ML20046C637
| ML20046C637 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Synar M HOUSE OF REP., GOVERNMENT OPERATIONS |
| Shared Package | |
| ML20044B476 | List: |
| References | |
| NUDOCS 9308110263 | |
| Download: ML20046C637 (20) | |
Text
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July 14, 1993 The Honorable Mike Synar, Chairman Subcommittee on Environment, Energy, and
' Natural Resources Committee on Government Operations United States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman:
I am pleased to provide responses to the questions posed in the June 16 and 17, 1993 letters from your staff regarding the activities of the NRC in the regulation of Agreement States and materials licensees.
Enclosed is the mark-up key of the June 16 and 17,1993 letters with the new numbers.
We will continue to renumber new questions sequentially.
Y Sincerely, gg n;g signe g
James M. Til)Ttif Executive Director for Operations
Enclosures:
As stated cc:
Rep. J. Dennis Hastert (w/ enclosures)
Distribution:
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h 00ESTI0n 52.
NRC conducted a review of the New Hampshire program in March 1984. A letter transmitting the NRC's findings was transmitted by the Regional Administrator in a May 4,1984 letter. No staff evaluation or report was provided for this review. Please provide this documentation.
T ANSWER.
The review referenced in the May 4, 1984 letter was conducted on March 20, 1984 which was a follow-on to complete the review conducted on August 29-September 2, 1983. A July 3,1984 letter for Diane Tefft, Administrator, Division of Public Health Services, from Paul Lohaus, State Agreements Officer, Region I, transmitted the res.lts of the March 20, 1984 review as an
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addendum to the staff evaluation and report of the August 29-September 2,1983 review. The staff evaluation for the August 29-September 2,1983 review was transmitted to the State on October 24, 1983 in a letter to William Wallace, Director, Division of Public Health Services, New Hampshire Department of Health and Welfare from Thomas E. fiurley, Regional Administrator, Region I.
A copy of the October 24, 1983 letter is enclosed. All other referenced documents were provided to the Subcommittee in response to Question Ib. of the March 25, 1993 letter.
Enclosure:
i As stated l
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00ESTION 53.
An October 27, 1987 letter from C. Kammerer to W. Wallace, Dir, Div of Public Health Services, State of New Hampshire cites a September 9,1987 from Wallace to NRC. This letter i
was not provided.
Please provide this documentation.
l ANSWER.
The September 9,1987 letter to Donald Nussbaumer, Assistant Director, State f
Agreements Program, from William Wallace, Director, Division of Public Health Services, New Hampshire Department of Health and Human Services is provided.
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Enclosure:
As stated l
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OVESTION 54.
In 1989, NRC conducted a review of the New Hampshire program. No questionnaire, staff report, or evaluation for this review was provided.
Please provide this documentation.
ANSWER.
A memorandum for Vandy L. Miller, Assistant Director for State Agreements Program, SLITP, from John R. McGrath, Regional State Agreements Officer, Region I, transmitting the staff evaluation and report for the 1989 New Hampshire review is enclosed (Enclosure 1). The staff evaluation and report dated April 10, 1989 to William T. Wallace, Director, Division of Public Health Services, New Hampshire Department of Health and Welfare, from Carlton l
Kammerer, Director, SLITP, is also enclosed (Enclosure 2).
Enclosures:
As stated i
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OVESTION 55.
In September 1991, NRC completed a review of the New Hampshire program.
NRC findings of this review were transmitted to the' State in a November 21, 1991 letter from C. Kammerer to P. Meeham, Director, Div. of Public Health Services, State of New Hampshire. No state reply to Mr. Kammerer's letter was provided and no staff evaluation or report to September 1991 review was provided.
Please
[
provide this documentation.
ANSWER.
