ML20148P298
| ML20148P298 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/1978 |
| From: | Ryan R NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Sutton R LOUISIANA, STATE OF |
| References | |
| NUDOCS 7811280167 | |
| Download: ML20148P298 (2) | |
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NUCLEAR REGULATOPY COMMISSION
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WASHINGTON, l' C. 20555 v**1,
NOV 17 s**
397g Ref:SA/J0L Mr. R. T. Sutton, Commissioner Office of Conservation Department of Natural Resources State of Louisiana Baton Rouge, Louisiana 31520
Dear Mr. Sutton:
This is to confirm the discussion Joel Lubenau, Lloyd Bolling and Wayne Kerr held with you and Mr. Porter following our review of the Louisiana radiation control program.
The review covered the principal administrative and technical aspects of the program including organi-zation, funding and personnel resources, licensing, inspection and enforcement activities, and the status of the State's radiation control regulations.
The review also included field evaluations of State inspectors.
As a result of our review of the State's program and the routine exchange of information between the Nuclear Regulatory Commission (NRC) and the State, the staff believes that the State's program for regula-tion 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 continue to believe that the program is understaffed. We noted, for example, that in this review there was an inspection backlog of 34 inspections.
The previous review, in contrast, disclosed no back-log.
Fewer inspections were performed during the recent review period, in pa'rt, because of past and pending major compliance actions which require significant staff effort to properly investigate, docu-ment and otherwise prepare for enforcement actions.
In past reviews, we have also noted that the growth in the number of licenses admin-istered by Louisiana has increased without a corresponding increase in staff. Our experience with Agreement State programs indicates a professional staffing level of 1.0 to 1.5 person-years per 100 licenses is needed.
In this review, we found that the professional staffing level decreased again and now is about 0.6 person-years per 100 licenses.
The need for additional staff is becoming critical and we urge that two full-time professional positions be added to the radioactive materials program.
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Mr. R. T. Sutton -
The Louisiana radiation control program is to be commended for its program of conducting frequent inspections of industrial radiography operations at locations of use, including field sites. One significant result of this program is that Louisiana has become especially know-ledgeable of radiation safety as it is practiced in the field and the factors that motivate and influence individual radiographers to comply with (or ignore) radiation safety requirements.
This infor-mation is relevant when developing radiation safety requirements.
Un-fortunately, reports on field radiography radiation safety practices are not frequently found in the professional journals that health physicists consult when preparing radiation safety standards. We recommend the State consider compiling the results of its regulatory efforts to assess and reduce radiation hazards in industrial radiography and submit it for consideration for publication by appropriate professional journals.
To this end, the Offices of State Programs and Standards Development would be pleased to discuss with you and Mr. Porter alternate ways of meeting this objective; for example, NRC funding of a review of Louisiana inspections reports by qualified persons to obtain statisti-cal and other pertinent information.
Such information should be valuable to us and may also serve as a basis for a Louisiana report on the subject.
I would appreciate your review of our recommendations and receiving ar,y comments you may have on them. A letter to Mr. Porter regarding the technical aspects of the program review is enclosed for your information.
I am also enclosing a copy of this letter for placement in the State Public Document Room or otherwise be nade available for public review.
Sincerely, f b> p/[/]ll. T N M41 t
Robert G. Ryan, Director Office of State Programs
Enclosures:
As stated cc:
B. Jim Porter NRC Public Document Room S' ate Public Document Room l
.