ML20050C572
| ML20050C572 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/1981 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Harkins J KANSAS, STATE OF |
| Shared Package | |
| ML20050C571 | List: |
| References | |
| NUDOCS 8204090100 | |
| Download: ML20050C572 (3) | |
Text
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UNITED STATES e
NUCLEAR REGULATORY COMMISS!CN
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.n...: 5 15P,1 Mr. Joseph F. Harkins, Secretary D fl.;.g,..
Department of Health & Environment
~ *! Q g Topeka, Kansas 66620
Dear Mr. Harkins:
This is to confirm the discussion Mr. Lubenau and Mr. Heyer held with you and members of your staff on December 11, 1981 following the recent -
review and evaluation of the Kansas radiation control program.
The review covered the principal administrative and technical aspects of the State's program for radioactive materials. This included an examination of the State's legislation and regulations, organization, management afid administration, personnel, and licensing and compliance functions.
For this review, the " Guidelines for NRC Review of Agreement State Radiation Control Programs," recently revised and published in the Federal Register December 4, 1981, were used. They were previously published for public comment and incorporated, where possible, Agreement 3
State coments. The guidelines contain indicators which address specific,
functions, categories ~ which denote the relative importance of each indicator and guidelines which delineate specific' objectives or operationiil' goals.
Category I indicators address program functions which directly relate to the State's ability to protect the public health and safety.
If significant problems exist in several Category I indicator areas, then the need for improvements may be critical.
Category II indicators address program functions which provide essential technical and administra-tive support.
Good performance in meeting the guidelines for these indicators is essential in order to avoid the development of problems in Category I areas.
Following each of the previous three program reviews we have comented on the serious need to augment the professional staffing level for the radioactive materials program. The staffing level should be 1.0 to 1.5 person-year per 100 licenses (a Category II indicator).
From 1978 to 1981 the Kansas staffing level has varied from 0.7 to 0.5, the current level.
Even with the scheduled addition of one full-time professional on January 4,1982, the staffing level will rise to only 0.8 person-year 9
8204090100 820224 PDR LTPRO E90KS PDR
. Mr. Joseph F. Harkins We were pleased to learn at the time of our meeting per 100 licenses.that there are plans to make two additional positions available for t radioactive materials program, but serious problems that need immediate attention exist now in two Category I areas, Status of Inspection Program and Status of Regulations.
The In 1979, the number of overdue inspections stood at 29 licenses.
overdue backlog rose sharply in 1980 to 82 and at the time of this The figure includes 11 review was 119 which is 36% of Kansas licenses.
Priority I licenses, that is, licenses which present significant hazards potential based on the type, quantity and use of materials authorized.
Two Priority I licenses should be inspected at 12 months intervals.
Priority I licenses are overdue 56 months and the least overdue time is 17 months.
Kansas' Radiation Protection Regulations were last revised May 1,1976.-
Our guidelines state the State must have regulations essentially identical to 10 CFR Parts 19, 20 (radiation dose standards and effluent limits)-
and adopt other regulations to maintain a high degree of uniformity 1/ith those of NRC (Category I). Updating should be accomplished so that State amendments necessary to maintain compatibility with NRC are adopted no later than 3 years after NRC.
A. number of significant amend-ments affecting the regulation of radioactive material in nuclear medicine, industrial radiography and transportation have been issu NRC since 1976.
radioactive material' must be adopted by Kansas to maintain compatibility..'tu The eventual addition of three full-time staff members to the radioac materials program represents action that will permit long-term management More immediate action is needed to assure the of program problems.
Kansas program remains adequate to protect the public health and safety Specifically, immediate action needs and compatible with NRC's program.
to be taken on the problems of updating the regulations and reducing the inspection backlog.
In view of the concurrent needs to continue to handle license applications, update and expand administrative and technical procedures, and provide training to new staff, we recommend a formal Such a plan action plan be developed for the next six to twelve months.
should include goals and set benchmarks, establish priorities, and Mr. Lubenau and Mr. Heyer provide for progress reports to management.
To assist discussed options and details of such a plan with Mr. Allen.
Kansas in one key area, updating the regulations, we are prepared to modify a copy of the Suggested State Regulations so that they conform to Kansas' codification system. We understand that Kansas' administrative
Mr. Joseph F. Harkins
- procedures provide for emergency adoption of regulations as an interim With respect to the new Kansas personnel, we will look forward measure.
to receiving applications for them to attend appropriate NRC sponsored short-term training courses.
NRC pays the travel and per diem costs for persons accepted for these courses.
Because of the critical need for improvements in the areas of regulations and inspection backlog, we have not developed a staff conclusion on the adequacy and compatibility of Kansas' program at this time.
We would like to know what steps the State plans to take to address this matter and would appreciate your early response.
If you agree that an appropriate course of action should include development and implementation of a short-term action plan, we would appreciate receiving a copy of the proposed plan for our review.
I am enclosing a copy of a letter to Mr. Allen regarding other aspects
- of the State's program. Also enclosed is an extra copy qf these letters for placement in the State Public Document Room or otherwise made available for public review.
I appreciate the courtesy and cooperation extended to Mr. Lubenau and c
Mr. Heyer during the meeting with you and your staff.
Sincerely,
)
i k
G. Wa Kerr, Director Office of State Programs
Enclosures:
As stated cc:
Mr. G. Allen NRC Public Document Room State Public Document Room l
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