ML20246H537

Forwards Natl Program Review Schedule,Agenda & Questionnaire for 1989

ML20246H537
Person / Time
Issue date:	02/06/1989
From:	Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Dan Collins, Ebneter S, Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20245G190	List: IA-89-180, Forwards Natl Program Review Schedule,Agenda & Questionnaire for 1989 ML20245G187 ML20245G202 ML20246H537
References
FOIA-89-180 NUDOCS 8903200305
Download: ML20246H537 (26)

Text

~

FEB s's met MEMCAANDIM FOR: Stewart D. Ebnete'r Director Division of Radia. tion,5afety and Safeguards, RI Douglas M. Collins Acting Director Divlsion of Radiation Safety and safeguards, RII charles E. Morelius, Director Division of Radiation Safety and Safeguards, RIII

~

.RichardL.Bangart' Director i

DivisionofRadiatIonSafetyandSafeguards,RIV 4

Ross A. Scarano Di tor.

r' DivisionofRadIsti Safety and Safeguards, RY a

FADN Richard E. Cunningham Director i

l DivisionofIndustrialand Medical Nuclear Safety, NM55 i

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EUBJECT:

NATIONAL PROGRAM REVIEW SCHEDULE AND AGENDA 1

j tP Dn January 24 1989 we sent you the final schedule for the 1989 regional visitstorevIewfuelcycleandmaterialsprograms. This memorandum confirms. :.,

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.the schedule, and transmits our pr9 posed discussion topics and a questionnaire *.-

.i to be completed and provided to us at the time of the visit. The NMSS review

,iteams will include members from each of the NMSS regionalized progress-materials.

si

. fuel qycle, low-1evel waste, safeguards, and transportation. '

,We would appreciate it if you_could make appropriate.nenbers of your licensing,

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uinspection, and resource manageinent:st&ffs av&ilable'during.ourevisit.ffs 2nust we

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' Please note that the visits are~ hot o'ntyko'teview the regionabprogressWhat,w u=,-

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also to evalusta the quality of,the support and guidance which Headquarters 11 provides to you. Also, we intend to issue our reports more promptly than in past years. We will send draft reports to the Regions for connent no later than April. If you have further questions please call me, or have a member of your staff contact John Hickey, or George deegan (FTS 49-20625).

Richard E. Cunningham Director DivisionofIndustrialand Medical Nuclear Safety, NMS5 i

cc: Hugh L. Thompson, Jr.

Robert M. Bernero Enclosures 1.

Schedule 2.

Viscussion Topics 3.

Questionnaire 3 #

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$$5MA80NALFR0GRANREY!dWSCHEDULE-1989

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Region I Region T.!*

Region III t

Date: March 9-10 Date: Feb 28-March 1 Dater March 7-8 e

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E. $joblom 1.

8. Sjoblom. -

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G. Sjoblos N. McElroy 2.

J. Austin 2.

M. LamastrE 2.

S. 81dinger;-

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J Swift 3.

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J. Swift 4.

D. Cool 4'.

J. Mickey 4.

D. Cool 5.

A. Gre11a 5.

W. Floyd 5.

J. White

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W. Floyd 6.-A. Pangburn 6.

A. Gre11a 7.

L. Person t-7.

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C.'$eelig

8. -:P. McLaughlin 8.

C. Seelig RegionIV(URFD)':

Region IV(Arl. TX) ';_..

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i* 't ii, f ' i t ' ' ' #Each visit irill begin at 8:30 a.m. en 04y 1 and and before non on Day 2.

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DISCUS $!0N TOPIC $

During the visits, the following tcpics may be discussed:

. n 1-technical quality of licensing and inspection Thoroughness, cargleteness,6 c{ t.c.

