ML20126E302
| ML20126E302 | |
| Person / Time | |
|---|---|
| Issue date: | 12/22/1992 |
| From: | Woodruff R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Michael Clark FLORIDA, STATE OF |
| References | |
| NUDOCS 9212290087 | |
| Download: ML20126E302 (23) | |
Text
I.i December 22, 1992 Mary E. Clark, Ph.D., Chief Office of Radiation Control Department of Health and Rehabilitation Services 1317 Winewood Boulevard Tallahassee, Florida 32399-0700
Dear Dr. Clark:
This will confirm my recent discussion with you and Mr. Nash concerning the review of your Radiation Control Program scheduled for the weeks of February 8 - 12 and 22 - 26, 1993.
The week of February 8 - 12, 1993'will be utilized for accompaniments of materials inspectors from each of your Area Field Offices, and the week of February 22 - 26, 1993 is reserved for our review in the Tallahassee office.
I am enclosing a list of questions entitled, " Appendix A, Evaluation of -
Agreement State Radiation Control Program, State Questionnaire Update".
These questions and your response to the questions will become Appendix A to our final report.
This questionnaire is a revised version of the previous list of questions that was used during the previous review in 1991.
The new questions are an attempt to standardize the questionnaire and simplify the information collected during_
our reviews.
Please note that with the exception of the organizational charts, all other information should be incorporated into the answers to the extent possible.
Reference documents should be made available during the review as needed.
A diskette containing the review guidelines and the questions is enclosed for your use, Copies of the Organizational _ Charts should be included as Appendix B.
Part II of the questionnaire it identical to the " annual summary" that was-requested from all States for the calendar year 1991.
Therefore, to simplify the collection of data, the Part II data should reflect the annual summary for the calendar year 1992.
To facilitate the review process, please return a completed copy of the document (on diskette) including your answers to this office prior to February 15, 1993.
Sincerely,
,y Richard L. Woodruff Regional State Agreements Officer
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APPENDIX A EVALUAT10N Of AGREEMENT STALE RADIATION CONTROL PROGRAM PART I PROGRAM GUIDELINES AND STALE QUESil0NNAIRE UPDATE Name of State Program; fl0RIDA Reporting Period from: lianlLL_l9.1L to hebruary 26, 19M I.
EGlhLATJON AND REGUlAT10NS A.
1351al Authority (Category I)
NRC Guidelines:
Clear statutory authority should exist, designating a State radiation control agency and providing for promulgation of regulations, licensing, inspection and enforcement.
States regulating uranium or thorium recovery and associated wastes pursuant to the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA) must have statutes enacted to establish clear authority for the State to carry out the requirements of UMTRCA.
Questions:
1.
What changes were made to the State's statutory authority to regulate agreement materials, low level waste disposal, or uranium mill operations in the reporting period?
2.
Are your regulations subject to a " Sunset" or equivalent law?
If so, explain and include the next expiration date for your regulations.
B.
Status and Compatibility of Reguttations (Category 1)
NRC Guidelines:
The State must have regulations essentially identical to 10 CFR Part 19, Part 20 (radiation dose standards, effluent limits, waste manifest rule and certain other parts),
Part 61 (technical definitions and requirements, performance objectives, financial assurances) and those required by UMTRCA, as implemented by Part 40.
The State should adopt other regulations to maintain a high degree of uniformity with NRC regulations, for those regulations deemed a matter of compatibility by NRC, State regulations should be amended as soon as practicable but no later than 3 years.
The RCP should have established procedures for effecting appropriate amendments to State regulations in a timely manner, normally within 3 years of adoption by NRC.
Opportunity should be provided for the public to comment on proposed regulation changes.
(Required by UMTRCA for uranium mill regulation.)
Pursuant to the terms of the Agreement, opportunity should be provided for the NRC to comment on draft changes in State regulations.
A2 Questions:
1.
What'is the ' effective date of the last compatibilityrrelated amendment to the State's regulations?
2.
Referring to the latest NRC chronology of amendments, identify those that have not been adopted by the State,-
explain why they were not adopted, and discuss actions being taken to adopt them.
3.
Identify the person responsible for developing new or amended regulations affecting agreement materials.
