ML20216C688

Responds to 971126 Memo Requesting That Region II Provide Answers to Encl Impep Questionnaire

ML20216C688
Person / Time
Issue date:	01/16/1998
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20013H163	List: ML20216C688 ML20216C698 ML20216C715 ML20216C744 ML20216C839
References
NUDOCS 9804150018
Download: ML20216C688 (90)

Text

l i

A E8% UNITED STATES 9

fo,, NUCLEAR REGULATORY COMMISSION '

n REGION ll 5

,y ATLANTA FEDERAL CENTER

'* 61 FORSYTH STREET, SW, SUITE 23T85

[ ATLANTA, GEORGIA 30303-3415 g /1/ $

3,p1oote January 16, 1998 MEMORANDUM T0: Carl J. Pa)eriello. Director .

Office of luclear Material Safety and Safeg ,ar s i

1. '~

FROM: Luis A. Reyes, Regional Administrat

SUBJECT:

INTEGRATED MATERIALS PERPJRMANCE EVALUATION (IMPEP) ,

OVESTIONNAIRE l 1

This is in response to your memorandum dated November 26. 1997, requesting Region II to provide answers to the IMPEP questionnaire. Tne completed questionnaire is attached. We believe that our inspection and licensing staff '

have the proper safety focus and that our programs are identifying safety '

issues during licensing reviews and inspections.

1 You will note that we have identified items during our self-assessments where  !

l improvements are needed as indicated in the questionnaire answers. We have discussed several of these areas during our management retreats, and we have I actions ongoing to make improvements. Areas of particular emphasis are improvement in the quality and timeliness of materials licensing actions and l inspection reports, and improvement in the quality and timeliness of fuel l facility inspection report drafts provided to the Branch Chief for review. In l

addition. due to the recent loss of staff due to retirements, we continue to emphasize recruiting quality staff and the training of backups for critical i functions. I l

If you have any questions. please give me a call. '

Attachment:

IMPEP Ouestionnaire cc w/att:

G. Deegan NMSS

~

9804150018 980402 PDR ORG NOMA PDR

,vu , .svv, v .

I 1 I

I I

1 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM OUESTIONNAIRE Peo M1 II Reporting Period: March 1996 to February 1998 A. COMMON PERFORMANCE INDICATORS I. Status of Materials Insoection Proaram

1. Please prepare a table identifying the licenses with inspections that are overdue by more than 25% of the scheduled frequency set out in NRC Inspection Manual Chapter 2800. The list should include initial inspections that are overdue.

RESPONSE

There are currently no overdue inspections. However, during the assessment period the following inspections were overdue:

Insp. Frequency Licensee Name (Years) Op1 1alg Months 0/D Princeton Diagnostic 1 5/96 5 (Inspected Isotopes 10/96)

[Two attempts had been made to inspect prior to overdue date, but the licensee was not available]

Technical Welding 1 11/96 6 (Inspected 5/97)

[ Licensee's home office is in Texas: Region II is licensing and inspecting region since all work was done in the Virgin Islands.

l Wit 1 a Texas prefix or !"e license number, it was not picked up on the inspection due list, developed from LTS. Region II identified i l

this as a generic problem and worked with NMSS to have it l corrected.] 3 l 2. Do you currently have an action plan for completing overdue  !

j inspections? If so, please describe the plan or provide a written j copy with your response to this questionnal.e.

l

RESPONSE

l Currently Region II has no overdue inspections. The Region'has a l process to maintain a minimum of overdue inspections. Under this l process, the Branch Chief or his designee obtains a "Due List" I

printout to identify those inspections coming due. The Branch i Chief or designee develops itineraries and monthly schedules for  ;

inspections. These itineraries are reviewed by the Branch Chiefs after the inspection trips to determine whether inspections have been com]leted. If an inspection is not completed the Branch Chief scledules the inspection for a subsequent trip.

1 l

3. Please identify individual licensees or groups of licensees the I State / Region is inspecting more or less frequently than called for in NRC Inspection Manual Chapter 2800 and state the reason for the change.

I

RESPONSE

Region II implements the criteria in MC 2800 for the inspection i frequency includin extension and reduction of inspection frequency based on icensee performance (inspection findings). )

The frequencies for future inspections are established, based on type of licensee and inspection findings. by the Branch Chief as

) art of the process for review of ins)ection reports (narrative or I rield Notes) after each inspection. Region II is accelerating the inspection of licensees using Sr-90 eye applicators to assure that '

licensees are properly c.0culating doses to be administered. This is based on findings that licensees have made errors in determining output (rads /second) either because of improper i calibration or decay of the sources. In January 1998. Region II began special ins)ections of these licensees with a goal to complete them by iarch 1998. As a result of this special effort.

1 l several of these licensees will be inspected before their next due l date. )

l l

4. Please complete the following table for licensees granted j i

reciprocity during the reporting period.

RESPONSE

l l The Table below provides the requested information. The table l shows that Region II has not met the goal for inspections of licensees conducting inspections under reciprocity. Our emphasis has been on conducting inspections of such licensees when actually doing work in NRC jurisdiction rather than completing inspections l at the licensees permanent facilities in Agreement States. In the past, we have been more successful in inspecting licensees in the field, but within the last year we have found that licensees have been giving shorter notice for reciprocity work. As a result, we have not been able to inspect these licensees in the field.

However, we will conduct office inspections for licensees who are located in Region II and have indicated in the NRC Form 241 that they planned to conduct licensed activities in areas of exclusive Federal jurisdiction within Region II for 1997. These inspections will be completed by March 31, 1998. We have re-emphasized the need to complete reciprocity inspections and will continue emphasis on completing field inspections. We will conduct inspections at licensee's facilities (rather in the field) who have filed for reci3rocity in 1998 starting in September of 1998 if we have been unaale to ins)ect the licensee in the field. This action has been added to the )NMS tracking system.

2

Number of Licensees Number of Priority Goal Granted Licensees (Percent) Reciprocity Inspected Each Permits Each Year Year Service Licensees 1996-3 1996-3 performing 1997-2 1997-0 teletherapy and 100 1998-1 1998-0 irradiator source installations or changes 1996-11 1996-6 1 50 1997-12 1997-4 1998-1 1998-0 1996-0 1996-0 2 50 1997-0 1997-0 1998-0 1998-0

- l 1

1996-5 1996-3 j 3 30 1997-10 1997-0 1998-4 1998-0 5/7 10 1996-29 1996-6 1997-20 1997-7 1998-5 1998-0 l

S. Other than reciprocity licensees. how many field inspections of radiographers were performed?

RESPONSE

l Region II attempts to perform a field inspection of each

, radiography licensee with temporary job site authority during each l inspection. We accomplish this by determining where the licensee I is doing or planning to do field work. We make such l determinations by review of licensees records during inspections at their facility, by interaction with State representatives, and i

by interactions with facilities that routinely contract for radiography services (power authorities, refineries. etc.) In some cases, we have made multiple attempts (in one case four attempts) to conduct field inspections. If we are unable to observe field operations, the inspections have been closed based 3

1 l

f

on an inspection conducted at the office facilities. Listed below is the information on field inspections for the current and two previous fiscal years.

FY 96 - 6 (28 percent of radiograpny licensees)

FY 97 - 8 (30 percent)

FY 98 - 1 (4 Percent)

6. For NRC Regions, did you establish numerical goals for the number of inspections to be performed during this review period? If so, please describe your goals the number of inspections actually

! performed, and the reasons for any differences between the goals and the actual number of inspections performed.

RESPONSE

In pst fiscal years (FY) the Region II Operating Plan established two goals for inspections: number of inspections to be completed l and no overdue inspections. Our aerformance in meeting these goals has been monitored during tie quarterly self-assessments.

In addition, we tracked completion of inspections throughout the year as part of the regional Management Information Report (MIR).

, As a result we have been able to complete the planned inspections

! and have had a minimum number of overdue inspections. In the current Region II Operating Plan, the primary goals are to do reactive inspections to review events and to perform inspections when they are due based on IMC 2800 frequencies, including consideration of inspection results. This is in keeping with the l 3rototype Regional Operating Plan developed by NMSS. We currently lave no overdue inspections. We are revising the MIR for FY 98 to show any overdue inspections rather than the number of inspections. The number of inspection due and actual completions for the IMPEP period are: ,

A GOAL ACTUAL COMPLETIONS FY 96 260 323 l FY 97 250 322 FY 98 based on due list 63(thru 12/31/97) none overdue II. Technical Quality of Insoections

7. What, if any, changes were made to your written inspection procedures during the reporting period?

RESPONSE: )

The main changes in Region II-specific processes and procedures I are discussed below (program changes. e.g. IMC 2800 and 0610, l changes in IPs. changes in the Enforcement Manual, etc., are not discussed). Region II formalized our previous processes for 4

l

selecting areas and ap) roaches to inspection of fuel facilities (see Attachment 7. Ris c Informed. Performance-based Ins and Attachment 7a. Targeting Information, for details).pections, In the I materials area, we began conducting inspections of Type A broad I licensees with two or more inspectors based on written inspection l plans and writing narrative reports for such inspections.

8. Prepare a table showing the number and types of supervisory j ccompaniments made during the review period. Include: .

, insoector Suoervisor License Cat. D.ats

RESPONSE

Attachments 8, 8a. and 8b show DNMS management site visits for j

! FY 1996. 1997, and 1998 respectively. Attachments 8c. 8d, and 8e j show dates when inspectors were accompanied by their supervisor. .

Normally for materials inspectors, the accompaniments are for

. several licenses over a period of several days, '

l

9. Describe internal procedures for conducting supervisory l accompaniments of inspectors in the field. If supervisory l l accompaniments were documented, please provide copies of the 1 documentation for each accompaniment.

]

i i RESPONSE: l l

The Region II Operating Plan establishes goals for inspector 1 accompaniment b,i su)ervisors. The DNMS self-assessments review accomplishment of t1ese goals on a quarterly basis. Regional Office Instruction (ROI) 2213 (Attachment 9) establishes the process for inspector accompaniments. This establishes that, on the average, the Division Director or Deputy will visit a site each month, each Branch Chief will accompany an inspector each quarter, and each Branch Chief will accompany each ins)ector once each fiscal year. The ROI requires documentation of tie site visits by each su>ervisor. Copies of such documentation is provided as Attac1 ment 9a for certain of those visits conducted in the )ast six months. We identified that such documentation was not Seing completed, and have re-emphasized to suservisors and managers that this must be done in accordance wit 1 the ROI. A check of this documentation on a quarterly basis has been added to the DNMS tracking system.

In addition, the Branch Chief observes the performance of each l inspector during an inspection before recommending the individual l be qualified as an inspector. ]

1 5

y

10. Describe or provide an update on your instrumentation and methods of calibration. Are all instruments properly calibrated at the present time?

RESPONSE

l Region II established an inspector in charge of the laboratory and instruments (part time, rotating among inspectors) and a Branch Chief responsible for such activities. In addition, procedures for such activities have been established. With regard to instrumer.tation, the Region has two types of instruments:

(1) fixed gamma, beta, and alpha counting systems in the screening laboratory, and (2) portable instruments (survey meters, area monitors, alarming dosimeters, and air samplers) for use by field inspectors during routine as well as decommissioning inspections.

l The fixed instruments in the screening laboratory are calibrated i l by the staff using current NIST traceable standards. The portable i instruments are calibrated by a vendor in accordance with ANSI ,

l calibration standards. The calibration s  !

I the vendor are provided as Attachment 10,pecifications and Attachmentapplied 10a is ato

list of portable instruments used in Region II. 1 III. Technical Staffino and Trainino l 11. Please provide a staffing plan, or complete a listing using the l suggested format below, of the professional (technical) person- )

l years of effort applied to the agreement or radioactive material i program by individual. Include the name, position, and, for Agreement States, the fraction of time spent in the following i

areas: administration, materials licensing and compliance.

emergency response. LLW, U-mills, other. If these regulatory responsibilities are divided between offices, the table should be I consolidated to include all personnel contributing to the radioactive materials program. Include all vacancies and identify all senior personnel assigned to monitor work of junior personnel, i If consultants were used to carry out the program's radioactive materials responsibilities, include their efforts. The table heading should be:

NRE POSITION AREA 0F EFFORT ETf1

RESPONSE

Attachment 11 is a copy of the Region II DNMS organization chart.

In 1995. Region II reorganized to place NMSS programs and the Agreement State Officer in DNMS. Coordination of escalate f enforcement and allegations was placed in the Enforcement and l~ Allegation Coordination staff reporting to the Regional l Administrator.

)

I 6

1 l

I

The Table below lists the requested information for materials staff. In addition. DNMS obtains engineering support from the Division of Reactor Safety when necessary, such as in the case of concrete construction work at ARECO. Similar information is provided in B.I 4 and B.I.3. below for Fuel Facilities Branch staff. There have been several recent retirements by staff in and supporting the materials area. (Earl Wright and Jerry Ennis who retired on January 3. 1998. John Potter, who retired on December 3.1997, and Bruno Uryc. who retired in December 1997, and these are included below but noted with an *. Prior to these retirements. DNMS established a listing of skills needed in the Division, and developed backups so that skills would not be lost if an individual left the agency. As a result, when the individuals retired, there were sufficient staff with the necessary skills to continue activities. For example. Earl Wright j had been lead for Financial Assurance Reviews. We designated John l Pelchat as backup, and he now has the lead for these cases.

There is one vacancy in the materialt 'rea. The position is j posted and we are actively working t. fill it. j NAME POSITION PRIMARY AREA LEVEL OF LEVEL OF 0F EFFORT EFFORT-% EFFORT-%

LICENSING INSPECTION BERMUDEZ SR RAD SPEC INSPECTION 25 75 ,

I COLLINS (DJ) RAD SPEC LICENSING 75 25(including l reciprocity) l DIAZ RAD SPEC INSPECTION 25 75 i

ENNIS RAD SPEC INSPECTION 0 100 FRANKLIN RAD SPEC INSPECTION 0 100 FULLER RAD SPEC INSPECTION 0 100 HEIM LIC ASST LICENSING 100 0 HENSON RAD SPEC LICENSING 75 25 JONES RAD SPEC INSPECTION 10 90 LOO RAD SPEC LICENSING 40 60 MASNYK BAILEY RAD SPEC INSPECTION 50 50 PARKER RAD SPEC INSPECTION 10 90 (inc.

l term.

l ,

sites)

PELCHAT RAD SPEC LICENSING 50 50 7

l l

r l NAME POSITION PRIMARY AREA LEVEL OF LEVEL OF t

OF EFFORT EFFORT-% EFFORT-%

LICENSIN, INSPECTION I

WRIGHT

• SR LIC LICENSING 100 0 REVIEWER l WATSON / SPARKS ENFORCEMENT INSPECTION 0 0.4 FTE (enforcement) COORDINATOR DEMIRANDA/ ALLEGATION INSPECTION 0 0.4 FTE IGNAT0NIS C0ORDINATOR (allegations)

HOSEY BRANCH CHIEF BOTH 25 75 l AND DEP. DIV.

DIR.

t POTTER

• BRANCH CHIEF BOTH 50 50 COLLINS (DM) DIV. DIR. BOTH 10 90 l MALLETT FORMER DIV. BOTH 10 90 I (THROUGH DIR. J MAY 7, 1997)

DECKER BRANCH CHIEF BOTH 25 75 l BOLAND/URYC* DIRECTOR. INSPECTION 0 30 (Enf. and ENF. AND j aleg.) ALEG.

12. Please arovide a listing of all new professional personnel hired since tie last review, indicate the degree (s) they received. if applicable, and additional training and years of experience in health physics, or other disciplines. if appropriate.

RESPONSE

The following individuals. 'added to the Division during the l period, are currently qualified as inspectors (Ayres and Humphrey interim qualified pending completion of specific courses).

l Michael Fuller (Materials Radiation Specialist)- BS degree (minor in HP) 15 years experience in radiation protection, five years as Radiation Specialist in Region II prior to returning recently.

David Ayres (Senior Fuel Facility Project Inspector) - BS in l

chemical Engineering,15 years of experience in fuel facility operations and nuclear criticality safety, including three years experience with the NRC.

8

[

l Gary Humphrey (Senior Resident Inspector) - BS in Industrial Technology. eight years experience in gaseous diffusion plant l operations, five years reactor service engineering, and 11 years l as reactor resident inspector.

' Deborah Seymour (Senior Fuel Facility Inspector) - BS in Chemical Engineering and Materials Engineering, six years of research in j high voltage electrical cables (including neutron effects), three

years as an MC&A inspector, three years as a radiological I

effluents and chemistry inspector of reactors and fuel facilities.

l two and a half years as a reactor project inspector. and two and a half years as a reactor resident inspector.

13. Please list all professional staff who have not yet met the qualification requirements of license reviewer / materials inspection staff (for NRC. Inspection Manual Chapters 1246: for Agreement States, please describe your qualifications requirements for materials license reviewers and inspectors). For each, list the courses or equivalent training / experience they need to attend and a tentative schedule for completion of these requirements.

RESPONSE

Region II is in the process of qualifying materials staff as both inspectors and license reviewers. All technical staff in MLIB1 and 2 are qualified as inspectors. The staff below are'in the 3rocess of becoming qualified as license reviewers; all other iLIB1 and 2 technical staff are qualified license reviewers.