On January 24-27, 1989 NRC conducted a full review of the New Hampshire program. and a copy of the report was transmitted to William Wallace, Director, Division of Publ.c Health Services, New Hampshire, from Carlton Kammerer, Director, State Programs, on April 10, 1989. A finding of adequacy and compatibility was withheld as a result of this review. On February 20-22, 1990 NRC did a follow-up review and still found that we could not offer a finding of adequacy and compatibility. This evaluation was transmitted in a March 13, 1990 letter to Mary Mongan, Commissioner, New liampshire Department of Health and Human Services, from Carlton Kammerer, Director, State Programs.
On September 19-20, 1990 NRC did a review visit which is documented in a memorandum for Vandy Miller, Assistant Director, State Agreements Program, thru Joel Lubenau, Senior Project Manager, from John McGrath, Regional State Agreements Officer, Region I, dated October 5, 1990. On April 16-17, 1991 another review visit was conducted which is documented in a May 9, 1991 memorandum to Vandy Miller, Assistant Director, State Agreements Program, thru Joel tubenau, Senior Project Manager, from John McGrath, Regional State Agreements Officer, Region I (Enclosure 1). A follow-up review was conducted on September 9-12, 1991 which found the program to be adequate and compatible.
OVESTION 55.
(Continued)
A memorandum report dated October 8, 1991 was provided to Vandy Miller, Assistant Director, State Agreements Program, from Francis Costello, Acting Regional State Agreements Officer, Region I, on this follow-up review, which 4
was not provided to the State (Enclosure 2). A letter dated November 21, 1991 l
to Patrick Meehan, Director, Division of Public Health Services, New Hampshire, from Carlton Kammerer, Director, State Programs documented the results of this follow-up review; the staff evaluation is Enclosure 2 of this letter titled " Summary of Assessments and Comm:nts" (Enclosure 3).
F l
No State reply was submitted to the November 21, 1991 letter. All referenced 6
documents other than the enclosures indicated above were provided to the l
l Subcommittee in response to Question Ib. of the March 25, 1993 letter.
l
Enclosures:
As stated r
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OVESTION 56.
Apparently in February 1982, NRC conducted a review of the Tennessee program.
Reference to this review is made in a January 27, 1982 letter from R. Woodruff, Region II, to J.A.
l Bill Graham, Director, Div. of Radiological Health, State of Tennessee, and in a May 12, 1982 letter from R. Woodruff to Dr. E.W. Fowinkle.
No staff report, evaluation, questionnaire or letter transmitting the NRC's findings to the State were provided.
ANSWER.
The regulatory review and staff report for the 19th regulatory review for the period October 4, 1980 to March 26, 1982 is enclosed.
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Enclosure:
As stated L
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QUESTION 57.
A February 27, 1984 letter from J. Word, Commissioner, Department of Public Health responding to the NRC's 1983 review findings was not provided.
1 ANSWER.
We have searched our files, including retirement and microfiche, and could not locate a copy of the February 27, 1984 letter from J. Word, Commissioner, Department of Public Health, responding to the NRC's 1983 review findings. We also contacted our Region II office, but they do not keep Agreement State files going back to 1984. We contacted the State of Tennessee, and they have provided us with an unsigned copy which we are enclosing.
Enclosure:
As stated i
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OVESTION 58.
A January 3, 1989 memo from Region II transmitting the staff' l
evaluation of the 1988 review of the Tennessee program to V.
Miller states that as noted in the report, the program was compatible with NRC's program for regulation and adequate to t
protect the public health and safety.-
The accompanying l
report, however, does Ep1 state that the program is adequate and compatible. It states that "a statement of compatibility f
is being withheld until the Tennessee regulations have been revised." Was the program at this time compatible?
I i
I ANSWER.
j No. The internal NRC memorandum from Region II to Vandy L. Miller, dated January 3,1989 was in error. Both the " accompanying report" to the January 3, l
1989 memorandum and the letter to the State of Tennessee concerning the NRC staff evaluation of the Tennessee Radiation Control Program for the period June 30, 1986 to January 29, 1988 indicated that NRC was unable to offer a statement of compatibility until the Tennessee regulations had been revised. A copy of the letter to James E. Wood, Commissioner, Tennessee Department of Health from i
Carlton Kammerer, Director of the State, local and Indian Tribe Programs, dated April 15, 1988, was provided to the Subcommittee in the response to Question Ib.
l of Chairman Synar's letter of March 25, 1993.
