ML20151Y017
| ML20151Y017 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1998 |
| From: | Combs F NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Blaha J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| SSD, NUDOCS 9809180055 | |
| Download: ML20151Y017 (9) | |
Text
.
MEMORANDUM TO:
Jim:s L. Blihn, Assistant for Operations September 16, 1998 Office of ths Ex:cutiva Dir:ctor for Operations FROM:
Frederick C. Combs, Acting Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
REPORT OF THE TASK FORCE REVIEWING MATERIALS LICENSING RENEWAL RESOURCE REQUIREMENTS Please find attached the report pertaining to the review of NMSS's licensing and inspection program as recommended by the Executive Council per your memorandum dated November 28,1997, regarding planning for the expected cyclical peak of license renewals caused by the "one-time, five-year license extensioii.= NMSSilMNS developed a task force to address the situation ar.d explore the viable options concerning the expected increase of materials licensing renewals and the effect of the new Agreement states in the next few years.
The budget was modified accommodating the recommendations that are provided within the report. Work will continue to develop guidance and procedures as necessary to implement the preferred options in the attached report.
Attachment:
As stated CONTACT:
Steven L. Baggett, NMSS/IMNS (301) 415-7273 i
Distribution: Closes 9700297 & 9700550 j
IMNS r/f JKinneman, R-l CPoland NE02-SSDd JHenson, R-Il JMadera, R-til CEstep DOCUMENT NAME: J:\\BAGGETT\\BLAHA.MEDI
- See previous concurrence
. Ta receive e copy of th&e document, indicate in the box: 'C' = Copy without ettschment/ enclosure "E" = Copy with a hment/ enclosure
- N' = No copy OFFICE MSB*
E MSB*
E MSB*
1%S \\
)l NAME ECompton SBaggett LCamper l FCfmbs
/
DATE 7/27/98 7/30/98 9/10/98 9/h(9_8 /
OFFICIAL RECORD COPY h*
9809180055 980916 PDR RC SSD PDR
MEMORANDUM TO:
J:mes L.' Bithm, Assistint for Operations 1 Office of the Ex:cutiva Dir:ctor for Operations i
FROM:
Frederick C. Combs, Acting Director L
Division of Industrial and Medical Nuclear Safety l
Office of Nuclear Material Safety
^
and Safeguards
SUBJECT:
REPORT OF THE TASK FORCE REVIEWING MATERIALS i
LICENSING RENEWAL RESOURCE REQUIREMENTS Please find attached the report pertaining to the review of NMSS's licensing and inspection program as recommended by the Executive Council per your memorandum dated i
November 28,1997, regarding planning for the expected cyclical peak of license renewals caused by the "one-time, five-year license extension." NMSS/IMNS developed a task force to 1
address the situation and explore the viable options concerning the expected increase of materials licensing renewals and the effect of the new Agreement states in the next few years.
The budget was modified accommodating the recommendations that are provided within the report. Work will continue to develop guidance and procedures as necessary to complete this task.
i
Attachment:
As stated CONTACT:
Steven L. Baggett, IMNS/NMSS (301) 415-7273 Distribution: Closes 9700297 & 9700550 IMNS r/f JKinneman, R-l CPoland NE02-SSD7-.
JHenson, R-il JMcdera, R-111 j
DOCUMENT NAME: G:\\BAGGETT\\BLAHA.MEM - See previous concurrence
. Ta receive e copy of this document. Wilcate in the box:
"C"
- Copy without attachment / enclosure "E" = Copy with ettachment/ enclosure
'N' = No copy OFFICE MSB lE MSB*
E MSB*
IMNS l
l NAME ECompton SBaggett LCamper FCombs DATE 7/27/98 7/30/98 9/10/98 9/ /98 gy OFFICIAL RECORD _ COPY I
MEMORANDUM TO:
Jimss L. Blaha, Assistant for Operations
]
Office of ths Ex::cutiva Dirsctor for Operations
)
i FROM:
Frederick C. Combs, Acting Director
(
Division of Industrial and l'
Medical Nuclear Safety Office of Nuclear Mriterial Safety and Safeguards-p j
SUBJECT:
REPORT OF THE TASK FORCE REVIEWING MATERIALS LICENSING RENEWAL RESOURCE REQUIREMENTS l
' Please find enclosed the report pertaining to the review of NMSS's licensing and inspection program as recommended b'y the Executive Council per your memorandum dated November 28,1997, regarding planning for the expected cyclical peak of license renewals
[
- caused by the "one-time, five-year license extension." NMSS/IMNS developed a task force to address the situation and explore the viable options conceming the expected increase of i
' materials licensing renewals and the effect of the new Agreement states in the next few years.