Hector Bermudez - qualified as a license reviewer for several categories of licenses but not qualified for all categories. We plan to finish his full qualification by May 1998.

Jose Diaz - not qualified as a license reviewer. He is in the process of qualification with a goal of completion in September 1998.

Lee Franklin - not qualified as a license reviewer. A schedule for his qualification has not been developed.

Michael Fuller - qualified as a license reviewer for several categories of licenses, but not qualified for all categories. We plan to finish his full qualification by July 1998.

Andrea Jones - not qualified as a license reviewer. She is in the process of qualification, with a goal for completion in January 1999.

! Wade Loo - not qualified as a license reviewer. He is in the l process of qualification, with a goal for completion in March 1998.

l 9

l Orysia Masnyk Bailey - not qualified as a lice.1se reviewer. She is in the process of qualification, with a goal for completion of in July 1998.

l l Bryan Parker - not qualified as a license reviewer. He has begun the process of qualification, with a goal for completion in May 1999.

14 Please identify the technical staff who left the RCP/ Regional DNMS l program during this period.

i

! RESPONSE: )

Those who left the Fuel Facility Branch are discussed in B.I.S.

below. Division level and materials staff changes were:

Bruce Mallett - assigned to position of Acting Deputy Regional Administrator 1 Jerry Ennis - retired John Potter - retired Earl Wright - retired )

I

15. List the vacant positions in each program, the length of time each position has been vacant, and a brief summary of efforts to fill the vacancy.

RESPONSE

Fuel Facility Inspector (2) - Two positions became available in the Fuel Facility Branch when one staff member (GS-14) transferred to NRR in July 1997, and another staff member (GS-14) retired in 3 August 1997. A GS-14 and two GG-13s were posted in September 1997. One of the GS-13s was filled by a transfer in October 1997.

This individual was selected for the GS-14 in November, 1997, leaving two GS-13 positions open again. Region II interviewed

three applicants for the GS-13s in December 1997. The individual l selected declined to move to Region II (from outside the agency)

! for personal reasons. The GS-13 positions have been re-posted.

Radiation Specialist - In anticipation of the retirement of two staff in early 1998, Region II selected a GS-13 Radiation Specialist in October 1997. In addition we posted a GS-14 Senior

! Radiation Specialist position in November 1997 and selected the I

GS-14 from Region II materials staff in December 1997. We posted a GS-13 in December 1997. Apalications are currently being received and interviews will 3e scheduled after the candidates are rated.

I 10 l

l

Branch Chief. MLIB2 - The Deputy Division Director is acting as Branch Chief for this Branch. The Branch Chief position will be I filled by a staff member from HQ for a five week period beginning j late in January 1998. We are in the process of evaluating options for filling this position.

l Secretary. NFS Resident Office (part time) - We posted and advertised the position, but the individual selected declined to accept the job. We have re-advertised the position.

l l IV. Technical Quality of Licensina . Actions

16. Please identify any major, unusual, or complex licenses which were issued, received a major amendment, terminated, decommissioned.

! bankruptcy notification or renewed in this period. Also identify any new or amended licenses that now require emergency plans.

RESPONSE

l Licensing cases that involved major, unusual or complex liccases included:

l AREC0 - renewal of large underwater irradiator.

B&W Services - license for site remediation. Major, complex license.

Baxter - request by irradiator licensee to perform l maintenance of safety related equipment.

Unusual and complex amendment still in progress.

Syncor - complex change of ownership.

Ashford Pharm. - radiopharmacy. Majorlicense.

St. Luke Pharm. - radiopharmacy. Majorlicense.

There were four cases involving bankruptcy: Haben Energy.

Westmoreland Coal, Now Care, and Newport News General Hospital.

There were no new licenses requiring emergency plans or amendments to licenses that increased possession limits such that emergency plans would be required.

17. Discuss any variances in licensing policies and 3rocedures or exemptions from the regulations granted during t1e review period.

RESPONSE

Unless Region II is authorized to issue an exemption to the regulations in an NMSS Policy and Guidance Directive or generic Technical Assistance Request (TAR) response from NMSS. Region II 11

i l

l l

l evaluates such requests and sends a TAR to NMSS for review. As l part of self-assessment process, we performed an audit of our l

process for granting exemptions. Attachment 17 is a copy of a memorandum documenting this audit of exemptions granted for the period April 1996 to April 1997. This audit concluded that l exemptions granted were either approved in an NMSS Directive or were reviewed by NMSS via TAR from the Region. On June 30. 1997 Region II provided a listing of exemptions to licensees during the period January 1 to June 30, 1997 (Attachment 17a). Since that time. B&W Services was issued a remediation license that included i license conditions (standard for such licenses as specified in

! Policy and Guidance Directive FC 94-02) that did not require an

emergency plan or financial assurance.

In addition, we occasionally identify cases where we have deviated l from licensing guidance in error. In these instances, we review

! each case and take corrective action. Cases where we have

identified licensing actions not fully in accordance with policies and procedures include:

l Ashford PharmaLogic - We issued a radiopharmacy license without i verifying that the facility was a pharmacy licensed by the State, i We received an allegation to this effect. In reviewing the allegation we found that the Commonwealth of Puerto Rico did not require a license for Ashford to operate. We have sent to NMSS a TAR for review. We have reminded materials staff that we are required to verify that applicants for radiopharmacy licenses must demonstrate that they are a pharmacy licensed by the State and that if the State does not require such a license, we are to send a TAR to NMSS for review for an exemption to our regulations.

Westinghouse de Puerto Rico/Wittnauer Worldwide - We amended the license to transfer the license to Wittnauer without first obtaining new financial assurance. In the application for transfer. Wittnauer committed to provide Financial Assurance information separately, but did not do so promptly. We identified  !

this discrepancy in December 1996 during our annual review of Financial Assurance files as required by MD 8.12. We subsequently l l

coamunicated with Wittnauer to obtain the Financial Assurance -

documentation (including a Demand for Information (DFI)). In res)onse to the DFI. Wittnauer provided a Financial Assurance l paccage, which has been reviewed by an NRC contractor who identified deficiencies in the documentation. We are in the process of requesting additional information from Wittnauer.

Isomedix Operations Inc. - We transferred the Abbott Health Products license to Isomedix without having a satisfactory Financial Assurance package from Isomedix. The application for transfer committed to provide Financial Assurance, but it was not reviewed and found acceptable before the transfer of the license.

The Financial Assurance package was found to be deficient, and these deficiencies were sent to the licensee for resolution.

12

I To assure that we do not again transfer licenses without adequate Financial Assurance, we have discussed with materials staff the requirement to have an acceptable Financial Assurance document  !

i from the entity taking over a license before transferring a license.

18. What, if any, changes were made in your written licensing procedures (new procedures. u during the reporting period? pdates, policy memoranda, etc.)

RESPONSE

Generally Region II attempts to minimize the issuance of Region II-specific licensing procedures. As a result of our self-assessment findings, we issued one such procedure during the period. Licensing Procedure 1.0, Processing of Exemption Requests.

which is included as Attachment 18.

19. For NRC Regions, identify by licensee name, license number and type, any renewal applications that have been pending for one year or more.

RESPONSE

There are currently none in Region II. Region II, as part of our self-assessment reviews, identified that we has several renewals that had been in process for some time and were not coming to closure. We began a focus on these renewal applications. As a result, when licenses were extended by regulation. Region II had very few renewals pending.

V. Resoonses to Incidents and Alleoations i

20. Please provide a list of the reportable incidents (i.e.. medical '

misadministration, overexposures, lost and abandonea sources. l incidents requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less notification, etc. See i Handbook on Nuclear Material Event Reporting in Agreement States '

for additional guidance.) that occurred in the Region / State during the review Jeriod. For Agreement States, information included in previous su)mittals to NRC need not be repeated (i.e., those submitted under OMB 3150-0178). The list should be in the following format:

LICENSEE NAME LICENSE # DATE OF INCIDENT TYPE OF INCIDENT TSPONSE:

Events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification of the NRC are captured by AE00 Event Reporting System, and frequently result in a PN or MR.

The dates listed below under " Event Date" are the date the event (s) was reported, since the report may be for several events '

13

over a period of time. In the cases of significant events, we promptly notify NMSS, OSP and the ED0's office verbally, and followup with a PN or MR.

Materials Licensees LICENSEE NAME LICENSE # DATE OF INCIDENT TYPE OF INCIDENT Dr. Jose De. Leon 52-19206-01 12/11/97 misadministrations Ryder Hospital 52-21026-01 12/11/97 misadministrations i V A. Hosaital, 01-00643-02 12/10/97 received cont.

Birminglam, AL package WV Deat, of 47-07838-01 12/02/97 damaged moisture l Hig1 ways density gauge l Navy, Bremerton 45-23645-01NA 11/25/97 received cont.

' Naval Hospital package Virginia Beach 45-11035-01 11/25/97 misaJministration Hospital VA Army, Ft. Campbell 12-00722-06 11/20/97 broken H-3 l KY collimator Air Force, 42-23539-01AF 10/31/97 lost compasses Tyndall AFB, FL (H-3) l Navy, Arlington, 45-23645-01NA 10/08/97 lost Am-241 VA sources Baxter Healthcare 52-21175-01 10/1/97 inoperable floor PR mat l Mayaguez Medical 52-13598-03 9/17/97 I-131 spill Center, PR Ames Inc., Scrap Yard 9/3/97 found cont, steel Parkersburg, WV Marshall Miller & 45-17195-01 8/29/97 overexposures Assoc., VA Army, Ft. Bragg, 12-00722-13 8/*" lost Am-241 NC sources Law Engineering 45-21498-01 8/2J/97 lost moisture Chantilly, VA density gauge Weavexx, Wake 32-18405-02 8/26/97 lost moisture Forest, NC density gauge Potomac Hospital, 45-15367-01 8/1/97 found I-125 Reston, VA sources in aatient Northern Virginia 45-25221-01MD 7/29/97 ligh film badge l

Isotopes VA reading (445 Rem)

Bluefield Medical 47-19142-01 7/14/97 potential Center, WV misadministration Steel of WV, Scrap Yard 6/4/97 found cont, steel Huntington, WV Hos) ital San Pablo 52-21325-01 5/14/97 lost Cs-137, l'

PR Co-(0, and Co-57 l

cal. sources Luis Vasquez Out)t. 52-16660-03 3/7/97 misedministrations Sve. Clinic, PR 14 I

l

i l'

National Hospital 45-17123-01 ' 2/27/97 received cont.

l Med. Ctr., VA package Navy, Arlington, VA 45-23645-01NA 1/27/97 lost Am-241 source Jaca & Sierra Test. 52-19064-01 12/31/96 lost moisture Labs. PR density gauge Army. Ft. Bragg, NC 12-00722-07 12/9/96 missing cont. dirt (Pm-147)-

l Pinkerton Chevrolet, Gen. License 11/14/96 lost Po-210 VA sources Baxter Healthcare PR 52-21175-01 11/13/96 inoperable floor mat L

Army, Ft. Bragg, NC 12-00722-06 11/8/96 area cont. with' H-3, 2 exposures i PSI, Bristol, VA 45-25088-01 11/8/96 overexposure j' Portsmouth General 45-09102-02 10/31/96 lost Cs-137

! Hospital, VA cal. source Herman Strauss Scrap Yard 10/4/96 found cont, steel Industries Wheeling, t

WV Navy, National Naval 45-23645-01NA 10/1/96 lost Pd-103 source Medical Center, MD l

VA Hospital, Memphis 41-00119-08 9/23/96 misadministration i TN i

Navy, Arlington, VA 45-23645-01NA 9/4/96 lost Am-241 sources Dr. Fernandez, PR 52-25114-01 8/7/96 misadministrations Centro de Card. Y 52-25075-01 5/16/96 misadministrations

! Med., PR l Longview Insp., 45-25279-01 4/10/96 lost radiography l Richmond, VA camera l Centro De Med. Nuc., 52-25127-01 3/29/96 stolen spent Mo-99 l PR generators l VA Hospital Tampa, 09-15294-01 3/1/96 cont, area with

FL P-32 PR Opth, Inst., PR 52-25114-01 3/1/96 misadministrations l Fuel Facilities BWXT/NNFD SNM-42 6/10/96 Alert-Tornado.

SRI Response l BWXT/NNFD SNM-42 12/19/96 91-01-Mass limit exceeded in vault.

SRI response.

BWXT/NNFD SNM-42 03/04/97 Alert-Spill causing evacuation. SRI response.

15 1

1

BWXT/NNFD SNM-42 07/28/97 91-01-Transport cart exceeded mass limit. SRI response. Special RII/HQ inspection (97-08).

BWXT/NNFD SNM-42 09/96 Although not reportable, a special RII inspection was conducted in response to a series of zirconium fires.

FCF SNM-1168 11/13/96 50.72(b)-Loss of Fuel Assembly.

Special RII/HQ inspection (IR 96-205).

Westinghouse SNM-1107 3/11/97 70.50(b)(3)-

Medical Treatment involving contamination.

Westinghouse SNM-1107 4/17/97 74.11(a)-Missing Fuel Rods. Special HQ/RIl inspection.

Westinghouse SNM-1107 6/23/97 91-01-Loss of Contingency in pellet line.

Special HQ/RII inspection.

Westinghouse SNM-1107 10/16/97 91-01-Deficient analysis on ventilation system.

GE SNM-1097 3/28/96 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report-small fire in incinerator.

GE SNM-1097 3/29/96 91-01-Loss of Geometry control l (powder spill).

16 l

l

GE SNM-1097 7/12/96 50.72(b)(2)(I).

Alert. Hurricane force winds.

GE SNM-1097 8/8/96 91-01-Loss of criticality control. Bulging.

tank.

GE SNM-1097 10/30/96 91-01-Mass control l loss. Scrubber l failure.

l GE SNM-1097 12/3/96 91-01-Failed l calciner tube.

Special HQ/RII {

l inspection (IR 96- j 12). 1 1

l GE SNM-1097 2/3/97 91-01-Buildup of )

material in filter !

l housing.

GE SNM-1097 9/5/97 70.50(b)(2)(ii)- t Release through recovery stack.

NFS SNM-124 3/25/96 70.50(b)(2)(I)-

Failure of criticality alarm.

NFS SNM-124 4/2/96 Site Area Emergency-Incinerator fire.

AIT (IR 96-05). ,

1 NFS SNM-124 8/8/96 70.50(b)(2)(I)- 1 Criticality alarm system failure.

NFS SNM-124 10/22/96 UPS for security system inop.

NFS SNM-124 9/4/97 29.73-FFD-Positive drug test.

l t

17 l

21. During this review period, did any incidents occur that involved equipment or source failure or ap3 roved operating procedures that were deficient? If so, how and w1en were other State /NRC licensees who might be affected notified? For States, was timely notification made to NRC? For Regions, was an appropriate and timely PN generated?

RESPONSE

Haterials Licensees PSI (11/8/96)- initially it appeared that there might have been a malfunction of the aortable gauge, but evaluation of the gauge by the manufacturer, caserved by a member of the NRC AIT, showed no indication of gauge malfunction. A PN was issued.

Baxter Healthcare (10/1/97 and 11/13/96)- failure of the floor mat that activates source drop when an individual steps on the mat.

The failures resulted from product carrier impact on the mat and -

these failures did not appear to be of generic applicability. A l MR was issued after the 1996 event. The 1997 event was discussed with NMSS in the morning telephone call.

Baxter Healthcare - failure of roof plug interlock switch. Based I on NRC and irradiator vendor review of the failure, it did not appear to have generic applicability. This'was identified during a routine inspection. An MR was issued.

Region II did contribute to the development of Information Notice 96-66. Recent Misadmir n rations Caused by Incorrect Calibrations of Strontium-90 Eye Applicators. PNs were issued if the above events met PN criteria.

Fuel Facilities Many of the events above did involve failures of equipment or inadequate procedures. In each instance. Region II (frequently in conjunction with NMSS) reviewed the failures to determine if there might be applicability to other licensees. Because of the uniqueness of equipment and procedures at these facilities, there were no failures identified that had generic applicability.

I 22. For incidents involving failure of equipment or sources, was

, information on the incident provided to the agency responsible for l evaluation of the device for an assessment of possible generic l design deficiency? Please provide details for each case.

RESPONSE

Region II did not identify any failures that warranted such a referral.

18 I

t- --

l

23. In the period covered by this review, were there any cases involving possible wrongdoing that were reviewed or are presently undergoing review? If so, please describe the circumstances for each case.

RESPONSE

l l Region II follows MD 8.8 and holds an Allegation Review Board i (ARB) meeting for each wrongdoing case with DNMS and 01 representatives as part of the ARB. The Deputy Regional l

i Administrator reviews the status of each 01 case with 01 monthly.

After each OI report is issued. DNMS and EICS review the report

for appropriate action.

l During the period. the Office of Investigation (01) opened 10 cases in the NMSS program areas. .These cases are listed the agency Allegation Management System (AMS). In one of these cases.

