ML20140H066

Forwards Short Summary of Issues from Handwritten Notes Provided to Branch Chiefs Following Aug 1996 Visit to Region Iv,Including Actions U Recovery Branch Has or Is Taking to Address Concern

ML20140H066
Person / Time
Issue date:	05/01/1997
From:	Cain C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Federline M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-5 NUDOCS 9705120318
Download: ML20140H066 (4)

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. i'ay 1,1997 MEMORANDUM TO: Margaret V. Federline, Deputy Director Division of Waste Management FROM: Charles L. Cain, Acting Chief (Original signed by)

Uranium Recovery Branch Division of Waste Management

SUBJECT:

RESPONSE TO ISSUES IDENTIFIED DURING AUGUST 1996 VISIT TO REGION IV in August 1996 you visited the Region IV office as Acting Director of the Division of Waste Management to discuss issues of mutual concern. As a result of that visit, you identified a number of areas in the uranium recovery program that required follow up.

Since that time, the Uranium Recovery Branch has undertaken a number of actions to respond to the issues identified from your visit. The attachment to this memorandum contains a short summary of the issues from the handwritten notes you provided to the Branch Chiefs following your trip along with the actions URB has or is taking to address the concern. Based on the information provided in the attachment, URB believes it has or is taking appropriate actions to address the issues. The information provided in the attachment has been coordinated with Region IV, and there is agreement on the success of the actions.

cc: J. Greeves R. Scarano J. Holonich D. Gillen C. Abrams M. Layton CONTACT: J. Holonich 415-7238 DISTRIBUTION: FILE CENTERx PUBLIC NMSS r/f URB r/f  !

CNWRA ACNW 'DG )LLly )

lJU DOCUMENT NAME: S:\DWM\ URB \CLC\MVFVISIT. DOC VA OFC U"RB / URB &

NAME JHolaMch CCain 64Q..

DATE [97 N. 5/l/97 OFFICl AL RECORD COPY 9705120318 970501 WASTE fpff PDR PDR WM-5

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- 1 Follow-Up Actions for Uranium Reccverv Proaram from  !

Auaust 1996 Visit to Reaion IV 4

Charaina of Time for Uranit.m Recovery inspections This item appears to be resolved. Time charged by regionel and headquarters inspectors is

being charged to the appropriate accounts. Data from last fiscal year showed that 2.4 FTE were charged to inspection support by Region IV staff versus 2.5. FTE budgeted.

In addition, the number of inspections completed by Region IV was 34, versus 35 budgeted. This continues to be the case for the first four months of FY 1997. Regional time charged towards inspect:ons was recorded at 0.7 FTE versus the 0.8 budgeted.

Therefore, it appears that time charged by inspection staff from the region is appropriate i and demonstrates a fairly accurate adherence to resource budget projects and planned accomplishments.

With respect to time charged for headquarters support of regional inspections or headquarters lead inspections, weekly reviews of time charges by Joe Holonich end Dan Gillen show that time is being appropriately charged when Uranium Recovery Branch (URS) staff conduct inspection work. Because the URB-oudgeted resources for inspections are included as part of an account covering both inspections and workshops, it is not possible

to accurately track how well actual expenditures track with budget projections. URB will l continue to ensure accurate time charges for inspection work.

Attendance at a Uranium Recoverv Workshoo l

You were unable to attend the November 1996 workshop due to scheduling conflicts. The next workshop is scheduled to be held in Denver on June 3,4, and 5,1997.

Reoort of Uranium Recoverv Events to the Operations Center 1

Region IV personnel raised a concern that licensee events reported to the Operations Center require the Headquarters Operations Office (HOO) to engage the National Response Center. This action causes several Federal, State, and Local agencies to undertake actions. However, in most instances, there is not a need for this type of response to events at uranium recovery facilities.

