ML19256G371
| ML19256G371 | |
| Person / Time | |
|---|---|
| Issue date: | 12/13/1979 |
| From: | Ryan R NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Moore R TEXAS, STATE OF |
| References | |
| SA-LAB, NUDOCS 7912310185 | |
| Download: ML19256G371 (2) | |
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SA/ LAB Raymond T. Moore, M.D., Director Texas Department of Health 1100 West 49th Street Austin, Texas 78756
Dear Dr. Moore:
This confirms the discussion Messrs. Bolling and Doda and Ms. McCarthy held with Messrs. Herzik, Cochran and Bailey, following our recent review of the Texas radiation control program. The review covered the principal administrative and technical aspects of the Department's program. This included an examination of the program's funding and personnel resources; examination of emergency response capabilities for agreement materials; and the status of the State's radiation control regulations.
There was also a review of selected licensing, inspection and enforcement activities.
In addition, there were field accompaniments of two State inspectors during this review.
As a result of our review of the State's program and the routine exchange of information between the Nuclear Regulatory Commission and the State, the staff believes that the State's program for regulation of agreement material is adequate to protect the public health and safety and is compatible with NRC's program for the regulation of similar material. We believe,however, that improvements may be made especially in the program's budget and can be made in the staffing level.
The program's limited travel budget has reportedly adversely affected the environmental radiation s"rveillance program and the program's ability to perform prelicensing vis ts. We have been informed by program staff that routine inspection activities must be severely curtailed by the 3rd quarter of fiscal year 1980 if travel budget limitations remain unchanged. We recommend that additional funds be obtained to support the regulatory program and in particular the inspection program.
The staffing level for the agreement materials program is presently 1.14 person-years per 100 licenses. This is within NRC's recommended level of 1.0 to 1.5 person-years per 100 licenses, however, the staffing level should be higher for States administering major and/or complex licensed activities.
Further, the guideline does not include consideration of staffing requirements for regulating low-level comercial waste burial sites and uranium mills.
Current indications are that 2-2.5 professional person years' effort and 516,300 contract costs is needed to process a new mil! license or major renewal to meet the requirements of the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA) for a conventional mill. This effort must include expertise in radiological matters, hydrology, geology, and structural aspects.
We believe that additional staffing is necessary if Texas is to 1661 360 7912310 h
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Raymond T. Moore, M.D.
maintain a quality program and one which, for uranium mill licensing, will enable the State to meet the requirements of UMTRCA. We recommend that additional staff be obtained to enable the State to carry out its expanded responsibilities under UMTRCA.
A letter to Mr. David Lacker regarding the technical aspects of the program is enclosed for your information.
I am enclosing a copy of these letters for placement in the State Public Document Room or otherwise be made available for public review.
I would appreciate your comments on the above recommendations.
Since, rely,
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Robert G. Ryan, Director Office of State Programs
Enclosure:
Letter to D. Lacker dtd 11/ /79 cc:
Mr. G. Herzik Mr. David K. Lacker flRC Public Document Room, w/ encl.
State Public Document Room, w/ encl.
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