Baxter Healthcare Corporation. 01 substantiated that the RSO l deliberately authorized operation of the irradiator in an altered condition that was prohibited by Condition 14 of the license.

l This finding was provided to the licensee and the individual. and

! a pre-decisional enforcement conference was held on January 12.

l 1998. The final resolution of the case is in progress.

l During the IMPEP period. Region II completed enforcement action related to an 01 investigation of activities at NDT Services. In this case 01 found that the Radiation Safety Officer and former President of the Company deliberately failed to use qualified )

radiographers. The licensee was issued Severity Level I and Severity Level III violations. The two individuals were issued Orders prohibiting their involvement in licensed activities for five years. 1 l

l 24. Identify any changes to your procedures for handling allegations j that occurred during the period of this review.

a. For Agreement States. please identify any allegations referred to your program by the NRC that have not been closed.

j j

1

RESPONSE

l .

' Attachment 24 is a copy of ROI 1030. Revision 9. Processing Allegations. Complaints, and Concerns. This ROI provides details on the implementation of Management Directive (MD) 8.8. Management of Allegations. Region II has updated this ROI each time MD 8.8 has been updated. We review the status of allegations each week with the Deputy Regional Administrator.

19

VI. General

25. Please pre)are a summary of the status of the State's or Region's actions ta(en in response to the comments and recommendat1ons following the last review.

RESPONSE

The IMPEP/MRB recommendations for Region II action (numbers listed below are the number for the recommendation in the IMPEP report) and actions in response were:

(1) License reviewers add written explanatory comments in the tie-down condition listing the aaplicable sections in each old reference (i.e., references aefore the most recent license application) (Section 3.3).

Action: Licensing staff were informed to include such clarification in tie-down conditions, and Branch Chiefs have been verifying that such clarifications are in the tie-down conditions as part of their review of each licensing action prior to their concurrence on the action.

(2) Region II document the basis for complex or unusual licensing decisions, and retain these documents in the licensing file (Section 3.3).

Action: Staff were informed of the need to improve documentation, particularly when the written documentation might not be clear as to why certain actions were taken.

Since the last IMPEP, staff have been encouraged to document discussions with supervisors, managers, or program office staff that contributed to their decisionmaking. Each licensing action is reviewed by the license reviewer's Branch Chief.

(3) Region II continue to emphasize performing and documenting performance-based materials inspections, and internally evaluate progress on this issue in about a year.

(Section 3.4)

Action: Region II supervisors and managers have continued to emphasize performance-based inspection, including 3roviding information to staff in the Division Operating 1 31an in FY 97 to assist in such inspection (Attachment 25).

l In addition, this is emphasized in planning and in l discussion of results with staff. Region II has begun to require written ins)ection >lans for inspections of Type A broad licenses, wit 1 an emplasis on planning review of licensee performance in the more safety-significant areas. l In July 1997, the Acting Division Director audited a i sampling of inspection reports (narrative and Field Notes) 20 i

and discussed the reports, inspections and findings with select staff in an effort to determine the degree of performance-based inspection being conducted and documented.

This review found that there was considerable performance-based inspection being conducted, but that the documentation of inspections did not reflect this well. Supervisors and managers in the Division continue to emphasize performance-based inspection in planning, conduct and documentation of results. The revision of the materials inspection procedures and method of documentation that has been recently developed by NMSS should contribute to improved performance-based inspections and documentation.

(7) Allegations received by the Region which are outside of NRC jurisdiction be referred ex)editiously to the appropriate regulatory authority, and tlat the Region follow MD 8.8 and guidance developed by the Office of State Programs which specifically addresses referrals to Agreement States

(~0ffice of State Programs Internal Procedures for Management of Allegations") (Section 3.5).

Action: All allegations are reviewed by the Region II ARB. .

The ARB normally designates DNMS/the Agreement State Program Officer as responsible for referral of allegations to '

Agreement States. Referrals to licensees are normally i assigned to the Branch responsible for inspecting the '

licensee. Those issues that are not within the NRC's jurisdiction which an ARB suggests be referred to a party <

outside the NRC are normally assigned to the Branch  !

responsible for inspecting the licensee or to the Government Liaison Officer for referrals to other government agencies (other than Agreement State Programs). The status of i referrals and licensee or Agreement State responses to allegations (when required) is monitored weekly through an {

1 AMS printout of open allegations, and the status is ,

discussed weekly with the Deputy Regional Administrator.

Attachment 25a is a copy of a recent summary of allegation i timeliness for DNMS. (Note that the four cases over 180 days involve two 01 cases, a referral to an Agreement State and on case awaiting a TAR response.) If an allegation indicates improper actions by an Agreement State, the allegation is discussed with representatives of the Office of State Programs (OSP), and referred to OSP for review by l an OSP ARB. In instances where there are allegations that contain both technical issues and issues related to the Agreement State performance, a joint ARB has been held that '

includes OSP and Region II re3resentation. Since the last IMPEP, Region II was audited )y the agency Senior Allegation Advisor, and found to have generally effectively implemented MD 8.8. '

21 l

(8) Region II closely adhere to ROI 1030. Rev. 7, dated March 18, 1996, regarding advising allegers of the status of allegations every six months, particularly for allegations requiring extended time periods to resolve (Section 3.5).

Action: The status of allegations, including six month notifications, is reviewed every week with the Deputy Regional Administrator. Each Monday, a Senior Allegation Coordinator obtains a printout that shows the time period sinco last written contact with each alleger. For those that are approaching six months, a status letter is developed and sent. This has been effective in assuring that status letters are sent, with rare exception. When the new AMS went into operation there were some cases that did not receive timely letters because of problems in using the new system. There also have been instances when six month letters have not been sent when the closure letter to the i alleger was in concurrence at the time. Now the system in place is assuring the status letters are sent in a timely manner.

From 1994 IMPEP:

(8) Region II should reconcile its written internal procedure (Branch Guidance Memoranda 4.2) for event evaluation and its i informal practices for event evaluation.

Action: With the initiation of the Nuclear Material Event Database (NMED), Region II began using NMED as the database for events rather than using the Region II-specific method.

Region II inspection staff have been informed that, as part of the preparation for inspections, they are to review NMED for events at facilities to be inspected. We are in the process of revising the Field Notes to add this as a specific item to be reviewed prior to an inspection.

26. Provide a brief description of your arogram's strengths and weaknesses. These strengths and wea(nesses should be supported by examples of successes, problems or difficulties which occurred during this review period.

RESPONSE

Each Branch performs self-assessments of their program areas quarterly. The assessment criteria for FY 97 are provided in i Attachment 26. The assessment criteria for FY 98 are the elements l l in the Region II Operating Plan (Attachment 26a). These self- l assessments identify areas where aerformance is good and where a performance needs improvements. 4here improvement is needed, the i Branch develops actions to implement improvements. The current i strengths and areas needing improvement are listed below. l l

22 1

Haterials Program The strengths in the materials program area are:

1. Safety focus of inspections and identification of safety issues.

2. Response to events - understanding of event, evaluation of safets significance of events (with NMSS).

l

3. Timeliness of inspections.

The areas we are working to' improve in the materials area are:

l 1. Quality and timeliness of materials licensing actions.

l 2. Quality and timeliness of materials inspection resorts.

3. More effective use of NMED. including assurance t1at it is complete and accurate for Region II licensee events.

4. Development of a more efficient method or accumulation and monitoring information needed for program management.

5. More effective and efficient completion of licensing actions.

6. Timeliness, completeness and accuracy of filing in docket

files.

Fuel Facilities The strengths in the fuel facility inspection program include:

I

1. Safety focus of inspections and identification of safety issues.

2. Overall planning of inspections (Master Inspection Plan) for each facility with emphasis on risk specific to each facility. I

3. Response to events - understanding of event, evaluation of  !

safety significance of events (with NMSS), followup to j

, monitor licensee corrective action, integration of event into future planning.

The areas we are working to improve in the fuel facility area are:

1. Technical quality, clarity, and content of draft inspection reports (prior to review by the Branch Chief), including improving the flow of inspection findings from report observations and findings, to conclusions, to enforcement,

, to executive summaries, to site integration matrices, to Licensee Performance Reviews (LPRs).

2. Inspection planning for specific inspections (not overall plan for a facility and not for special inspections) with

emphasis on performance measures (implementing the overall facility plan into specific inspections).

3. Cross-training of staff in technical areas to increase l versatility and scheduling flexibility. l L

4. Timeliness of enforcement actions. l f 5. Timeliness of team inspection reports.  !

l 23

B. NON COMMON PERFORMANCE INDICATORS

1. Fuel Cycle Insoections Status of Insoection Proaram l 1. List in chronological order the fuel cycle inspections (or assessments, in the case of non-licensee facilities) performed during the reporting period by facility and type (i.e. U =

unannounced routine .nspections R = reactive inspections, D =

decommissioning inspections, etc.). Please include the inspection 3rocedure number (e.g., IP 88020). A sample format is shown

]elow.

RESPONSE

l The following is a list of the inspections aerformed by Region II since the last IMPEP. Inspections led by NiSS that included I

Region II participation are not included below. These inspections were conducted in accordance with the criteria of IMC 2600 and 2681 as implemented by the Master Inspection Plan (MIP). The development and change of the MIP are coordinated with NMSS.

' Inspections at fuel facilities are unannounced except for rare instances such as in responding to an event or in inspecting the readiness of a facility or portion of a facility for operation (GE l Dry Conversion Facility and NFS startup of certain operations).

l Decommissioning inspections are listed separately under l Section B.V.12. The inspections specified in the IMC were completed except for IP 88050. Emergency Preparedness (EP). at i Framatome in FY 97 because they do not have an emergency plan and i

the MIP planned not to do an EP inspection, and IP 83822, Radiation Protection, was done only once at Framatome in FY 97, as planned in the MIP based on the work at the facility.

Licensee Dates / Procedures Iyp.g BWXT 96-04 4/29/96 81912,88020.88015 81915,88010,88025 83822,88005,88035 l BWXT 96-05 5/2/96 81933.81601.81820 i 81930.81932.81501 81931, 93880 BWXT 96-06 5/11/96 88015.88020,83822, 92901 BWXT 96-07 6/22/96 88020.88005,88015 88025.92701, 24

l BWXT 96-09 7/12/96 81038,81915,81917, 81919,81920,81921 81924,81927.81916 81925,81911,81918, 81928 BWXT 96-10 8/3/96 92702,88020,88005, 88050,88015 BWXT 96-11 8/23/96 88050 BWXT 96-12 9/14/96 88050,88015,88020, 83822.88035,86740, 92701,92702.88045, 84850,88025,88010 BWXT 96-13 8/23/96 81934,81922,81935, 81930,81022,81912, 81914,81926.81034, i 81020,81929

]

BWXT 96-14 10/4/96 88055 Reactive L

BWXT 96-15 10/26/96 83822,88005,88020, I 88055,88010 BWXT 96-16 10/24/96 81911,81935,81020, 81022,81920,81914, i 81917,81925,81930, 81928,81038,81916, l

81919 BWXT 96-17 12/7/96 88020 BWXT 96-18 12/13/96 88045.88035,83822 BWXT 96-19 1/18/97 88020 BWXT 97-01 1/10/97 81022,81910,81918,

81923,81020,81335, 81034,81038,81926 ,

81913 l BWXT 97-02 3/1/97 88020,88025,88055 BWXT 97-03 2/28/97 81931,81914,81921, 81927,81934,81929, >

81922,81924,81932, 81933 BWXT 97-04 4/12/97 88020,88025 25

BWXT 97-05 5/24/97 88020,88005,88010, 92702,88050 BWXT 97-07 7/5/97 88020.81925.81928, 81601.81911,81916, 81919.81920,81917, 81915.81501.81930 BWXT 97-08 9/15/97 88020,88005.88010 Reactive BWXT 97-10 9/27/97 81916,81919,81920 81917,81915.81501, 81930.88020 BWXT 97-11 11/1/97 88020,81022.81911, 81914,81923.81930.

, 81501.81601.81935, 81924.81922.81913, 81910,81020,92702, 88020 BWXT 97-12 12/6/97 88020.88005 BWXT 97-13 1/10/98 88020 FCF 96-02 3/29/96 88005.88015.88025, 36100,88020,86010 FCF 96-03 7/26/96 88020,83822,88055.

92701.88050 FCF 96-04 9/23/96 88045.88035,84850 FCF 97-01 1/17/97 83822,92701,84850.

88045,92702, 88035 FCF 97-02 3/4/97 92701.92702 FCF 97-03 4/4/97 88020 FCF 97-04 5/16/97 88055,92702 FCF 97-05 6/20/97 88025,88010.88005, l 88020 l

FCF 97-06 11/7/97 88010.88005.8804b, l

86740,84850,88035 88020.84900 GE 96-02 3/1/96 88005.88020,88015 26

GE 96-05 4/19/96 88050 GE 96-06 5/24/96 88025,92701,88020, 88015 GE 96-07 8/9/96 84850,83822.86740 GE 96-08 8/2/96 88025,88005,92701, 88020,88055,92702 GE 96-09 7/26/96 88020 GE 96-11 10/18/96 88025,88020,88005 GE 96-12 12/8/96 88020 Reactive GE 97-01 1/31/97 88020.88010.88005, 88010.88025,92701 GE 97-02 3/21/97 88020,88010,88025 GE 97-03 3/28/97 83822.88045,88035 GE 97-04 5/9/97 88020,88005,88025, 88010,92701 GE 97-05 4/18/97 88055.83822.88050 GE 97-06 6/27/97 88020,88005.88010, 88025.92701, GE 97-07 7/18/97 84900,88020.86740, 88050,84850, GE 97-08 12/12/97 88025,88020 NFS 96-02 3/8/96 81502 NFS 96-03 3/22/96 81924.81927,81931, 81911,81913,81919, 81921,81926.81928, 81920,81918,81923, 81910 NFS 96-04 4/18/96 81501,81932,81934, 81917,81925,81914, 81916,81929.81912, 81930.81601,81933, 81915,81922 NFS 96-05 4/6/96 93800 Reactive 27 l

k _ _ _ _ _ _

l l NFS 96-06 5/12/96 81915.81022,81038, 81501.81917,81916.

81601,81911,81020.

l 81034,81030,81820 l NFS 96-07 5/17/96 88055,88010.88020.

88025,88015.88005 i NFS 96-08 5/24/96 83822,92703,88045, 92701,88035 NFS 96-09 6/5/96 81925,81920,81038, 81915,81917,81919, 81911,81020,81928.

81916 l

l NFS 96-10 7/12/96 84850.88045,88050. l l 83822,86740 NFS 96-11 8/30/96 88010.88025,88020.

l 88025.92703.83822, l 81929,88055.92701 l NFS 96-12 9/12/96 81918,81924.81820, l'

81601,81935,81022. l 81038.81911.81913. l

( 81915,81917,81921, i 81922,81923.81927, !

l 81929,81931,81933.

81925,81934,81034, )

81920,81501,81910, ;

i 81932.81926.81916, i l 81928,81030.81020, l 81912,81919,81914 l

NFS 96-13 9/27/96 88020.88010,88025.

88005 l NFS 96-14 12/18/96 88035,88045,83822 NFS 96-15 11/15/96 88025,92701,88010 92701.88020 NFS 96-16 11/22/96 81919,81930.81501, 81038,81918,81923, 81924.81911,81601.

! 81920,81928,81935 NFS 97-01 1/28/97 88055,88025,88020 NFS 97-02 3/7/97 86740,83822,84850 92701 28 i

I NFS 97-03 3/21/97 88020.81335.88055 I NFS 97-04 4/25/97 88025.92701,88020 NFS 97-05 5/16/97 92701',88045.88035, 4 NFS 97-06. 8/15/97 88020,81922.81929.

l. 81933,88055.88025, 81914,83822.88005, 88010,81501.81934, 81912,88015

)

NFS 97-07 6/13/97 88050 I NFS 97-08 6/27/97 81917,81925.81918, 81034.81915.81916, 81923,81926,81924, 81038 l- NFS 97-09 9/29/97 81917,81919,81921,

! 81925,81920,81601.

81930,81927.81928, 81931,81815,81020, 81022.81911,81932, 81935,81930,81810, 81913,81915.81910, 81916,81820,81915, 81912,81910,,81920, 81935 NFS 97-10 9/27/97 88020.88015,88025.

81930.88055 NFS 97-11 11/8/97 88020,88025,88015, 83822 l NFS 97-12 12/20/97 88025.83822,88015,

( 88020.81911.81916, 81919,81923,81926, 81502,81917,81915, 81920,81038,81928, 81925.81921,83822, 81601.81935,88055, 88060,88058,88035, 81930.88010,88025.

81501,88057,88061, 88056,88059 NFS 97-13 1/31/98 83822.88025,88020, 88015 29 J

T West 96-02 7/12/96 88055.88010.88025, 88005 West 96-03 10/4/96 88050.88045.83822.

88035.84850 West 96-04 9/27/96 88015.88020 West 96-05 11/1/96 88025 West 97-01 2/6/97 83822.84850.86740 West 97-02 2/28/97 88020 West 97-03 5/30/97 88020.88005 l

l West 97-04 6/27/97 88045.88035 l West 97-05 9/26/97 88050.88055.88020.

88010.88005

2. Please identify any individual licensees with planned inspection frequencies different from the normal frequencies listed in Table 1 of the Appendix to IMC 2600, and indicate the inspection procedure (s) so affected.

