ML20040F679
| ML20040F679 | |
| Person / Time | |
|---|---|
| Issue date: | 01/20/1982 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Traylor F COLORADO, STATE OF |
| References | |
| NUDOCS 8202100102 | |
| Download: ML20040F679 (2) | |
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Frank Traylor,11.D.
Executive Director Colorado Department of Health 4210 East lith Avenue Denver, Colorado 80220
Dear Dr. Traylor:
This is to confirm the discussion "r. R. J. Doda held with you and i1r.
A. J. Hazle of your staff following our review and evaluation of the Colorado radiation control program.
The review covered the principal administrative and technical aspects of the program. This included an evaluation of the status of the State's radiation control regulations; and an examination of the program's funding and personnel resources, licensing and inspection activities, enforcement procedures and actions, and emergency response capabilities for agreement materials. There was also a field accompaniment of a State inspector during this review.
Our review used as a reference the liRC " Guide for Evaluation of 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 three 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.
If no serious problems are found in these areas, staff opinions on the adequacy and compatibility of the program may be made following the review meeting.
Our review did not include regulatory activities concerning uranium l
mills and tailings, since this part of Colorado's radiation control program has just been evaluated in connection with the Governor's recent request for an amended agreement under the requirements of the Uranium ilill Tailings Radiation Control Act of 1978.
However, we expect to conduct a review of this aspect of the State's program in 1982.
l 8202100102 820120
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Frank Traylor, M.D. -
As a result of this review of the State's program and the routina exchanga of information between the Nuclear Regulatory Commission (NRC) and the State of Colorado, the staff believes that the Colorado program for l
regulation of agreement materials is adequate to protect the public health and safety and is compatible with the Commission's program for regulation of similar materials.
It was noted, during the administrative part of the review, that staff efforts devoted to the agreement materials program (excluding uranium mills) compared favorably with NRC's recommended range of 1 to 1.5 professional staff years per 100 licenses. However, we found that the turnover in technical staff was three persons during the review period.
We recommend the State monitor any future staff turnover and take steps to minimize the causes of such losses, wherever possible. This is a Category II indicator.
The staff training level for the review period was 7.3% of available staff time, which compares favorably with the NRC's reconmended range of 5% to 10% for technical training (a Category II indicator). We encourage the State to continue this training effort, particularly in light of the turnover in technical staff recently sustained by the radiation control program.
On October 20, 1980, following our review of the CBI report on Cotter Corp., we recommended that your Department seek authority to apply civil penal ties. Although legislation was introduced into the State legislature in 1981 for this purpose, no action was taken.
I understand legislation will again be introduced this year. We continue to support your efforts to obtain civil penalty authority.
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. A. J. Hazie 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, ti. wy%
/
G. Wayne Kerr, Director Office of State Programs
Enclosures:
As Stated cc: Mr. A. J. Hazle Mr. J. Collins, Administrator, NRC Region IV NRC Public Document Room State Public Document Room g-m w
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