ML20057A762
| ML20057A762 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/1992 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20055C202 | List:
|
| References | |
| NUDOCS 9309150281 | |
| Download: ML20057A762 (12) | |
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APR 2 4 E MEMORANDUM FOR: Ross A. Scarano, Director Division of Radiation Safety and Safeguards, RV FROM:
Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
DRAFT NATIONAL PROGRAM REVIEW REPORT REGION V I have enclosed the National Program Review (NPR) report for Region V.
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.
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/hardE. Cunni'gbim, irector a
1 vision of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
Draft NPR Report DISTRIBUTION:
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REPORT OF NMSS NATIONAL PROGRAM REVIEW AT NRC REGION V, FEBRUARY 25-26, 1992 1
BACKGROUND AND PURPOSE This report provides the results of the Office of Nuclear Material Safety and Safeguards (NMSS) review of Region V programs under the Headquarters responsibility of NMSS. The Headquarters team participating in this review p;6,w &
V consisted of three persons: John Greeves, Deputy Director of the Industrial and Medical Nuclear Safety; John Hickey, Chief of the fuel Cycle Safety Branch; and Chuck Cain, Materials Inspection Section Leader, Region IV (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 V Division of Radiation Safety and Safeguards (DRSS). A February 11, 1992 memorandum from Richard Cunningham listed the areas to be coeerad ard transmitted a questionnaire to the regions. Region V responses to the questionnaire are shown on Attachment 2.
The National Program Review (NPR) is based not only on the visit to the Region, but also on the collective Regional / Headquarters interfacas throughout the year, through review of some licensing casework and inspectio't statistics, resource utilization, technical assistance and coordination, and the questionnaire. The NPR is intended to provide a review of effect;veness of both the Region and Headquarters activities insofar as they relate to Region V activities and to identify suggestions for improving the effectiveness of the joint efforts of NMSS, and Region V.
The emphasis relates to achieving two goals:
technical quality and timely completion of licensing casework and inspections, on 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 summary in each of the following areas:
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Background and Purpose 2.
Licensing 3.
Inspections 4.
Training 5.
Initiatives 6.
Interface of Region / Headquarters 7.
Resource Utilization 8.
Reconnendations/ Suggestions
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2 LICENSING Region V currently regulates 255 byproduct materials licensees.
In FY91, they completed 220 licensing actions, as compared against an adjusted Operating Plan Target of 200 (110 percent). They received 211 cases during this timeframe. Through February 28, 1992, the Region had completed 92 cases, which helped to reduce the number of pending cases to 54, and put them ahead of their licensing goal for the fiscal year.
The Region continues to exercise tight control over " backlogged" cases.
Only 3 such cases existed in early March.
The Headquarters staff reviews a fraction of completed materials licensing actions and inspection reports as they are completed by the Regions.
Both licensing and inspection actions are in accordance with Standard Review Plans, Inspection Manual Chapters, and other guidance documents.
Region V staff has sought guidance via telephone or technical assistance requests on matters that are technically complex or may have policy implications.
They requested that Headquarters continue to provide licensing guidance in areas such as decommissioning funding plans, Part 20 implementation, and license conditions.
The Region continues to use telephone contacts for minor deficiencies in licensing submissions to maintain excellent turnaround time.
The Region is to be commended for identifying a generic issue regarding the need to clarify the responsibilities of management at broad licensed facilities. This resulted in an ongoing effort among Headquarters and the G
Regions to resolve this issue.
The Region also resolved a suggestion from the 1991 Review concerning the need for 100% quality assurance reviews of completed casework. The Region has reduced management reviews of more straightforward cases, and increased peer reviews, which improved quality and efficiency.
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3 INSPECTIONS a.
Materials Inspections In FY91, Region V achieved their Operating Plan inspection goal by completing 133 materials safety inspections. This figure includes a large percentage of inspections of the Department of Agriculture, U.S. Air Force and U.S. Navy permittees, which are licensed by other regions. Through February 1992, the Region had completed 38 inspections. The annual goal is 133, so the Region was slightly behind. However, they had only two inspections overdue as of early March. The review team suggested that the inspections be closely monitored to assure that the budgeted goals were achieved.
The Region is encouraging safety-oriented, performance-based inspections that emphasize the licensees' implementation of safety programs rather than paperwork. The team commended the Region for its use of prelicensing renewal inspections to provide timely input on renewals.
In general, the communication between the licensing and inspection staff was excellent.
