ML20057A754
| ML20057A754 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1992 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309150271 | |
| Download: ML20057A754 (15) | |
Text
.
M 141992 MEMORANDUM FOR:
Leonard J. Callan, Director Division of Radiation Safety and Safeguards, RIV FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
DRAFT NATIONAL PROGRAM REVIEW REPORT REGION RIY I have enclosed the National Program Review (NPR) report for Region IV.
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 might 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 within two weeks of receipt.
9MMN Richard E Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS Enclosure NPR Report Distribution:
NMSS R/F IM0B R/F IMNS R/F SCDB R/F JGlenn RHall JHickey CHaughney RCunningham EFlack RBangart WBrach CDefino RBurnett i
FCombs JSurmeier LBell RBellamy, RI JGreeves GDeegan ~
JLieberman 1
- sae previous concurrence DTC :
SCDB*
- INNS /DD
- IMNS/Dir.:
......................................... g.....- #......................
NAME:
CJHaughney/tk
- JGreeves
- RCunningfiam:
DATE:
04/10 /92
- 04/
/92
- 04/// /92:
OFFICIAL RECORD COPY 9309150271 930830 PDR STPRC ESGGEN f "; ( 9 PDR
9 ENCLOSURE REPORT OF NMSS NATIONAL PROGRAM REVIEW AT NRC REGION IV, AND THE URANIUM RECOVERY FIELD OFFICE FEBRUARY 26, - MARCH 4, 1992 1.
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety cnd Safeguards (NMSS) review of Region IV programs under NMSS responsibility. The team participating in this review consisted of persons from NMSS and one person from Region I.
A separate three person team visited the Uranium Recovery Field Office (URF0) the previous week. A list of both teams appears as attachment 1.
Additional input from other elements of NMSS was used in the preparation of this report. The principal regional activities are primarily under the responsibility of the Region IV Division of Radiation Safety and Safeguards (DRSS). A February 11, 1992, memorandum from Richard E. Cunningham listed the areas to be covered and transmitted a questionnaire to the regions that was used to aid discussions during the visit.
The National Program Review (NPR) is based not only on the visit to the Region, but also on the collective Regional / Headquarters interfaces throughout the year, on review of selected licensing casework, inspection reports, accompaniments of region-based inspectors, review of casework and inspection statistics, resource utilization, technical assistance and coordination, and the completed questionnaire. This process is intended to provide a review of effectiveness of both the Region and Headquarters activities insofar as they relate to Region IV and to identify suggestions for improving the effectiveness of the joint efforts of NMSS, and Region IV. The emphasis relates to achieving two goals:
technical quality and timely completion of licensing casework and inspect 1:ns, en the basis that both elements contribute to assuring the safety and safeguards of operations involving NRC licensed activities.
The report is organized so as to present an integrated sumary in each of the following areas:
1.
Background and Purpose 2.
Licensing 3.
Inspections 4.
Decomissioning 5.
Training 6.
Initiatives 7.
Interfaces of Region / Headquarters 8.
Resource Utilization 9.
Recommendations /for Region IV 10.
Recommendations for Headquarters
2.
LICENSING In FY 91, Region IV completed 530 licensing actions, as compared against an unadjusted Operating Plan target of 520 (102%).
They received 828 cases during this timeframe, approximately 300 more cases than expected.
Through February 29, 1992, the Region had completed 246 cases, or 41% of the FY 92 Operating Plan goal. With the recent addition of a new licensing reviewer, the Region should have no problem in meeting, and even exceeding, the FY 92 goal of 590 licensing actions.
The larger number of receipts than expected is primarily due to the return of all licenses from the State of Idaho, and the 100% fee recovery rule.
New applications and amendments are worked on before renewals, in accordance with Program Office guidance. With the new staff, the backlog of 107 new/ amendments and 121 renewals as of February 29, 1992, will begin to be eliminated during the end of FY 92, and should be completely eliminated by the end of FY 93.
The budgeted FTE for licensing actions in FY 91 was 2.4, compared to a usage of 2.9.
The use of overtime accounts for the difference.