RESPONSE

, All inspections are generally based on MC 2600 required frequencies. Specific adjustments are based on LPR results for a

, particular facility. The actual MIP for each facility was-developed in conjunction with NMSS for FY 97 and FY 98. Any I changes to the MIP have been coordinated with NMSS.

Attachments FF2 and FF2a contain general details of planned inspections for the branch. As noted in B.I.1. above, in FY 97 there were two inspections listed in IMC 2600 that were not conducted at Framatome. Attachment 7a discusses particular areas of emphasis for each facility.

Technical Quality of Insoections

3. With reference to the inspections described in Item 1 above, please indicate the supervisory accompaniments made during the review period, and by whom. Also, briefly describe the way the accompaniments were conducted and documented.

RESPONSE

The Region II Operating Plan establishes goals for inspector accompaniment by su)ervisors. The DNMS self-assessments review accomplishment of tiese goals on a quarterly basis. Regional i Office Instruction (ROI) 2213 (Attachment 9) establishes the 30 L_ _. _

l process for inspector accompaniments. This establishes that, on the average, the Division Director or Deputy will visit a site each month, each Branch Chief will accompany an inspector each quarter, and each Branch Chief will accompany each inspector once each fiscal year. The Branch Chief selects the accompaniment based on the schedule and the significance of any issues to be reviewed during the inspection. The accompaniment includes a l review of the inspection plan, direct observations of the l inspector, debriefing of issues, attendance of exit meetings, and

feedback to the inspector. The ROI requires documentation of the  ;

I site visits by each supervisor. Copies of such documentation is  !

provided as Attachment 9 for those visits conducted in the )ast six months. We identified that such documentation was not )eing l

completed, and have re-emphasized to supervisors and managers that this must be done in accordance with the ROI. A check of this documentation on a quarterly basis has been added to the DNMS tracking system.

l In addition, the Branch Chief observes the performance of each

! inspector during an inspection before recommending the individual be qualified as an inspector.

See Attachments 8, 8a, 8b 8c, 8d and 8e for accompaniments.

i Technical Staffino and Trainina 1

! 4. Please list the professional (technical) personnel assigned to l perform inspections in the fuel cycle facilities inspection program, and the fractional amount of 3erson-years of effort to which they are normally committed in t1e program. Also, include the general inspection areas of responsibility (e.g., E -

environmental protection, M = nuclear criticality. 0 - operations, i

P - physical security, R = radiation protection. T = other). For those who joined the program since the last review, and any others who have not yet met the qualification requirements of fuel cycle facility inspection staff, please indicate when they joined the staff. the degrees they received, the years of experience in the general areas they inspect (e.g. , health physics, engineering, etc.). and the extent to which they are qualified as NRC inspectors. A sample format is shown below.

Nyg Position Level of Effort Insoection Ares

RESPONSE

All individuals listed below are qualified inspectors per IMC 1246. The Senior Resident Inspectors were qualified under a Region II develoaed program reviewed and concurred in by NMSS. In addition, DNMS o3tains support from the Division of Reactor Safety stc c' for certain engineering reviews when needed.

31 l

NAME LEVEL OF INSPECTION BACKGROUND EFFORT AREAS AYRES* 1.0 N0 Chemical Engineering GL0ERSEN* 1.0 ER Radiological Protection 1

GOODEN 1.0 R T(EP) Biology l

ENOR HUGHEY 1.0 Chemistry l HUMPHREY 1.0 EN0R Industrial Engineering 1

l SEYMOUR* 1.0 N0 Chemical Engineering TOBIN 1.0 P Physical Security MCALPINE 1.0 Branch Chief Chemical Engineering l " Also have Project Inspector respons1bilities.

Seymour Humphrey and Ayres have not completed all courses in the current MC 1246, but are interim qualified until these courses are completed. (See the response to item A.I.12 above for their degrees and experiences.)

5. Please identify any professional or technical staff who left the fuel facility inspection program during the review period, and if possible, describe the reasons for their departures.

Describe what plans and procedures are in place to assure full coverage of the specified fuel cycle inspection procedures, as specified in Inspection Manual Chapter 2600. in view of the possible impacts of retirements and other turnover on a small inspection staff. Also, please describe the extent to which current fuel cycle inspection program goals have been achieved, and the reasons for any differences between the goals and the actual implementation of your program as the result of such personnel issues.

RESPONSE

The staff who left the Fuel Facility Branch during the period were Craig Bassett (transferred to NRR), Dennis Kasnicki (resigned),

and Gerry Troup (retired). Prior to these staff leaving DNMS established a listing of skills needed in the Division, and developed backups so that skills would not be lost if an individual left the agency. As a result. when the individuals retired, there were sufficient staff with the necessary skills to continue activities. For example, in anticipation of Gerry Troup's retirement, we were developing David Ayres as a fuel facility operations inspector. In planning for the inspections l for FY 98. the required inspections were planned using the current i

staff. Attachments 2, 2a, and 2b show the planned inspections by facility and staff member. This plan does not include reactive 32 l

inspection that might be needed, and if there is substantial reactive inspection, the schedule for inspections will be revisited. As noted in I.A.15 above, two Fuel Facility Inspector positions are currently being re-posted.

II. SDMP Procram

6. What is the status of meeting the milestones in SECY-96-207 for the SDMP listed sites? Were any significant delays identified and corrective actions put in place in a timely manner? Are policy issues being resolved in a timely manner?

RESPONSE

Region II has no SDMP sites. There are sites where we are following up on licensee's actions for cleanu) in a manner similar to SDMP remediations, e.g. NFS. portions of tie GE site, and part of the Framatome site.

III. Uranium Recovery Procram

7. Please include information on the following questions in  :

Section A. as they apply to the Uranium Recovery Program: 1 Status of Materials Inspection Program- AI. 1-3. A.I.6 i Technical Staffing and Training- A.III 12-15 l Technical Quality of Licensing Actions- A.IV. 19 '

l Responses to Incidents and Allegations- A.V. 20-23.

RESPONSE

Region II has no Uranium Recovery sites.

IV. General l 8. Provide a summary of actual expenditures and accomplishments as I

compared to operating plan / budgeted expenditures and accomplishments for FY 98 to date. Discuss reprogramming changes l or diversions of resources for items unbudgeted.

RESPONSE

The information below for resource expenditure is from the RWAT printout, but does not include resources in the EICS staff for support in coordination of escalated enforcement and allegations.

PROGRAM FY98 BUDGET EXPENDITURES THRU (12/20/97)

Materials Licensing 2.3 1.09 Materials Inspection 4.0 1.22 Event Evaluation 2.2 0.43 33

Program Initiatives

• 4.6 0.47 Fuel Cycle Inspection 9.5 1.90 LLW ins)ection 0 0 Matls. Jecomm. Insp. 0.8 0.11 Uranium Rec. Insp. 0 0 React Decomm. Insp. 0 0 Spent Fuel Stor. Insp. 0.4 0.04 TOTAL 23.8 5.26

• Includes regional initiatives. IMPEP, GLA registration program, Part 35, Regulatory Product Development activities, risk assessment, and regulatory guidance activities.

Our initial analysis of the data for the first quarter of the FY shows that the Region is under-spending resources at a rate of approximately 2.0 FTE/yr, but again this does not include EICS support for escalated enforcement and allegations. The under-expenditure in the Fuel Cycle Inspection area results from the two o)cnings that the region is recruiting for. The underspending in t1e Spent Fuel Storage Inspection Area, which is also in the Fuel Facility Branch, is a result of the schedule for the North Anna ISFSI facility, which has only recently started active construction and as a result of planning ISFSI inspections later in the FY. Resources will be spent in this area as part of the inspection of this new ISFSI construction and in completing the l

routine inspection program for the other ISFSIs in Region II. The rate of resource use for Program Inititiative is low because of {

I the number of staff assigned to Guidance Consolidation Projects '

early in the FY. We currently have four staff assigned to Projects and thus the resource use should increase for the l remainder of the FY. The rate of resource use for " Materials i Licensing Casework" is higher than the budget. and this results from our emphasis on competing old casework actions and the training of inspectors to become qualified license reviewers. We expect our rate of use of resources for decommissioning to ,

increase since we recently began an emphasis on terminated sites  ;

resolution.  !

9. Provide any comments and recommendations regarding the  ;

effectiveness of Headquarters support to regional activities an~

the Region / Headquarters interface. Identify any regional interaction with Headquarters and licensees to improve the quality '

of your licensing / inspection program.

RESPONSE

In general. Region II views the interface between NMSS and OSP to be very effective. When issues or potential interface problems appear, we believe that Region II and NMSS and OSP have worked effectively to resolve them. For example, one area we have emphasized this past year was to clarify, in response to an event at a fuel facility, whether NMSS or Region II had the lead for 34

followup. We have worked to make this clear after receiving initial information, and we believe this has worked effectively.

In addition, the Agreement States Officer has worked effectively with OSP in the application of the IMPEP program at Agreement States.

10. In which areas of licensing and inspection guidance do you need the most training? Please provide a list by priority, highest first.

RESPONSE

Region II's most pressing needs are in the areas of Fuel Cycle Facility Courses listed in IMC 1246. We recognize that the Fuel Cycle Courses are being converted to self-study in an effort to provide cost-effective training to the limited number of staff who need the courses. Region II will schedule staff into these self-study courses as they are developed for staff still needing the training. In addition. it would be helpful, as course are offered less frequently, if courses could be video taped and the tapes made available for new staff to review. We recognize that this is not as effective as personal attendance at the course, but this could be useful in training staff in the period until the course is presented.

V. Decommissionina

11. Identify all licensees that initiated decommissioning during the review period (do not include those licensees that were terminated during the review period, as DWM will use the LTS to compile this information).

RESPONSE

Lics.ngg License No. Insoector Date initiated

• Dept of Army Ft. McClellan 01-02861-05 0. Masnyk Bailey 6/96 PEPA-Montgomery 01-07317-01 J. Henson/0. Masnyk Bailey 8/96 P Dept of Interior USGS 45-15923-01 A. Jones 12/96 P Roanoke College 45-10085-04 J. Pelchat 12/96 PHHS-NIEHS 32-12358-01 J. Henson/B. Parker 1/97 j PEPA-Athens 10-10146-01 0. Masnyk Bailey /B. Parker 3/97

• Phillip Morris 45-00385-06 J. Ennis 4/97 35 I

1

College of William and Mary 45-03499-09 J. Pelchat/B. Parker 5/97 U.S. Navy 45-23645-01NA

• NAMRL B. Parker 7/97

1. • White.0ak J. Henson 9/97

1. • NOW CARE 47-25152-01 A. Jones 9/97 Radiology Services of Hampton 45-25349-01MD B. Parker 11/97 Charleston Area Med. Ctr. 47-15473-01 W. Loo /B. Parker 12/97

1. • Pharmaco 45-25314-01 0. Masnyk Bailey /J. Pelchat 1/98

12. List the decommissioning inspections that were carried out during l the review period. Please indicate if the inspection schedules i recuired by MC 2602 were prepared for licensed facilities I uncergoing decommissioning and if this schedule was developed, I indicate inspections that are overdue by more than 25% of the ,

inspection due date. Indicate which inspections revealed that licensees were not conducting their decommissioning in accordance with the approved decommissioning plan and describe how these I projects were managed. l 1

RESPONSE

]

N__E S1IE REPORT NO. DAIE Gloersen BWXT 96-12 8/4-9/96 96-18 12/9-13/96 j 97-10 8/17-9/27/97 Gloersen Framatome 96-04 9/10.13,23/96 Gloersen GE 96-07 8/5-9/96 97-03 3/24-27/97 97-07 7/14-18/97 j Gloersen NFS 96-10 7/8-12/96 96-14 11/4-7/96 97-05 5/12-16/97

• All entries in Item No.11 marked by an asterisk (*) were l inspected during and/or after the licensee's decommissioning i activities. l

. Schedules per MC 2602 were not generally required or prepared in these instances.

36 l

l l

4 i

e There were no inspections that were overdue by more than 25t.

l No issues were identified where licensee's were not conducting their decommissioning activities in accordance with decommissioning plans where such plans were required.

13. Identify all licenses (both terminated and otherwise) that have received in-process inspections of licensees

• final survey programs and confirmatory surveys, in accordance with IP 87104 and l

IP 88104, during the review period. Describe the inspection activities covered during inspections of these licensees.

RESPONSE

l . All entries in Item No. 11 marked by a pound sign (#) were j inspected and included a review of licensee's final surveys l l and/or confirmatory surveys were conducted.

• In addition to the above, the following licenses were  ;

terminated after decommissioning inspections were completed:

Arc Professional 45-25126-01 A. Jones 4 & 10/96

( Dept. of Army

' Ft. Knox 16-05033-01 W. Loo 6/96 SUB-417 l l

Provalid Corp. 45-25060-01 A. Jones 12/96

, 45-25060-02G Deit. of Interior l

rish & Wildlife 01-10058-01 0. Bailey 3/97

. In all of the above decommissioning ins activities included review of licensee'pections, s inspection decontamination / decommissioning methods and procedures:

instrumentation (calibration, MDA. counting, appropriateness and capability): review of records (inventory, use, surveys, leak tests, incidents, spills, etc.): and independent / confirmatory surveys per inspection plans developed for the inspection.

14. List all appropriate staff who have not yet met the qualification requirements of Decommissioning Inspector as identified in MC 1246. List the courses or equivalent training / experience they need to attend and a tentative schedule for completing these requirements.

37 I

l 1

RESPONSE

RegionIIhasdesignatedB.ParkerastheDecommissioningProject 6 Manager for all materials cases. In addition, we have designated i J. Henson, and O. Masnyk Bailey (materials) and W. Gloersen (fuel l facilities) as decommissioning inspectors. These staff were i

qualified as inspectors under the previous IMCs 1245 and 1246.

j Our plan is that these staff complete the currently required l courses for Decommissioning Project Manager and Inspector.

l Remaining IMC 1246 (6/7/96) courses are:

i -

Environmental Monitoring for Radioactivity - Masnyk Bailey,

to be scheduled Finance for Non-Financial Professionals - Henson. Gloersen.

Masnyk Bailey, and Parker (self-study course to be obtained)

Environmental Transport - Henson Gloersen. Masnyk Bailey.

and Parker (to be scheduled) i Root Cause/ Incident Investigation - Gloersen (scheduled for j

course 3/98) l

15. Identify by name, license number and type all licensees with outstanding decommissioning financial assurance reviews. Describe the outstanding issue and the plans to resolve the issue. <

RESPONSE

Isomedix. 52-24884 See A.I 21 above. The licensee has submitted additional information and that information is under ,

review by Headquarters. )

Wittnauer. 52-19336 See A.I. 21 above. The licensee was issued a Demand for Information to send in Financial Assurance 3 information. In response, the licensee provided Financial Assurance instruments, but these were found to be deficient by contractor review. The Region is sending the results of this review to the licensee.

Belair Quartz, 55-23732 The licensee was issued a letter that stated that their failure to provide Financial Assurance i information was being considered for enforcement. In response, the licensee sent Financial Assurance information and has been communicating frequently with the NRC in its efforts to obtain an adequate instrument. The licensee has encountered significant difficulties in obtaining, from financial institutions, an i instrument that satisfies our criteria. The licensee has even  !

offered to sent the NRC the actual money for the NRC to hold.  !

which is also not acceptable. We continue to work with Headquarters and the licensee to resolve issues.

l Communications Inst.. 45-06589 The licensee underwent a name ha nd the Financial Assurance information is under review by 38 l

l

PLEASE NOTE THAT ATTACHMENTS BEAR THE QUESTIONNAIRE NUMBER THEY ARE RELATED TO.

1 t

k f

l f

l l

l l

l 1 i

f I

l i

l 1

I

ATTACHMENTS Memorandum to Fuel Facilities Branch dated 7/14/97 a Targeting Information 1996 Site Visits a 1997 Site Visits b 1998 Site Visits c Accompaniment of Inspectors FY 96 d Accompaniment of Inspectors FY 97 e Accompaliment of Inspectors FY 98 PDI 2213. Rev. 7 a Trip Reports 0 Specifications 0a Instrument Inventory , 1 DNMS Organization Chart 7 Memorandum to B. Mallett dated 4/16/97 7a Memorandum to D. Cool dated 6/30/97 8 Licensing Procedure 1.0 4 ROI 1030. Rev. 9 5 Principles of Performance-Based Inspection 5a DNMS Allegation Timeliness Report 6 DNMS FY 97 Self-Assessment Plan . 6a RII Operating Plan Attachment FF2 RII FFB Inspection Targeting for FY 98 Attachment FF2a RII FFB Inspection Schedule for FY 98

May 16,1997 Babcock and Wilcox Company

) ATTN: Mr. J. A. Conner l Vice President & General Manager Naval Nuclear Fuel Division P. O. Box 785 j Lynchburg, VA 24505-0785 l

l

SUBJECT:

NRC PERFORMANCE REVIEW OF LICENSED ACTIVITIES 1

Dear Mr. Conner:

On February 6 and 10,1997, managers and staffin Region 11 and the Office of Nuclear Material Safety and Safeguards (NMSS) reviewed your program for conducting NRC licensed activities. The review evaluated your performance for the period July 1,19Po, through Septe.mber 30,1996, with a focus on performance during the last six montns of the period. The revle.w also provides you with -

feedback on how NRC senior management assesses your performance. T ne review will be used to form a basis for establishing the NRC inspection program for your conduct of licensed activities during the next year. 1 Ycur perfc mance was evaluated in the four major areas of safety operations, safeguards, radiologicai controls, and facility support. The results of the review will be discussed with you at the l

Babcock ar:d Wilcox Facility during a meeting to be arranged in the near future. During that meeting, l l

i we expect you to discuss your view of your performance in the same major areas. An outline of the i results of the review in the form of strengths and challenges is enclosed. I The review indicates that your performance was focused on safety in all areas. Performance in the .

areas of radiological controls and security was excellent. Performance in other areas was good. I You significantly improved in implementing followup action to correct deficiencies identified during your self-assessments and audits. Your greatest challenges appear to be in maintenance of equipment and operational upsets in the uranium recovery area.