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i OUESTION 59.
In April,1989 officials of the State of Tennessee wrote to NRC, apparently to C. Kammerer concerning the regulation of Low-Level Waste processors. This letter was cited in a September 29, 1989 response from C. Kammerer. The April, 1989 letter was not provided.
ANSWER.
i The September 29, 1989 letter was inadvertently sent to the Subcommittee in l
response to Question Ib. of the Subcommittee's March 25, 1993 request. This letter deals with the subject of low-level waste and was not germane to Question Ib. which asked for all material relating to biennial program reviews and interim reviews.
Enclosed is the April 1989 letter from Michael Mobley to Carlton Kammerer which is undated, but was received in our office on May 22, t
1989 (Enclosure 1).
For completeness we are also attaching the September 14, j
1989 letter referenced in the September 29, 1989 letter (Enclosure 2). This letter was also requested in Question 60.
Enclosures:
As stated i
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OUESTION 60.
A September 14, 1989 letter from C. Kammerer to M. Mobley,
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i Dir. Div of Radiological Health, State of Tennessee cited in a September 29, 1989 response from Mobley was not provided.
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ANSWER.
d Please see Question 59 for answer.
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l OUESTION 61.
A May 17, 1991 letter from C. Kammerer to Commissioner Luna, j
State of Tennessee, cites an April 17, 1991 letter from M.
Mobley transmitting quarterly status report. Neither this April 17, 1991 letter nor any other transmitting quarterly status reports were provided.
l ANSWER.
i The request for a quarterly status report was made in our January 24, 1991 letter to Commissioner Luna, following the November 29, 1990 follow-up review.
In response, Mr. Mobley provided the enclosed first quarter status report by letter dated April 17, 1991 (Enclosure 1). We are also enclosing the second quarter status report dated July 24, 1991 (Enclosure 2) and the third quarter status report dated October 28, 1991 (Enclosure 3). The March 6,1992 letter f
from C. Kammerer to Commissioner Luna, which we provided to the Subcommittee in response to Question Ib., documented the review conducted on December 9-13, 1991. A continuation of the quarterly reports was not requested after this review.
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Enclosures:
As stated I
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DUESTION 62.
Apparently NRC conducted a mid-review visit of the Tennessee program in 1991. This visit is cited in an undated memo from Region II (R. Woodruff) to V. Miller transmitting report package on final 1991 review.
Please provide the 4
staff report for the mid-review visit.
ANSWER.
The Tennessee mid-review visit report conducted July 10-12, 1991 is enclosed.
Enclosure:
As stated 1
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J OVESTION 63.
The undated memo from Region II to V. Miller transmitting
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report package for 1991 review package was not complete.
In particular, Appendix C " Reviewer Explanatory Comments and Observations" was not complete.
Please provide Appendix C in its entirety.
I ANSWER.
Appendix C " Reviewer Explanatory Comments and Observations" of the undated j
memo from Region II to V. Miller transmitting the report package for the 1991 review is enclosed (Enclosure 1). We have also enclosed Appendix D " Review of Selected License Files" (Enclosure 2) and Appendix E " Review of Selected l
Compliance Files" (Enclosure 3).
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Enclosures:
1 As stated j
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OVESTION 64.
An August 11, 1992 letter from Commissioner Luna, State of Tennessee to C. Kammerer referenced in an October 30, 1992 letter from C. Kammerer responding to the August 11 letter was not provided.
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ANSWER.
The August 11, 1992 letter from Commissioner J. W. Luna, State of Tennessee, i
to C. Kammerer, Office of State Programs, referenced in an October 30, 1992 letter from C. Kammerer responding to the August 11 letter is enclosed.