In FY 92, the budgeted FTE of 2.8 is again expected to be exceeded by actual use, and expenditures to date in FY 92 project to about 3.5 FTE utilized in the entire FY 92.
Region IV continues to make excellent use of the Licensing Assistant, giving her limited signature authority.
She had been approving as many as 20-22 '
licensing actions per month, but due to her administrative duties, this rate has been reduced to 7-8 licensing actions per month.
She has received the appropriate classroom training yet her usefulness and experience would be increased dramatically if she were afforded the opportunity to participate in more pre-licensing visits and inspection accompaniments.
The issue discussed in last year's review with respect to the maintenance of the licensing docket files remains and has yet to be adequately addressed by regional management.
The administrative burden appears to be falling more and more on the Licensing Assistant, with a resultant negative impact on her other activities.
The technical staff is also working overtime to keep the docket files in order.
The Region should pursue ways to keep the materials docket files in order, such as a co-op position or a stay-in-school hire.
The recent backlog of licensing actions has arisen basically due to two reasons outside the Region's control.
First, the licenses returned from Idaho, although up-to-date, were cumbersome to use and needed (and continue to need) work. More than one licensing action (on the average) has resulted from each returned license.
These licensees have needed significant education and explanation of issues by Regional staff.
Second, 100% fee recovery has increased the number of licensing actions received, and again many of these licensees require extensive interaction with Regional staff.
The Region's oversi o t of the U.S. Air Force's master license continu excellent.
Management responsibilities have been shifted from the Nuclear Materials Licensing Section to the Nuclear Materials Inspection Section in order to evenly distribute work assignnents.
Frequent comunication continues, numerous inspections occur, and the appropriate assistance is obtained fro other regions.
Director of the Division of Reactor Safety becam Director of the Division of Radiation Safety and Safeguards.
goals, and is seen as a long-term net benefit. experience has no Region IV has continued to meet licensees in an open forum to discuss n regulations (Part 20), recent incidents, regulatory perspectives, and iss interest to attendees.
There were three held:
Boise and Helena, Montana.
This is considered to be an exce,llent regional activity Regional stoff made a useful recomendation in the area of Technical A Requests (TARS).
HMSS is presently sending a copy of all TAR responses to all e
the regions.
However the transmittal information is not included, so in effect the regions are, seeing the answer without knowing what w for the region that submitted the TAR).
issue was and the specific questions.information in all TAR respo There are 0.2 FTE budgeted in FY 92 for materials facilities decomis Region IV.
Region IV uses the RITS system to capture time charged against materials facilities decomissioning efforts.
Region IV has comitted to that sufficient resources are brought to bear on fina Region IV is aware of the listing criteria in SECY-91-096 used to evaluate problems with contaminated sites that require non-routine cleanup.
is comitted to continuing to apply these criteria in order to determine if The Region a given site should be listed in the SDMP.
In 1991, 73 license terminations were processed.
site with a decommissioning plan.
Of these only one involved a issues identified and forwarded to Headquarters for resolution. Curing 199 routine license termination.there is not a need for guidance from Headquar Region to track routine license terminations.The Licensing Tracking System is used 4
k
)
URANIUM RECOVERY FIELD OFFICE (URFO)
The NMSS National Program Review (?!PR) of the URF0 activities was conducted on February 26-27, 1992, at the URF0 offices in Golden, Colorado. The NMSS NPR team consisted of two staff members from the Division of Low-Level Waste Management and Decommissioning and one staff member from the Program Management and Policy Development Staff. The review of the URF0 program was based on the planned accomplis 1ments for uranium recovery licensing, inspection, and related activities.ccntained in the Region IV Operating Plan for FY 1992, and included an overview of URF0's accomplishments for FY 1991. The review team also included as an area of emphasis, the adequacy of the policy and program guidance for URF0 licensing, inspection, and review activities.
i Overall, the review team concluded that URF0 accomplished the goals in the Operating Plan.
In FY 1991, completed licensing casework and reviews, and inspections exceeded the planned accomplishments in several areas.
URF0 completed 93% more licensing cases and reviews than originally budgeted i
(planned 70 and completed 135).