Based upon the review, the NRC has decided to reduce the routine inspection effort in the area of radiological controls at your facility during the next period. We will perform special focus inspections in criticality safety operations, and maintenance in the uranium recovery area and increase our efforts in evaluating your material control and accountability program.

1 in accordance with Section 2.790 of the NRC's " Rules of Practice," a copy of this letter and its Enclosure will be placed in the NRC Public Document Room.

Should you have any questions or comments, I would be pleased to discuss them with you.

Sincerely, Luis A. Reyes Regional Administrator l Docket No. 70 27 j License No. SNM-42

Enclosure:

Licensee Performance Review - Summary Outline Attachment 1

B&W NNFD - LICENSEE PERFORMANCE REVIEW-

SUMMARY

OUTLINE PERFORMANCE PERIOD: JULY 1,1994 - SEPTEMBER 30,1996

" The following is a summary of the program strengths and challenges for the performance of Babcock and Wilcox Naval Nuclear Fuel Division in the conduct of NRC licensed activities.

PERFORMANCE AREA: SAFETY OPERATION 5 This area is comprised of plant operations, criticality safety, chemical safety, fire safety and management controls.

PROGRAM STRENGTHS Competent criticality safety staff i

Management and staff support for safety programs e immediate response to events Self-identification of deficiencies l

AREAS NEEDING IMPROVEMENT Operator adherence to nuclear criticality safety controls (postings and procedures) in uranium recovery and storage areas Review or walk down of procedures and equipment in uranium recovery to reduce number of spills of hazardous materials CHALLENGES TO PERFORMANCE

• I Continued management oversight of the conduct of operations in the uranium recovery area l

e I Control of changes to assure they are conservative in providing the same or better margin of  !

safety than the original design PERFORMANCE AREA: SAFEGUARDS i i

This area is comprised of material control and accountability and physical security.

PROGRAM STRENGTHS  !

i e

Response to events, including timeliness, analysis of root causes and recognition of generic issues within the facility )

j Training of security force and conduct of daily operations by the security managers and staff i

Enclosure to Attachment 1

+

I l

2 j AREAS NEEDING IMPROVEMENT (

j No significant areas needing improvement were identified.

CHALLENGES TO PERFORMANCE

.o- Continued management attention on item monitoring program, and self-identification and l l

correction of deficiencies. I PERFORMANCE AREA: RADIOLOGICAL CONTROLS 1

)

This area is comprised of radiation protection, environmental protection, waste management and transportation.

j PROGRAM STRENGTHS o

Early identification of problems in radiation safety via use of the Radiation Safety Incident Notice (RSlN) program o Al. ARA program effective in minimizing radiation exposures o Control of radioactivity in effluents AREAS NEEDING IMPROVEMENT o

Completeness of audits performed in radioactive waste and packaging areas o

Number of releases of airborne radioactivity into uranium recovery area CHALLENGES TO PERFORMANCE No significant challenges to performance were identified other than the issues specified under Areas Needing improvement.

PERFORMANCE AREA: FACILITY SUPPORT This area is comprised of maintenance and surveillance, training in safety and emergency preparedness, PROGRAM STRENGTHS i t

o Effective safety training with emphasis on job function and requirements o

Strong management and staff involvement in emergency preparedness and training 1 o Good intemal audits and critiques in emergency preparedness resulted in performance

~

enhancements. .

Enclosure to Attachment 1 i

l J

3 AREAS NEEDING IMPROVEMENT No significant areas needing improvement were identified.

CHALLENGES TO PERFORMANCE Maintenance for equipment important to safety as equipment continues to age to prevent or mitigate consequences of process upsets in uranium recovery area e

implementation of periodic / refresher training in nuclear criticality safety for managers and supervisors and leesons learned for managers and supervisors and lessons learned for operators involved in high risk operations l

l l

4 i

l 4

I I

Enclosure to Attachment 1

FUEL FACILITIES BRANCH INSPECTION PLAN Rsvision Date: 06/12/07 Inspectiori of; on Inspection Report Number:

Licensee Dates (From + To)

On Site Hours Anticipated:

Back. shift Hours Anticipated:

TYPE oF INSPECTION TIMING oF INSPECTION INSPECTION NOTIFICATION ALLEGAT1oN FOLLOWUP lNTEGRATEo REPORT Routine Back Shift Announced Yes . Plan Attached Yes Special Normal Shift Unannounced No No Team Both Shifts Lead Inspector: Accompanying inspector (s): -

Licensee Contact Name Telephone Number '

Motel:

Name and Location Telephone N.imber Print :< view, and attach a copy of the Site Integration Matrix (See G:\SIM\*.SIM)

Inspectors initials Attach a list of H A open items for the facility (See G:\OPENITEM) and rnark with a hiah lichter the issues that will be reviewed for closure. If there are items that have been closed but ate not reflected as such on the list, mark them appropriately. .

Inspectors initials On the reverse side of this form (Region ll Fuel Facilities Branch inspection Areas), mark with a high lighter the areas (e.g. F1.05, S2.07, etc.) to be inspected and cross out those areas previously inspected during the FiscalYear. .

Inspectors initials in an attachment, list the performance measures to be inspected for each area to be inspected and specify the indicators that will be used to measure the acceptability of that performance. Also, indicate how the performance measures relate to performance characteristics for this licensee that you discovered during your review of the SIM. Note that this part of the plan is the most important because here is where the real focus of the inspection is developed. .

Inspectors initials l

inspection Instructions from the Project inspector (Ayres for Framatome, Westinghouse; Bassett for Research Reactors; Gloersen for NFS & ISFSis, and Troup for B&W NNFD & GE): )

l 1

l 1

i Project inspector Certification that 1) the inspection focus is appropriate,2) the planned inspection is based on acceptable performance measures,3) performance trends from an up-to date SIM have been appropriately considered, and 4) the inspection is specified on the Master inspection Schedule Signature Date Additionalinspection Instructions from Branch Chief; ca wm ame.--e. 7.

srotuh seerstry hopeaset.)

Presses hassmer sransh eher l Branch Chief Approval:

Signature Date Attachment 2

)

Reaion !! Fuel Facilities Branch Insoection Areas

1. SAFETY OPERATIONS 03 Plant Oper:tirns (88020) 03.01 Conduct of Operations 03.02 Facility Modi 5 cations and Configuration Controls R2 03.03 Implementation of Process Safety Controts Environmental Protection (88045)

R2.01 Monitoring Program Implementation 0 3.04 Implementation of Storage Safety Controls R2.02 Monitoring Program Results O3.05 Implementation of Safety Controls for Material Handling R2.03 Management Audits, inspections and Controls and Movement R2.04 Quality Control of AnaYtical Measurements 03.06 Housekeeping 03.07 R2.05 Independent Measurement Veri $ cation (Sample l Review of Previous Events Splitting) l 03.08 Followup on Previously identified issues R2.06 Monitoring Program Reports 04 R2.07 Decommissioning Activities Fire Safety (88055)

R2.08 FoRowup on Previoush Identined issues i 04.01 Review of Fire Protection Program Documentation l 04.02 Review of Documentation Related to the Fire Protection R3 Waste Management (64850 and 88035) l Program R3.01 Liquid Effluent Program Controls, Procedures and 04.03 Building Design, Constnaction, and Ventilation System 04.04 Instrumentation Fra Safety of Processes, Equipment, and Storage R3.02 Liquid Efnuent Monitoring Results Areas R3.03 Airt> cme Efnuent Controls, Procedures and 04.05 Fire Protection Systems 04.06 Instrumentation Fire Hazards Anatysis R3.04 04.07 Art >ome Etnuent Monitoring Results Pre-Fire Plan 4 R3.05 On site Waste Storage '

04.03 Fire Brigade Training R3.06 Waste Classi5 cation 04.09 Fire Emergency Drins R3.07 Waste Form and Characterization 04.10 Off Site Support 04,11 R3.08 Waste Shipping (Manifests, Lat>eling, and Surveys)

Fonowup on PreviousY Identified issues R3.0g Tracking of Waste Shipments R3.10 Management Controlof Liquid & Airt>ome Efnuents and 05 Management Organization and Controls (88005) 05.01 Solid Waste Organizational Structure R3.11 Quality Assurance Programs 05.02 Procedure Controls R3.12 Followup on Previousy identined issues 05.03 IntemalReviews and Audits 0 5.04 Safety Committees )

R4 Transportation (48740) 05.05 Quahty Assurance Programs  !

R4.01 Preparation of Packages for Shipment 0 5.06 Followup on Previously identified issues R4.02 Delivery of Completed Packages to Carriers j R4.03 Receipt of Packages

11. SAFEGUARDS R4.04 Certincates of Compliance )

R4.05 Management Controls )

32 Physical Protection (81000 series) R4.06 Records and Reports S2.01 Adequacy of Physical Security Plan R4.07 Followup on Previousy identined issues S2.02 Implementing Procedures and Guard Orders S2.03 Management Reviews, Audits and Controls

$2.04 Ouality of Physical Barriers TV. FACittTY SUPPORT S2.05 Personnel Management. Training, Qualincation, and F1 Fitness for Duty Maintenance /Surveltlance (88025)

F1.01 Conduct of Maintenance S2.06 Assessment Aids and Lighting F1.02 Work Control Procedures S2.07 Detection Aids and ingress & Egress Controis F1.03 Work Control Authorizations {

S2.08 Equipment Testing and Maintenanos

$2.0g F1.04 Qualincations of Maintenance Personnel Locks, Keys, and Combinations F1.05 Management Audit of Maintenance {

S2.10 Supply of Electrical Power to Security Systems F1.06 Surwi!!saca Testing S2.11 Compensatory Measures F1.07 Calibrations of Equipment

$2.12 Alarm Stations and Communications F1.08 Fonowup on Previousy identined issues S2.13 Records, Reports, and Event Reporting S2.14 Protection of Shiptr.ents F2 Te sining (48010)

S2.15 Inform. tion Protection F2.01 TJ CFR 1g.12 Training

$2.16 Review of Events and Exercises F2.02 General Nuclear Criticality Safety Training S2.17 Fonowup on Previousy Identified Issues F2.03 General Radiological Safety Training F2.04 General Emergency Training Ill. RADIOLOGICAL CONTROLS F2.05 Operating Procedure Training F2.06 On-the-job Training R1 Radiation Protection (83822) F2.07 Fonowup on Previously identified issues R t.01 Radiation Protection Program implementation R1.02 Radiation Protection Prograrn Procedures F3 Emergency Preparedness (88050)

R1.03 Radiation Protection Program Equipment F3.01 Review of Program Changes ft1.04 Emiemal Exposure Control F3.02 Implementing Procedures R1.05 Intemal Exposure Control ,

F3.03 Training and StafRng of Emergency Organization '

Rt.06 Respiratory Protection F3.04 Off site Support R1.07 Postings, Labeling Control F3.05 Drills and Exercises R1.08 Surveys F3.06 Rt.0g Emergency Equipment and Facilities Notifications and Reports F3.07 R1,10 Fonowup on Previously identified issues Implementation of ALARA Program  ;

R t.11 Management Oversight of Program i l R1,12 Fonowup on Previoush identified Issues l Attachment 2

U.S. NUCLEAR REGULATORY COMMISSION REGION 11 Docket No.: 70-xx License No.: SNM xxx Report No.: Docket Number / Year Sequential Number Licensee: Licensee's Name l

Facility Name: Specific Facility Name Location: Town, State and Zip Code l

l Date: Dates of the inspection l

l Inspector: Name and Title i

Approved by: E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety I Note: There is no page number and the word " ENCLOSURE" is right justified at the bottom.

ENCLOSURE  !

1 Attachment 3

EXECUTIVE

SUMMARY

Facility Name NRC Inspection Report 70-xxxx/97 xx Note that this is an Executive Summary and should contain the most important findings from the inspection (both positive and negative). Note also that the title is centered and it is on a separate page from the cover page. Also centered below the title is the facility name and the report number. There is a summary for each functional area inspected, and the summaries are bulletized. If more than one functional area was inspected, they should be presented ir, the order specified below. No page number on this page. If this is a multiple page summary, the second page will be numbered 2 at the top.

This is a very important part of the report and should be afforded sufficient time for development. Also,it should be developed in the final phase of the report writing process. It must be consistent with the conclusion sections within the report. It should not, however, be a sum of a cut and paste job from those sections. Significant editing will probably be needed to make the final product a good one. Remember that the I contents of the Executivo Summary will end up in the Site integration Matrix and ulfmately in Licensee Performance Reviews (LPRs). Care and effort expended during development of the Executive Summary will pay off with less effort being required during LPRs.

SAFETY OPERATIONS For example:

Strong implementation of active engineered controlin DCP due in part to the cooperative working relationship between the maintenance and operations functions during functional testing (Section X.Y.3),

e Marginalimplementation of administrative nuclear criticality safety controls at the C87 distillation unit due to the difficulty in observing flow through downcomers between plates 11 and 23 (Section X.Y.3).

SAFEGUARDS l

RADIOLOGICAL CONTROLS )

FACILITY SUPPORT

Attachment:

Partial List of Persons Contacted '

Inspection Procedures Used List of items Opened, Closed, and Discussed  !

List of Acronyms '

l Attachment 3

Reoort Details No page number on this page. The next page in the report details is page 2.

1. Summarv of Plant Status l

This section contains a brief status of the facility during the inspection. For an integrated resident report, the status will, of course, be more detailed than for a region based inspector's report because it covers a longer period of time, typically six weeks. The inspector should specify in non-proprietary terms what parts of the facility were operating, and whether any special activities are underway - such as physical inventory, emergency exercises, physical security drills, extensive maintenance on a particular area, and the like. Think of this as almilar to what we provide in One Liners each Friday. It provides a backdrop describing the environment under which the inspection was conducted.

Areas of Insnection The major subdivisions within the report following the Summary of Plant Status are the individual areas of Inspection, and there will often be more than one. These areas of inspection include: Chemical Safety (8804x series) (S1), Criticality Safety (88015) (S2),

Plant Operations (88020) (03), Fire Safety (88055) (04), Management Organization and Controls (88005)(05), Material Control and Accounting (85000 series)(S1), Physical Protection (81000 series) (S2), Radiation Protection (83822) (R1), Environmental Protection (88045) (R2), Waste Management (84850 & 88035) (R3), Transportation (86740)

(R4), Maintenance / Surveillance (88025) (F1), Training (88010) (F2), and Emergency Preparedness (88050)(F3). Inspections in the areas of chemical safety, criticality safety, and material control and accounting will typically be performed by headquarters inspector and are included here so that the proper sequence will be maintained if an Integrated report is prepared. As the above areas ofinspection are added to the report, the paragraphs will be numbered beginning with the number 2. There will be no gaps in the numbering sequence. For example,if two areas ofinspection (Radiation Protection and Training) were covered, the paragraphs in the report details would be as follows:

1. Summary of Plant Status 2.

Radiation Protection (83822)(R1)

3. Training (88010)(F2)

4. Exit interview Insoection Reautrements The subdivision of each area of inspection is by inspection requirements. These are outlined on the Fuel Facilities Branch inspection Plan (See attached), and are typically covered in the specific Inspection Procedures. The inspection requirements are designated with a lower case letter beginning with the letter "a". Again there are no gaps in the substructure sequence within an inspection Requirement. For example, if three inspection requirements (Detection Aids and Ingress & Egress Controls; Records, Attachment 3

2 Reports, and Event Reportingl and Review of Events and Exercises) were inspected within the Area of Inspection - Pnysical Protection, the format would be:

2.

Physical Protection (applicable inspection procedures) (S2) a.

Detection Aids and Ingress & Egress Controls (S2.07)

b. Records, Reports, and Event Reporting (S2 3) c.