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Enclosure:
As stated
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June 16, 1993 To:
Tom Combs, NRC Congressionkl Affairs From:
Dave Berick Additional Follbw-Up Items for Agreement State Program Re:
g[1984.
NRC conducted a :deview of the New Hampshire program in March A letter transmitting the NRC's findings was transmitted by
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the Regional Ad~tinistrator in a May 4, 1984 letter.
No staff evaluation or report was provided for this review.
Please provide 43 this documentation.
d) f An October 27, dS87 letter from C. Kamerer to W. Wallace, Dir. Div. of Public H4alth Ser-ices, State of New Hampshire cites a September 9, 1987 from Wallace to NRC.
This letter was not Please provide this documentation.
f@4 provided.
In 1989, NRC conducted a review of the New Harpshire program.
/)o questionnaire, stuff report, or evaluation for this review was
.N provided.
Please pro;/ide this documentation.
NRC coupleted a review of the New Hampshire
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In September 1991a of this review ware transmitted to the State program. NRC findings in a November 21, 1 991 letter from C.
Xammerer to P.
- Meeham, Director, Div. of Public Health Services, State of New Harnpshire.
No state reply to Mr. Kammerer's letter was provided and no staff evaluation or report, to September, 1991 review was provided.
Please provide this decumentation.
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To:
Tom combs, EC Congressional Affairs From: Dave Berick Re:
Tollow-Up cn Agdeement State Documents Please provide the following documents:
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Apparently in FebL*cary 1982. NRC conducted a review of the 4
esses program. Reference to this review is made in a January 1
I 27, 1982 letter from R. Woodruff, Region II, to J.A. Bill Graha n, Director, Div. of Radiological Health, state of Tennessee, and in i
a Xay 12, 1982 letter from R. Woodruff to Dr. E.W. Fowinkle.
staff report, evaluation, questionnaire or letter transmitting. No the i
NRC's findings to the State were provided.
,{ fl A February 27, 1984 letter from J.
Word, Com::issioner, De;artment of Public Mpalth responding.to the NRC's 1983 review findings was not provid,ed.
Th)aluation of the 1988 ifsview of the Tennessee program to V. Miller A January 3,1989 nam from Region II transmitting the staff' ev states that as noted in the report, the program was ccqpatible with NRC's program for regulation and adequate to protect the public a
hesith and safety.
The accesqpanying report, however, does pg1 state that the program *is adequate and compatible. It states tnat
's statement of compatinility is being withheld until the Tennessee regulatiens have been revised.'
was the program at this time compatible?
N)
In April, 1989 of:!icials of the State of Tennessee wrote to
/NRC, apparently to C. Kammerer Concerning the regulation of Low-Level Waste processors.t mis letter was cited in a September 29 1989 response from C. W rer.
he April, 1989 letter was not provided.
l 9/) A September 14, 1988 letter from C. Kansnerer to M. Mobley, Dir.
Div of Radiological Health, State of Tennessee cited in a September 29, 1989 response frera Mobisy was not provided.
hl ) A May 17, 1991 letter from C. Rammerer to Costs:issicner Luna, f
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State of Tennessee cites an April 17, 1991 letter from N. Mobley
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transe.itting quarterly status report. Neither this April 17, 1991 letter nor any other transmitting quarterly status reports were provided.
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42/)
Apparently NRC conducted a mid-review visit of the Tennessee program in 1991.
This visit is cited in an undated memo from Region II (R. NoodruffI to V. Miller transmitting report package on final 1991 review.
Please provide the staff report for the mid-review visit.
4 3/)
The undated r.emo from Region II to V. Xiller transmitting repor package for 1991 re' den package was not coelplete.
In
- nrticular, Appendix C
- Reviewer Explanatory Comments and Observations" was not co @lete.
Please provide Appendix C in its entirety.
