ML19347D119
| ML19347D119 | |
| Person / Time | |
|---|---|
| Issue date: | 02/25/1981 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Myers I ALABAMA, STATE OF |
| References | |
| NUDOCS 8103110093 | |
| Download: ML19347D119 (2) | |
Text
[9 V '
t h UGOq p
g$
h UNITED STATES
'Ig i
(
)
g NUCLEAR REGULATORY COMMISSION j
WASHINGTON, D. C. 20555 5
t
\\
/
FEB 2 5 1981 Ref: (A/ECA G
[@
Ira L. Myers, M.D.
State Health Officer g7
@@g'/
Department of Public Health State Office Building Montgomery, Alabama 36130 L
Dear Dr. Myers:
This confirms the discussion Mr. Ashley held with you and Messrs. Willis and Godwin following our recent review of the state 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; an examination of emergency response capability 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 was a field accompaniment of a state inspector during this review.
As Mr. Ashley discussed, our review used as a reference, the NRC " Guide for Evaluation of Agreement State Radiation Control Programs, Revision 3," dated February, 1980. The Guide was published in the Federal Register as a proposed NRC policy statement on October 3, 1980 and public comments solicited. The Guide provides 37 Indicators for evaluating Agreement State program areas. Guidance on their relative importance to an Agreement State program is provided by categorizing the Indicators into 3 categories.
When serious problems are found in program areas for which Indicators are in Categories I or II, we will need additional information in the form of responses to our letters to you and the radiation control program director before we can offer staff opinions on the adequacy and compatibility of the program.
The professional staffing level for the agreement materials program is significantly below NRC's " Guide for Evaluation of Agreement State Radiation Control Programs" recommended level of 1.0-1.5 person-years per 100 licenses.
Number of Personnel is a Category II indicator. One senior level health physicist resigned his position in early 1980. The loss of this person, other staff turnover, and the assignment of experienced staff to emergency response and environmental activities have resulted in a current staffing level of about 0.49 person years per 100 licenses.
We urge every effort be made to bring the staff up to our recomended level. We understand the Division is experiencing difficulty in recruiting for one position at the Radiation Physicist III level. This level requires a Master's degree and 2 years experience. Perhaps recruitment efferts for less senior personnel would prove more successful. Additionally, we note that qualified personnel are available on the staff who could take up some of the slack in the interim.
8103110093
Ira L. Myers, M.D. A major, adverse impact of the staffing problem is that the number of overdue inspections rose significantly from 35 during the last review to 171 at the time of this review. The status of the inspection program is a Category I Indicator. A smaller number of these inspections would also be overdue under NRC inspection criteria. We believe the State should take action to eliminate the overdue inspections especially for the most potentially hazardous groups.
We are also concerned over tre lack of actions taken in regard to an industrial radiography incident which occurred on August 5,1980. No special inspection or investigation was made. Response to incidents and alleged incidents is a Category I Indicator.
I would like to receive a statement of the Department's policy for conducting cn-site investiga-tions in response to incidents which result in, or threaten to cause, a threat to the public health and safety.
I would appreciate your review of our recommendations and receiving your specific plans to improve the agreement materials program. A letter to Mr. Godwin regarding the technical aspects of the program review is enclosed for your information.
I am also enclosing a copy of this letter for placement in the State Public Document Room and otherwise be made available for public review.
Sincerely,
-(Al lI M G. Wayne Director Office of State Programs
Enclosures:
As stated cc:
A. V. Godwin NRC Public Document Room State Public Document Room l