11.
ORGANIZATION 4
Under the Appendix B title sheet provided at the end of this document, please enclose copies of your organization charts as follows:
a) organization chart (s) showing the position of the radiation control program (RCP) within the State organization and its relationship to the Governor, other' State and local RCPs (if any), and comparable health and safety programs.
b)
RCP internal organization charts.
If applicable, include regional offices and contract agencies.
All charts should be current, dated, and include names and titles for all positions.
A.
Location of the Radiation Control Proaram Within the State Orqanizatior, (Cateaorv II)
NRC Guidelines: The RCP should be located in a State organization parallel with comparable health and safety programs._ The Program-Director _should have-access to appropriate levels of State management,. Where regulatory responsibilities are divided between State agencies, clear understandings should exist as toJdivision of responsibilities and requirements for coordination.
Questions:
1.
During the reporting-period, did the management, program-name, or location of the RCP within-the State organization change?
B.
-Internal Oraanization of the RCP-(Category 11)
- NRC. Guidelines: The RCP should be organized with the view toward achieving an acceptable degree of staff efficiency,- place appropriate emphasis on major program functions, and provide specific lines of supervision from program management for the execution of program policy.1 Where regional-offices uor other government agencies-are utilized, the lines of communication and administrative control between these offices and the central office (Program Director) should be clearly drawn to provide p
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'A3 uniformity in licensing and inspection policies, procedures' and supervision.
Questions:
1.
What changes occurred in the organization of the tCP during the reporting period?
2.
If changes occurred, how have they affected-the RCP and its effectiveness?
C.
Legal Assistance (Category II)
NRC Guidelines:
Legal staff should be assigned to assist the RCP or procedures should exist to.obtain legal assistance expeditiously. Legal staff should be knowledgeable regarding the RCP program, statutes, and regulations.
Questions:
1.
If legal assistance was utilized during the reporting period, briefly describe the circumstances.
2.
Was the legal assistance satisfactory during this period?
If not, what were the problems?.
D.
Technical Advisor _v Committees (Category II)
NRC Guidelines:
Technical Committees, Federal _ Agencies, -and 'other resource organizations should be used to extend staff capabilities for unique or technically complex problems. A State Medical-Advisory Committee should be used to_ provide broad l guidance on the uses of-radioactive drugs in or on humans.
The Committee should represent a wide spectrum of medical disciplines. The Committee should advise the RCP on policy. matters'and regulations related-to-use of radioisotopes in or on humans.
Procedures should be developed to -avo9d conflict of interest, even though Committees ~
are advisory. This does not mean that representatives of the regulated community should not_ serve.on advisory committees or-not be used as consultants.
Questions:
1.
Please list the names, affiliations, and -terms of the.
technical committee (s) members.
r 2.
If an advisory committee or r.onsultant was used during the reporting period, briefly describe.each _ circumstance (i.e.,
the subject, the need, the result, and the-manner obtained -
by meeting, phone' call, or letter),
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Ill.
MANAGEMENT AND ADMINISTRATION:
A.
Quality of Emergency Planning (Category I)
NRC Guidelines:
The State RCP should have a written plan for response to such incidents as spills, overexposures,-
transportation accidents, fire or explosion, theft, etc..The Plan should define the responsibilities and actions.to be taken by State Agencies.
The Plan should be specific as to persons -
responsible for initiating response actions, conducting operations '
and cleanup.
Emergency communication procedures should be adequately established with appropriate local, county and State agencies.
Plans should be distributed to appropriate persons and agencies.
NRC should be provided the' opportunity to comment on-the Plan while in draft form.
The plan should be reviewed annually by Program staff for adequacy and to determine that content is current.
Periodic drills should be performed to test the plan.
Questions:
1.
Other than the communications list, when was the emergency plan last revised?
2.
If the plan was revised since the last review, what changes were made?
3.
If the plan was substantially revised during the reporting period, was the NRC provided the opportunity to comment on the revision while it was in draft form?
4.
When was the emergency communication list 'last reviewed or revised?
5.
When and how was the plan last tested?
8.