N)
An August 11, 1992 letter from Cemissioner Luna, state of f
Tennessee to C. Kam.erer referenced in an CCtober 30, 1992 letter from C.
Kar=terer responding to the August 11 letter was not provided.
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s July.14, 1993 NOTE FOR: Document Control Desk FROM:
Ann Tipton Correspondence & Records Branch The enclosed document (s) are to be entered into the DCS.
An advanced copy has been sent to the Public Document Room.
PLEASE PROCESS AS ONE DOCUMENT.
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Question 52 P'
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October 24, 1983 William T. Wallace, M.D., M.P.H.
Director, Division of Public Health Services State Department of Health and Welfare Health.and Welfare Building Hazen Drive Concord, NH 03301
Dear Dr. Wallace:
This is to confirm the discussion Ms. Campbell, Region I State Agreements Officer held with you and your staff following our review and evaluation of the State radiation control program on August 29-Sept. 2, 1983. The review covered the principal administrative and technical aspects of the program. This included an examination of the program's legislation and regulations, organization, management and administration, personnel, and licensing and compliance.
Our review was based on the NRC " Guidelines for NRC Review of Agreement State Radiation Control Programs," published as an NRC Policy Statement in the Federal Register on December 4, 1981. The Guide provides 30 indicators for evaluating Agreement State program areas which are divided into two categories. Category I Indicators address program functions that directly relate to the State's ability to protect public health and safety. Category II Indicators address functions which provide essential technical and administrative support.
If a significant problem exists in a Category I Indicator, the deficiency may seriously affect the State's ability to protect the public health and safety and needs to be addressed on a priority basis.
If significant problems exist in more than one Category I Indicator, then improvements are critically needed.
In such cases, we will need a timely response from the Stat.e and staff recommendations for adequacy and compatibility will not be offered until after the responses are received and evaluated. A follow-up review within six months may also be scheduled.
Our review of the State's program and the routine exchange of information between the Nuclear Regulatory Commission and the State of New Hampshire indicated that a significant problem continues to exist with respect to a Category I Indicator, " Technical Quality of Licensing Actions." While the scheduled implementation dates outlined in your July 7, 1982 letter for fully addressing this problem area (and others) have not been met,~we recognize significant steps have been taken by your staff to resolve the problems. These include updating and revising 1
the regulations and development of licensing guides. In addition, Ms.
Campbell in March,1983, visited Concord to assist your staff in developing license review checklists and to discuss current license review practices with the staff.
We believe that the present regulatory and procedural framework is i
sufficient to enable your staff to fully implement revisions to their licensing program that are necessary to ttrrrect the s-ignificant deficiencies initially identified in our 1982 review. We plan therefore C h/q 7
I to complete our review in January,1984 At that time we will review New Hampshire licensing actions for conformance with the recently updated New Hampsh're regulations and licens'ing guides. and compatibility with the NRC licensing program.
In the interim, we recommend that the radiological health program (RHP) prioritize the steps under consideration by the RHP manager to effect improvements in the program, and schedule the staff effort accordingly.
Those areas which were reviewed by the NRC staff in the first part of this review are described in more detail in the enclosed comments t
regarding the technical aspects of the program.
I would appreciate your review of our recommendations and receiving your I
confirmation that the necessary improvements in the licensing program will be implemented immediately.
I am also enclosing a 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 you and your staff extended to Ms. Campbell.
Sincerely, Original Signed 37:
i Thomas E. Murley Regional Administrator
Enclosure:
As stated cc:
J. Stanton, NH D. Tefft, NH NRC Public Document Room State Public Document Room G. Wayne Kerr 4
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Enclosure Technical Comments and Recomendations on the New Hampshire Department of Health'and l
l Welfare Radiological Health Program I.
Licensing l
i A.
Significant problems were noted with respect to technical quality of licensing actions, a Category I indicator. These are 1
essentially Tepeat coments from the last NRC review of the New Hampshire program. The specific coments and recomendations l
follow:
1.
