ML20195J344
| ML20195J344 | |
| Person / Time | |
|---|---|
| Issue date: | 05/21/1999 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20195J334 | List: |
| References | |
| NUDOCS 9906180183 | |
| Download: ML20195J344 (4) | |
Text
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- p'"% UNITED STATlis 3 4 NUCLEAR REGULATORY COMMISSION
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a a REGloN Iv e 611 RYAN PLAZA drive, sulTE 400
. ., g ARLINGTON, TEXAS 76011-8064 i
May 21, 1999 l
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l MEMORANDUM TO: Carl J. Paperiello, Director Office of Nuclear Material Safety and Safegut.rds FROM: Ellis W. Merschoff, Regional Administrator Region IV
SUBJECT:
DRAFT 1999 REGION IV INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM REPORT This refers to the draft report for the 1999 review of the Region IV materials program. I and my staff have reviewed the draft report and are providing comments in the attachment to this memorandum. Our comments primarily consist of suggestions for clarifying certain areas and minor corfections; on the whole, we found the report comprehensive and believe that it represents a balanced perspective of the region's performance.
We appreciate it.: opportunity to participate in an independent review of the Region's implementation of the materials inspection and licensing programs. These reviews provide an opportunity for new insights on how we might improve our performance, as well as an opportunity to discuss with headquarters staff initiatives which could result in improved efficiency and effectiveness in the materials program overall. To that extent, I want to convey my staff's appreciation for the team's willingness to seek feedback from regional staff and for the professional manner in which the review was conducted.
Should you or the team have any questions concerning our comments, please contact Dwight Chamberlain or Linda Howell of my staff at (817) 860-8106 or 860-8213, respectively.
Attachment:
As Stated l
1 f
I 9906180183 990608 PDR ORG NOMA Attachment 1 PDR
- dcc / EC/83
t Attachment Regional Comments
- Section 3.2, Page 6: It appears that some text may be missing from the last sentence in the second paragraph.
Section 3.3, Page 8: Because the region may elect to change tFe staffing levels within branches assigned to the Division of Nuclear Materials Safety, we recommend that the second paragraph on this page be modified so as to not reflect assignment of vacant positions to a specific branch. We suggest that the second paragraph be modified to read as follows:
RIV has experienced unique challenges since the last review. Closure of the WCFO in 1998 resulted in several vacancies in RIV's materials program.
Region IV has managed this challenge by hiring new staff and by retention of a license reviewer and three inspectors participating in a 2-year, remote, work-at-home program. ,
in the third paragraph on Page 8, we suggest that the sixth sentence be modified to read as shown below. This change will more accurately reflect the possibility that budget cuts may result in elimination of some FTE by the end of the 2 year pilot <
work-at-home program.
Since the pilot is for 2 years, and there is an expectation that most of the participants will not continue with NRC at the end of the pilot, Regional management is actively preparing to fill some of the potentially open positions.
- Section 3.4, Page 10: To provide context for readers who may not be familiar with decommissioning guidance, we suggest modifying the third paragraph on Page 10 to read as shown below.
The guidance in inspection Procedures 87104," Decommissioning inspection Procedure for Materials Licensees," and 88104, " Decommissioning Inspection Procedure for Fuel Cycle Facilities," specify that the field notes contained in the I
respective procedures be used to document each inspection conducted using the procedure. Inspection Manual Chapter 2602," Decommissioning Inspection Program for Fuel Cycle Facilities and Materials Licer sees," specifies that the inspection staff shall fully document , in the form of a written report, all visits to and inspections of each site undergoing decommissioning. RIV is following the prescribed guidance and is generating both field notes and formal reports for ;
each of its decommissioning inspections. The requirement for documenting !
inspection findings in both formats is somewhat burdensome and has yielded no l additional benefit in understanding the licensee's program or documenting site !
status. The Region would prefer the option of preparing either a formal report or j field notes, depending on the scope of the inspection. Formal reports issued by the Region would continue to include applicable items identified in the field l notes. This IMPEP team recommends that additional oiscussions be held between NMSS and all Regions to determine if both the field notes and formal reports are needed.
s The sixth full paragraph on Page 10 contains discussion regarding a recommendation concerning financial assurance guidance. As noted in this paragraph, RIV staff did identify to IMPEP team . members a need to update existing guidance; this project is already underway. Since all regions and headquarters staff performing financial assurance reviews will use the updated guidance, we suggest that the last sentence in this paragraph be modified to read as shown below.
