ML19309H733
| ML19309H733 | |
| Person / Time | |
|---|---|
| Issue date: | 04/25/1980 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Bradley F NEW YORK, STATE OF |
| References | |
| NUDOCS 8005190653 | |
| Download: ML19309H733 (4) | |
Text
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Francis J. Bradley, Ph.D.
Principal Radiophysicist New York State Department of Labor 2 World Trade Center flew York, New York 10047
Dear Dr. Bradley:
This is to confirm the coments made to you at the conclusion of the recent radiation control program review.
Based on the results of the review, the staff believes that the Department's program for con'. col of agreement materials is adequate to protect the public health and safety and is compatible with the NRC's program.
tie believe, however, that improvement can be made in the program.
Specific comments and recommendations are enclosed.
I would appreciate your review of our recommendations and receiving your comments regarding them.
I appreciate the courtesy and cooperation extended to f1r. Solling during the meeting.
j Sincerely,
[
G. Wayne K rr, Assistant Director j
for State Agreements Program Office of State Programs l
Enclosure:
As stated cc:
P. Ross C. ilattei T. DeBoer State Public Document Room NRC Public Document Room /
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/
, Comments and Recon:mendations on the New York Department of Labor Radiation Control Program I.
Administration A.
Comment It was noted that since our last review the level of professional staff effort devoted to training was less than 1% of available staff time.
We recognize that the radiation control program hires only qualified 4
professionals, however, NRC training is designed to increase and maintain technical competence of State personnel.
Recommendation We recommend that the professional staff, especially the new members, be afforded the opportunity to attend NRC sponsored training courses.
Wc recommend that the newest staff member attend the inspection procedures course to be held in August,1980.
II.
Licensin,q A.
Comment A review of selected license files indicated that at least on one license authorizing plutonium, the license condition banning air shipments was omitted.
Recommendation W'e recommend that the license condition banning the air shipment of plutonium except in NRC approved containers be included on all licenses authorizing the use of plutonium.
I B.
Comment A review of selected license files indicated in several instances that the applicants were not being required to state what their action levels were for samples collected during contamination surveys.
Recommendation We recommend that license applicants be required to state at what minimum level of removable contamination corrective measureswill be initiated.
C.
Comment A review of selected' license ' files indicated that two of the three licenses requiring bioassasy for tritium lacked an action plan to deal with elevated levels of tritium in the urine.
Recommendation We recommend that licenseesusing uncontained tritium be required to state what actions will be taken with regard to workers whose urine shows elevoted levels of tritium.
(See Enclosure A).
2-D.
Comment 1
A review of selected license files indicated that one large user of tritium had numerous amendments dating back to 1968 when the license was last renewed in entirety.
Since that time the licensee's possession limit for tritium has increased and their safety manual was fragmented.
Recommendation We recommend that rerewal in entirety _at no greater than 5-year intervals be required for licensees whose programs have grown in size and complexity since the license was originally issued.
This would help to assure that safety programs are consistent with the licensees' activities.
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III.
Compliance A.
Comment A review of selected compliance files indicated that worker interviews were 4
not adequately documented in inspection reports.
l Recommendation We recommend that inspectors interview radiation workers to ascertain their basic knowledge of radiation safety. These interviews or questions should be documented in the inspection report.
B.
Comment Our discussions with the staff and review of available procedures, indicates that the State has developed procedures governing escalated enforcement action. These include procedures for show-cause hearings, cease and desist orders and orders for revocation of licenses.
However.
the role of the Labor Department's attorneys needs to be described and procedures governing off-duty actions have not been integrated nito a single written plan.
Recommendation We recommend that a written plan be developed to cover your procedures for escalated enforcement actions. This plan should cover what would be needed during emergencies, especially during non-working hours when key legal and administrative persons may not be immediately available.
We are enclosing an outline of the key elements which should be included in a written plan.
(See enclosure B) 4
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_ 3-C.
Comment 4
During a review of inspection files it was noted that the present format for inspection reports does not provide a space to indicata the date of the l
previous inspection and any noncomplian:e items found at that time.
i j
Recommendation i
We recommend the foimit of the inspec; ion reports be revised to include the date and noncompliance items if any from the previous inspection. We feel that this will serve as a quick reference for inspectors and that it will I
e;
.e that all previous noncompliance items are reviewed for corrective action.
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