Coment Licensee applications which did not contain all of the essential infomation were being used as the basis for issuing licenses and
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amendments. For example, our review of four selected medical i
license files revealed renewal applications were deficient in the l
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following areas:
The licenses were issued without obtaining preceptor a.
statements documenting that physicians requesting to be authorized users had the necessary training and i
experience in medical uses of radioactive material, j
b.
Three of the four licenses were issued without obtaining 1
information concerning the licensee's radiation safety comittee, such as membership, duties, and f
responsibilities.
j One of the licenses was issued without requiring l
c.
6 procedures for use of an operational dose calibrator including for testing the instrument's constancy, i
linearity, accuracy, and geometrical variation.
i d.
Three of the four licenses were issued without an adequate description of the training program. The i
licensed programs did not address the training of all l
categories of individuals involved in the use of radioactive materials.
i Two of the four licenses were amended without evidence e.
that the hospital administration had approved the
'l proposed change.
I f.
The State did not require the licensees to submit a i
program description to keep occupational radiation i
expcsures low as is reasonabl,< 'chievable (ALARA). The licensees did not document r.ar.c9ement's cornitment to the i
f
. 4 ALARA concept, establish an internal audit program, and establish ALARA action levels, g.
Detailed procedures were also lacking in several other aspects of the applicants' programs as follows:. survey-procedures did not state who performs surveys and specify action levels; calibration procedures for survey instruments were not described; and special instructions to hospital personnel in facilities authorized to receive isotopes for threapeutic use were not always included.
Two radiography renewal applications were reviewed and were deficient in the following areas:
h.
Descriptions of required training for radiographers'were inadequate.
i.
No pro'cedures were submitted to assure that radiography equipment would be stored and transported in accordance with radiation safety requirer,ents.
j.
No procedures were provided describing how survey meters and pocket chamber dosireters would be calibrated.
k.
There was no description of in-house audit programs by licensee management.
1.
There was no description of how daily inspections of radiographic equipment would be conducted, m.
There were no descriptions or examples of forms to be filled out for daily inspection of radiographic devices, utilization logs, survey records, daily dosimeter reading and quarterly inventory logs.
Reconnendat io_n_
Based on the above comments, we believe there is a need to obtain from such applicants clear and complete descriptions of proposed licensed programs. Deficiencies, such as those identified above, can be identified by the staff by following applicable licensing guides and checklists (see below) that have been furnished to the program by the NRC reviewer. Applications and supplementary information submitted in response to deficiency letters should be j
reviewed in sufficient depth to assure that all submitted information and procedures are explicit and complete.
[
2.
Comment We noted that out-of-State applicants have been issued licenses to use radioactive materials in New Hampshire without being required to establish an office in the State and in addition, are not recuired to provide prior notification to New Hampshire when they
s enter the State to use radioactive materials. As a result, New Hampshire is unable to inspect such persons because they have no office in the State and the State has no infomation on when or where they wili use radioactive materials at field sites.
Recomendation New Hampshire regulations provide for unlimited (i.e., no time limit) reciprocal recognition of out-of-State licensees authorized to use materials at temporary job sites (He P 2030.05).
Furthermore, He P 2030.05b requires prior notification of the State before engaging in licensed activities in the State, thus enabling inspections to be made at field sites.
In view of this, we i
recomend discontinuing the routine issuance of specific licenses to out-of-State licensees.
In exceptional cases where such a license may be needed, the applicant should be required to (a) establish an in-State office and (b) the specific license should include a notification requirement equivalent to He P 2030.05b.
B.
With respect to licensing procedures, a Category II indicator, the following coment is made:
Coment We were pleased to find that the license reviewer routinely uses licensing checklists to evaluate applications. However, these checklists were found to be outdated.
Recomendation We recomend that the outdated checklists not be used. During the technical assistance provided to New Hampshire in March,1983, a number of updated checklists were prepared by the NRC representative. These should be put into use as soon as possible.