URF0 completed two more inspections than I
budgeted (planned 35 and completed 37) and the review of monitoring reports was consistent with the plan (planned 135 and completed 132). As of the review t(am's visit in February 1992, URF0's performance was on track with the FY 199?
Operating Plan planned accomplishments. As a result of the review of FY 1992 performance, the review team suggested that URF0 consider an amendment to the Operating Plan to a.ccount for the current unbudgeted effort being expended on the increased review of Title II reclamation plans.
This effort is redirected from Title I project reviews and reviews of monitoring reports. This incre m t.
effort is required to comply with the October 1991 NRC/ EPA / Agreement Stetts itemorandum of Understanding (MOV). The team noted that resources expended on J
the review of Title I UMTRCA activities were lower than budgeted based on delays by DOE in submitting plans and the recent transfer of a Title I case to Headquarters. Approximately 1 FTE should be rebudgeted from this area to the review of the Title II reclamation plans.
In the area of Policy and Program guidance, a general lack of formal guidance for licensing and inspection activities was noted. However, the review team concluded that URF0's program is proceeding well based on staff expertise and the experience of management personnel.
For Title I reviews, inspection guidance is providad in the NRC Inspection Manual (MC 2620) and draft licensing guidance is available. Headquarters is reviewing the Title I licensing and inspection guidance and plans to issue revised Title I guidance by mid-1992.
For Title II licensing and inspection activities, no formal program guidance has been provided to URFO.
Headquarters is currently proceeding to develop guidance for Title II reclamation plan reviews and for inspection frequency and conduct.
It plans to provide this guidance to URF0 by the end of FY 1992.
I f
1 Each Title II licensed facility was inspected during the year and re)erts were issued on a timely basis for most inspections.
For FY 1991, 32 of tie 35 inspections were reported out within 30 days.
For FY 1992 through February, seven of the eight reports were completed within 30 days of the inspection with one being issued 50 days after the inspection. Overall timeliness for issuing reports is good.
URF0 annually reviews approximately 10E nonitcring reports related to Title II licenses. These reviews are submitted t) licensees on license condition required testing arc recsureme'nt programs.
URF0 reviews and follows-up on the monitor reports as needed at the next site inspection. A recent initiative by URF0 is to strengthen the review process by conducting their review of monitoring reports as part of the inspection preparation activities for the annual inspection. Questions that arise from this report review can then be addressed during the inspection.
This espect of the program appears to be satisfactory.
Increased emphasis is being placed on Title II reclamation plan reviews and approvals for FY 1992 and FY 1993 with 6 plans scheduled for completion during the two fiscal years. Reclamation plans are required to be submitted to NRC under the license and NRC is required to complete the review by the end of FY 1993 in accordance with the October 1991 MOU with EPA. URF0 appears to be allocating sufficient staff resources to complete these reviews on a timely basis.
Continued management oversight should be provided to assure that the planned reviews are completed in the time frame required and without open
' issues except in unusual circumstances.
URF0 has prepared a draft set of functionally grouped generic license conditions as a standard license for an operating in-situ leach uranium facility. URF0 provided the draft generic license to NMSS for review and approval. The generic license will be implemented for new licensees and should assure a high degree of completeness and consistency among licenses.
URF0 has identified a need to review the frequency of inspections at uranium mills, in-situ leach facilities, and other URF0 licensees. The practice is to conduct annual inspections at each facility and URF0 suggested that the frequency be revised to increase the frequency at operating facilities such as in-situ facilities, and decrease the frequency at non-operating facilities.
The review team agreed with the URF0 suggestion and inspection frequency will be addressed in the changes being made to the inspection program during FY 1992.
- 3. INSPECTIONS In the area of fuel cycle inspections, the major fuel facility in RIV is Sequoyah Fuels Corporations (SFC). The inspections program for the SFC plant has been custcr:-rrade, reactive, and fluid for many months, even before the plant was placed on the watch list.