Budget (Category II)
NRL Guidelines:
Operating funds should be sufficient to support-program needs such as staff travel necessary to conduct an effective compliance program, including routine inspections,-
follow-up or special inspections (including pre-licensing visits) and responses to incidents and other-emergencies, instrumentation and other equipment to support the RCP, administrative costs in operating the program including rental charges, printing costs, laboratory services, computer and/or word processing support, preparation of correspondence, office equipment, hearing-costs,'
etc. as appropriate.
Principal operating funds should be from
-sources which provide continuity and reliability, i.e., general tax, license fees, etc. Supplemental funds may be obtained through contracts, cash grants, etc.
AS Questions:
1.
Show the amount for funus for the RCP for the current fiscal.
year obtained from:
a.
State general fund b.
Fees c.
Federal grants and contracts (identify) d.
Other e.
Total:
2.
Show the total amounts in the current _RCP budget allocated for the following (if contract costs are incurred, e.g, in LLW regulation, please include):
a.
' Administration b.
Radioactive materials c.
X-ray-d.
Environmental surveillance e.
Emergency planning f.
LLW regulation (regulation only, do not include site development) g.
U-mill regulation h.-
Other (radon, non-ionizing, operator credentialing, etc.
Please identify).
1 1.
Total:
3.
What percentage of your radioactive materials program is
. supported by fees?
4.
Discuss'any changes in-program funding that occurred during the _ reporting period, the reasons-for the changes (new programs, change in emphasis, statewide reduction, fee cost recovery percentage, etc.), and_how the changes affected the
-program.
5.
Overall,'is. funding sufficient 'to support all of the program needs? -If not,_ what -are the problem areas?
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- A6 C.
Laboratory:Sufport (Category,11).
NRC Guidelines: The RCP should have the laboratory support-capability in-house, or readily' available through established' procedures, to conduct bioassays, analyze environmental samples, analyze samples collected by inspectors, etc., on.a priority established by the.RCP.
Questions:
y 1.
Describe changes in your laboratory support, such as new instruments, cutbacks, etc., in this period.
2.
Have there been problems in obtaining timely and accurate lab results?
If yes, discuss the circumstances and how the problem might be corrected.
D.
Administrative Procedures (Category II)
NRC Guidelines: The RCP should establish written internal procedures to assure that the staff performs its duties as required and to provide a high degree of uniformity and continuity in regulatory practices.
These procedures.should-address _ internal-.
processing of license applications, inspection policies, decommissioning and license termination, fee collection, contacts with communication media, conflict of interest policies:for,
employees, exchange of information and other functions.: required of the program. Administrative procedures are in addition to the technical procedures utilized in licensing, and inspection and enforcement.
Questions:
1.
Briefly list the changes, such as new procedures, updates, policy memoranda,.etc., made in your written administrative procedures during-the reporting period.
Include internal processing of ~ license applications, inspection policies, decommissioning and license termination, fee collection, contacts with media,-
conflict of interest policies for employees, and exchange of information procedures.
E.
Management (Category II)
NRC Guidelines:
Program management should receive periodic reports from the staff on the status.of-_ regulatory actions
-(backlogs, problem cases, inquiries,- regulation revisions). RCP
-management should periodically assess workload trends, resources and changes in legislative and. regulatory responsibilities to forecast needs for increased staff, equipment,-services. and.
findings.
Program management should perform periodic reviews of selected license cases handled by each reviewer and document the results. Complex licenses (major manufacturers, large scope i Type A Broad, or ones with the potential' for significant releases 'to-environment) should-receive second party review (supervisory, 1 i
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Supervisory review of inspections, reports and enforcement actions should also be performed. When regional offices or other government agencies are utilized, program management should conduct periodic audits of these offices.
Questions:
1.
How many management reviews of license cases were performed in this period?
2.
Were all license reviewers included in the cases selected for management review?
If not, explain.
3.
What audits were made of regional and contract offices?
F.
Office Eauipment and Support Services (Category 11)
NRC Guidelines: The RCP should have adequate secretarial and clerical support. Automatic typing and Automatic Data Processing and retrieval capability should be available to larger (300-400 licenses) programs.
Similar services should be available to regional offices, if utilized.
Professional staff should not be used for fee collection and other clerical duties.
