ML20040D195
| ML20040D195 | |
| Person / Time | |
|---|---|
| Issue date: | 01/04/1982 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Tedford C ARIZONA, STATE OF |
| References | |
| NUDOCS 8201300422 | |
| Download: ML20040D195 (9) | |
Text
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Ref:.SA/JRMcG UNITED STATES Mcc NUCLEAR REGULATORY COMMISSION
(
WASHINGTON, D. C. 20555 if I-t JAN 4 198?
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Mr. Charles F. Tedford, Director-0 Arizona Radiation Regulatory Agency 925 South 52nd Street, Suite 2 y
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T Tempe, Arizona 85281 2-g 51992s.
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Dear Mr. Tedford:
p" uw g Th'e is to confirm the discussion Mr. McGrath held with you and (our.
g staff on November 20, 1981 during our recent review of the Arizona 67::c radiation control program. The review covered the prinicipal adminfs C@'
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trative and technical aspects of the State's program.
This included an examination of the program's funding and personnel resources; licensing,-
l inspection, and enforcement activities; emergency response capabilities;.
and the status of the State's radiation control regulations. Mr. McGrath i
also accompanied State inspectors on licensee inspections.
The most recent edition of the Arizona regulations was effective on June 30, 1977. There have been numerous changes to NRC regulations which should be adopted in order to maintain'a high degree of uniformity.
with NRC and other Agreement State regulations. We understand the State has plans to draft revised regulations.
This should be'_ treated as a high priority project and completed in 1982, if at all possible. We are i.
enclosing a list of changes in NRC regulations to assist you in the revision.
In line with our usual practice, we will review and coment on the revisions.
We are prepared to offer a-finding of adequacy and-compatibility for your program when we receive a commitment from you that you will proceed to update your regulations on an expedited basis.
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The updating of regulations is a Category II indicator.
At the present time, the State has no Medical Advisory Committee, although informal assistance is sometimes solicited from individuals in the-State. We suggest that a committee be formalized in order to establish a credible and accessible process of obtaining necessary guidance.
Technical advisory committees is a Category II indicator.
.We were pleased to learn of the State's proposed license fee program.
We feel that license fees are a reliable and suitable means of obtaining operating funds for the radiation control program and encourage the State in its efforts to institute its fee program.
e2013oo422 e20104 PDR STPRG ESGAZ PDR
Mr. Charles F. Tedford -
We wish to commend the State on its efforts in providing in-service training for its staff. We feel that this is an important factor in maintaining an adequate radiation control program and Arizona has been exceptionally diligent in this area.
We are somewhat concerned with the degree of staff turnover which has occurred since our last review.
It would appear that salary level was a major consideration in at least two of the terminations.
Your own studies have indicated that State salaries are from $4,000-$11,000 below comparable positions in the geographical area. We are enclosing a copy of data concerning Agreement State staff salaries (as of August 1981).
Staff continuity is a Cateogry II indicator.
In general, the licensing program appears to be in good shape. We do, however, have the following suggestions for improving documentation:
(1) Correspondence from licensees should be signed by responsible management personnel.
(2) Licenses authorizing large numbers of in-plant or portable gauges should have a condition requiring periodic inventories.
(3) Drawings of applicant facilities should provide details on areas adjacent to those where radioactive material will be used.
(3) The State should obtain information from the University of Arizona on their waste burial program including such items as location, layout, and estimates of radioactive material buried.
The technical quality of licensing actions is a Category I indicator.
With regard to the compliance program, we have a number of suggestions for improvement. We were pleased to note that accompaniments of inspectors are being conducted by the supervisor of the radioactive materiale-section; however, we would suggest that in the report on the accompaniment, the supervisor provide a statement on his assessment of the inspector's l
performance. The Agency has authority to impound material, issue orders and take other escalated enforcement actions. We suggest that the State prepare written procedures for handling these cases.
With regard to the performance of inspections, we suggest that inspectors be encouraged to observe licensee operations during inspections. This is particularly important with regard to industrial radiography licenses.
Inspectors' observations should also be documented in inspection reports.
