ML20003C468
| ML20003C468 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/1981 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Ashby F LOUISIANA, STATE OF |
| References | |
| NUDOCS 8103060175 | |
| Download: ML20003C468 (2) | |
Text
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- es'o, UNITED STATES l'
/ 7, NUCLEAR REGULATORY COMMISSION i
WASHINGTON, D. C. 20555 s,,
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FEB 131331 Ref:
SA/RJD 5l.6 4
Mr. Frank A. Ashby, Jr., Secretary Department 17 Natural Resources g
P. O. Box 443SJ Q
Baton Rouge, Louisiana 70804 24 k
[l 4
Dear Mr. Ashby:
This is to confirm the discussion Mr. R. J. Doda held with you Messrs. B. J. Porter and W. H. Spell of your staff following our
- ,i and evaluation of the Louisiana radiation control program. The revi..
covered the principal administrative and technical aspects of the program. This included an examination of the program's funding and personnel resources; licensing, inspection and enforcement activities; emergency response capabilities for agreement materials; and the status of the State's radiation control regulations. There were also field accompaniments of State inspectors during this review.
Our review used as a reference the NRC " Guide for Evaluation of Agencies and 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 as to their relative importance to an Agreement State program is provided by dividing the Indicators into 3 categories. When significant problems are found in program areas for which Indicators are in Categories I or II, we will need additional information in the fonn 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.
If no significant problems are found in these areas, staff opinions on the adequacy and compatibility of the program may be made following the review meeting.
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 Louisiana, the staff believes that the Louisiana program for regulation of agreement materials is adequate to protect the public health and safety, and is compatible with the NRC's program for regula-tion of similar materials.
It was noted, during the administrative part of the review, that the agreement materials program expended an average of $315 per license.
(This is an average value calculated by considering first all of the State's licenses and then deleting certain in vitro and gauge licenses.)
This is within the NRC's recommended range of $200-$350 per license for a program not involved in complex licensing actions and for an average geographical area. The staff training level for the review period was 8.4% of available staff time, which compares favorably with the NRC's recommended range of 5% to 10% for technical training.
3060179
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g Mr. Frank A. Ashby, Jr.
2 Staff efforts devoted to the agreement material program were found to be about.85 professional staff years per 100 licenses which is below nhe NRC's recomended range of 1 to 1.5 professional staff years per 100 licenses.
(This, again, is an average value calculated as indicated above.) This is a Category II Indicator. No significant problems in the technical aspects of the program were found which were attributable to this indicator. However, we believe this is due to the quality of the agreement materials staff and, since the overall program is particu-larly vulnerable at this staffing level, we recommend that the State closely monitor this situation and consider ways of obtaining additional staff.
In this regard, we are aware of the State's current activities concerning license fees and believe this is a responsible solution to partial funding of the program.
We recommend that the State consider performing more of its routine inspections on an unannounced basis.
Our recent experience indicates that a policy of announcing most inspections may produce some detri-mental effects in a State's overall program.
The technical aspects of the license and compliance file reviews were discussed with the staff in detail.
Enclosed for your information is a copy of a letter to Mr. W. H. Spell with comments regarding certain technical aspects of the program.
I am also enclosing a second copy of each letter which should be placed in your State Public Document Room or otherwise be made available for public review.
I appreciate the courtesy and cooperation extended to Mr. Doda during the meeting with your staff.
I would appreciate your review of these recommendations and your comments on them.
Sincerely, h
f G. Wayne ' err, Director Office of State Programs
Enclosures:
As stated cc: Mr. B. J. Porter Mr. W. H. Spell NRC Public Document Room State Public Document Room