Questions:
1.
Has the secretarial and clerical support been adequate during this period? If not, explain.
2.
What word processing, data base, and spread sheet programs are you using?
G.
Public Information (Category II)
NRC Guidelines:
Inspection and licensing files should be available to the public consistent with State administrative procedures.
It is desirable, however, that there be provisions for protecting from public disclosure proprietary information and information of a clearly personal nature. Opportunity for public hearings should be provided in accordance with VMTRCA and applicable State administrative procedure laws.
Questions:
1.
Have changes occurred in the manner in which you handle public information?
IV.
PERSONNEL A.
Qualifications of Technical Staff (Category II)
NRC Guidelines:
Professional staff should have a bachelor's degree or equivalent training in the physical and/or life sciences. Additional training and experience in radiation
A8 protection for senior personnel including the director of the radiation protection program should be commensurate with the. type of licenses issued and inspected by the State. Written job descriptions should be prepared so-that professional qualifications needed to fill vacancies can be readily identified.
Questions:
1.
Please list all new professional personnel, indicate the degree they received, if applicable, and additional training and years of experience in health physics.
B.
Staffina level (Category II)
NRC Guidelines:
Professional staffing level should be approximately 1-1.5 person-year per 100 licenses in effect. RCP H
must not have less than two professionals available with training and experience to operate RCP in a way which provides_ continuous coverage and continuity.. For States regulating uranium mills and mill tailings current indications are that 2-2.75 professional person-years' of effort, including consultants, are needed to process a new mill license (including in situ mills) or major renewai, to meet requirements of Uranium Mill Tailings Radiation Control Act of 1978.
This effort must include expertise in radiological matters, hydrology, geology,'and structural engineering.
Questions:
1.
Complete a table listing the professional (technical) person-years of effort applied to the agreement or radioactive material program by individual. _ Include the name, position, and fraction of time spent 'in the following _
. areas: administration,-materials licensing & compliance-emergency response, LLW, U-mills.
If these regulatory responsibilities are divided between offices, the table should be consolidated to include all personnel contributing to the radioactive materials program.
If consultants were used to carry out the program's RAM responsibilities, include their efforts.
The table ' heading should be:
NAME POSITION AREA 0F EFFORT FTE%
2.
Is the staffing level adequate to meet normal-and special-needs and backup? If not, explain.
3.
Do you currently-have vacancies?
If so, when do you expect to_ fill'them?
C.
Staff Supervision (Category II)
NRC Guidelines:
Supervisory personnel should be adequate'to provide guidance and review the work of senior and junior personnel.
Senior personnel should review applications and inspect licenses -independently, monitor work of junior-personnel, l
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-A9 and participate in the establishment-of policy. Junior personnel" should be initially limited to reviewing license, applications and-inspecting small programs under close supervision.
Questions:
1.
Identify your senior _ personnel assigned to monitor the work of junior personnel.
D.
Trainina (Category 11)
NRC Guidelines:
Senior-personnel should.have attended NRC core courses in licensing orientation, inspection procedures, medical practices and industrial radiography practices. - (For mill' States, mill training should also be included.) The RCP should have a program to utilize _ specific short courses and; workshops to maintain appropriate level of staff technical competence in areas of changing technology.
Questions:
1.
Prepare a table listing all of the training courses, workshops, seminars, symposia, etc. that your materials personnel have attended since the last review. The table heading should be:
Student Course Sponsor Dates 2.
If any of your materials staff currently need NRC training, please identify the employees and the courses needed.
E.
Staff Continuity (Category II)
NRC Guidelines: Staff ~ turnover should be minimized by combinations-of opportunities for training.. promotions, and. competitive salaries.
Salary. levels should be adequatr to recruit and retain persons of appropriate professional qualifications. (Selaries-should be comparable to similar employment in.the: geographical' area.
The RCP organization structure should:be such that: staff turnover is minimized and. program _ continuity maintained'through.
opportunities for-promotion.
Promotion opportunitiesLshould-exist from junior level to senior level or supervisory positions.
There also should be opportunity:for periodic salary increases compatible with experience and responsibility.
Questions:
-1.
Identify the technical staff who-left the Agreement: program during this period and,. if possible, give the reasons for.