II. Compliance A.
Status of inspection programs is a Category I indicator. The 1
following minor coment and recomendation is made.
Coment We found that some inspections were overdue. At the time of the review, 7 priority I and 11 licensees had been overdue for inspection for at least six months according to the New Hampshire priority system.
i Recomendatice i
We recomend that the program staff should establish and adhere to j
a schec'ule to inspect the priority I and 11 licensees now overdue for inspectice..
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B.
Inspection procedures is a Category 11 indicator. The following coments and recomendations are made.
1.
Coment We found the State is continuing its practice of announcing all routine materials inspections.
Recomendations We again recommend the State adopt the practice of unannounced inspections. Unannounced inspections are more likely to enable inspectors to observe operations and review licensed radiation control programs as they are actually implemented by licensees. We recognize that announcing visits to licensees increases the likelihood that requisite licensee personnel and records will be available, but recent Agreement State and NRC experience indicates that a policy of announcing inspections does not allow inspectors to always obtain a representative sampling of licensee radiation safety practices. NRC practice is to conduct all of its inspections on an unannounced basis except for cause.
2.
Comment Our review of inspection reports indicates that inspectors do not always conduct exit interviews with licensee management representatives to discuss inspection results. Two cases were found where no individuals except the technologists had been infomed of inspection results. In addition, enforcement correspondence is ususily directed to the licensee RSO or radiologist, with a carbon copy to licensee management.
Recomendation We recomend that exit interviews with licensee nnagement always be conducted at the conclusion of all inspections and that enforcement correspondence be addressed to management. Licensee management is ultimately responsible for all licensee radiation safety, even though some duties have been delegated to licensee staff.
C.
Response to actual and alleged incidents is a Category I indicator.
The following minor coment is noted:
Coment There is no established policy for setting priorities for inve:tigations. As a result, an alleged incident involving failure to control access to radiographic operations, reported by NRC to the program in May, was not investigated by the program until August, and the investigation is still not completed.
i
i
-5 Recommendation We recommend that the program establish a policy for priorities for conduct of investigations.
D.
Independent measure;nents is a Category II Indicator.
Comment Agency instrurents should be calibrated at intervals not greater than that required of licensees being inspected. We commented in 1982 on the need to follow this practice. Some licensees' survey instruments must be calibrated at three month intervals but the State's practice was to calibrate its instruments aarually.
In this review, we learned no calibration of State survey instruments have been perforred in 1983.
Recommendation We again recocmend calibration of survey instruments at intervals not exceeding those of the licensees being inspected. We understand the recently hired Laboratory Scientist III will have, as one duty, such calibration work.
III. Legislation and Regulations Updating of regulations is a Category 11 comment. The following comment is noted:
Commert During the review, we found that the State has expended a considerable amount of time in updating and recodifying its radiation safety regulations to conform them with other State rules. We commend the State for this effort. Detailed comments on the most recent revision will be forthcoming in a separate letter.
IV. Kanagement and Administration I
Administrative procedu es is a Category II indicatte. The following minor comment (repeat from the 1981 and 1982 reviews) is noted:
Comment Internal policy memoranda and written procedures have not been prepared to document the administrative practices and policies the staff should follow.
In addition, the inspection procedures or.
file also need updating.
t 6-Recomendation We believe these procedures and practices should be written and updated as changes occur. Such documentation helps assure the staff perfoms its duties with a high degree of unifomity and continuity in regulatory practices.
It also provides femal guidance and direction to new staff members.
V.
Personnel Qualifications of technical staff is a Category II indicator. The following minor coment (repeat from the 1982 review) is noted:
Coment Written job descriptions outlining actual functions and duties for the Radiation Specialist II and Laboratory Scientist III are out of date.
Recommendation These job descriptions should be updated to assure that incumbents are aware of critical job functions and to assure
?. hat essential functions are carried out.
9 f
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