ML20137G827
| ML20137G827 | |
| Person / Time | |
|---|---|
| Issue date: | 01/13/1986 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Kerr G NRC |
| References | |
| NUDOCS 8601210221 | |
| Download: ML20137G827 (2) | |
Text
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13 JAN Bd6 MEMORANDUM FOR:
G. Wayne Kerr FROM:
Ross A. Scarano, Director Division of Radiation Safety and Safeguards
SUBJECT:
NRC POLICY STATEMENT ON GUIDELINES FOR REVIEW OF AGREEMENT STATE PROGRAMS - SUGGESTIONS FOR IMPROVEMENT In.accordance with your request to review the current NRC Policy Statement for evaluating Agreement State Programs, the staff has submitted a number of suggestions for improving the present guidelines. Generally, we feel the Policy Statement has worked well in maintaining the desired level of adequacy in Agreement State radiation control programs. However, in evaluating the programs in our Region, it has been noted that the guidelines need to be more specific or clarified in some areas.
Internal Organization of the RCP. The current guidelines do not address the practice of contracting the inspection and enforcement functions of the program to other agencies, su,ch as cities or counties. This could easily be remedied by adding the words, "or contract agencies," to the last sentence, "Where regional of fices are utilized...."
Administrative Procedures. These guidelines should be expanded to call for written procedures pertaining to license termination, escalated enforcement, instrument calibration, relear,es to communication media, fee collection, and the exchange of pertinent information with other Agreement States and the NRC.
The lack of written procedures in these areas has caused problems in several State programs and the statement should be strengthened.
Personnel. The guidelines do not address the issue of State technical personnel who work part time for licensees. Although this only occurred in one instance, perhaps it should be considered for inclusion.
Technical Quality of Licensing Actions. The guidelines could be strengthened by suggesting that licensing actions be made in accordance with good health physics practices.
Licensing Procedures. The guidelines do not cover license termination or expired licenses. Additional guidelines should be established to assure proper close-out of terminated licenses as well as proper action on expired licenses.
Responses to Incidents and Alleged Incidents. The guideline statement requiring that state licensees and the NRC be notified of pertinent information about any incident which could be relevant to other licensed operations possibly should be expanded to specifically include interstate operations.
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' Enforcement Procedures. It has been observed that some licensees move their operation and radioactive materials to another state in order to avoid escalated enforcement actions. New guidelines are needed to assure this
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information when known to an Agreement State, be relayed to the NRC as well.as the new state or 'other jurisdiction.
We hope :these comments are of assistance.
If you have any questions, please feel free to call.
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L R. A. Scarano, Director Division of Radiation Safety and Safeguards i
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-- J. Martin i
B. Faulkenberry G. Cook
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