The budget was modified accommodating the recommendations that are provided within the
. report. Work will continue to develop guidance and procedures as necessary to complete this j
task.
Attachment:
As stated CONTACT:
Steven L. Baggett, IMNS/NMSS L
(301) 415-7273 Distribution: Closes 9700297 & 9700550 IMNS r/f =
JKinneman, R-l CPoland NE02-SSD7 JHenson, R-Il JMadera, R-Ill i
i DOCUMENT NAME: G:\\BAGGETT\\BLAHA.MEM -- See prev' us egncurrence Te veceive a cow of this document. Indcate in the boa: "C" = Copy without attachment /
llosure /*E" = Copy with ettschment/ enclosure "N* = No copy i
OFFICE MSB lE MSB*
lE N){%) [ /
l lMNS l
l NAME ECompton SBaggett 1[Q @ b(
FCombs DATE 7/27/98 7/30/98 s/ J/98 9/ /98 OFFICIAL RECORD COPY F
i e
i
1 REPORT OF THE TASK FORCE REVIEWING MATERIALS LICENSING RENEWAL RESOURCE REQUIREMENTS I
Backaround: Under the present set of conditions, staff expects to receive a significantly larger number of receipts for materials license renewals beginning in late FY 2000, and continuing steadily for the next five years. Based on license expiration dates, I
the staff would expect the renewals to increase from about 40 in FY 1999, to about
)
230 in FY 2000, eventually reaching a range of 950 to 1100 yearly in FY 2001-2005.
1 This trend is primarily the result of the 1996 policy decision to extend most materials license expiration dates by five years. This created an artificial five year cluster of license expirat% Jates. This also allowed reprogramming of licensing resources to the Guidance Consolidation Program for this 5-year period.
These projectionswould be reduced by timely transfers of about 1,600 NRC licentes to the States of Ohio, Oklahoma, and Pennsylvania over the next three years. When this impact is factored into the licensing forecast, the estimated number of renewals, and the projected FTE required to complete these reviews is revised, as shown below:
Renewals Projected Labor Rate' FTE Reauired FY 98 42
.021 0.9 FY 99 41
.021 0.9 FY 00 211
.014 3.0 j
FY 01 991
.014 14.0 FY02 719
.014 10.6
)
FY 03 688
.014 9.6 I
FY 04 746
.014 10.4 FY O5 724
.014 10.1 FY 06 124
.014 1.7 Issue.
. How can the Nuclear Materials Safety Program Manager, plan for, and address the impending peak workload projected to develop in FY 2000-2005, with respect to materials renewals?
Acoroach:
NMSS/IMNS assembled a Task Force to addreds the above issue. T e h
Task Force met on March 17-18,1998, and developed the proposals that follow. The Task Force included the following mcmbers:
Steven Baggett, Leader, NMSS/IMNS John Kinneman, Region 1/DNMS Jay Henson, Region ll/DNMS John Macare, Region lil/DNMS Charles Cain, Region IV/DNMS George Deegan, NMSS/IMNS 4
2 Uncertainties
- A r umber of uncertainties and variables have the potential to affect the issue between now and FY 2001 (the year for which the most significant impact is-expected. to occur).
The Task Force recognized these uncertainties but made its recommendations consistent with budget assumptions and management guidance. The uncertain ^s and variables that nre most likely to influence this issue are listed below:
Current efforts to revise the regulatory process based on the future recommendations of the Risk Review Group. (This could result in a rerack of the number of specific licenses).