Regional management has juggled changing priorities, responded to a string of events, and assessed the results of several management changes in attempts to improve licensee programs. The region has, at times, established resident-like coverage by rotating several inspectors from regional offices, LTF0, and NMSS to closely mcnitor plant performance. All these activities have created an extraordinary and highly variable situation with respect to inspection reports.
Inspections report timeliness for SFC has varied drastically and has often been substantially behind. Recent efforts by regional management to regain proper report timeliness are well understood by the regional inspection staff. Although, the results of this effort will not be known for sometime, the seriousness of regional resolve to attain proper timeliness should lead to success.
The unique inspection scope applied to the SFC plant the past several months does not necessarily comply with the routine inspection programs as defined in Inspection Manual Chapter (MC) 2600.
The routine inspection requirements of MC 2600 do not apply to a plant experiencing substantial difficulty like SFC.
However, the region should periodically examine the routine program to ensure l
that some important attribute is not being neglected by conducting all customized inspections. The project inspector for SFC had looked at this issue briefly but had not systematically ensured that inspection coverage was truly adequate. The region agreed to examine this issue.
In FY91, 318 material safety inspections were completed compared to a revised goal of 310. Through February 1992, the Region completed 110 inspections. The project annual goal is 310, recently revised from 433. The revision is based on LTS data, which indicates that no more than 310 inspections are due in FY92.
Although the Region is slightly behind target in the number of inspections to date, this is basically due to the geography considerations when scheduling inspections. Region IV generally runs with a minimal backlog of due inspections, and they fully expect to complete the entire core program in FY 92. Quality and timeliness of inspection reports are good. Regional staff questioned why there was the emphasis on timely issuance of inspection reports, when they saw no such parallel guidelines for issuance of reports that the Office of Investigations (01) prepares.
Certain technical reports are held up waiting for 01 reports, usually for several months.
i Regional staff has been interpreting the guidance with respect to the reci-procity issues of 10 CFR 150.20 as using Form 241 as simply a notification to regional staff. This issue has been discussed on numerous NMSS conference calls, and input from the other regions indicates that this implementation is not consistent among the regions. Pegicns IV is recommending that HMSS conduct a trainir.g session for the appropriate regional stuff to resolve this issue.
4 Escalated enforcement cases are appropriately handled, and are given the proper safety significance.
Region IV is recommending that more consistency would be obtained if the Office of Enforcement held a counterpart meeting specifically to discuss materials escalated cases.
In addition, Region IV would like to see more proactive involvement of HMSS in enforcement conferences via telephone so that NMSS can be up to speed on all of the issues and buy into the enforcement action at an early date.
The Region believes that the NMSS Newsletters are an extremely useful tool for disseminating information, and mean more to a materials licensee than an Information Notice.
They recommend that significant issues be included in the Newsletter, even if they were the subjects of Information Notices.
The Region is processing financial assurance submittals in accordance with program office guidance, but is training its staff on a one-on-one basis.
RIV recommends that NMSS provide structured training to each of the regions in this important area.
The region inspects licensee transportation safety programs as part of its materials, reactor, and fuel facility inspection program.
There are approx-imately 820 licensees in Region IV.
In FY91, Region IV conducted a total of 205 transportation safety inspections, using Inspection Procedures 86740, 867408, and 86750.
Region IV inspectors also reviewed transportation issues (but did not use an Inspection Procedure) at an additional 124 material licensees that have little, if any, occasion to ship licensed material.
There was a total of 329 inspections conducted during which a transportation inspection procedure was completed, or transportation issues were reviewed.
Twenty-five 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.
4.
DECOMMISSIONING The Headquarters staff reviewed decommissioning activities in Region IV for which NMSS has lead programmatic responsibilities.
In the area of financial assurance the staff's review was keyed to tracking and management of financial assurance submittals, the backlog of financial assurance submittals, timeliness goals, Headquarters guidance, policy issues, and resource utilization.
In Region IV all financial assurance matters are assigned to a single individual. Management and oversight of the process as implemented in the Region is working.
Seventy-six of approximately 820 licenses within the geographical area covered by Region IV met the requirements for having financial assurance in place.
