ML19256E699
| ML19256E699 | |
| Person / Time | |
|---|---|
| Issue date: | 10/25/1979 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Hazle A COLORADO, STATE OF |
| References | |
| NUDOCS 7911150033 | |
| Download: ML19256E699 (2) | |
Text
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OCT 2 51979 Ref: SA/J0L Mr. A. J. Hazle, Director Radiation & Hazardous Waste Control Division Department of Health 4210 East lith Avenue Denver, Colorado 80220
Dear Mr. Hazle:
This is to confirm the comments made to you and your staff regarding the recant regulatory program review conductec by Joel Lubenau.
Based on the results of the review, the staff believes that the State's program for control of agreement material is adequate to protect the public health and safety and compatible with the programs of the Nuclear Regulatory Commission (NRC) and the Agreement States.
We believe improvements are possible in several areas. Specific comments and recommendations are enclosed.
I would appreciate your review of our recommendations and would like your resp,onse to them.
I appreciate the courtesy and cooperation extended to Mr. Lubenau during his meeting with you and your staff.
Sincerely,
[
d G. Wayne Ke r, Assistant Director for State Agreements Progran Office of State Programs
Enclosure:
As stated cc: Dr. F. Traylor 1337 286 0
7911150
'9 COMMENTS AND RECOMMENDATIONS ON THE COLORADO RADIATION CONTROL PROGRAM I.
Administration 1.
We recommend the staff develop and document its procedures for carrying out escalated enforcement actions, such as Orders to impound sources or to cease and desist, modify, suspend or revoke a license.
2.
We recommend the Radiological Emergency Response Plan for Transportation Incidents be updated, the pages show the date of issuance (or of revision) and a distribution list be completed and incorporated into the plan.
3.
We believe management of the files should be improved. We noted instances where file folders did not contain all relevant documents; confusion existed amongst the staff as to the status of an apparently expired license; and folders contained excess, superceded materials which could be purged and placed into storage.
We also noted that filing of uranium mill license files (which are separated from other materials files) is perform,:d by professional staff.
II.
Licensing 1.
We noted that when licenses are
- renewed, licensees have not been submitting updated information. As an example, one license file incorporated 20 letters and applications, some dating to the early 1960's. We found instances where applications for renewal were granted without a review being made of the application according '
to current licensing criteria. We recommend all applicants for renewal receive, in addition to their renewal notice, a copy of the current licensing and applicable regulatory guides. Reviewers should review renewal applications against current license requirements.
References to out-dated and superseded materials should be deleted from licenses.
III.
Compliance 1.
Inspectors should be accompanied periodically by the supervisory staff for the purpose of evaluating their performance in the field.
2.
We recommend arrangements be made to conduct close-out surveys of the premises vacated by Statitrol.
3.
Intpectors should evaluate ventilation controls in facilities having potential for airborne radioactivity and where engineering controls are used to control such hazards, for examples, surveys of air flow velocities at hood faces. A velometer is available, however, smoke tubes and aspirators are needed.
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