Review of Events and Exercises (S2.16)

Substructure Within each inspection requirement there are three numbered subdivisions. These are:

1nspection Scope, Observations and Findings, and Conclusions. There can be multiple paragraphs within these numbered subdivisions. The subdivisions are designated with numbers in parentheses. See Enclosure insoection Scone This section describes the performance measures the inspector evaluated, why the inspector evaluated it, and the performance standard was used. This is where the contract between the inspector (s) and the branch chief that was approved in the inspection Plan comes into play. As stated in the inspection Plan, the performance measures are the most important part of the inspection Plan. In the inspection Report, {

the performance measure is again the key element. An example is:

- The inspector observed the licensee's emergency exercise conducted on January 19, 1994 to determine if: (a) the objectives outlined in the erarcise scenario dated October 3, 1993 were met, and (b) the exercise was conducted in accordance with requirements specified in the licensee approved Radiological Contingency Plan, dated November 4, 1993, and implementing procedures. Particular inspection emphasis was placed on the timeliness of event classification and subsequent offsite agency notification since these had been identified as weakness during the previous emergency exercise in addition to

- commitments in the licensee's approved Radiological Contingency Plan, the inspector used selected aspects of NUREG 0645 that were equally applicable to fuel facilities to judge the licensee's performance.

This will probable be the shortest of the three subdivisions within the inspection requirement area of the report and the easiest to write. Actually, most of it is written before the inspection and included in the inspection Plan.

Observations and Findinas This section should describe what the inspector observed and found, and how the inspector went about performing the inspection. This is where the real meat of the inspection is documented. These are facts, observations, and findings by the inspector.

The emphasis during the inspection which must carry through into this section of the Attachment 3

l I

3 report is on verification and analysis of licensee performance. That is, what did the inspector verify through independent methods, and what does it all mean relative to l safety? It could also include data that the inspector obtained from a review of the  !

licensee's records.

f!'

For example, if the inspector determines that the licensee has 65 open maintenance work orders, this finding needs to be placed in safety perspective. Is the number of open work orders increasing or decreasing? .ls there a specific class of equipment that is proving to be particularly unreliable? Is that class of equipment of safety significance i and why? What does it mean with respect of the maintenance of safety margin?

If violations, unresolved items, or inspector followup items are identified, they must be clearly specified in this section. In particular, it an item is unresolved, what aspect of the issue is unresolved? Whose court is the ballin to resolve the issue, who will resolution be obtained, and within what time period will it be resolved?

This should be the longest of the three sub-parts.

Conclusions This section has typically been the hardest part for inspectors to write, in part because the previous section did not contain sufficient analysis. This section should contain conclusion hawn by the inspector about the licensee's performance. I am looking for good strong conclusions in this section. No violations or deviations were identified is l

not an adequate conclusion. The type of conclusions should be like the following two conclusions:

Through the evaluation of written procedures, review of records for previous shipments, i observation of packaging operations underway during the inspection, and discussions  !

with personnel responsible for the function, the inspector concluded that the licensee had implemented an adequate program for preparation of radioactive material packages for shipment in accordance with NRC and DOT requirements. In particular, the inspector >

found the radiation monitoring of packages to be noteworthy based on the diligence of  !

the responsible individual. The area of labeling, however, was a candidate for additional l management attention due to upcoming changes in both NRC and DOT requirements.

On the basis of:(1) tours of the area, (2) detailed review of the design of the nuclear criticality safety controls, (3) a review of the operating procedures and observation of licensee personnel complying with the approved procedures, (4) the results of functional testing of active engineered safety controls, the inspector concluded that the licensee had implemented strong safety controis in Dry Conversion Process. This was due in part to the cooperative manner in which the maintenance and operations functions ,

worked in during functional testing of equipment. The implementation of the '

administrative nuclear criticality safety controls at the C87 distillation unit, however, was marginal due to the difficulty that licensee personnel had in observing flow through Attachment 3

4 downcomers between plates 11 and 23. The observational difficulty will be further evaluated by the licensee with emphasis on redesign of observation ports.

This sub-part should be the second longest of the three.

The report continues with additional inspection requirements followed by additional inspection areas, as appropriate.

• Exit Interview (30703)

This section contains a brief summary of the exit interview, including the date it was held. If the licensee disagrees with a position taken by the inspector during the inspection, a clear statement of the licensee's position should be included. A statement of whether proprietary information is included in the report should be made. Remember, the significant issues discussed and items opened and closed are specified in the attachment. Also, sometimes it is necessary to perform a second exit interview by telephone following review ofinspection findings with management. When that occurs, ]

it should be documented in this section.

1 l

1 l

l l

Attachment 3 l

ATTACHMENT Note: No page number on this page. If the attachment is more than one page, the next page is number 2.

PARTIAL LIST OF PERSONS CONTACTED Note: This list is a partial list and need not be exhaustive, but the important contacts should be listed. Format is as follows:

Licensee Personnel Licensee employees contacted should be listed. This typically includes managers, '

engineers, technicians, production staff, and security personnel.

Other Personnel f

i Other personnel contacted should be listed. This typically includes off site personnel such as emergency responders, and support groups such as police, hospital personnel, l and personnel from State and local agencies. personnel.

NRC Personnel NRC personnel contacted should be listed. This might include individuals in l headquarters contacted on a specific issue or accompanying management from the l regional office.

l Mark each person contacted with an "*" to denote those present at the exit interview.

INSPECTION PROCEDURES USED i i

l Format for this section is as follows:

l IP 88005 Management Organization and Controls LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED I Format for this section is as follows:

Opened 70 xxxx/96 xx xx VIO Failure to meet some specific requirement (Paragraph X.Y.2).

Closed 70-xxxx/96 xx-xx VIO Failure to meet some specific requirement (Paragraph X.Y.2).

Attachment 3

Enclosure 1 Fuel Facility Report Structure Coverletter Safety significant issues are highlighted in the coverletter, but only if they are contained in the Executive Summary and the Exit interview Section.

Notice of Violation and/or Deviation Cover Paae Executive Summarv items discussed in the Executive Summary should be significant findings from the inspection. Minor aspects should not be included here. Allitems in the Executive Summary would have been discussed in the Exit interview with the licensee.

Reoort Details

1. Summary of Plant Status

2. Area of Inspection #1

a. Inspection Requirement #1 (1) Inspection Scope .

(2) Observations and Findings (3) Conclusions

b. Inspection Requirement #2 (1) inspection Scope (2) Observations and Findings (3) Conclusions

c. Inspection Requirement #3 (1) Inspection Scope (2) Observations and Findings (3) Conclusions

3. Area of Inspection #2

a. Inspection Requirement #1 (1) Inspection Scope (2) Observations and Findings (3) Conclusions

b. Inspection Requirement #2 (1) Inspection Scope (2) Observations and Findings (3) Conclusions

4. Exit interview 6ttachment Attachment 3

l 2

Discussed 70 xxxx196-xx-xx URI Additional review needed to determine if a specific requirement was met (Paragraph X.Y.2).

LIST OF ACRONYMS This section should contain a list of acronyms used in the report. Note that even if an acronym is used, it should be spelled out the first time it is used in the report. Format is as follows:

NCS Nuclear Criticality Safety SOP Standard Operating Procedure Attachment 3

July 14,1997 MEMORANDUM TO: Fuel Facilities Branch FROM: E. J. McAlpine, Chief M '

Fuel Facility Branch

SUBJECT:

RISK-lNFORMED, PERFORMANCE-BASED INSPECTION CYCLE I

The purpose of this memorandum is to discuss my views on the risk-informed, performance-based inspection cycle and to provide guidance on the implementation of its elements in the Region ll Fuel Facilities Branch. The inspection cycle has six distinct phases that are repeated on a predetermined frequency - annually for high-enriched uranium facilities and biennially for low-enriched uranium facilities. The steps are as follows:

1. Performance Review . review of licensee performance by functional area based on i inspection findings documented in inspection reports and the Site Integration Matrix.

2.

Inspection Targeting - specification of inspection frequency and/or level of inspection i effort by functional area. This includes identification of specific areas within each I

' functional area where inspections will be focused due to identified deficiencies in the licensee programs, specific plant areas where the risk in highest, and inspections to be ,

conducted conjointly with NMSS. Note that a portion of this is conducted as part of the -

performance review process, but the specific decision on actual level of effort is l j

completed independent of that process. Note also that this phase forlow-enriched '

uranium facilities will be conducted without the benefit of a recent formal review of licensee performance every second year.

3. Inspection Scheduling - establishment and periodic modification of the annual inspection schedule.

4. Inspection Planning - preparation of inspection plans for the conduct of individual inspections.

5. Inspection Performance and Documentation - performance of the inspection and documentation of results in an inspection report.

6. Performance Tracking - tracking of licensee performance in the Site Integration Matrix to permit identification of trends on a more frequent basis than the formal performance reviews. Note that the Site Integration Matrix for the entire period covered by a Licensee Performance Review should provide the necessary and sufficient information to perform the review - thus reinitiating the cycle.

Performance Review This aspect of the process is specified in Manual Chapter 2604. The letter to B&W NNFD dated May 16,1997 with a subject of "NRC Performance Review of Licensed Activities" presents the most recerit example of what the finished product should look like. It is presented as Attachment 1 to this memorandum. Also, we should expect a high level of performance in areas where the risk is high.

Attachment 7 l

I l

2 Insoection Taraetino inspection targeting should be set forth in writing before the beginning of the fiscal year. This document should specify areas to be emphasized during the coming fiscal year and the level of inspection ef, ort to be expended. Such guidance would be based on areas of risk within the individual facilities and the levels of performance observed during and subsequent to the last performance review. The basis for performance since the last performance review should be based on information included in the Site integration Matrices. This particular area is one where branch performance (at both the Branch Chief and Inspector levels) needs  ;

improvement. For Fiscal Year 1998, such a document will be prepared in draft and circulated within the Branch prior to the development of the annualinspection schedule. Guidance was not specifically created for Fiscal Year 1997, but Fiscal Year 1996 guidance which was also applicable to Fiscal Year 1997 is available in two files - G;\ PLANS \ EMPHASIS.NCS and G:\ PLANS \LOOKFOR.EJM.

Insnection Schedulina Once the inspection targeting document has been created, the project inspectors (in concert with other inspectors) can prepare the inspection schedule for the fiscal year. This will take into consideration such issues as targeted level of effort by inspection area, inspector training and leave schedules, holidays, plant shutdown periods, licensee performance review schedules, specific inspections to be conducted in conjunction with the program office, etc. The Region ll  ;

. inspection schedule is then integrated into the national master inspection schedule. The .

{

inspection scheduling process is dynamic in that factors such as reactive inspections due to events, changes to training schedules, and time needed to complete specifically assigned j action items will necessitate periodic schedule modification. Notwithstanding that, each time l the schedule is estab!ished or modified our best effort to prepare a schedule that most efficiently utilizes our time is needed, it is important to recogni.'.e that by virtue of integrating the Region ll inspection schedule into the national master inspection schedule, we have established a contract with the program office i

relative to the type and timing of our inspections. This is tracked and briefed at the office l director level during periodic operating plan reviews.

Insnection Plannina The inspection planning process is where the elements ofinspection targeting and scheduling come together to produce the plan that will be implemented during the on-site inspection. The Fuel Facilities Branch inspection Plan form (Attachment 2) provides a road map to this planning process. During this phase, the inspector reviews the Site Integration Matrix for performance

' trends, reviews the Open items List for issues needing closure, and prepares the list of performance measures to be inspected. The planning of the inspection occurs with an eye on the level of effort, areas to be emphasized, and the performance as specified in the Licensee Performance Review and the Site Integration Matrix. Planning of the inspection is the key to assuring that time on site is spent in those areas where the risk is highest and/or the licensee's performance is lowest. The approval of the inspection plan by the project inspector and the branch chief is a contract with the inspector.

3 Insoection Performance and Documentation inspections must be performance based. Allinspectors are required to attend training on

" Inspecting for Performance" and the techniques learned in that course are carried out during the performance of on-site inspections. During performance-based inspections, the inspectors should continually remind themselves of the ' Trust, but Verify" motto. The use of the performance measures developed during the inspection planning phase will keep the inspection focused on performance and risk.

No inspection is complete until the report documenting the inspection findings is issued.

Attachment 3 presents the format for inspection reports prepared within the Region !! Fuel Facilities Branch. Note that the format has been modified slightly based on comments received from Bruce Mallett when he was the Division Director and is consistent with Manual Chapter 0610. The two most important aspects of the inspection report is the assessment of licensee performance that is documented in conclusions and the timely issuanc' to the licensee.

Reports should be prepared promptly so that we can forward them to the program office for review and comment. The target is to provide the program office with two days to perform their review.

Perforrnance Trackino I The performance of licensees as documented in inspection reports is tracked on the Site l Integration Matrices. These are inaintained by the Project inspectors and provide the mechanism by which performance can be judged during performance reviews and at t

' intervening times, it is important to keep a close eye on the performance of our licensees i because it is far easier to correct a minor degradation of performance than a major -

performance decline. Toward that end, the types of entries into the Site Integration Matrix are important. The must be clear, concise, and based on performance.

This brings us full cycle. The types of performance that should be documented in the Site Integration matrix can be seen in Attachment 1 - the results of the Licensee Performance l

Review. The successfulimplementation of this cycle will make a major contribution to improved i performance as reflected in our quarterly Branch Self-Assessment.

i If you have any questions about this memorandum, I will be pleased to discuss them with you.

Distribution:

Branch Members D. Collins T. Decker C. Hosey B. Mallett J. Potter Reading File P. Ting

. P:\WP51\RIPBINSP.CYC

r 3

TARGETING INFORMATION A. Management Controls (88005)

B&W NNFD i No particular emphasis was identified.

1 Framatome Cogema Fuels l No particular emphasis was identified, l i General Electric '

No particular emphasis was identified. .

i Nuclear Fuel Services l

l No particular emphasis was identified.

l

- Westinghouse l

No particular emphasis was identified.

! B. Operations Review (88020)

B&W NNFD 1

1 The program should emphasize the Uranium Recovery and Compact Reactor Fuels portions of the facility since these are the areas where the highest risk exists because of the presence of solutions. Other portions of the facility should l' not be ignored. Target should be 70% high risk and 30% balance of plant. At l least 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of effort should be devoted to the Lynchburg Technology Center.

Major reviews should be conducted of any preparations to continue process of l uranium-beryllium scrap with recognition that such processing is covered by a Confirmation of Action Letter.

Framatome Cogema Fuels Program emphasis should be a balance between normal plant operations and operations associated with new work. The new work emphasis should be based I. on the lessons learned by the licensee from the inadvertent shipment of two fuel assemblies to Germany which resulted from failure to conduct new, short term projects in a manner similar to the normal routine work.

Attachment 7a

4 General Electric 1

The program emphasis should be divided about equally between the dry conversion facility, uranium recovery, and the balance of plant. Particular emphasis should be placed on any phase out of the ADU process. We don't want to see problems developing in ADU as the facility's attention becomes more focused on DCF.

Nuclear Fuel Services The program emphasis should be on new programs coming on line. These will be in the order in which they occur: uranium aluminum scrap recovery, down-blending of high enriched uranyl nitrate to low-enriched uranyl nitrate, and the design, construction, and testing of facilities for the new naval fuel manufacturing process.

Westinghouse The program emphasis should be on the implementation of safety controls on a plant-wide basis. Particular attention should be given to the robustness of control implementation. We have seen indications that administrative controls are not always included in approved operating procedures and operators are not always trained on the implementation of those controls, in addition, attention should be directed to areas where geometry controls are used. There have been indications that the development of the Criticality Safety Evaluations have

^

not always involved a review of source evaluations resulting in the belief that geometries were favorable when they were not.

C. Fire Protection (88055)

Overall, particular emphasis should be placed at each facility on the controls over and use of moderating materials in fighting fires. Also, the existence of significant fire loads in areas where a fire could result in the compromise of nuclear criticality safety controls i is of extremely high significance. Fire protection inspection should be focused based on input from operations inspectors.

B&W NNFD Emphasis should be on portions of the plant where fires could involve uranium.  !

l ' The licensee may be pursuing an analysis to demonstrate that zirconium fires in i machining area could not result in the involvement of uranium. If so, this should be factored into the program emphasis by de-emphasizing this area after a technical review of such demonstration information or data by NRC. Given that the uranium recovery area (including Compact Reactor Fuels) appears to contain the major fire load, this area should receive particular emphasis, i

5 l Framatome Cogema Fuels No particular area of emphasis other than to assure that the SERF facilities receive significant attention. The presence of byproduct material with its significance as a source term causes those areas to be of importance.

General Electric

{

No particular area of emphasis has been identified. Entire program area should j be addressed. Of note is that the fire loading in solvent extraction is lower than at other facilities because of the organic used.

Nuclear F.:el Services Emphasis should be on the control of fire loading and on the conversion of the sprinkler system in the High Enriched Uranium Recovery Facility from a manual ,

to an automatic system. Emphasis should also be on issues developed during the UF readiness inspection. The entire program should be covered. ]

Westinghouse 1 The entire program should be covered. Only specific area of emphasis is on the I Fitzmills. These have been the source of fires in the past when UO, powder #

burned back to U3 0, due to the presena of oxygen in the collection system.

D. HEU Access Controls (81012,81914,81915,81916,81917. S1922,81925,81929 j 81932,81933, and 81934)  !

B&W NNFD i

, No particular area of emphasis has been identified.

1 Nuclear Fuel Services I Emphasis should be on changes to controls for the 300 complex as the new naval fuel process becomes ready for operation. ),

E. HEU Alarms and Barriers (81910,81911,81913,81918,81919,81920,81921,81923, 81924, 81926, 81927, 81928, 81931, 81401, and 81402)

B&W NNFD No particular area of emphasis has been identified.

