ML19207C333
| ML19207C333 | |
| Person / Time | |
|---|---|
| Issue date: | 08/20/1979 |
| From: | Ryan R NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Harkins J KANSAS, STATE OF |
| References | |
| NUDOCS 7909110284 | |
| Download: ML19207C333 (2) | |
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AUG 2 01979 Ref: SA/ LAB Mr. Joseph Harkins, Secretary Department of Health and Environment Forbes Field, Building 740 Topeka, Kansas 66620
Dear Mr Harkins:
This is to confirm the comments that Mr. Bolling made to you and Messrs. Gray, Borchert and Spiker on August 3,1979 regarding our review of the Kansas radiation control program. This included an examination of program organization, administration, personnel, regulations, and licensing and compliance activities.
As a result of our review of the State's program and the routine exchange of information between the Nuclear Regulatory Commission (NRC) and the State, the staff believes that the State's program for regulation of agreement materials is adequate to protect the public health and safety and compatibl' with the NRC's program for regulation of similar materials.
Four problem areas were identified in this year's review, however, which we believe are scrious and interrelated and which need your attention:
1.
During this year's review it was noted that 82 inspections were overdue, mostly in the priority I and II categories. This is a significant increase compared to 1978 when 29 inspections were overdue and in 1977 when 23 were overdue. Eighteen of these inspections are overdue by two years.
2.
We determined that the total professional person-years devoted to the agreement materials program was 2.0 person-years for 253 licenses.
This converts to 0.79 person-years per 100 licenses which is well below our recommended guideline of 1.0 to 1.5 person-years per 100 licenses.
I must point out that this guideline does not take into account the extra staff effort needed to handle complex licenses, such as a low-level radioactive waste repository.
3.
The State has been trying without success to recruit a Public Health Physicist for the past two and one-half years. We learned that a number of qualified applicants have expressed interest, but declined to accept the position because of inadequate salaries.
4.
The current budget for the control of agreement materials was reported to be $52,518 for 253 agreement license;. This is equivalent to $207 per license which is at the lower range of NRC's recommended level of $200 to $350 per license.
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Mr. Joseph Harkins Since 1975, there has been a 35% increase in the number of agreement material licenses administered by the State. There is good reason to believe that this rate of new licenses will continue or may even increase.
Incident investigations and the need to devote staff effort to the proposed ' low-level waste operation have further strained staff resources.
'.le believe the cumulative affects of these factors are now affecting the State's routine inspection schedule. We noted last year that the low-level radioactive waste repository licensing action alone may, at least initially, requjre one-half to one person-year of effort depending upon the scope of the operation.
We therefore recommend action be taken to increase salaries and staffing levels.
Such action, in our opinion, is essential to enable correction of present problems and to enable the State to effectively meet future needs.
Our review of license and compliance files indicated that our recommendations following last year's review have been accomplished. We wish to commend Mr. Allen's efforts in this regard.
I would appreciate your review of our comments and recommendations and receiving any written remarks you may have.
I have enclosed a copy of our letter to Mr. Allen regarding the technical aspects of the program. An extra copy of this letter is being provided for placement in your public document files or other location for public viewing.
I appreciate the cooperation and assistance extended to Mr. Bolling by your staff during the review.
- incerely, g? 'l 9
Robert :G. Ry n, Director Office 'of S ate Programs
Enclosure:
Letter.to Mr. G. Allen cc:
Mr. M. W. Gray, w/ encl.
Mr. G. W. Allen NRC Public Document Room, w/ encl.
State Public Document Room, w/ encl.
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