.the' turnovers.
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-e A10 V.
LICENSING 1
A.
Technical Quality of Licensina Actions (Category I)
NRC Guidelines: The RCP should assure that essential elements of applications have been submitted to-the agency, and which meet current regulatory guidance for describing the isotopes and-quantities -to be used, qualifications of persons who will use material, facilities and equipment, and operating and emergency procedures sufficient to establish the basis for licensing actions.
Prelicensing visits should be-made for-complex and major licensing actions.
Licenses should be clear, complete, and accurate as to isotopes, forms, quantities, authorized uses,.
and permissive or restrictive conditions. The RCP should_have procedures for reviewing licenses prior to renewal to assure that supporting information in the-file reflects the current scope of the licensed program.
Questions:
1.
Update the list of the State's major licensees.
In addition to the name, license number and type, please indicate if the license is new or was terminated (action).
Include:
o Broad Licenses o
LLW Disposal o
LLW Brokers (All Types) o
-Manufacturers and Distributors o
Uranium Mills o
Irradiators (Other than Self-Contained) o Nuclear Pharmacies o
Other Licenses With-a Potential Significance for Environmental Impact The table heading should.be:
Licensee Name License Number License-Type Action 2.
Identify any major, unusual, or complex 1icenses ~ issued or renewed in this period.
3.
Have any new.or amended licenses affected.the list of licensees requiring contingency plans?
4.
Discuss any variances'in licensing policies and procedures or-exemptions from the regulations granted-during the period.
B.
Adequacy of Product Evaluations (Category I)
NRC Guidelines: -RCP evaluations of manufacturer's or-distributor's data'on sealed sources and devices outlined.in NRC, State, or appropriate ANSI Guides, should be sufficient to assure integrity and safety for users. The RCP should review manufacturer's information on labels.and brochures relating to a.,
-a.
All radiation health and safety, assay, and calibration procedures for adequacy. Approval documents for sealed source or device designs should be clear, complete and accurate as to isotopes, forms, quantities, uses, drawing identifications, and permissive or restrictive conditions.
Questions:
1.
Prepare a table listing new and revised SS&D registrations of sealed sources and devices issued during the reporting period.
The table heading should be:
SS&D Manufacturer, Type of Indicate Indicate if Registry Distributor or Device if Agreement
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Custom User or Source NARM Material t
2.
List the applications for SS&D registrations for which registry documents have not yet been issued.
C.
Licensino Procedures (Category 11)
NRC Guidelines:
The RCP should have internal licensing guides, checklists, and policy memoranda consistent with current NRC practice.
License applicants (including applicants for renewals) should be furnished copies of applicable guides and regulatory positions.
The present compliance status of licensees should be considered in licensing actions.
Under the NRC Exchange-of-Information program, evaluation sheets, service licenses, and licenses authorizing distribution to general licensees and persons exempt from licensing should be submitted to NRC on a timely basis.
Standard license conditions comparable with current NRC standard license conditions should be used to expedite and provide uniformity in the licensing process.
Files should be maintained in an orderly fashion to allow fast, accurate retrieval of information and documentation of discussions and visits.
Questions:
1.
What changes were made in your written licensing procedures (new procedures, updates, policy memoranda, etc.) during the reporting period?
VI.
COMPLIANCE A.
Status of Inspection Proqram (Category I)
NRC Guidelines:
The State RCP should maintain an inspection program adequate to assess licensee compliance with State regulations and license conditions. The RCP should maintain statistics which are adequate to permit Program Management to assess the status of the inspection program on a periodic basis.
Information showing the number of inspections conducted, the number overdue, the length of time overdue and the priority categories should be readily available.
There should be at least
A12 semiannual inspection planning for the number of inspections to be performed, assignments to senior versus. junior staff, assignments to regions, identification of special needs and periodic status reports.
When backlogs occur the program should develop and implement a plan to reduce the backlog.
The plan should identify priorities for inspections and establish target dates and milestones for assessing progress.
Questions:
1.
Prepare a table identifying the Priority 1, 2, and 3 licenses with inspections that are overdue by more than 50%
of their scheduled frequency.