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-. Trends in timeliness fo711 censing casework and inspections how i

delays are identified and corrected in licensing process 7e,~,, mf,

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fiey ch ~n <-~ < <K ;<cwec.em Supe,rvisory participation and feedback in licensing casswork and

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and train 1np. fe }es and involvement with inspector accompaniments.

inspection activiti 6 k 4... case Q(,a rf g,. cz'. ir-wm.> Hee, </r d w,ew,f e5.aco~p.a,.,,,,,e SYP2:<~TJ#~U,,-

Training prop ass for&,cr4 es +s and inspectors Jeff WA %.r,v. e,a /

reviewer A

Mar to id re

<a w ~y iG. ap,,vvee/-7 Inspection performance on allegations, incidents, decommissioning.

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and medical misadministration

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deficiency

' procedures for 11cer.se application resubmissions,ies, expired 9

letters, abandonment letters, telephone deficienc vi

.t licenses, returned mail

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Procedures for prelicensinglisi_ts.;-fc Af$ "</Macob,v/sg 1..

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. Resoured utilization and operating 1 plan accomplishments

=+;AE.1 ---T Open action items from Executhe Seminar,-Reviewer Workshop, last

. year',s program reviews etc.

i Regions.1 initiatives ~ z< a - / e v - + /' b 4-rri Interface with licensees; proposed seminars / workshops etcg dealing 4

.a with problem licensens i

Interface with Headquarters i

4 Performance Evaluation Factors i '

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R$$-1989 REGIONAL QUE'5T!0NNA!RE This questionnaire is for the purpose of obtaining information about regional M SS licensing and inspection activities. The. space'provided is not adequate.

so we ask that you provide separate sheets for for responding to the questions,lude at part of the respor.se a copy of any each question and response. Inc l

pertinent. written internal procedure which you have developed and have in l

place.

It is not necessary for the res >onses to be sent to NHSS Headquarters.

Rather, eight copies of the responses stould be given to the National Program Review Team when it conducts its review at your o,ffice.

1.

Using the current version of your regfonal staffing plan related to the MSS program, specify the approximate percentage of time that each individual sp. ends on the following' aStivitiesi fuel cycle licensing, fuel activities, and inspections of deco.ng, materials inspection, safeguards cycle inspection, materials licensi n

t

~/

l mmissioned facilities and..

Provide a sunmary of actual expenditures and ac lishments as com>ared i i

2. '

to operating plan / budgeted expenditures and acco ishments, for FM6 and FY89 to date.

t 3.

Are there any changes need9d in the estimate of workload projection for the current fiscal (licensing actions and inspections conducted)hanges with justification.

)

year? If so', p. lease provide your suggested c

." Are there any foreseeable barriers to cog leting inspection modules ip 1

' accordance with' Manual Chapters 2600 and 28007 A., A g /g, g.rn.

ort functions erformed in a timal ' i.7*^

j Are.re!fonah administrative su amannerinwhchthesesupportfufctions 4.

manner Are changes'needed in are wrformedi If so, please be prepared.to discuss theJ anges needed h

a a

whic) would result in optimal administrative: support fpr;$he pdgramsA _m.=

I 5;

Please provide your comments on the programs for interaction-of

- ~ +

Headquarters with your Region. Please include your comments on the usefulnes's of the conference calls licensing workshops, executive management seminars, inspection acc,ompaniments, telephone calls on case.

reviews, technical assistance provided on a day-to-day basis, standard I

review plans, guides, etc. Include iri your comments your suggestions and

' recommendations for modifications, changes improvements, etc., in the interaction programs.

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f Sunnarize regional initiatives to improve the qualiti of ins $eCions and

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5.

p license reviews 1censee safety problems,, particularly those aimed toward preventinnor those aim I

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/s activities in a safe manner.

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Summarize the total number of inspections of, Transportation activities at f

'" " ' 7 i MC 2800 licensed program facilities (Procedure 86740) including average staff-hours per inrpection and a brief summary of the most typically observed violations. Sunnarize (Regions II and V) referrals to other regions of state identified violations on shipments by NRC licensees to.

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commercihl burial sites. Summarize the com)1etion status of inspections o!'

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of transportation activities at 2600 (f8674)) and 2500 (#86740) and

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1. 86721) program facilities. Please provide early observations on.the l

impact of tte Core Inspection Procedure #83760 on the inspection of l'5.1 transportation activities at 2600 program facilities.j..,,,

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DaTe ROUTING AND TRANSMITTALSUP 2/8/89 l

TO: (Name,o#lce symbol,toorn run6er.