Other States, in addition to the three listed above, becoming AgreementStates. (The more that become Agreement States, the fewer license renewals processed by NRC).
Current Agreement States returning their programs to NRC. (This would have the opposite effect).
Policy or regulatory changes that could influence licensees to consolidate their programs er terminate existing licenses (similar to the 100% fee recovery rule of the early 1990s, that caused many license amendments or terminations, or the decommissioning rule of several years ago).
' Industry sdvances and demographics as a function of time.
Efficiency gained.with fullimplementation of ADAMS.
Assumotions:.
- Ohio becomes an Agreement State in FY 1999, causing a drop in renewals the following year.
- Oklahoma becomes an Agreement State in FY 2000, causing a drop in renewals the following year.
Pennsylvania becomes an Agreement State in FY 2001, causing a drop in renewals the following year.
The guidance consolidation effort to issue new Standard Review
- Plans and other NUREG products for nearly all major categolas of
. materials licenses will be completed on schedule, and available to regional reviewers, This will result in lower labor rates for certain categor;es of renewals. (see additional discussion in Options section).
l 3
Preferred Ootions:
The following options are not mutually exclusive.
I 1.
Take into account the effectiveness achieved from the new auidance to reduce the labor rate. Using a comWer printout of expiration dates, the Task Force looked at th. ontribution of renewals projected in FY 2001 sorted by prograi.. de, and compared it to the staff hour expenditure data collected from FY 1991-95 (the most recent years with complete renewal data). The group analyzed four program codes with expenditure rates that could be expected to drop
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significantlyonce new guidance is available. These program codes comprised the majority of the licenses scheduled to expire in FY 2001.' This analysis is shown below:
FYO1 Expend.
Proposed Potential Renewals Hours New Rate Savinas Self-Shielded irrad.
11 15 8!
77 Fixed Gauges.
115 11-5.5 632 Portable Gauges '
254 10 5
1270 Comm. Hospitals 173 15 10
_Jfi5 Net Potential Savings (hours) -
2.1 2844 Net Potential Savings (1350 hours0.0156 days <br />0.375 hours <br />0.00223 weeks <br />5.13675e-4 months <br /> = 1 FTE) i Other categories, such as broad scope licenses, research and development (R&D) licenses, and radiographerswere also considered. The Task Force felt that savings were more difficult to forecast. For example, the R&D category includes a broad spectrum of licenses. While consolidated guidance may help streamline the review process for some of them, it may do lens for others. This hindered the group's efforts to quac.tify potential savings.
2.
Develoo auidance for reaional reviewen to allow them to reduce the scone of some license renewal reviews based on an acknowledamentreview and screenina orocess. This option allows j
license reviewers to make decisions based upon the licensee's inspection and enforcement history, and it uses the routine inspection program to augment a licensing determination. The Task i
Force. supports this option, based on the development of clear guidance from the program office. This option has the potential to save several FTE each year, depending upon how widely we implement the process, and how much we decide to limit the reviews. The Task Force conservatively estimated a savings of 2 FTE per year.
~
4 1
.,-.,e- - - - -
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4 This option assumes that all renewal applications will be filed without reference to old information, and in accordance with the most recent NUREG guidance.
An acknowledgment review would be conducted for completeness and accuracy of some basic information, such as name, address, and location. Then, the reviewer would conduct either a reduced technical review, or a full review depending on a series of performance factors. It is envisionedthat a review check sheet would be developed to allow for IMPEP auditing of the process. If the determination is made to conduct a reduced review (i.e., a vertical slice of select program areas), it could be based on strong enforcement history, few significant program changes, or the presence of other key attributes, that provide NRC more assurance of the licensee's commitmentto safe operations. Anothervariation on this approach would be to allow inspectors to recommend whether or not to allow for a reduced-scale renewal as they complete their inspection field notes. This would require some slight increase to inspection labor rates, but might be the most logical time to make this type of determination.