To date, approximately 60 percent (46 of 76) of the licenses that require financial assurance submittals have completed m
e financial assurance instruments in place. The Region is aware of, and follows, Headquarters guidance related to trtnsreittfrg non-routine submittals to Headquarters for resolution.
The timing, resolution, and response from Headquarters on non-routine financial assurance submittals has been very good.
There is a need for regional staff to be aware of expiration dates of financial instruments in advance of the expiration date.
There is a feature of the Licensing Tracking System (LTS) designed for this purpose.
Region IV should make use of the automated tracking provisions of the LTS for tracking financial assurance instruments expiration dates, so that regional staff can remain cognizant of the status of all completed financial assurance submittals already in-place.
To their credit, the regional staff has established timeliness goals for approving all financial assurance submittals.
Region IV has an objective of completing all negotiations with licensees that do not have completed financial assurance plans in-place by the end of calendar yer 1992.
Region IV staff is believes that their regular interactions with licensees related to financial assurance issues could be enhanced with additional training.
Headquarters staff agrees that additional training would be beneficial, and will support the Region's request for training.
Based on their financial assurance experience to date, the Region should be in a sesition to define the specific areas where training would yield the greatest aenefits.
To that end, Region IV will provide Headquarters with a written request that will define its specific training needs.
Region IV staff aware of all existing guidance related to financial assurance, and does not feel that there is at present a need for additional guidance.
Staff reassignments and shifting staff responsibilities can have an impact on financial assurance issues.
Periodic updates by the Headquarters staff in areas that include guidance, existing financial assurance tracking methods, policy, and management methods would go a long way toward enhancing both Regional and Headquarters effective management of financial assurance and other decomissioning requirements.
5.
TRAINING In FY91, eight Region IV inspectors conducted transportation safety inspections. Of these, six had taken NRC's Transportation of Radioactive Material course (H-308).
Region IV had scheduled two inspectors for H-308 in late March 1992.
Several RIV staff members were asked to describe their opinions concerning the usefulness and adequacy of the recently conducted Part 20 training program.
The staff tembers consulted were universally high in their praise of this training program.
They suggested that training manuals be made available for future new employees.
In addition, they suggested that the course be made available on some periodic basis to train new employees or allow refresher training for well-experienced staff members.
in one cf these discussions a regional section chief with many years experience in materials licensing ard insa c1 M.3, cescribec a ccepciling need for similar detailed training on Parts 30-39 of the regulations.
He felt that such detailed training was needed to better normalize the level of understanding of NRC personnel working in this field. He felt such a course shculd be developed carefully so that it could achieve the high standards demonstrated during the Purt 20 course.
He mentioned that such a comprehensive course would have claicw tenefits for new employees and for supervisors rcsponsible for training such new employees.
He suggested that such a course include descriptions of what the regulations contain and mean and what they don't contain and don't mean, and that the course describe the traditional method of interpreting certain sections or phrases as applied in licensing and inspections matters.
- 6. REGICNAL INITIATIVES The program for qualifying URF0 inspectors and documentation thereof needs additional attention by URF0 management and staff.
Inspector Qualification Journals need to be reviewed and updated for the new staff.
A qualification board should be established as required by the NRC Inspection Manual (MC 1245) to review and assure the qualifications and readiness of the new staff to perform independent inspections.
The review team understands that URF0 management has established a goal of December 1992 to complete Inspector Qualification Journals for the new staff.
The Region is to be commended for its extraordinary efforts in the use of the LAN and the conversion of all materials licenses to Wordperfect. The conversion is ongoing, and should be completed by the end of April 1992. This effort will allct: licensing reviewers to change, amend and write licenses from their PCs, and maintain close coordination on their licensing actions. Not only can licenses be reviewed, they can be searched and identified with respect to specific codes, names, license types, or any other parameters.
Inspectors will only have read capability. The efforts of the Senior Licensin in DRSS, and DRMA (in particular the Chief Data Management Section)g Reviewer should be noted. A demonstration of the capabilities available was given, including the conversion of a specific license, and illustrated how useful this system is.
Region IV has volunteered to hold a workshop for NMSS and the other Regions on their efforts to date.
