ML20148P287
| ML20148P287 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/1978 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Porter B LOUISIANA, STATE OF |
| References | |
| NUDOCS 7811280165 | |
| Download: ML20148P287 (4) | |
Text
p26 PD k.
4 UNITED ST TES e
[,f
,'k NUCLEAR REGULATC< Y COMMisslON j.k%I ). y WASHINGTON, i C.20555 W$bf/
\\,
NOV 17 197a Ref: SA/J0L Mr. B. Jim Porter, Administrator Nuclear Energy Division Office of Conservation Department of Natural Resources P. O. Box 14690 Baton Rouge, Louisiana 70808
Dear Mr. Porter:
This is to ccnfirm the comments and recommendations made to you following the recent review of the Lousiana radiation control program.
Based upon the results of our review of the State's program and the routine exchange of information between the Nuclear Regulatory Commission and the State, the staff believes the State program for regulation of agreement material is adequate to protect the public health and safety and is compatible with the NRC's program for regulation of similar materials.
We believe improvements are possible in the licensing and compliance programs.
Specific comments and recommendations are enclosed.
I would app"eciate your review of our recommendations and receiving any comments you may have regarding them.
I appreciate the courtesies and cooperation extended to Mr. Lubenau, Mr. Bolling and myself during the review.
Sincerely, a A W,, ~ J & / >
G. Wayne LVrr, Assistant Director for State Agreements Program Office of State Programs
Enclosure:
Comments and Recommendations cc:
(w/ encl.)
R. T. Sutton, Commissioner NRC Public Document Room Louisiana Public Document Room 781120o(Gf
COMMENTS AND RECMMENDATIONS FOR THE LOUISIANA RADIATION CONTROL PROGRAM I.
Licensing We recommend that the licensing program can be improved in the following two areas:
1.
License applications should provide information on the organization of the institution or firm applying for a license, including an organization chart.
The appli-cation should also be signed by a member of management or evidence submitted indicating management approval of the proposed use of radioactive material.
2.
Telephone conversations of any substance with license applicants, regarding license applications, should be transcribed and placed in the licensee's folder.
II. Compliance We believe improvements are possible in the following areas of the compliance program:
1.
We recommend each inspector be accompanied by a supervisor at least annually for the purpose of confirming the inspector conducts his inspections in a professional, business-like manner and in a manner adequate to assure protection of the public health and safety.
Such supervisory evaluations also serve to provide supervisory staff with opportunities to observe first-hand radiation safety practices and problems encountered at licensed operations.
2.
We recommend inspectors regularly interview workers at licensed facilities for the purpose of determining the extent of their training and instruction in radia-tion safety as required by Louisiana Radiation Regula-tions, Section J.12.
When inspecting licensed indus-trial radiography operations, such interviews can be useful in verifying that " helpers" and "radiographers' assistants" are not performing duties for which they are not qualified or authorized.
=
~ mamee w-or.
.. II.
Compliarcelconti nued) 3.
We recommend inspection reports include a note concerning close-out of previous citations for non-compliance.
The licensee's corrective actions should be verified and evaluated for adequacy by the inspector.
Enforcement cor respondence should also mention closing out of previous items on non-compliance. This stresses the continuity of the regulatory program.
4.
We reviewed two reports of investigations of reported overexposures of radiographer assistants or helpers.
We believe additional investigation and documentation of the role of the radiographer was needed in both cases.
Radiographers should be interviewed in such cases.
If there are allegations of improper instruc-tions having been given by a radiographer, they should be thoroughly explored and, if verified, brought to the licensee's attention.
5.
We recommend procedures be developed which will enable closer monitoring of licensee's enforcement and com-pliance histories. One method is to set up a cover sheet for the compliance file which briefly lists inspection dates and findings.
Both inspectors and compliance supervisors should be alert to patterns of repetition of violations. These are frequently indicative of inadequacies in the management of the radiation control program and should be specifically mentioned in enforcement correspondence.
6.
We noted cases where enforcement correspondence was addressed to the radiation safety officer (RS0) but it was not clear from information in the file that the RSO represented management. Organization charts or other information clarifying the RS0's relation to management should be sought in the license review process and verified by inspectors. Management should receive enforcement correspondence, m _,_. -
- 7.
Management is responsible for compliance with all requirements of the regulations and the license and citations of violations should reflect this.
For exanple, a licensee who permits a person not named as an authorized user on the license to use licensed material has failed in his responsibility to comply with the license requirement concerning users. The citation should avoid any suggestion that the matter can be resolved by submitting an application for amendment to add the person to the license. Repeti-tions of such violations may be indicative of manage-ment deficiencies in the radiation safety program and should be highlighted in enforcement letters.
Under separate cover, we are furnishing copies of forms and letters utilized by NRC's Office of Inspection and Enforcement which exemplify our comments.
_