Given the short time allotted to it, the Task Force did not attempt to develop the guidance that would allow reviewers to determine which renewals could be reviewed under the reduced-scope protocol. However, there was a shared view that this guidance could use an approach based on performance factors and a series of other attributes similar to what NRC uses now to decide whetner or not to extend inspection intervals. For example, one performance factor could be enforcemert-based, and allow a reduced-scope review to be conducted if the history were good and there were nu recent event reports of contamination, exposures or releases. This would require a one time resource expenditure of about 1 FTE to develop the guidance.
3.
Provide license reviewers with clear menaaement exoectations reaardina the level of effort exoected for various tvoes of renewal reviews. The Task Force had access to past license renewal expenditure rates. If management were to support this approach, the Task Force could, at a later date, review these rates to recommend what reviewee might reasonably expect to expend on average reviews for each category of license. While everyone acknowledged that there is no such thing as an average review, the Task Force felt that there would be some benefit for both the reviewers and their management, if hourly expenditure rates could be estimated in advance. The purpose would not be to use these in individual performance tracking or assessment, but rather to assign casework in a more equitable fashion, and better estimate what we might generally expect to expend in each category of review. This may not save resources directly, but it should lead to greater program efficiency, and allow all parties to identify problem cases (those that are consuming significantly more resources than the model suggests).
In implementing this option, some regional l
managers might also want to use this to establish an artificial hourly ceiling. If we clearly articulate the components of a full review vis-a-vis the components of a smaller scale review, this could also I
i l
1
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' allow usto define what information is most essential during a (licensing review and could provide significant feed back to the ongoing guidance revision process, and provide opportunities for the regions to improve' the efficiency of the process on an ongoing bases.
i Other Options Considered (but not recommended):
-l 1.
Stanaer the distribution of renewals over the next 10 vear
~
i cycle usina a system anoroximatinathe risk of the act!vity bv l
aoolvino a factor based on the insoection orioritv. The renewel period could be five years plus the inspection priority
{
of the program, with a maximum period of 10 years for any i
inspection priority equal to or greater than 5.
An enforcement factor would be applied to screen the cases (e.g., using the same criteria that we used during the last i
extension process).
This would be another one-time extension.
This option was considered, but deferred.
implementationwould help to stagger the next renewal cycle, l
but would not lead to any resource savings. ' In addition, the Task Force felt that the current priorities and procedures in Inspection Manual Chapter 2800 already provide allowances for the different risks of activity.
2.
Staaoer the distribution of renewals by acolvino a uerformance factor based on violations. For example, the
. license expiration date could be established t'/ using the baseline frequency of 10 years minus 1 to 5 years depending on the number of violationsthe licensee has had. This would also help to stagger the next renewal cycle, but would not lead to any resource savings. This option may have me:it in the long-term, but the Task Force felt that there was no urgency to consider it at this time.
3.
Reduce or extend the next license exoiration date (renewal term) based uoon the cuality of the licensees submission.
and its confunnance to our auidance in terms of format and content.
While this option has considerable appeal, especially since it rewards good licensee submissions, several members of the Task Force did not want to penalize licensees who take the time and effort to do a more thorough intemal program review, and as a consequence, send us a more customized renewal package.
While these submissions may require more effort for NRC reviewers, the Task Force felt that there is a potential safety benefit from having the licensee review his program in detail in order to submit a more complete renewal application. Like the other
6 options in this group, if this were implemented, it would help stagger the next renewal cycle, but would have no impact on the resource issues for FY 2001-2005.
Recommendations; 1.
Pursue Preferred Options 1,2, and 3. Reflect the changes in the FY 2001 resources for renewals by reducing the FTE requirementsfrom 14 FTE to 9-10 FTE. Similar reductions, based on caseload forecasts for FY 2002-2005 would suggest a target of about 7-8 FTE.for ensuing years.
, Reinvest the potential savings within the nuclear materials program area.
2.-
Develop guidance as discussed in each of the Preferred Options.
3.
Increase inspector resources slightly to acknowledge additional effort to link their findings with recommendations on renewals (as stated in Preferred Option 2).
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