Nuclear Fuel Services Emphasis should be on changes to controls for the 300 complex as the new

8 naval fuel process becomes ready for operation.

F. HEU Other Security Areas (81930,81935,81020,81022,81034,81038,81501,81502, and 81601)

B&W NNFD Emphasis should be on the management of the program. Changes in the management structure have occurred and we need to assure that the program continues to be managed in an effective manner.

Nuclear Fuel Services No particular area of emphasis has been identified.

l G. LEU Security (81431)

Framatome Cogema Fuels No particular area of emphasis has been identified.

l General Electric -

No particular area of emphasis has been identified, l

- Westinghouse No particular area of emphasis has been identified, H. Transportation Security (81310, 81335, 81340, 81360, 81365, and 81370)

B&W NNFD No particular area of emphasis has been identified.

Nue:aar Fuel Services No particular area of emphasis has been identified.

Spent Fuel Shipments No particular area of emphasis has been identified.

7 1.

Radiation Protection (83822)

B&W NNFD Emphasis should be on the control of dose to workers. Particular attention should be focused on Uranium Recovery and Waste Treatment and the development and enhancement of engineered controls to minimized airbome radioactivity.

Framatome Cogema Fuels Emphasis should be on control of dose to the following classes of workers -

pellet loading, fuel rod downloading, and workers in the SERF facilities.

General Electric Particular emphasis should be placed on the Dry Conversion Facility (DCF) relative to the assessment of worker dose. With the startup of the DCF, the size f and shape of any airbome radioactivity is expected to change. The particles should be smaller and be of a shape that does not readily clear from the lower lung. As a result, the biological half life may be increase.

Nuclear Fuel Services Emphasis should be on controls over worker dose. With respect to HEURF, a review should be conducted to assure concentrations of radioactivity in air to which the workers are exposed is being properly measured. There may be a move to use fixed air samplers in the HEURF. If so, we should review the data demonstrating that fix air samplers provide meaningful data. NFS has had ,

problems in the past when attempting to demonstrate the adequacy of fixed air samplers. l l

l Westinghouse Continued sensitivity to the occurrence of unauthorized activities such as eat in controlled areas.

J. Waste Generator Requirements (84850)

B&W NNFD Emphasis on proper waste characterization and program assessment.

Framatome Cogema Fuels Emphasis on proper waste characterization and program assessment.

8 I

General Electric Emphasis on proper waste characterization and program assessment.

Nuclear Fuel Services Emphasis on proper waste characterization and program assessment.

Westinghouse

Emphasis on proper waste characterization and program assessment.

K. Low-Level Waste Storage (84900)

B&W NNFD I

No particular area of emphasis was identified.

Framatome Cogema Fuels 1 1

i k

No particular area of emphasis was identified.

{

General Electric l

No particular area of emphasis was identified.

Nuclear Fuel Services No particular area of emphasis was identified. I Westinghouse No particular area of emphasis was identified.

L. Transportation (86740)

B&W NNFO Shipment to Envirocare. Compliance with CoC requirements.

Framatome Cogema Fuels Compliance with CoC requirements.

General Electric )

1 Compliance with CoC requirements.

9 Nuclear Fuel Services Shipment to Envirocare. Compliance with CoC requirements.

Westinghouse Compliance with CoC requirements.

M. Rad. Waste Management (88035)

B&W NNFD No particular area of emphasis was identified.

Framatome Cogema Fuels i

No particular area of emphasis was identified.

General Electric No particular area of emphasis was identified.

Nuclear Fuel Services No particular area of emphasis was identified.

Westinghouse No particular area of emphasis was identified.

i N. Environmental Protection (88045) l B&W NNFD No particular area of emphasis was identified.

Framatome Cogema Fuels No particular area of emphasis was identified.

General Electric No particular Plea of emphasis was identified.

Nuclear Fuel Services No particu ar area of emphasis was identified.

10 Westinghouse l l

No particular area of emphasis was identified.  !

O. Decommissioning (88104)

Nuclear Fuel Services Work associated with North Site and Pond 4.

P. Operator Training (88010) 1 B&W NNFD l

Emphasis on adherence to procedures and controls associated with calculations of H/X ratios.

Framatome Cogema Fuels Emphasis on training associated with new or non-routine work.

General Electric Emphasis on training associated with new or non-routine work.

Nuclear Fuel Services Emphas!s on training associated with new or non-routine work.

Westinghouse Emphasis on training associated with new or non-routine work.

Q. Maintenance / Surveillance (88025)

B&W NNFD Emphasis on maintenance of equipment and controls in Uranium Recovery which is performed by operators.

Framatome Cogema Fuels l Emphasis on maintenance of safety related controls.

l General Electric Emphasis on maintenance of new controls established for the DCF.

l

11 Nuclear Fuel Services

{

t Emphasis on maintenance of safety related controls associated with HEURF. )

Westinghouse i Emphasis on maintenance of safety related controls, i

R. Emergency Preparedness (88050)

B&W NNFD No particular emphasis was identified.

Framatome Cogema Fuels No particular emphasis was identified.

General Electric No particular emphasis was identified.

l Nuclear Fuel Services No particular emphasis was identified.

l Westinghouse No particular emphasis was identified.

S. ISFSI Inspection North Anna Emphasis on dry run of case loading.

T. NNFD Resident Emphasis in accordance with LPR U. NFS Resident Emphasis in accordance with LPR G:\ SCHEDULE \98 TARGET.

l l

~

la t 8 0 6 5 5 4 0 6 o 4 2 6 1 1 O 4 0 0 0 0 -

. T 4 4 4 9 9 5 6 3 -

4 d

ln ea Fu ts S 2 8 0 3 2 6 1 1

- ^

" 6 4 5 6 6 7

- 9 6 7 8 9 5 3

J

- I t

- s us

- Ferc 4 0 8 1 2 6 5 aw er 6 0 1

2 1

4 6 5 9 5 5 5

le 8 1 1

- c 1 uS N

7 lae rn ed n 6 9

4 5 4 6 5 elo 6 7 5 6 $ 3 GE ls ee mu oF

_ ts o 4 0 0 4 8 6 _

6 8 6 6 1 _

mm ee 4 3 rg _

Fc _

C D

F N 8 8 5

_ N 2 0 2 1

5 4 8 2

6 5 3 1 8 8 6 5 W 1 1 1 1

_ B s

n e n y i.

e r

y s

r o

e d

o e

h g 4 o

a a in b

t c

n a

t n

a c

la t

lo o u R ,. o a a o A G H T V T G  :

C V

y C

E D

F e

r le E F GN S

e s

u V o h

P 0

sf S

g e

tsS t

n F ANI O e F N VTMM WN e m

h c

_ r e

a _

w t

_ T b t

_ C I O fa t

A

_ s yQ

. r L Q CH A H e

s u D T C o F

_ P $ h g N

_ E R N S n

_ y i a

v A A tsSW e F &

N V G WNB y

_ r r

e

_ G F U s A n w

o r E A QE

_ BG V HG S Y R T Y E E L F U G A J A S S

F A $

F N N V N A S L

M A I

6 9

9 S R 1 E

M E N U

N T J D A Q A Q Y M H G H

_ B R S A +

E T

I L Y S C A M

I V U V N W L ~

E F A

T I

O S

6 N 9 O I

L W

9 S M I A 1 S V

I F Q NH D

e s e u

hc s H o e o u

C h e T h A g b e g A n w tg n M its re r o n.

E e a A eE o GW C V GGW D ._ Oche ;

F _ F B N T E N N f .

F Niog W'

R Wo:

& e r .

SW_ P BGw N

A J

A s V e _

it _ _

S

_ t o _

s _

it e . . _

is r o d a

V t

c e

r m -_ _

rosa t

es ie Dm rvm 1 y

e s 2 tt r

e W A

ts es ._

u o B o ~_

c w tcM e B e e r p C.

e fL H. U F. 8 F M. h _

MC .

i .

1 DB DO MJ F E

E lg _ I B

e e.

C m m E

a A to O ta a e

m G. mS r A R eF F m V P r

F N a

W 8 O

N t o n H e m

h c

a T t C E t O G.

S A

F R Q R N P H P T

F E

S S

F N

Q G

U H.y A r w o Q A

$ H H G S Y R T Y D.

E E L F S NF F U G A J N N.

A 98 S A WS

&O N9 S G BH -

A1 L T -

M 3 A

I S1 R ,

E C My E se u S R

l o

c r T J Na A y

v t ew Du a Et Ya n M N G BJ R SF A E

TO I

L Y A

SS C M I

VA U N A V

EA F TT I O SA N A

B 7 D O L N

W A

9 I I P

T 9 S I

A A 1 A S V

I tC.

v P

V U

O H

D H I C S A

A O A

R H. A S C o A L O N H V F H B N E

F T, S

O _

H _

N .

A _

J _

S _

O s H e

t l

i S

t o

s . y m

e s

y ,

it e o ,o s is .H o V

r o

C.

ot a.

.e C on

/

yl k s r e

k H.

C

/

e r

W m. .

tc .

ie u.

r wa

, C.

e l c e e u D.

MT 2

so t

t i P.

L BM T

A c

~.

N I

De o0 MJ F E .

C E

D V

O s

8 b

8 t

n _

e T

m _

C h O c _ _

a _ _

t _

t A

T P

E S

G U

A S Y R T Y E E L F U G 8 A J A9 N9 S

A1 S L

M 3 A

I m S1 R i t

My E su _

U Na r T J _

A Du _

Ya n M BJ R SF A _

E TO I

L Y A

SS C R I

VA U B N _

EA F TT I O SA D N 8 O L _

9 I I

R P

9 S I A 1

V I

D H

C R

. A S

R S

E F

t s

A J

s Q

H R

P as T

R P .

e it _

S t

o s

it e _

r d e

a a Vis c e

r m

s e ir r e y r k De e on y m t kc ee 2 no tc o u o t

e e B ee r

C. p e H. s D.

L E L H. 8 F se I

DO DC MT MC F E

ACCOMPANIMENT OF INSPECTORS BY DNMS MANAGERS IN FY-96 i

NAME DATE OF ACCOMPANIMENT l Materials Licensing / inspection Branch 1 l J. Ennis 7/96 1

l A. Jones 8/96 l

W. Loo B. Parker 11/95,5/96 J. Pelchat BPR, licensing l

Materials Licensing / Inspection Branch 2 i

H. Bermudez 2/96 D. Collins licensing, reciprocity J. Diaz 10/96 L. Franklin 2/96, 6/96 J. Henson 5/96 j O. Masnyk Bailey 12/95,9/96 Fuel Facilities Branch D. Ayres started 9/1/96 C. Bassett 3/96,9/96 W. Gloersen 10/95,9/96 A. Gooden 3/96,9/96 l D. Kasnicki 9/96 l

W. Tobin 3/96 l C. Hughey 9/96 G. Troup 9/96 I Attachment 8e

ACCOMPANIMENT OF INSPECTORS BY DNMS MANAGERS IN FY-97 NAME DATE OF ACCOMPANIMENT Materials Licensing / Inspection Branch 1 J. Ennis 9/97 A. Jones 4/97 W. Loo 3/97 B. Parker 5/97 J. Pelchat 5/97,7/97 Materials Licensing / inspection Branch 2 H. Bermudez 9/97 1

D. Collins licensing, reciprocity J. Diaz 10/96 L. Franklin 3/97 J. Henson O. Masnyk Bailey 4/97,7/97,8/97 Fuel Facilities Branch D. Ayres 10/96,12/96,6/97,9/97 C. Bassett 11/96,1/97,7/97 W. Gloorsen 9/97 A. Gooden 9/97 W. Tobin 7/97,9/97 G. Humphrey 7/97 C. Hughoy 10/96,7/97,9/97 G. Troup 11/96,1/97,6/97,7/97 Attachment 8d

r 1

ACCOMPANIMENT OF INSPECTORS BY DNMS MANAGERS IN FY-98 NAME DATE OF ACCOMPANIMENT Materials Licensing / Inspection Branch 1 I J. Ennis A. Jones W. Loo >

s.

O. Masynk Bailey B, Parker 12/97 J. Pelchat Materials Licensing / Inspection Branch 2 l

H. Bermudez D. Collins J. Diaz l L. Franklin 12/97 I J.Henson Fuel Facilities Branch

! D. Ayres C. Bassett l l

, W. Gloersen 12/97 l

\

l A. Gooden '

W. Tobin 12/97 G. Humphrey 12/97 C. Hughey G. Troup l

Attachment 8e

{

We4 9

/ UNITED STATES NUCLEAR REGULATORY COMMISSION

[ ih REGION 11 101 MARIETTA STREET N.W., SUfTE 2500

{ f ATLANTA GEORGIA 303D01SB

/ August 7, 1996 j Reaional Office Instruction No. 2213. Rev. 7 MANAGEMENT OVERSIGHT OF INSPECTION AND LICENSEE ACTIVITIES

~

A.

Puroose:

To establish goals for overview of the implementation of the inspection program to ensure adequate management perspective on licensee activities; overview of NRC activities in the field including the effectiveness .of inspection; NRC staff performance and communication effectiveness; communication between Regional managers and their licensee counterparts; Regional management visibility at licensee facilities, and inspector objectivity.

This Instruction applies to all Regional managers and supervisors responsible for inspection program activities at nuclear power plants, l non-power. reactors and fuel facilities.

This revision incorporates the guidance of MC 0102, dated March 15, 1996.

This Instruction incorporates the Regulatory Impact Reporting Form (Attachment C). This form, to be filled out by Division Directors, the Regional Administrator, and their Deputies will be used to document feedback, both favorable and unfavorable, obtained from licensee counterparts during routine visits to sites.

B. Discussion:

It is the responsibility of managers and supervisors to be knowledgeable of facilities, licensee organizations, and management control systems for which they have inspection program cognizance. It is also the responsibility of managers and supervisors to be knowledgeable of the quality of inspection activities, capabilities of inspection personnel, and the general status of the program at assigned facilities.

Additionally, it is the responsibility of managers and supervisors to keep their immediate supervisors informed of significant personnel or safety issues which arise during the course of implementing the inspection program. Judgment should be used to achieve the desired goals for h?C management overview of licensee and inspection program activities b3 conducting onsite visits efficiently, such as, during periods where other-NRC inspections or meetings can be observed. These visits should be 1 supplemented by frequent one-on-one communications, such as periodic '

conference calls in the case of resident inspectors.

The requirements and guidance provided in this ROI shall be used by NRC managers to verify inspector and examiner performance and objectivity by direct observation of on-site activities at power reactor facilities, non-power reactors and fuel facilities and through other available indirect methods as appropriate. On-site activities include individual or team

, . Attachment 9

J MANAGEMENT OVERSIGHT RESPON'IBILITIES S

Procedures

1. Division of Reactor Proiects (DRP) ,

I

a. Division management and supervisors will visit reactor sitds in I accordance with the schedule in Appendix A.

b.. Managers and supervisors sho'uld meet with licensee counterparts to discuss licensee performance and problems and elicit ' licensee comments regarding NRC programs and activities. They should observe the implementation of NRC programs in the field and the effectiveness of NRC staff communication with the licensee.

l At the conclusion of each trip, prepare a b.d.gf trip report (Appendix B) for the Deputy Regional Administrator identifying the licensee, person (s) contacted, inspection staff observed, and any ictntifying problem (s) or concern (s). (See Appendix 8 for distribution.) At the conclusion of each trip taken'by a Regional Division' Director or Deputy Director, a Regulatory Impact Form (Appendix C) identifying the licensee, person (s) contacted, favorable feedback, unfavorable feedback, comments and recommendations / solutions is to be prepared.

l The Division Director or Deputy is responsible for making quarterly l telephone calls to SRIs to discuss key inspection issues and the j position the SRI is taking with regard to those issues.

c. Division Directors or their deputies shall conduct self-assessments to evaluate management's performance in oversight activities.

d. For all team inspections, a regional manager at the Branch Chief level or higher will attend the team exit. The manager attending the exit will prepare for the exit .by at least meeting with the team that day or evening before the exit.

e. Branch Chiefs shall perform the following: make at least a monthly visit, at one of the assigned sites (see Table in Appendix A), and should attend exit interviews with licensee if significant inspection or examination findings especially if possible escalated enforcement or unsatisfactory requalification evaluation will be discussed. Communicate with the resident' staff at each of their sites several times per week.

Inspection or examination plans are discussed before on-s'ite  ;

activities are initiated to ensure the employee's activities are i properly scheduled, coordinated and focused. 1 l

ATTACHMuiT

! r t

)

i i

3 Inspector Objectivity Focus:

l (1) Does the inspector independently verify licensee provided i information? .

(2) Does' the inspector adhere to NRC regulatory positions and

, policies when. discussing issues.with. licensee management or '

. . NRC management? -

(3) Does the inspector maintain a professional relationship with

[ the licensee using good interpersonal relationship skills?

i (4) Has the inspector provided an accurate and balanced account of licensee performance, and plant conditions, in communication with NRC regional management via inspection reports, telephone, or other means?

l (5) How do licensee staff and management respond to the inspector's questions or concerns?

(6) Is the inspector focused on safety significant concerns, applying the enforcement guidance when required?

