facilities.
Response E.1 Not applicable in Region III Question E.2 Provide a summary of your FY 91 inspection efforts to include regional initiatives and training provided to the inspectors.
Response E.2 Not applicable to Region III i
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