Include the licensee name, inspection priority, the due date, and the number of months the inspection is overdue.
The list should include initial inspections that are overdue.
The table heading should be:
Insp. Freq.
Licensee Name (Yearsl Due Date Months 0/0 2,
Describe your action plan for completing your overdue inspections.
If there is a backlog of (1) inspections with an inspection frequency of 3 year or less that are overdue by more than 50%
of + heir scheduled frequency, or (2) inspections with lower insaection frequencies that are overdue by more t1an 100% of their scheduled frequency, please include with the questionnaire a written action plan for eliminating the backlog.
The written action plan should contain inspection u
priorities, numerical and time frame goals for reducing the backlog, provide a method to measure the program's progress, and provide for management review of the program's success in meeting the goals.
3.
How many on-site close-out inspections prior to license termination were made during the reporting period?
4.
How many on-site close-out inspections are pending at this time?
5.
How many reciprocity notices were received in the reporting period?
6.
How many reciprocity inspections were conducted?
7.
Other than reciprocity licensees, how many field inspections of radiographers were performed?
8.
What percentage is this of your total number of radiographer
A13 licensees?
10sp_e_ction frequntcJ (Category 1) 6.
c 11RC Guidelines:
The RCP should establish an inspection priority system.
The specific frequency of inspections should be based upon the potential hatards of licensed operations, e.g., major processors, broad licensees, and industrial radiographers should be inspected approximately annually -
smaller or less hazardous operations may be inspected less frequently.
The minimum inspection frequency inc'uding for initial inspections should be no less than the 14RC system.
Questions:
1.
Identify individual licensees or groups of licen ees the State is inspecting more frequently than called for in the State's inspottion priority system and discuss the reason for the change.
C.
Lnspector's Performance and Capability (Category I) f4RC Guidelines:
Inspectors should be competent to evaluate health and safety problems and to determine compliance with State regulations.
Inspectors must demonstrate to supervision an
- unde,
, ding of regulations, inspection guides, and policies prior independently conducting inspections. The compliance supers e (may be RCD mnager) should conduct annual field evaluat,ns of each
.s.ctor to assess p s formance and assure application of appro
. ate and consistent policies and guides.
r Questions:
1.
Prepare a table showing the number and types of supervisory accompaniments made during the reporting period, include:
Supervisor inspector _,
License Catraory Date 2.
Were all inspectors accompanied at least annually by the ccmpliance supervisor during the reporting period?
If not, explain.
D.
Responses to incidents and Alleged in.,cidents (Category I)
IIRC Guidelines:
Inquiries should be promptly made to evaluate the need for on-site investigations.
On-site investigations should be promptly made of incidents requiring reporting to the Agency in less than 30 days (10 CFR 20.403 t:> pes)=
For those incidents not requiring reporting to the Agency ir, less 'han 30 days, investigations should be inade during the next :cheduled inspection.
('n-site investigations should be promptly made of non-reportable incidents which may be of significant public interest and concern, e.g. transportation accidents.
Investigations should include in-depth reviews of circumstances and should be completed on a high priority basis.
When
A14 appropriate, investigations should include reenactments and time-study measurements (normally within a few days).
Investigation (or inspection) results should be documented and enforcement action taken when appropriate.
State licensees and the NRC should 1
be notified of-pertinent information about any incident which could be relevant to other licensed operations (e.g., equipment fiilure, improper operating procedures). Information on incidents involving failure of equipment should be provided to the agency responsible for evaluation of the device for an assessment of 4
possible generic design deficiency.
The RCP should have access to medical consultants when needed to diagnose or treat radiation injuries.
The PCP should use other technical consultants for special problems when needed.
Questions:
1.
In this reporting period, did any incidents occur that involved equipment or source failure or approved operating pe ocedures that were deficient? If so, a.
How and when were other State licensees who might be affected notified?
b.
Was the NRC notified?
2.
For incidents involving failure of equipment or sources, was information on the incident provided to the agency responsible for evaluation of the device for an assessment of possible generic design deficiency? Please provide.
details for each case.
3.
If the RCP utilized medical or technical consultants' for an emergency during the reporting period, please describe the circumstances for each case.
4.