Inittels Date

- hannne, AgencyPoet)

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Act6en Flie Note and Retam r-Appewel For Clearance Per Converestion g

As Roguested For Correction Propero Reply i

Circulate For Your information See Me Comment in "'_-

Signature I

coonsnation I,sustwy j

REMARKS A reminder, I will be on leave during the NMSS review.

Art will be acting for l

me and will have a briefing book prepared.

i I anticipate no problems in the NMSS areas I

of licensing (they may comment on how long it takes us to complete a case), inspections i

lh transportation or route surveys.

Bill Floyd will be the one to conduct the review and he will be talking with Art next week.

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cc: ADM, LRN l il-I f

DO NOT use this term as a RECORD of apptwels, concurrenoot, mapamah I

cteerences, and similar actions i

PROM: (Nems,'orp, eyrnhof, AgencyPost)

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BRIEFING INFORMATION FOR NMSS REVIEW 1.

Number of Materials Licensees 323 Rc-l ion V does the licensing reviews for 293 Also Region V does assist inspections (approx 20/ year) for the broad licensees i.e., Department of Agriculture, Air Force, and Navy.

2.

Headquarters Personnel doing Review G. Sjoblom NMSS/IMNS Industrial & Medical Nuclear Safety N. McElroy NMSS/LMAB Medical Academic & Connercial Use G. Bidinger NMSS/IMSB Fuel Cycle Safety G. Deegan NMSS/IM0B Operations Branch, Industrial & Medical A. Gre11a NMSS/SGOB Operations Branch, Safeguards &

Transportation W. Floyd NMSS/SGOB Operations Branch, Safeguards &

Transportation L. Person NMSS/LLTB Technical Branch P. McLaughlin NMSS/PMPA Program Analysis 3.

Backlog Data

" Oldies" are renewal requests received prior to January 1,1988.

There are 6 renewals on our " Oldie" List. 2 of these were completed N

in February 1989 - Chevron and EPA Las Vegas

/

I

___11.___1_____.____

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l

, 4 others are:

V. A. Sepulveda - Pending University of Hawaii - Management Meeting March Plant Inspection - Second round deficiency letter Army Yuma - Technical: Assistance Request to Headquarters Greater than 180 days New Applications and Amendments O

Renewals 11 Greater than 90 days New Applications and Amendments 3

Renewals 8

4.

Performance Evaluation Factors as of January 31, 1989.

a.

Number of licensees evaluated using PEFs:

Industrial:

46 Medical:

10 Academic:

1 Total of 57 licensees b.

Number of licensees evaluated as showing degrsded performance:

Industrial:

16 with violations on 591 form.

3 with Notice of Violation letter.

Medical:

4 with violations on 591 form.

3 with Notice of Violation letter.

-. _ = _ - _ - _ _ _ _

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. c.

Types of follow-up action'taken for each case of degraded performance:

Industrial:

1.

The violations on the 591 form are to be reviewed during the next inspection.

2.

One NOV lead to an enforcement ccnference and a

$2,000. civil penalty.

3.

One NOV lead to a management meeting with an early re-insepetion.

4.

One NOV lead to an early re-inspection only.

Medical:

1.

The violations on the 591 form are to be reviewed during the next inspection.

2.

One NOV lead to an enforcement conference and a

$2,500. civil penalty.

j 3.

Two other.NOVs rated an early re-inspection j

status.

5.

July Meeting with Licensees.

We are planning a two day workshop to discuss the implementation of 10 CFR Part 35. The agenda items currently planned include:

i Effective date for Part 35 Responsibilities and Authority of the Radiation Safety Committee Responsibilities and Authority of the Radiation Safety Officer l

Visiting Authorized Users Misadministration Report and Record Keeping Training Requirement for Professional and Ancillary Staff

" Moonlighting" personnel in Nuclear Medicine and Radiation Therapy Performance Eva'suation Factors Program Quality Assurance Questionnaire i

I1 1.

o__ _-__ _---

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7

. 6.