In addition, we feel that all items of noncompliance and significant recomendations should be discussed with licensee management during the inspection close-out meeting.
Inspection reports were for the most part adequate.
However, we suggest that reports include documentation of the status of previous items of noncogliance, details on the licensees receipt pro-cedures including procedures for opening packages, and inspector con-clusions regarding observed operations.
As discussed during our meeting i
l f
Mr. Charles F. Tedford.
with you and your staff, there is also some need for improvement in the substantiation of items of noncompliance and the manner in which certain items are cited in enforce.:ent letters.
Inspector.i' performance and capability are Category I indicators.
The adequacy of inspection reports is a Category II indicator.
We would appreciate your review of the above comments and any response you might have. As is our usual practice, I am enclosing a second copy of this letter for placement in the State public document room or otherwise be made available for public review.
I appreciate the courtesy and cooperation extended to Mr. McGrath during his meeting with you and your staff.
Sincerely, h / @d.I G.WayndKerr, Director Office of, State Programs
Enclosure:
As stated cc: George Britton, w/ enc 1.
NRC Public Document Room, w/ enc 1.
State Public Document Room, w/ encl.
W
CHRONOLOGY Amendments to be Considered by Agreement States (from September 1971)
Suggested State Effective Date 10 CFR Part Regulations Summary Sept. 24, 1971 20 Part C. Sch. B Addition of an exempt 30 Part 0, App. B quantity for BA-133.
March 26, 1972 20 A. 3, C.40 Addition and modification 30 C.100, 0.207 of transport and packaging 40 procedures.
i 70 71 Nov. 2, 1972 20 Part D, App. A Changes in values of radionuclides of all concentrations in air and water.
Sept. 17, 1973 19 Part J Requirements for notices, instructions and reports by licensees to workers, and options available to workers with regard to inspections.
l Oct. 24, 1973 20 A.2(i)
Change to abbreviations 30 Part B, Sch. A for " curie" and " micro-32 Part D, App. A curie," and addition of and App. B definiticn for "millicurie."
Jan. 10, 1974 31 C.22(i)
Authorization to use 32 C.28(h) carban-14 in in vitro clinical or laboratory tests.
March 11, 1974 30 C.40 Requirement that suppliers 31 must verify that customers 40 are authorized to receive 70 the material shipped.
150 July 29, 1974 30 A.2(i)
Special curie definitions Part D and concentration values Appendix for U and Th.
2 l
1 Suggested State Effective Date 10 CFR Part Regulations Summary Aug. 16, 1974 31 C.22(h)
Addition of 3H and 59Fe 32 C.26(c) to in vitro tests and 35 C.28(h) extension of Medical C.28(j)
Group licensing.
Jan. 15, 1975 31 C.22(d)
Modification of require-32 C.28(d) ments for distribution of 31.5 GL devices.
A.3(c)
Clarification of AEC Jan. 19, 1975 contractors exemption pursuant to Energy Reorganization Act.
June 25, 1975 20 D.206 Requrements for control of licensed material in unrestricted areas and not in storage.
June 25, 1975 35 Part C, Sch. C Addition of I-125 seeds for interstitial treatment of cancer to Group VI.
Jan. 19, 1976 20 D.1(a)
Incorporation of "As Low As Is Reasonably Achiev-able (ALARA)". wording.
Jan. 29, 1976 20 Part D, App. A Modification of occupational exposure limit for Rn-222.
Feb. 23, 1976 35 Part C, Sch. C Addition of tin-113/
indium-113m generators to Group III.
April 19, 1976 35 Part C, Sch. C Addition of ytterbium-169 DTPA for cisernography to Group II.
June 2, 1976 20 Parts C, D Requirements for 31 and E preservation of certain 32 records required by the 34 regulations.
40 70 150
3 Suggested State Effective Date 10 CFR Part Regulations Summary Aug. 4,1976 34 E.203 Personnel monitoring requirements for industrial radiographers.
Aug. 16, 1976 35 Part C, Sch. C Addition of I-125 fibrinogen for detection of deep vein thrombosis to Group II.