(7) Does the inspector appropriately respond to issues or events duririg normal and off normal working hours? '

, (8) Does the inspector develop ' issues fairly and objectively without biased interpretation of facts?

(9) Are findings adequately supported by the facts and are i assessments of licensee performance adequately supported by j the findings? l

, i g. '.The Br.anch Chief shall ensure the following:

1 (1) NRR manager is informed of all significant issues (2) Inspectors, team leaders, chief examiners, and other staff who I lead NRC on site activities (including headquarters based l staff) use an appropriate inspection plan, brief and receive approval from the line supervisor responsible for the activity on their planned activities and provide a copy of the l

inspection, examination, or audit plan to the responsible regional office Division of Reactor Projects (DRP) supervisor before the on-site activities begin.

(3) All NRC staff (including headquarters staff) who lead NRC on-site activities conduct an entrance meeting with the '

a'ppropriate facility personnel before beginning on-site activities. . The senior resident inspector (SRI) should be invited to all entrance briefings.

5

d. For all team inspections, a Regional Manager at the Branch Chief level or higher will attend the team exit. The manager will prepare for the exit by at least meeting with the team that day or evening before the exit.

e. Branch Chi' e fs should ensure that their. Division Director and the Division Director of DRP are. informed of significant issues

, identified by insp'ec' tors and examiners whom they supervise..

l f. Branch Chiefs should attend exit interviews with licensees if significant inspection or examination findings (e.g., possible escalated enforcement or unsatisfactory requalification evaluation) will be discussed.

g. Branch Chiefs should accompany each inspector and examiner over whom they have direct supervisory authority during conduct of onsite activities, including . preparation for and presentation of an exit interview. The Branch Chief should focus on the following l performance and objectivity attributes:

safety perspective and the application of safety principles during conduct of onsite activities the adequacy of technical training and preparation for the onsite activity being conducted j knowledge of applicable regulatory requirements 1

the ability to apply performance based-inspection / examination '

techniques to enhance safe and reliable facility operation l adherence to agency-wide regulatory positions and policies and avoidance of personal interpretations and opinions o'bjectivity, demeanor, profe.ssionalism, interpersonal skills Inspector Objectivity Focus:

(1) Does the inspector independently verify 1,1censee provided information?

^

(2) Does the inspector adhere to NRC regulatory positions and policies when discussing issues with licensee management or NRC management?

(3) Does the inspector maintain a professional relationship with the licensee using good interpersonal relationship skills?

(4) Has the inspector provided an accurate and balanced account of licensee performance, and plant condi,tions, in communication e

7 one inspection to evaluate the adequacy of the inspector's effective implementation of the program. The manager or supervisor should meet with licensee counterparts to discuss licensee performance and problems and elicit licensee comments regarding NRC activities and programs. At the conclusion of each trip, they will prepare a h trip report (Appendix B) for the Deputy Regional Administrator i

, identifying the licensee (s), person (s) contacted, inspector (s)

, observed, and any identified problems or concernss (See Appendix B fordistribution.) -

d. Division Directors or their deputies shall conduct self-assessments to evaluate management's performance in oversight activities.

e. For all team inspections, a Regional Manager at the Branch Chief level or higher will attend the team exit. The manager will . prepare for the exit by at least meeting with the team that day or evening before the exit. (This does not include routine emergency exercise observations.)

f. Branch Chiefs should ensure that their Division Director and the Division Director of Reactor Projects (for Power Reactor facilities) are informed of significant issues identified by inspectors whom they supervise,

g. Branch Chiefs should attend exit interviews with licensees if significant inspections findings (e.g., possible escalated enforcement) will be discussed..  ;

h. Branch Chiefs should accompany each inspector and examiner over whom they have direct supervisory authority during conduct of onsite activities, including preparation for and presentation of an exit interview. The Branch Chief should focus on the following j performance and objectivity attributes: -

safety. perspectiv' e and the application of safety principles during conduct of onsite activ.ities the adequacy of technical training and preparation for the onsite activity being conducted (See Appendix B for distribution) knowledge of applicable regulatory requirements the ability to apply performance-based inspection / examination techniques to enhance safe and reliable facility / operation adherence to agency-wide regulatory positions and policies and avoidance of personal interpretations and opinion objectivity, demeanor, professionalism, interpersonal skills

9 Does the inspector use a performance-based approach to conduct inspection activities that stresses safe and reliable facility operation?

.* Does the to agency-wide positions an' d policy '

avoiding pe, inspector rsonal adhere interpretations and opinions? '

'~

.. Does th'e inspector use the licensing and design bases information.-

for the. facility including the Updated FSAR in preparation for and during conduct of inspections?

=

Does the inspector conduct exit interviews in accordance with NRC (

policies and practices?

! 5. Beaional Administrator's Office I

a. The Regional Administrator and Deputy Regional Administrator will visit reactor sites in accordance with the schedule in Appendix A.

b. The Regional Administrator or the Deputy Regional Administrator will monitor Regional management activities and site visits to ensure that all onsite activities receive adequate oversight. The RA shall ensure that the appropriate NRR manager is informed of all significant, issues.

c. The Regional Administrator or the Deputy Regional Administrator should contact each Senior Resident Inspector (SRI) periodically to i discuss key inspection issues and the position of the SRI regarding , '

those issues,

d. ras must ensure that facility adverse comments are validated and appropriate corrective actions are initiated. The feedback obtained from the licensee shall be forwarded using Appendix C to the NRR Division of Inspection and Support Programs (DISP), Inspection Program Branch (PIPB). . This feedback will be used in the continuing assessment of the regulatory impact of NRC activities on reactor plant operations.

4 6

8

APPEN' DIX B l

TRIP REPORT

! MEMORANDUM TO: Deputy Regional Administrator 1

i FROM:

SUBJECT:

. REPORT ON TRIP TO DATE(S) 0F VISIT:

PURPOSE OF VISIT:

INSPECTOR (S) OBSERVED:

SENIOR LICENSEE PERSON CONTACTED: _

STRENGTHS OR WEAKNESSES fiOTED WITH PLANT:

OTHER COMMENTS:

1 Signature /Date cc: Regional Administrator Technical Division Directors

, Cognizant. Senior Resident. Inspector Cognizant DRP Branch Chief Cognizant NRR Project Manager

January 9,1998 TRIP REPORT MEMORANDUM T0: Bruce S. Mallett, Deputy Regional Admiristrator FROM: Charles M. Hosey, Acting Deputy Director Division of Nuclear Materials Safety

SUBJECT:

REPORT ON TRIP T0: Puerto Rico DATE(S) 0F VISIT: October 21-22, 1997 PURPOSE OF VISIT: Accompany Inspector INSPECTOR (S) OBSERVED: L. Franklin SENIOR LICENSEE PERSON CONTACTED:

Hospitel Metropolitano -Racheline A. Gonzalez, Administrator San Juan Cement Co. - Rolando Melendez. Administrator Bernardo A. Puebla, MD - Dr. Puebla. Owner Universidad Central del Caribe - Dr. Richard Hann, Chairman, Department of Biochemistry STRENGTHS OR WEAKNESSES NOTED WITH PLANT:

Hosoital Metrooolitano Hospital exercising little control over Oncology Department San Juan Cement Co.

RS0 involved in radiation safety on a daily basis, well maintained 3rogram 3ernardo A. Puebla. MD Little use of source. Good records and user very knowledgeable of requirements.

Universidad Central del Caribe Small amount of research. Users very Knowledgeable of requirements. Well managed program OTHER COMMENTS:

None cc: Regional Administrator DNMS Division Director Attachment 9 a

APPENDIX B TRIP REPORT MEMORANDUM TO: Deputy Regional Administrator FRON: P Ad d //1T

SUBJECT:

, REPORT ON TRIP TO [nme/-i.en.L DATE(S) 0F VISIT: l 2./ /0 [0 ~J PURPOSE OF VISIT: h f n h1, 2/E INSPECTOR (5) OBSERVED: Alvas ,n s be n s [ fz E n A 4 4 (A -

/ U U TN.,,h Guav,rvstr>mnaHi/h o Yi Tiu?t

//

>r Y J h b $

SENIOR LICENSEE PERSON CONTACTED: ' khSve STRENGTHS OR WEAKNESSES NOTED WITH PLANT:

!%d lop per seupid&.Jkf 99 ,

MidII[1 4[-pt.th f b Ft p / M k'd [N, If d[I / dkl 8 OTHER COMMENTS:

.SfWbd&14' Signature i/ey I/Date cc: Regional Administrator Technical Division Directors Cognizant Senior Resident Inspector Cognizant DRP Branch Chief Cognizant NRR Project Manager

APPENDIX B TRIP REPORT MEMORANDUM TO: Deputy Regional Administrator FROM: D /L1 OhnC

SUBJECT:

REPORT ON TRIP TO NF(

DATE(S) 0F VISIT: 9!/ $7 ria /) f/[ E PURPOSE OF VISIT: $/3 c W ri/M/ l INSPECTOR (S) OBSERVED: [m/d(>tt.ift4f1

/ (/

SENIOR LICENSEE PERSON CONTACTED: [), [/4 f u (m'\

STRENGTHS OR WEAKNESSES NOTED WITH PLANT: .

liY1(k Col 1 ih 6Y) /10/'111tLf

• kl0M l Mb L' L)  ;

ussi?5 et,nbu . .% hrs i!LtymM A c Head- 1 p* JfMLb.'& hlbMpf k iNCb T STM1 hMG -

i i

OTHER COMMENTS: hntt/f,tt yJ)((g'[ 33 p g gj_

MllA III')t/f7 ((btf bN, inh Il'l$1/ 6M% ltii 1 ff,A9il N/^-

^l * \f .f vc f ' fjh l ) Yf{ltibf,.hl*fel'GLLVV%' .

au tsn}pu kt<k(fnyt (10 lion vy 9 4(0 0%G b'L h\ f f Ifh }4^Ot L l A$'lJl}gij'izhsrs

}^f bid /.

9 I e m s(wtM(c Dk4on'J 00f$AM (Signature illVl92' VDate cc: Regional Administrator /L (/41, th Technical Division Directors gf

'ognizant Senior Resident Inspector Cognizant DRP Branch Chief Cognizant NRR Project Manager

APPENDIX B TRIP REPORT MEMORANDUM TO: Deputy Regional Administrator FROM: 3 kI (2,/l)rtf

SUBJECT:

REPORT ON TRIP TO [f DATE(S) 0F VISIT: /4 [7-8f97 PURPOSE OF VISIT: /Tra-/ -/rnet. , L//# ;fus,,,41d r yn INSPECTOR (S) OBSERVED: A/d 4tt<,7 c insft,, fb1 O /

SENIOR LICENSEE PERSON CONTACTED: [. [i f) p STRENGTHS OR WEAKNESSES NOTED WITH PLANT:

IdL 00l[th f Mh* Ni kgfb hh D(f TVENdh n (({f In I hf hy$> . pQU [',y g l9 pjp 9 gohh

                              ,                                    th& &

hj u s&&a bb b slud aum - OTHER COMMENTS:

                                                  /M7/Sitku Signature ihv/d
                                                                        '/Date cc:     Regional Administrator                                 ((pjjg Technical Division Directors Cognizant Senior Resident Inspector Cognizant DRP Branch Chief Cognizant NRR Project Manager t

                                                                             \

i SPECIFICATIONS

1. Calibration facilities for radiation detection / measuring instruments shall hold accreditation from the National Institute of Standards and ,

Technology as a Secondary Standards Facility. I

2. All instruments shall be calibrated by m' *is and standards traceable to NIST. All calibration techniques uset inust meet or exceed the l American National Standard Radiation Protection Instrumentation Test and )

Calibration procedures described in ANSI W323-1978, with the following { exceptions or clarifications: )

                                                                             \

The instrument will not necessarily be labeled with all of the l calibration information specified in section 4.5 of the standard. l

        'but appropriate calibration data shall be provided NRC via a calibration certificate. Instruments shall be labeled with the date of calibration, date of expiration, and the identity of the person performing the calibration. Beta correction factors shall be indicated on the instrument where applicable.

3. The facility selected for this contract may be subject to a quality assurance audit by NRC personnel prior to and at any time following the awarding of the contract.

4. Instruments shall be shipped or delivered to personnel / locations specified by NRC.

5. The facility must be capable of calibrating and returning instruments within 24 hours of receipt by the calibration facility. Approximately 6 such " emergency calibrations ~ may be required per year.

Instruments received for routine calibration shall be calibrated and 6. returned to NRC within 14 days of receipt by the calibration facility.

7. Probes / detectors listed with instruments on the attached list reflect the current status of the inventory and is submitted for planning purposes only. Probes may be switched among instruments as dictated by operational requirements, thereby requiring recalibration of the instrument-probe pair. Approximately 10% of the inventory may require recalibration in this manner during the period of the contract.

Further, approximately 25% of the inventory may require some repair during the year.

8. The attached list of instruments is for planning purposes only and reflects the majority but not necessarily the total inventory of instruments. Additionally, the instrument inventory may change due to the purchase of new. replacement, instruments of similar types during the year.

Attachment 10

INSTRUMENT INVENTORY Manufacturer /Model Qg Comment RATEMETERS (count rate) Bicron 2000 1 w/ pancake GM Eberline E 120 9 w/HP 260 Eberline PRM-5-3 l 3 w/HP-260 Eberline PRM 6 2 w/HP-260 Eberline PRM 6 2 w/HP 270 Eberline RM-14 4 w/HP 260 Eberline RM-19 1 w/HP-270 1 Eberline RM-21-1 2 w/HP-270 Ludlum 3 5 w/ pancake GM t Ludlum 2401 P 2 Benhold LB122 1 2 w/100cm alpha / beta and beta / gamma detector (gas proportional) Ludlum 2221 2 w/100 cm 243 68 detector (gas proportional) l RATEMETERS (Dose rate) { l Eberline 6112B 2 l Eberline E-500B 4 , l Xetex 305 61 l Ludlum 2401 EC 4 l MULTI PROBE / FUNCTION METERS 1 l Eberline ESP 2 4 2 w/HP-260, HP-270, PG-2 2 w/HP-260, SPA-6, LEG-1 1 DIGITAL DOSIMETERS Dosimeter 1888B 6 Stephen 6000 10 ALPHA METERS Eberline PAC-1 3 w/AC-3 l Eberline PRM 5 3 3 w/AC 3 l NEUTRON METERS Attachment 10a l

i 2 Eberline PNR-4 1 w/ neutron rem-ball Eberline PRS 2 1 w/ neutron rem-ball i MICRO R METERS l Eberline PRM-7 3 i Ludlum 19 5 l ION CHAMBERS Eberline RO-2 5 Eberline RO-2A 4 Ludlum 9 3 AIR SAMPLERS RADECO H 809V-II 5 RADECO H 809C 4 RADECO C 8528 1 RADECO C 828 2 PORTABLE MCA Oxford Prospector 1 l l s:\drss\ repair. con

1 _ 1 b ) t n t n e a _ f f N c t m _ u O a n h d r I T V a c

   " oo                SC

( t is s t t a W LE s lis a t k AP IS2 A iz ce t z A _ . ic n ~

   " RD I

RNH EA b o ed pu sen l e _ TGCN s e k t Sm nr

                                                                   - nVir
   ^P                  ANA              n   mi  t o  e      ;.Ezke l

MISR a tW o bB Sloanl l) NB yB r a uy ar nCiaut o DrFa n E C f tep e r T. Ac io dt e n ac a be v seka F e ec _ I L ih cC ic fN a .H Re idDJLM( a oeiV a C Se r f O S R _ R . O N t RTY O r n OCR e a R I t T k s TEA c A Y CRT C is y - SE e s t is le E L TE EDE D I R R LP 1 A l a ia _ AS t m g s B C F DT IYC RNH I o n i c e k A SP,USE k _ US I EAC T is p a s TGN n S i c e yea nrt N , ANA e iciem non pooar e n skhc F LS NEE I LDI L MSR I r o L e os SJoMal B s H bn iae naL aPe L ,L N yo O A OYA I E r aM la n e dH oeein P NIR CEC SC C f t e rdea tra ay adbrdsanaryyh lad Ra U ei in r o OE S T SOM I AH ih cn C ei r. J daAWOB J A SL M d R GS N I L V IM E D UELR ORA r _ DAK t o H c C ey pe

    -                                                                                         sr nhp
    "                                                                                        i
                                                                                                        )

t nm t eu ycan dH r er tVa a s _ sy e( S E Ra r .G r c e N S S t n t is t a _ e la is s i n i c s Ar lp e p A S A r o E c S m r o LI M y t c a EITH . i u o n t t is e p r g t c UILC d l e I FCN E s ie mu nye e c la ic s n P o r pye s e AA FR t h s e S e i s) sb y nh ig kr B iecrsS l an Se pn e( 2 er y v t u u ayrh bi a nH i B FAoe a e t ci n d i) l t ihK oo ib in de y ry so c l eiGo dl r uv l e yT io a ca ce ac N - isl i r arr e Failb Pil dtG Fa Fin ea erhe t h f l al a &W Rh ih r C S

                                       .DBD S

r. B RaAi lev F u( leJ F

u B S r .C S cS e}}