ML19312E712
| ML19312E712 | |
| Person / Time | |
|---|---|
| Issue date: | 05/13/1980 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Smith H NEBRASKA, STATE OF |
| Shared Package | |
| ML19312E713 | List: |
| References | |
| NUDOCS 8006090430 | |
| Download: ML19312E712 (5) | |
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UNITED STATES
! Ts.,. ~.' j NUCLEAR REGULATORY COMMISSION
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A ASMNGTON, O C. 20555
%.. /sl eb Ref:
SA/ECA Henry C. Smith, M.D.
Director of Health Nebraska State Department of Health 301 Centennial itall South P.O. Box 95007 Lincoln, Nebraska 68509
Dear Dr. Smith:
This is to confirm the discussion Mr. Ashley held with Messrs. Lawrence Graham and H. Ellis Simons following our review anc evaluation of the Nebraska radiation control program.
The review covered tne principal admin-istrative and technical aspects of the program. This included; an examina-tion of the program's funding and personnel resources; licensing, inspection and enforcement activities including acccmpaniment of an inspector; emergency response capabilities for agreement materials; and the status of the State's radiation control regulations.
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 of Nebraska, the staff believes that tra Nebraska pregram for regulation of agreement material is adequate to protect the public health and safety and is compatible with the NRC's program for the regulation cf similar material.
We are pleased to note that the radiation control program staff has com-pleted work on updating and revising the State's radiation control regula-tions and they are ready for the next procedural step towards adoption.
It has been six years since the regulations were completely revised; there-fore, we urge that the regulations be promulgated as soon as possible.
We believe that outstanding questions regarding the organization, administra-tive controls and specific areas of use of radioactive materials at the various locations of the University of Nebraska should be resolved.
There appears to be a need for clearly defined areas of use for each of the specific pro-grams at the University. We understand there are currently separate licenses issued for activities of the University of Nebraska - Lincoln; University of Nebraska - Omaha (Phamacy); University of Nebraska - Omaha (Medical Center);
and other discrete University of Nebraska operations. We believe each specif.cally licensed activity (facility) should operate as a functional unit.
8006000 bd
1 Henry D. Smith, M. D. >
For example, quality control on radio pharmaceuticals by the receiving organization (e.g., Medical Center) should be carried out regardless of who the materi'l is received from. This will help the staff in its efforts in renewing ex1 sting licenses and issuing new licenses to the University.
I would appreciate your review of these recommendations and would like to receive your comments.
Enclosed for your information is a copy of a letter to Mr. Simmons with comments regarding technical aspects of the program.
I am also encicsing a second copy of each letter which should be placed in your State Public Document Roca or otherwise made available for public review.
I appreciate the courtesy and cooperation extended to Mr. Ashley during the review meeting.
I Sincerely, Y
s.ujM (dAA 0
G. Wayne Kerr Acting Director Office of State Programs
Enclosure:
Ltr to H. E. Simmons cc:
L. Graham, w/ enc 1.
l H. E. Simmons i
NRC Public Document Room, w/ encl.
State Public Document Room, w/ encl.
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COMiiEtlTS AND RECOM!!ENDAT10f15 A.
Administration l.
Conment periodic staff meetings are held on an informal basis to discuss general items of interest to the staff.
Recommendation i
We believe scheduled monthly staff meetings which include a j
planned agenda of specific items for discussion would be useful, particularly since the establishment of your field office in Omaha. A monthly report from each of the staff members would also help in the routine assessment of the status of the program.
2.
Comment License and compliance documents are mixed together in the same folder for each licensee. This system of filing makes it difficult to locate all the documents related to a particular inspection or to a particular license amendment.
Recommendation i
We recommend that license and compliance information be filed separately, whether they be in the same folder or separate folders. This would allow a more efficient retrieval of information pertaining to any licensing or compliance action.
3.
Comment The licensing manual appears to be quite complete and up-to-date.
The compliance manual, however, contains many old references and is not ccmplete insofar as policies and procedures for handling all the various types of compliance matters.
1 Recommendation The Compliance Manual should be updated and include detailed inspection and enforcement guidance.
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B.
Personnel 5
Comment Short term courses sponsored by NRC are designed to increase and naintain appropriate levels of staff competence.
1 Recommendation We recommend that the inspector operating independently out of your Omaha field office attend the next Inspection Procedures course.
C.
Licensing Connent As a result of the review of selected license files, we offer the I
folicwing recommendations for improving the State's licensing activities.
1 Recommenda tions a.
The flebraska regulation equivalent to 10 CFR 19, " Notices, Instructions and Reports to Workers; Inspections," should 1
i be added to the standard condition which requires licensees to comply with the provisions of Part IV of the Nebraska regulations.
b.
For each radioisotope listed on a license, ali licenses should show the maximum quantity (curies, pounds, grams, as appropriate) the licensee may possess at any one time.
Specific instances where these deficiencies were noted involved brachytherapy sources and irradiated nails.
D.
Comoliance i
Comment As a result of the review of selected compliance files and discussions with the inspection staff, we offer the folicwing recommendations for improving the compliance program:
Reconnendations a.
We recommend that the State utilize at inspection report format which is designed to assure that all necessary areas are covered during inspections and reported in sufficient detail. Each area inspected should be highlighted in the report.
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. 5.
Recommendations made to licensees as a result of an inspection should be limited to those items having a direct health and safety implication and which are not covered by regulation or license requirements. The reviewer noted some recommenda-tions which should have been items of noncompliance. Care should be exercised in oroviding recommendations which appear to place the State in the role of a consultant. Detailed information on radiation safety practices and techniques are more properly handled by means of seminars or training sessions.
c.
We recommend that the results of all investigations be documented. We understand that investigations were made of three complaints during the past year but the results were not documented because the investigations revealed that the complaints were unfounded. We believe it to be good regulatory practice for the agency to document the findings of any investigation.
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