Licensing Action Turnaround Time C

l Target 75 days l.

Average 1988 49 days-1!

Average 1989 (10/1-1/31) 44 days Cases pending as of January 31, 1989-1 New and Amendment -

36 Renewals 34 Terminations 3

Total' 73 e

l l

1

1 An interim update to the Performance Evaluation Factors (PEF) Program as of February 21, 1989.

e (1) Number of licensees evaluated using PEFs:

Industrial:

58 Medical:

12 Academic:

4 Total of 74 licensees (2) Number of licensees evaluated as showing degraded performance:

Industrial:

25 with violations on 591 form.

4 with Notice of Violation letter.

2 with escalated enforcement actions.

Medical:

6 with violations on 591 form.

3 with Notice of Violation letter.

I with escalated enforcement actions.

Academic:

I with violations on 591 form.

I with escalated enforcement actions.

(3) Types of follow-up action taken for each case of degraded performance:

Industrial:

1.

The violations on the 591 form are to be reviewed during the next inspection.

2.

One NOV lead to an enforcement conference and a

$2,000, civil penalty.

3.

One NOV lead to a nanagement meeting with an early re-insepetion.

i 4.

One NOV lead to an early re-inspection only.

5.

One NOV lead to an enforcement conference.

4

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.. Medical:

1.

The violations on the 591 form are to be reviewed during the next inspection.

2.

'One NOV lead to an enforcement conference and a

$2,500. civil penalty.

3.

Two other NOVs rated an early re-inspection status.

Academic:

1.

One NOV lead to an enforcement conference.

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REGION V MATERIALS SAFETY AND SAFEGUARDS PRJGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE

-1.

Using the current version of your regional staffing plan related to the NMSS program, specify the approximate percentage of time that each individual spends on the following activities: fuel cycle licensng, fuel cycle inepction, materials licensing, materials inspection, safeguards -

-activities, and inspections of decommissioned facilities and reactors.

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REGION V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE 2.

Provide a sumary of actual expenditures and accomplishments as compared to operating plan / budgeted expenditures and accomplishments, for FY 88 and FY 89 to daie.

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fc REGION V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE 3.

Are there any changes needed in the estimate of workload projection l

(licensing actions and inspections conducted) for the current fiscal year? If so, please provide your suggested changes with justification.

Are there any foreseeable barriers to completing inspection modules in accordance with Manual Chapters 2600 and 28007 Fuel Cycle Inspection No changes are needed for FY 89 fuel fabrication inspection program.

If Atomics International and/or General Atomics become involved in l

decontamination / decommissioning of their facilities, some changes may be necessary. There are no foreseeable barriers to completing the MC 2600 inspection modules for FY 89.

Materials Inspection No changes are needed for FY 89. The estimated 120 inspections will be completed in accordance with MC 2800.

Materials Licensing The estimated case workload projection may need to be adjusted due to the increased effort necessary to complete the "old" cases and the escalated enforcement activities by reviewers - Skov and Montgomery.

Safeguards Fuel Facility Licensing Program Our experiece for FY 88 reveals that while 3 casework estimated receipts were projected; actual receipts were 6 cases. The fuel facilities regional safeguards licensing casework estimated receipts for FY 89 is projected as 8 cases, and two cases were received in the first quarter.

The projections are therefore, at present, right on for FY 89.

Safeguards Fuel Facility Inspection Program No changes are needed for FY 89. There are no foreseeable barriers to completing the inspection modules in accordance with MC 2681.

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4' REGION V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE 4.

'Are regional administrative support functions performed in a timely manner? Are changes needed in the manner in which these support functins are performed? If so, please be perepared to discuss the changes needed which would result in optimal administrative support for the programs.

Regional support functions appear adequate to support the NMSS programs in Region V.

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REGION V MATE 21ALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 i

REGIONAL QUESTIGHNAIRE q

5.

Please provide comments on the programs for interaction of Headquarters with your Region.

