ML20023D280
| ML20023D280 | |
| Person / Time | |
|---|---|
| Issue date: | 05/13/1983 |
| From: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Purce T IDAHO, STATE OF |
| References | |
| NUDOCS 8305200320 | |
| Download: ML20023D280 (5) | |
Text
_.
MY 131933 Thcmas L. Purce, Ph.D.
Director Idaho Department of Health and Welfare Statehouse Mall Boise, Idaho 83720
Dear Dr. Purce:
This is to confirm the discussions Mr. Ralph S. Heyer held with you, br. Lee Stokes, Mr. Robert Olson, and Mr. Robert Funderburg of your staff following our review and evaluation of the Idaho radiation control program.
The review covered the principal administrative and technical aspects of the program. This included an examination of the progret's legislation and regulations, orgdnizaticn, canagement and administration, personnel, and licensing end compliance activities. There was also a field accompaniment of a State inspector conducted during this reviev.
Our review used as a reference the NRC policy statement, " Evaluation of Agreement State Radiation Control Programs," published in the Federal Register on December 4, 1981. This policy statement provides 30 indicators for evalu-ating Agreement State program areas. Guidance as to their relative importance to an Agreement State program is provicea by dividing the indicators into two categories. Category I indicators address program functions that directly relate to the State's ability to protect public health ar.d safety.
Category II indicators address functions which provide essential technical and administra-tive support.
If a significant prcblem exists in a Category I indicator, the deficiency may seriously affect the State's cbility to protect the public health and safety and needs to be addressed on a priority basis.
If signifi-cant problenis exist in more than one Category I indicator, then improvements are critically nec& d.
In such cases, we will need a timely response from the State anc the I;RC staff will not make recor:mendations for adequacy and compatibility until after the responses are received and evaluated. A followup revicu within 6 months may also be scheduled.
As a result of our review of the State's program and the routine exchange of information between the NRC and the State, the hRC staff believes that the laaho program for the regulation of agreement materials is adequate to protect the public health and safety and is compatible with the Comission's program for the regulation of similar materials.
Our review utsclosed that most program indicators were within the NRC guidelines.
We were pleased to find that the organization of the license and compliance files has improved since the last review.
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., ??33 Thomas L. Purce, Ph.D.,
During the review last year, the hRC staff did not offer findings on adequacy and cenpatibility to the Idaho radiation control program pending clarification of the status of the program's radiation centrol regulations.
We were' pleased to find during this review that the State's regulations have been revised in their entirety and hRC cohrents have been incorporated.
Enclosed with this letter are conn.ents regarding technical aspects of the program.
You may wish to have Mr. Funderburg respond directly to these cconents.
I am enclosing a copy of this letter for placement in the State Public Document Room or to otherwise be nade available for public review.
I appreciate the courtesy and cooperation extended to R. S. Feyer during the review meeting.
Sincerely, C-
' ': ' c ' - ' hr J.can T. Collina John T. Collins Regional Administrator
Enclosures:
As stated cc W/ enclosure:
Dr. Lee Stokes, Idaho Mr. Robert Olson, Idaho G. W. Kerr, OSP.
NRC Public Document Room State Public Document Room bcc w/ enclosure:
DMB for dist. (SP01)
J. T. Collins P. S. Check R. L. Bangart G.'Sanborn R. J. Docu R. S. Heyer Idaho File i
I
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TECHNICAL CORIENTS AND RECOMMENDATIONS FOR THE IDAHO RADIATION CONTROL PROGRAM A.
Management and Administration Administrative Procedures (Category I_I Indicator)
Coment:
-The indicator, " Administrative Procedures," includes a guideline which reccmends that the radiation control program establish written internal procedures in order to assure that ti.e staff performs its duties as required and provides a high degree of uniformity and continuity in reg-ulatory practices.
It was identified that this type of written procedures do not exist.
Recomendation:
It is recomended that the internal procedures be developed in order to maintain consistency in staff licensing and compliance activities. They should cover. internal processing of license applications, scheduling and documenting inspections and enforcement guidelines, escalated enforcement action, and other functions required under the program.
(Attached is a suggested outline for content of a procedures trarual.)
B.
Personnel Training (Category II Indicator)
Coment:
The indicator, " Training," includes a guideline which recomends that senior personnel attend NRC core courses as well as utilize any specific short courses and workshops to maintain an appropriate level of staff technical competence in areas of changing technology.
It was noted during this review that there has been a slight increase in radiography activities in the State.
Recomendation:
It is recomended that the Senior Radiation Physicist attend the NPC sponsored course in " Safety Aspects of Industrial Radiography for State Regulatory Personnel." URC will cover the cost of travel and per diem as is our usual practice.
p 2-C.
Compliance Inspection Reports (Category II Indicator)
I Comment:
'The inspection reports did not always describe the scope of the inspection and indicate the substance of discussions with licensee management and the licensee's response. The reports did not always identify areas of the licensee's program which should. receive special attention during tte next j
inspection or give the results of any independent or confirnatory physical measuren,ents made by the inspector. We noted deficiencies in inspection reports in the 1982 review as well as this year.
Recommendation:
It is reconnended that specific guidelines be developed to assure inspection reports are consistent and complete.
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s ATTACliMENT 1 L
Suggested Outline for Content of an Internal Procedures Manual I.
General Format for Radiation Control Program Procedures and Information Manual II. General. Radiation Control Progran Policy Statements
- d III.
Policy for Training and Qualifications of Radiation Control Program Staff Responsible for Issuing Licenses and Performing Inspections IV.
Procedures for Trantnitting License Guides and other information to Licensees and Applicants V.
Procedures for Review, Retention, and/or Distribution of Materials Licenses VI.
Procedures for Scheduling, Conducting, Reporting, and Supervisory Review of Materials Inspections i
VII.
Procedure for Conducting Pre-Licensing Visits i
VIII.
Procedures for Conducting, Documenting, and Supervisory Review of Incident Investigations IX.
Procedures for Implementing Escalated Enforcement Actions X.
Interpretations The following may be part of this section or may be set out as separate parts of the Manual:
Responding to Public, State Legislature, and Media Inquiries Availability of Files to Public Inspection Organization Contacts with Federal, State and Local Agencies Supervisory Field Evaluations of Inspectors P'
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