In the reporting period, were=there any cases' involving possible criminal wrongdcing that were looked into or are-presently undergoing' review'r if so,-please describe the circumstances for each case.
E.
Enforcement Procedures.(Category I)
-NRC Guidelines:
Enforcement Procedures should be sufficient to provide a substantial deterrent to licensee noncompliance with regulatory requirements.
Provisions.for the levying of monetary penalties are recommended.
Enforcement letters should be-issued within 30 days following inspections andEshould employ appropriate regulatory language clearly-specifying -all-items of noncompliance-and health and safety matters identified during the inspection and refer _encing the appropriate regulation or license: condition being violated.
Enforcement letters-should specify the time period for the licensee-to respond indicating corrective actions and actions taken to prevent recurrence (normally 20-30 days).
The inspector and compliance supervisor should review licensee responses.
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.c AIS Licensee responses to enforcement letters should be promptly acknowledged as-to adequacy and resolution of previously unresolved items. Written procedures should exist for handling escalated enforcement cases of varying degrees.
Impounding of material should be in accordance with State administrative procedures.
Opportunity for hearings should be provided to assure impartial administration of the radiation control program.
Questions:
1.
If during the reporting period the State issued orders, applied civil penalties, sought criminal penalties, impounded sources, or held formal enforcement hearings, identify these cases and give a brief summary of the circumstances and results for each case.-
2.
Discuss changes made in the enforcement procedures during the reporting period.
l f.
Jnspection Procedurm (Category 11)
NRC Guidelit.es:
Inspection guides, consistent with current NRC
+
guidance, should be used by inspectors to assure uniform and complete inspection practices and provide technical guidance in the inspection of licensed programs.
NRC Guides may be used if.
properly supplemented by policy memoranda, agency interpretations, etc. Written inspection policies should be issued to establish a policy for conducting unannounced inspections, obtaining corrective action, following up and closing out previous violations,-interviewing workers and observing operations, assuring exit interviews with management, and issuing appropriate notification of violations of health and safety.probleus, procedures should be established for maintainintlicensees compliance histories. Oral briefing of supervision or the senior inspector should be performed upon return from non-routine inspections.
For States with separate licensing and inspection
- staffs, procedures sh ald be established for feedback of information to license reviewers -
Questions:
1.
- What changes were made to your written inspection procedures during the reporting period?
G.
Inspection Reports (Category 11)
NRC Guidelines:
Findings =of inspections shouldlbe documented in a report describing the scope of inspections, substantiating-all-items of noncompliance and health and: safety matters,- describing the s~ cope of licensees' programs, and indicating the sebstance of-discussions with licensee management and-licensee's response.
Reports.should uniformly and adequately document the results of i
inspections and identify areas of the. licensee's program which should receive special attention at the next inspection.- Reports should show the status of previous noncompliance and the t
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Questions:
l.
What ch p were made in the formats of your reports or inspection forms during this period?
H.
Confirmatory Measurements (Category 11)
NRC Guidelines:
Confirmatory measurements should be sufficient in number and type to ensure the licensee's control of materials and to validate the licensees measurements.
RCP instrumentation should be adequate for surveying _ license operations (e.g., survey meters, air samplers, lab counting equipment for smears, identification of isotopes, etc.).
RCP instrumentation should include the following types:
GM Survey Meter:
0 50 mr/hr lon Chamber Survey Meter:
up to several R/hr Neutren Survey Meter:- Fast & Thermal Alpha Survey Meter: 0-100,000 c/m Air Samplers: Hi and Low Volume Lab Counters: Detect 0.001 c/ wipe Velometers Smoke Tubes Lapel Air Samplers Instrument calibration services or facilities should be readily available and appropriate for instrumentation used.
Licensee equipment and-facilities should not be used unless under a service contract.
Exceptions for.other State Agencies, e.g., a State University, may be made.
Agency instruments should be calibrated at intervals not greater than that required to licensees being inspected.
(Note: Addition types of instrumentation that are highly desirable are thin window plastic or Nal detectors-for low energy gammas and
" micro R" meters with audio signal for searching for lost gamma.
emitter' sources.)
Questions:
1.
Describe any changes in your instrumentation or methods of:
calibration in this reporting period.