Please include your comments on the usefulness of the conference calls, licensing workshops, executive management seminars, inspection accompaniments, telephone calls on case reviews, technical assistance provided on a day-to-day basis, standard review plans, guides, etc., in the interaction programs.

Materials Licensing and Inspection Interaction with headquarters has improved over the recent months. The conference calls have become more useful since topics are being assigned to individuals for resolution. The licensing workshops are still important for the resolution of problems common to all regions and headquarters.

Inspection accompaniments are valuable to the headquarters staff in that a better understanding of regional activities is obtained.

Reviewer's guides and review plans should be upgraded.

Radiography guides do not address the transportation requirements, the RSO requirement, and the quality assorancs program. The medical review i

plan has disagreement between RG 10.8, Rev. 2 (Aug. 87) Appendix P and RG 8.20 relative to a bioassay requirement for I-131 capsules. Also, final guidance is needed for well-logging applications prepared relative to Part 39.

How do we handle Part 39.41 for well-logging devices which do not meet new criteria after July 14, 19897 Should we expand the type of cases which require technical assistance, i.e., 5 half lives vs. ten half lives for decay in storage?

Safeguards Licensing and Inspection Interaction between the regional safeguards inspector and the licensing reviewer and their NMSS counterparts has been effective and such interaction is conducted on an as needed basis.

The monthly safeguards inspection conference call sponsored by the NRR Safeguards Branch, and has been participated in by NMSS, appear to be an effective means of communicating generic type safeguards issues, problems, and program changes. We recommend they continue and that NMSS continue to participate when topics also appear to reflect on NMSS programs.

There have been no safeguards licensing workshops (formerly sponsored by NMSS) since the reorganization splitting materials and reactor safeguards licensing and inspection functions. This was a disappointment as these were considered to have been one of the most valuable mediums for interchange by all regions with the various headquarters elements managing or administrating regional safeguards program activities. They should be reinstituted, whether on a joint basis by NMSS and NRR or on a separate basis by each. The joint workshops would appear to be most desirable and efficient based on experience of the previous workshops.

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Question 5 Cont'd.

An NMSS/SGOB representative accompanied a Region V inspector during a Category I Fuel Facility safeguards inspection in February 1988. The interchange between the two during this inspection was considered to have been outstanding by the regional inspector. Recomend -

consideration be given'to documenting these accompaniments in a manner to preserve the positive and/or problem areas encountered during the inspection. This could also serve as educational feedback for other regions as well as the one involved.

Telephone calls on case reviews are made on an "as needed" basis.

In all cases where a licensee change appears unacceptable; where policy or generic issues may.be involved; or where a potential problem is identified or perceived; the case is telephonically discussed between region and the headquarters cognizant program office.

Safeguards licensing reviews are based on guidance contained in the NMSS provided " Safeguards Regional Guidance" Manual.

I Fuel Cycle Inspection There presently are no scheduled interactions between the Region and Headquarters in the area of fuel fabrication facilities. Contacts on an "as needed" basis have been satisfactory and responsive.

In the past Headquarters accompaniments on our fuel fabrication inspections have been most beneficial and we encourage continued support in this area.

We believe the Region (Fuel Facility Inspector) should be informed in a timely manner of the results of discussions between the licensee and NRC licensing on matters related to fuel fabrication license renewal or major modification.

We suggest a fuel facility counterpart meeting in Headquarters, possibly in connection with the Fuel Cycle Workshop being scheduled for April /May 1989.

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p REGION V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE 7.

Summarize' the total number of inspections of Transportation activities' at MC 2800 licensed program facilities (Procedure 86740) including average staff-hours per inspection and brief summary of the most typically observed violations. Summarize (Regions II and V) referrals to other regions of state identified violations on shipments by NRC licensees to commercial burial. sites. Summarize the completion status of inspections of transportation activities at 2600 (#86740) and 2500 (#86740) and

(#86721) program facilities. Please provide early observations on the impact of the Core Inspection Procedure #83750 on the inspection of transportation activities at 2500 program facilities.