Dec. 29, 1976 20 D.103 Authorizes use of respirators.
Bases internal exposure limits on intake into the body.
Jan. 5, 1977 40 C.21(d)
Establishes GL for depleted uranium products.
March 7, 1977 40 C.3(c)
Exemption for personnel neutron dosir:ieters containing thorium.
May 31, 1977 31 C.22(i)
Addition of SE-75 to 32 (C.28(h) in vitro GL.
June 27, 1977 31 C.22(i)
Addition of mock 32 C.28(h) iodine-125 calibration sources to in vitro GL.
August 15, 1977 35 C.26(b)
Modification of requirenients for indivi-dual physician use of radioactive material for human use.
Jan. 6, 1978 40 C.21(a)
Extends small quantity source material GL to Federal, State and local governments for nperational purposes.
Jan. 16, 1978 35 Part C, Sch. C Addition of Tc-99m human serum albumin for heart l
blood pool imaging to I
Group III.
Feb. 7, 1978 35 Part C, Sch. C Addition of Tc-99m medronate sodium for bone imaging to Group III.
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4 Suggested State Effective Date 10 CFR Part Regulations Summary 9
Feb.16,IJ8 30 C.4(c)
Exemption for spark gap frradiators containing cobalt-60.
March 14, 1978 20 D.203(c)
Additional requirmeents for controlling areas in which radiation levels in excess of 500 rems /hr exist.
June 16, 1978 35 Part C, Sch. C Addition of Tc-99m gluceptate sodium for brain and renal perfusion
. imaging to Group III.
June 23, 1978 20 D.203(f)
Removal or defacing of radioactive material labels on empty containers.
Sept. 7, 1978 35 Part C, Sch. C Addition of Tc-99m human serum albumin microspheres for venography to Group III.
Dec. 28, 1978 35 G.2(c)
Requirement to perform survey of patients to confirm that implants have been removed.
March 22, 1979 35 Part C, Sch. C Deletion of diagnostic procedures from medical groups.
June 5, 1979 30 C.31(d)
Notice of oiscontinued 40 licensed operctions.
70 July 9, 1979 35 G.3(d)(e), (f),
Teletherapy calibrations (g), (h)
August 20, 1979 19 0.1, Control of radiation to 20 0.101, D.102 transient workers.
J.13 September 27, 1979 71 C.100 Modification of transportation requirements.
5 Suggested State Effective Date 10 CFR Part Regulations Summary March 3, 1980 34 Part E Amendments to industrial C.26(e) radiography requirements.
March 28, 1980 71 A.3(b)
Correction to reference C.101 Postal service regulations.
September 2, 1980 35 C.26(c)
Testing of radioisotope generators.
September 19, 1980 40 C.21(a)
Deletion of GL for source material medicinals.
November 10, 1980 35 D.409 Medical misadministration s.e reporting.
i November 17, 1980 40 A.2 Requirements to implement C.25(e), (f), (g) the Uranium Mill Tailings (h)
Act C.29 Part C, Sch. E.
December 1, 1980 20 0.106(g)
Reference to 40 CFR 190 for uranium fuel cycle operations.
January 28, 1981 20 D.304 Deletion of waste burial authorization March 6, 1981 35 Part C, Sch. C Addition of Tc-99m oxidro0stesodiumto l
Group III.
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March 13, 1981 34 E.203(b)
Disposal of dosimeter records.
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March 31, 1981 20 D.306 Biomedical waste rule May 13, 1981 30 C.4(c)
Exemption for survey instrument calibration sources.
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8/81
~
MEDIAN ~ AGREEMENT STATE STAFF SALARIES 29602 1.
28699 2.
4 28108 3.
24746 4.
23991
~
5.
23577 6.
23394 7.
22205 8.
21668 9.
21492 10.
21353 11, 21245 l
12.
Arizona 4
21151 13.
j 21108 14.
20993 i
15.
1 20968 16.
20710 17.
20350 18.
20252 19.
1 9,627 20.
19,496-21.
19,276 22.
19,176 23.
18,824 24.
18,275 25.
17,996 26.
17,695 27.
15,610 28.
t
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