The Region maintains excellent timeliness on inspection documentation, follow-up on open items, and issuance of Notices of Violation.
The Region has made a concerted effort to perform more field inspections.
In FY91, approximately 10% of all inspections were conducted at remote locations and observed licensed activities under real world conditions. The Region has made significant findings as a result of this effort.
b.
Safeguards Inspections t
The Region completed their scheduled FY91 safeguards inspection program.
The inspection reports were detailed and technically sound.
RV was requested to conduct two long route surveys and one port survey. These surveys were requested by Headquarters with a short deadline, and the regions responded in a very timely manner with a thorough and detailed report.
In addition, Region V conducted one spent fuel inspection.
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c.
Fuel Cycle Inspections The fuel cycle inspection program is conducted primarily by one Seni6r Fuel Facility Inspector. He receives technical support from other specialists in the Regions and from NMSS licensing staff. As suggested by Headquarters during the 1991 Program Review, he participated in a fuel cycle inspection in Region II.
Based on NMSS' review of completed inspection reports, Region V prepares clear, understandable inspection reports that demonstrate good recognition of the safety issues. The reports reach defensible conclusions and are completed with the best overall turnaround time of any Region. The Region also initiates appropriate enforcement actions, as necessary.
The Region achieved several outstanding accomplishments during 1991, including the DRSS Division Director Ross Scarano, leading the GE-Wilmington Incident Investigation Team in Region II, providing an additional staff member for the IIT, and performing an outstanding team inspection at the Siemens facility.
The team leader, James Reese, will also lead a team inspection in Region II in 1992 as part of our overall effort to improve team inspections.
The Regional staff suggested that Headquarters coordinate closely with the Region on license renewals and upgrading fuel cycle license conditions.
d.
Transportation Safety Inspections programs The Region inspects licensee transportation safety programs as part of its materials, reactor and fuel facility inspection programs. There are approximately 270 facilities and material licensees in Region V.
In FY91, Region V conducted a total of 78 transportation safety inspections, using Inspection procedures 86740, 86740B and 86750.
Fourteen violations (all i
Severity level IV or V) were identified during these inspections. A review of selected inspection reports indicates that violations were properly cited against NRC and Department of Transportation (DOT) regulations.
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e.
Low Level Waste Management and Decommissioning Because of the limited resources devoted to low-level waste management and decommissioning licensing and inspection activities, and the positive interactions between the Division of Low-Level Waste Management and Decommissioning (LLWM) and RV staff during the year, and the results of the 1991 review, LLWM staff elected not to participate in the visit to RV offices in 1992.
No issues have been identified in our routine interaction with the Region in the last year.
4.
TRAINING The Regional staff reported that management is very supportive of training requests.
The Region has an experienced staff, so there is a reduced need for initial training courses.
The review team suggested that the Region continue to emphasize opportunities for refresher training.
Part 20 training was given by the Technical Training Center and NMSS at all five Regions during early 1992. Region V decicea to administer an exam at the end of the training.
Staff members reported that there was initially some concern about the exam, but afterwards, there was a consensus that the exam was an excellent idea, because it emphasized the importance of the training.
In FY91,14 Region V inspectors conducted transportation safety inspections.
Of these,13 have taken NRC's Transportation of Radioactive Material course (H-308). One inspector is scheduled to take the course in FY92; Region V has attained nearly 100% course training for transportation safety inspectors.
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INITIATIVES BY THE REGION The Region is to be commended for its outstanding initiatives during 1991 and 1992, including the following:
Leading and supporting the GE-Wilmington IIT Communications with medical licensees on implementation of the Quality Management Rule Implementation of lessons learned from the GE-Wilmington fuel cycle incident, as shown in inspections at Siemens and General Atomics Emphasis on performance-based materials inspections, including expanded field inspections and pre-licensing visits.
Use of " peer reviews" of completed licensing cases Administering an exam following Part 20 training, which emphasized the importance of the new rule 6.
INTERFACE OF REGION / HEADQUARTERS The interaction between the Region V fuel cycle inspector and Headquarters licensing staff was considered excellent.
Region V will lead a team inspection in Region II in 1992.
The Region requested that Headquarters continue to issue as much guidance as possible in appropriate areas, and hold more technical workshops.
Region V identified to Headquarters a deficiency in the documentation supplied by gauge manufacturers for packages use to transport moisture density gauges.