The IMPEP team recommends that NMSS staff confirm that the updated guidance is responsive to regional and headquarters staffs' needs.
- Section 3.5, Page 11: The fourth paragraph of this section describes an event involving an overexposure and the Region's review of the event. The fourth sentence of this paragraph should be correcteo to reflect the Region's review of the event during the spring of 1998 rather than the fall of 1998.
- Section 4.1, Page 14: For the paragraph identified under " Materials Licensing," we suggest entering the following text after the fifth sentence:
At the end of FY 98, the Region had reduced the renewal backlog case load to zero.
- Section 4.4.2, Page 24: We recommend that the second full paragraph on this page be deleted; it does not accurately reflect staff assignments in the Region's uranium recovery program.
- Section 5.0, Page 26: With regard to recommendation 2, the Region understood this recommendation to be directed to NMSS. Therefore, we suggest that the text be modified as follows:
The IMPEP team recommends that NMSS review the need for both field notes and formal inspection reports to document inspection results at decommissioning sites and revise guidance as appropriate.
- ' Appendix E, Page E.2: The comment under File No. 9 may mislead the reader to think that leak test intervals for this license were not properly updated. This particular licensing action involved an amendment request that was not related to leak test intervals. Therefore, when the action was processed, the license conditions were not reviewed or modified in their entirety to reflect a less restrictive leak test interval. The action taken in this case was consistent with agency guidance.
A minor typographical error appears in the text relating to File No.14. The liceasee is Endocrine Group.
- Appendix F: On Page F.2, the discussion on File No. 8 should be corrected to re' lect the current status of this case. A reactive inspection was conducted; however, no report or Notice of Violation has been issued because of a concurrent, ongoing investigatic n.
The Region considers this case to be open.
,a, Aaenda for Manaaement Review Board Meetina Wednesday. June 16.1999.10 a.m. - 12 m.
Room T285
- 1. Convention. MRB Chair convenes the meeting. (FMiraglia)
- 2. New Business - Consideration of RIV IMPEP Report A. Introduction of RIV IMPEP Team Members (SMerchant) <
B. Introduction of RIV representatives and State representatives (SMerchant)
C. Findings regarding RIV Program (IMPEP Team)
Status of Materials inspection Program Technical Quality of Inspections Technical Staffing and Training Technical Quality of Licensing Actions Response to incidents and Allegations Performance Against Operating Plan Goals Regional Fuel Cycle Inspection Program Site Decommissioning Management Plan D. Questions (MRB Members)
E. Comments from RIV F. MRB Consultation / Comments on issuance of Final Report (FMiraglia)
Recommendation for next IMPEP review
- 3. Old Business - Approval of Rlli MRB Minutes ,
- 4. Status of Upcoming Reviews (OSP)
- 5. Adjournment invitees:
Frank Miraglia, Jr., MRB Chair, DEDR Sally Merchant, Team Leader, NMSS/IMNS -
Carl J. Paperiello, MRB Member, NMSS James Myers, Team Member, OSP Martin Virgilio, NMSS Deputy Director Lance Lessler, Team Member, NMSS/FCSS Paul Lohaus, MRB Member, OSP Terry Johnson, Team Member, NMSS/DWM Karen Cyr, MRB Member, OGC Hector Bermudez, Team Member, Ril, Roland Fletcher, State of Maryland DNMS Ellis W. Merschoff, RIV Regional B.J. Smith, Team Member, State of Administrator Mississippi D. Chamberlain, RIV, DNMS Director Kathleen Schneider, OSP Donald Cool, NMSS/IMNS Director Lance Rakovan, OSP Frederick Combs, NMSS/IMNS George Deegan, NMSS/IMNS Deputy Director Margaret Fetsko, NMSS/IMNS Elizabeth Ten Eyck, NMSS/FCSS, Director John Greeves, NMSS/DWM Director Attachment 2
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