To address this situation, URB worked with staff from the Office of Analysis and Evaluation of Operational Data (AEOD). Dased on this effort, two initiatives that work in parallel were undertaken, and they should help alleviate the problem. First, AEOD has revised the HOO event response procedure for uranium recovery sites. Upon receiving a j q report from a uranium recovery licensee about an incident at a f acility, the HOO will initially call a member of the Mine Safety Team. This team is the second initiative, and it is comprised of three individuals, Joe Holonich, Dan Gillen, and Mike Layton. These three individuals will be contacted in that order, and one member of the Mine Safety Team will carry a beeper. Contacting a member of the Mine Safety Team will help the HOO put the event into context. This in turn will allow the HOO to inform other agencies of the event and to provide them with some idea of the significance of the event. These initiatives should eliminate any unnecessary activation of the National Response Center which has occurred in the past.

Attachment

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Define Criteria for Issuina or Denvino Ten-Year Licenses These criteria were outlined in the Commission paper and are currently being used by the staff to determine the acceptability of licensee requests for ten-year licenses. Copies of the Commission paper were provided to the licensees in the staff's July 1996 letter informing them of the opportunity to obtain ten-year licenses. Unless there is a specific issue to address, no further action is anticipated.

Laboratories Not Beina Authorized to Accept 11e.(2) Material i This issue was discussed between Joe Holonich and Chuck Cain in Region IV. Based on the conversation, it appears that there are severallaboratories that have either a NRC or Agreement State lice 1se to possess 11e.(2) material for analysis. Region IV agreed to review this issue during uranium recovery inspections in order to identify licensee contractor laboratories performing such analyses and to determine if they are properly licensed to receive 11e.(2) material.

In addition to the above issue, there is another concern with the fact that possession of any amount of 11e.(2) material requires a specific license, while 10 CFR Part 40 allows possession of 15 pounds of source material under a general license provision in Section 40.22. Often the annual fee for a specific 11e.(2) laboratory byproduct materiallicense exceeds the profit that can be made from doing the analyses. As part of its development of 10 CFR Part 41, URB is considering including a generallicense provision for the possession of a limited quantity of 11e.(2) byproduct material.

Planina for Insoections Starting last fiscal year, and again this fiscal year, the region has provided URB with an inspection schedule for uranium recovery sites. Using this schedule, URB has identified

_ particular inspections tnat headqua.ters staff, including contractor support, should attend.

Having headquarters staff support inspections scheduled by the region makes the  !

inspection process more efficient, since it eliminates the need for a headquarters-based inspection and ensures that critical aspects of reclamd.on or plant aperation are inspected.

Adherence to MC 610 for 30-Dav Insoection Reports The concern expressed in your notes was that the region needs input from the headquarters staff in a timely manner to allow the redon to complete the reports consi: tent with the time frame outlined in Manual Chapter 610.- Past experience confirms that headquarters staff have not been timely in getting the necessary input to the region, in addition, interactions with various headquarters staff shows that there is not a sound understanding of the inspection process. There are several corrective actions that URB needs to take to become more timely in providing input to regional inspection reports.

-1. All URB technical staff will take " Fundamentals of Inspection." This will allow the

- headquarters staff to better understand the inspection process, and what objectives should )

be accomplished. Unfortunately, the course is only offered once a year, so it may take a j few years for the entire technical staff in URB to attend the course. l

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2. There is now a requirement in URB that all staff conducting inspections, either headquarters-led or region-led, develop an inspection plan. Information contained in this plan is intended to: 1) lay out the inspection objectives, 2) list what inspection procedures will be followed, and 3) identify what activities will be inspected. This should help ensure a more focused inspection on tt. ' part of the URB staff, and conversely help ensure that all inspection reports can be prepare ' in a more timely manner, since the inspections will be more focused.

3. URB management, and the URB Technical Team Leader will become more involved in the planning, conduct, and follow up of inspections to ensure timely support to the region.

4. The region and headquarters have agreed that for teams less than three people, the report is due 30 days after completion of an inspection. For team inspections, those with three or moro people, the report is due 45 days af ter the inspection, l

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