The workshop is scheduled for May.
- 7. INTERFACES OF REGION / HEADQUARTERS To help retain sufficient inspection coverage at SFC, the region has periodically requested the assistance of technically-skilled HMSS personnel to supplement its inspection staff, both curing routine inspections and team i
inspections. This degree of cooperation is connendable and has helped the region maintain control of inspection activities at this troubled plant.
l
In regards to NMSS personnel accompanying regional inspectors in the field as assessors, care should be taken to ensure that the NMSS individual properly describes his or her role during the accompaniment.
For instance, the accompanying person should not claim to be in a dual but conflicting role such as an inspector trainee and an assessor. This matter appears to be more associated with the manner in which the individuals have, at times, described their roles rather than the quality of the assessment items disclosed.
But characterization l
of the assessor role is important in establishing the assessor's credibility.
Region IV participated in responding to the loss of a well-logging source from a truck in Huntsville, Texas.
Region IV prcvided notification of the event to several headquarters offices, and coordinated with Texas state officials on the recovery of the source.
Region IV investigated the incident and cited the licensee / shipper with violations of applicable NRC and Department of Transportation regulations.
Communication and coordination with Region IV on transportation matters was good throughout the year.
E.
RESOURCE UTILIZATION The table shows full-time equivalent (FTE) allccations for FY91 and FY92 through February 29, 1992. The table reflects only the expenditures of the DRSS staff, and ignores the valuable and significant contributions of the Region IV organizational units on projects such as Fort St. Vrain decommissioning, the development of inspection guidance and procedures for the Louisiana Energy Services enrichment facility and Sequoyah Fuels.
In FY 91, the Region fully expended the budgeted allotment for materials licensing and did not fully expend the resources allocated (-22%) for materials inspections. The reduced level is attributable to a revision of the operating plan completion goal from 370 inspections to 310 inspections. The revised accomplishment goal enablec the Region to redirect resources to oversight at Sequoyah Fuels that was necessary due to the environmental and radiological safety issues at the facility.
In FY 92 through February 29, 1992, the Region expenditure rate for materials licensing and inspection activities was below the projected levels (83% for materials licensing and 57% for inspections).
The Region's past expenditure trend to fully utilize resources for materials licensing and reallocate resources to fuel facility inspection at Sequoyah Fuels will likely continue through the fiscal year. The additional resource requirements for increased emphasis and inspection frequency at Sequoyah Fuels and/or Louisiana Energy Services will be addressed in the FY 1994 budget process.
In FY 91, URF0 exceeded the budgeted allotment (+44%) for uranium recovery licensing and did not fully expend resources allocated (-37%) for Uf1 TRAP Title I reviews. Resources were redirected to complete Title II licensing due to delays by DOE in submitting remediation plans for Title I sites, and resulted in the completion of 100% nore licensing cases than the planned
accomplishment goal.
Inspection resources were fully utilized during FY91, and resulted in the completion of 37 inspections against the budgeted gcal of 35 inspections.
URF0 also expended 0.8 FTE which was not budgeted to provide support to Region IV for inspection activity at Sequoyah Fuels.
In FY92, staff resources expended for Title I licensing are below the budgeted allocation since the number of receipts from DOE continue to be below the projected levels and the recent transfer of a Title I case to Headquarters.
A significant nucher of licensing actions will be requirea as a reruit of the provisions of an NRC/ EPA / Agreement States Nemorandum of Understanding.
To accomplish the review of reclamation plans by Septenber 1993, URF0 has reassigned work to dedicate two staff members to this effort and has streamlined the review of licensee monitoring reports. A revision to the FY92 Operating plan is being considered to reflect the increased effort to review the reclamation plans and reprogramming of 1 FTE for UMTRAP Title I reviews.
REGION IV RESOURCE UTILIZATION The following table shows FTE allocations and expenditures for the review period FY 92 FY 91 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED"!
BUDGET OCT-FEB. OCT-JAN.