Material Licensing and Inspection Thetransportationactivitiesunderthe(Procedure 86740)MC2800has involved a total of 108 inspections (10/1/87 to 12/31/88) for 30, 40, and 70 docket type'of licensees. A total of 148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br /> was expended. A total of 34 violations was identified. The majority of the. violations were associated with shipping paper requirements, labelling, and the Special Form and DDT 7A certifications. We have not had any regional referrals of NRC licensees with violations at the burial sites during FY 88.

Activities associated with Inspection Procedure 84850 have been as follows: 030 and 070 Dockets Number of inspections 16 Number of inspection hours 40 Number of violations O

Safeguards Licensing and Inspection t

As provided for in the letter from the Director, Division of Safeguards and Transportation, NMSS, to all regional Directors, Divisions of Radiation Safety and Safeguards,

Subject:

SAFETY / SAFEGUARDS TRANSPORTATION INSPECTIONS, dated November 4,1987; three transportation safeguards inspections were conducted in FY 88 and one to date in FY 89. Two more are programmed for FY 89, if the appropriate transport activities become available for inspection.

In FY 88, the three inspections indicated for Region V in the "FY 1988 NMSS Inspection Schedule" were one each for: Spent Fuel Imports, Category II Shipments, and Domestic Spent Fuel Shipments. One each was conducted for Category II. Shipments and Domestic Spent Fuel Shipments; however, since no Spent Fuel Imports were reported, a Spent Fuel Export was substituted.

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Question 7 Cont'd.

The FY 89 inspection pertained to a Category 11 shipment being exported through the Port of Oakland.

Inspection Modules used during Safety / Safeguards Transportation Inspections were 81335, 85301, and 86740.-

r No transportation activity has been available for inspection at 2500 program facilities; therefore no safeguards experience exists to date to gauge the impact of the Core Inspection Program on the inspection of transportation activity at those facilities.

Fuel Cycle Inspection Transportation activities have been inspected (Procedure 86740) at all fuel fabrication facilities within the last year.

Reactor Facilities (MC 2500)

Procedure 86740 has been completed at two Region V facilities (Diablo Canyon and Palo Verde). Procedure 66721 has been completed at one Region V facility (Palo Verde). Not enough of the Core Inspection Program has been completed to assess the impact of procedure 83750.

REGION V MATERIALS SAFETY AND SAFEGUARDS PROGRAMS RESPONSES TO NMSS-1989 REGIONAL QUESTIONNAIRE 6.

Sumarize regional initiatives to improve the quality of inspections and license reviews, particularly those aimed toward preventing licensee safety problems, or those aimed at licensee's performing their transportation activities in a safe manner.

Materials Licensing and Inspection The following initiatives have been implemented:

More time is spent with the licensees in discussing the license conditions and the associated regulations.

Inspections are more in depth using performance factors.

Problem licensees have reduced inspection frequencies and management meetings.

l Transportation module 86740 is reviewed during each inspection where applicable.

Safeguards Licensing and Inspection The Region V Safeguards Section initiated in the first quarter of FY 89, a goal of training an alternate inspector for fuel facility physical security inspections. For the past three years, fuel facilities had been inspected by one principal safeguards inspector. While an alternate had been designated for the same time period, the alternate performed no inspections or accompaniments at fuel facilities. A second inspector accompanied the principal inspector on an inspection of General Atomics, a Category I Fuel Facility, during December 1988. This allowed accomplishment of all semiannual program goals in one trip, instead of the usual two trips per semiannual inspection cycle at this facility.

It is intended to rotate these two inspectors in the future in a manner which will allow both to remain familiar with each fuel facility site and to be experienced in fuel cycle physical security inspections.

Fuel Cycle Inspection Regional management expects to visit each fuel fabrication facility each year.

The Fuel Facility Inspector attended an OSHA training course in FY 88.

Additional inspectors are scheduled to attend OSHA training courses (Hazardous Materials and Fire Protection) during FY 89.

Additional inspector training on transportation requirements is expected to be accomplished during FY 89.

Reactor Radiation Specialist and Emergency Preparedness Analysts are being used to support the Fuel Facility Inspector.

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