This documentation is required by DOT' regulations for Specification 7A packages. As a result of subsequent inspection by D0T, one manufacturer distributed updated package documentation to all users of its gauges.
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7 RESOURCE UTILIZATION The table shows full-time equivalent (FTE) allocations for FY91 and FY92 through 2/29/92. The following comments are based on a review of casework and inspections statistics, the regional staffing plan, RITS time expenditure reports and the region's responses to the questionnaire.
Region V resource expenditures for NMSS program activities have been approximately 25% below the budgeted allocations in FY91 and in FY92 through 2/29/92, as a result of two vacant Radiation Specialist positions.
In FY91, through the use of overtime, the Region was able to exceed the materials licensing goal by 11% and successfully meet the inspection goals for fuel facilities and material licenses.
In FY92, due to staff shortages, materials inspection accomplishments are below the performance goal. The Region continues to work towards and expects to achieve the annual goal despite the staffing shortfall.
In addition to recruitment efforts, additional staff has been dedicated to NMSS activities. Although resources have not being fully expended for the NMSS program during FY92, the expenditure rate for materials licensing activities has been higher than the projected utilization level.
This is attributable to Region V initiatives to improve quality and efficiency of licensing actions by conducting peer reviews and pre-licensing visits at selected large materials licensees. Another initiative undertaken by the Region was to send a letter to medical licensees to advise them of the requirements of the new Medical Quality Management Rule. This initiative will minimize staff time and effort to assure licensee compliance with the QM rule.
The Region has effectively met the Operating Plan goals for the Safeguards and Low-Level Waste programs with a reduced level of resources than the budgeted allocations.
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REGION V RESOURCE UTILIZATION The following table shows FTE allocations and expenditures for the review period FY92 FY91 ANNUAL BUDGET EXPENDED PROGRAM ACTIVITY BUDGET EXPENDED BUDGET OCT-FEB.
OCT-FEB. %
Fuel Facility Inspection 2.2 0.8 36 1.3 0.5 0.5 Materials Licensing 1.8 2.0 111 1.8 0.8 1.1 Materials Inspections 3.4 3.4 100 4.0 1.7 1.2 Event Evaluation 0.8 0.8 100 1.2 0.5 0.1 SG Transportation Insp.
0.26 0.1 38 0.3 0.1 0.004
& Plans SG Fuel Facility Lic.
0.1 0.01 10 0.06 0.03 0.01 SG Fuel Facility Insp.
0.2 0.11 55 0.2 0.08 Low-Level Waste 0.25 0.05 20 0.25 0.1 0.1 Reactor Decomm.
0.3 0.1 33 0.3 0.1 0.001 Materials Decomm.
0.2 0.07 35 0.1 0.04 0.1 NMS Section Supr.
1.0 0.6 60 1.2 0.5 0.2 NMTS Section Supr.
0.1 0.02 20 0.1 0.04 LLW Section Supr.
0.1 0.02 20 0.1 0.04 0.01 TOTAL 10.71 8.08 75 10.89 4.53 3.3 73 NOTE:
FY91 expenditures from regional input provided in response to FYP/ Green Book update in 11/91. FY92 expenditure data compiled from RITS report 3 and 4.
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RECOMMENDATION / SUGGESTIONS a.
For NMSS:
1.
Provide additional guidance to the Regions in various licensing and inspection areas.
2.
Hold more review / inspector workshops.
3.
Provide an up-to-date list of Headquarters contacts for various issues / subjects.
4.
During conference calls, highlight new policies and rules.
5.
Evaluate whether the review process for decommissioning funding plans can be streamlined to reduce Regional expenditures of resources.
6.
Coordinate closely with the Region on fuel cycle renewals.
7.
Improve team inspections of fuel cycle and major material licensees.
l b.
For Region V:
1.
Closely monitor completion of materials inspections, to assure Operating Planning goal is met.
2.
Continue periodic supervisory accompaniments of inspectors, including occasional participation by Division Director and Deputy Division Director.
3.
Because staff is experienced, assure that the Region takes full advantage of refresher training opportunities.
4.
Assure that the current one or two DRSS vacancies are filled in a timely fashion.
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Region V Review Team John W. N. Hickey (team leader), Chief, Fuel Cycle Safety Branch, IMNS/NMSS John T. Greeves, Deputy Director, Division of Industrial and Medical Nuclear Safety Charles E. f ain, Section Chief, Fuel Cycle and Materials Inspection Section, Region IV s
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