Vll.
STATUS OF PREVIOUS NRC COMMENTS-AND RECOMMENDATIONS-A.
Please prepare a summary of the status of the State's. actions taken in response to NRC's comments and recommendations following-
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the last_ review, Vill. SPECIAL TOPICS OF CURRENT INTEREST A.
If you like, describe your program's' successes, problems or difficulties that occurred during this reporting _ period..
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f A17 PART 11 PROGRAM STATISTICS 1
as of Recember 31. 1992
- l.
How many specific licenses are currently in effect?
2.
During the last calendar year,
- i a.
how many new licenses were issued?
b.
how many licenses were terminated?
c.
how many licenses were renewed?
d.
how many amendments were issued?
e.
how many SS&D evaluations were completed?
3.
How many prelicensing visits were made during this past calendar year?
4.
How many new licenses (or major amendments) were hand delivered to the licensee?
5.
How many materials incidents, other than unfounded allegations, occurred-during the last calendar year?
i 6.
How many on-site investigations of incidents were conducted during-the last calendar year?
- 7.
How many incidents required NRC notification, either by telephone or by written report?
- 8.
How many of the incidents required Atoormal Occurrence Reports?
- 9.
How many of the-incidents involved leacing from sealed sources?
- 10.
How many misadministrations occurred du'ing the last calendar year?
11.
How many civil penalties were imposed durirs the last calendar year?
12.
How many orders were issued during the last' calendar year?
- 13.
How many technical FTE's (not-including administrative,- clerical or unfilled vacancies) are currently assigned to the:
Radioactive materials program?
Low-level waste program?
(
Uranium mills program?
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- 14.
Compute the professional / technical person-year effort of person-years per 100 licenses'(excluding management above the direct RAM supervisor, vacancies and personnel assigned to mills and burial site licenses).
Count only time dedicated to radioactive materials.
- 15.
List the RCP salary schedule as follows:
position Title Annual Salary Ranae i
f
- 16.
Please complete the following table using the license categories as shown, and including the total number of specific licenses in each category, the priority or inspection frequency, the number of inspections made during the review period, and the number of overdue-inspections in each category.
(In Priorities 1-3, include those overdue by more than 50% of their scheduled inspection frequency; in lower priorities, include these overdue-by more than 100% of their scheduled frequency.)
Insp.
. No.
No.*
No. of-Freq.
I'n sps.
Overdue-ticense Cateaor_y Licenses (yea.r}1 Made insos.
Broad A Academic (Medical)
Broad A Industrial Broad A Medical Broad A Mfg. & Dist.
-Industrial Radiography irradiator - Pool or Large LLW Broker or Service - Processing, incineration, Repackaging LLW Disposal & Burial Nuclear Pharmacy Source Material Processing Teletherapy (Human Use)
U-Mill Operation Other Priority 1 Broad A Academic (Non-Medical)
Broad B Academic Broad A R & D Decontamination Services LLW Disposal Service (pre-packaged)
Mobile Nuclear Services SNM-(unsealed)
Other Priority 2 Broad B Industrial Broad B Mfg. & Dist.
Broad B R & D In vitro Distribution Irradiators, Self-Contained, Small Leak Test-&-Calibration Services-Medical Product Distribution Medical, Institutional (Hospitals and-Clinics)
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fJo.. of Eriqi JnnIFh Qverdue license Category Licenses (years)
Made
- jn30s, Nuclear Laundry Source Material, Rare Earth U-Mill lailings Well Logging, Field Flooding Other Priority 3 GL Distribution Lixiscopes, Bone Mineral Analyzer, Sr Eye Applicator Medical, Private Practice Limited Diagnostic or Therapy Portable Gauge Services - Teletherapy Gauge, or Irradiator Other Priority 4 Bread C Academic Broad C Industrial Broad C Mfg. & Dist.
Broad C R & O Fixed Gauge in vitro Labs SNM (sealed)
Veterinary Medicine Other Priority 5 Gas Chromatographs &
other Measuring Systems Leak Test Only Shielding, Depleted Uranium Other Priority 6 and 7 TOTALS l
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i APPENDIX B ORGANIZATION CHARTS i
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