1 Faterials Licensing 2.4 2.5 104 2.8 1.2 1.0 Materials Inspection 7.3 5.7 78 8.4 3.5 2.0 Fuel Facility Inspection 1.1 2.4 218 1.4 0.6 1.4 Event Evaluation 1.5 1.0 67 1.7 0.7 0.3 SG Fuel Facility Lic.
0 0
0 0
0 0
SG Fuel Facility Insp.
0 0
0 0
0 0
SG Transportation Insp.
0.06 0
0 0.06 0.03 0
& Plans LLW Inspection 0.25 0
0 0.15 0.06 0.03 Reactor Decomm.
0.1 0
0 0.2 0.08 0.3 Material Fac. Decomm.
0.2 0.4 200 0.2 0.08 0.3 Uranium Recovery Lic.
4.8 6.9 144 6.0 2.5 2.1 UMTRAP 3.0 1.1 37 1.9 0.8 0.6 Uranium Recovery Insp.
1.9 2.1 110 1.8 0.8 0.2 NMS Section Supv.
1.6 1.1 69 1.8 0.8 0
0 0
0 0.1 0.04 0
TOTAL K2 E2 T6 2U1 17 UT NOTE:
FY91 expenditures from regional input prcvided in response to FYP/ Green Book update in 11/gl.
l
9.
RECOMMENDATIONS FOR REGION IV AND URF0 a.
Continue to address the materials licensing backlog issue throughout FY 92 and FY 93.
b.
Provide the opportunity for the Licensing Assistant to obtain more experience ir. the field by performing inspection accompaniments and pre-licensing visits.
c.
Aggressively pursue a solution to the materials docket files to ensure that the files are up-to-date and in order.
d.
Continue the effort with respect to conversion of all licenses to Wordperfect on the LAN and ensure that the other regions are aware of this success story.
Provide training and guidance to those other regions that desire it.
Review MC 2600 inspection requirements to ensure appropriate portions of e.
these requirements are covered during inspections.
f.
Review timeliness and consistency of fuel cycle inspection reports g.
Provide continued management to assure reclamation plan reviews are completed without open issues.
h.
Maintain awareness of expiration dates of financial instruments.
- 10. RECOMfiENDATIONS FOR HEADQUARTERS a.
Region IV appreciates receiving 6 copy of every Technical Assistance Request (TAR) that NMSS completes, but in most cases is not aware of the incoming questions and issues.
It recommends that each TAR response include a copy of the incoming request, or at least a discussion of the questions being asked.
b.
Region IV would like to see workshops, training sessions, or counterpart meetings held on a number of topics to improve consistency among the regions. The topics include the reciprocity issues involved in 10 CFR 150.20, financial assurance, and recent escalated enforcement ctses and decisions for materials licensees, periodic Part 20 training for new employees and interpretation of Part 30-39 regulations.
c.
The NMSS' Newsletter is read by materials licensees to a greater extent than Information Notices, and important information should be in the flewsletters, even if it has been disseminated by another forum.
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-O d.
Region IV would like more involvement by MISS in escalated enforttner,t cases, via telephone.
e.
Since the Region's timeliness is tracked for inspection reports and escalated enforcement cases, they would like to see similar criteria for 01 referrals and reports.
f.
Increase the level of visibility of Program Office staff in the Region by attendance at meetings, and particularly by short-and long-term rotational assignments.
g.
Reconsider appropriate levels of Title I and II program resources.
h.
NMSS should revise Title I program guidance and provide new guidance for Title II licensing.
1.
Consider revising inspection frequencies for URF0 licensees.
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I a
4 i
ATTACHMENT 1 NPR Team for Region IV Charles J Mcughney,* Chief, Source Contair.rnent and Devices Branch, NMSS/IliNS Ronald R. Bellaray, Chief, Nuclear Materials Safety Branch, RI Ernest W. Brach, Acting Deputy Director, Division of Low-Level Waste Management and Decomissioning, NMSS Larry Bell, Project Manager, NMSS/LLWD NPR Team for URF0 Ernest W. Brach*
Allan Mullins, NMSS/LLWD Clare V. DeFino, Program Analyst, NMSS/Pf1DA
- Team Leader l
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