ML20151Z838
| ML20151Z838 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1988 |
| From: | Kammerer C NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Ellis M IOWA, STATE OF |
| References | |
| NUDOCS 8808300171 | |
| Download: ML20151Z838 (5) | |
Text
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1 NUCLEAR REGULATORY COMMISSION W ASHING TON, D. C. 20555 e
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.'.... ,6 AUG 16 888 Mary L. Ellis, Comissioner of Public Health *o Iowa Department of Health Lucas State Office Building Des Moines, Iowa 50319
Dear Comissioner Ellis:
This is to confirm the discussion Messrs. Bolling and Adam held with Messrs. Kelly and Flater on May 28, 1988 following our review of the Iowa radiation control program.
The results of our review indicate that the Iowa radiation control program is adequate to protect the public health and safety and is compatible with the NRC and other Agreement States for regulating agreement materials.
Enclosure 1 contains coments regarding technical and administrative aspects of the review. We would appreciate a review and a response to our coments. If you wish, Mr. Donald Flater, Chief of the Bureau of Radiological Health, may respond to these coments. Enclosure 2 contains an explanation of our policies and practices for reviewing Agreement State programs. Also enclosed is a copy of this letter for placement in the State's Public Document Room or otherwise to be made available for public review.
On April 12, 1987, NRC reorganized its staff. The State Agreements Progran is now a pert of the new Office of Governmental and Public Affairs, which reports to the Comission. One purpose of this organizational change was to provide an improved focus for NRC relationships with the States. Our regional offices will continue to administer and implement NRC's regulatory program. We encourage you and your staff to continue to look to the Regional Administrator and his staff as the primary contact with NRC.
8808300171 800S26 PDR STPRC ESCIA AGREE ST STATS PNU
Mary L. Ellis, Comissioner -
I apprtciate the courtesy and cooperation extended by your staff to Mr. Bolling and Mr. Adam during the review.
Sincerely, original Signed by MNALD A. FUS5BAWIR y
Carlton Kamerer, Director s State, Local and Indian Tribe Programs
Enclosures:
As stated cc: w/encls.
Donald Flater, Chief Bureau of Radiological Health Victor Stello, Executive Director for Operations, NRC NRC Public Document Room State Public Document Room Distribution:
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o , 1 Enclosure 1 Comments and Recommendations on Technical and Administrative Aspects of the Iowa Radiation Control Program for Agreement Materials I. Personnel Staffing level is a category II indicator. The following comment is made with our recommendation.
Comment Based on dnta supplied to us by your staff, the radiation control program is reported to have one fulltime professional and two additional persons each with less than 50% of their time devoted to the agreement materials program. It was further noted that due to new initiatives, in the areas of radon, hazardous materials, operator registration program and medical devices, the actual amount of professional time devoted to the agreement materials program is approximately 0.6 person-years per 100 licenses. This level is likely to decrease further as the numbers of licenses increases. From 1986 to 1988 the program gained 45 licenses, terminated 22 licenses and conducted 116 inspections while growing from 177 to 201 total licenses.
At the same time the professional staffing level decreased from approximately 1.8 to 1.2 FTE or 0.6 person-years per 100 licenses.
Our guideline for acceptable staffing is 1-1.5 person-years per 100 licenses and a minimum of two professionals for our smaller programs. The program is not currently meeting our minimum guideline for staffing level.
Recommendation We recommend that at least one additional fu11 tine professional be added to the agreement materials program. This person should be utilized in both the licensing and inspection areas and to provide ;
the kind of He3th and conti3uity which will allow the program to l grow and to respecd to new initiatives and emergencies. We will be pleased to provide training, as appropriate, for this individual.
II. Compliance Inspection procedures is a Category II indicator. The following ,
comment and recommendation of minor significance was made. l l
Comment A review of selected compliance files and accompaniments during two I program inspections indicate the neeo for interviews of workers and l ancillary staff documentation of these interviews, l l
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a Recomendation We recomend that the inspection report forms be specifically revised to include an area for worker interviews. We feel that this is the best way to learn the extent of radiation training and routine program activities.
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c Enclosure 2 Application of "Guidelines for NRC Review of Agreement State Radiation Control Programs" The "Guidelines for NRC Review of Agreement State Radiation Control Programs,"
were published in the Federal Register on June 4, 1987, as an NRC Policy Statement. The Guidelines provides 29 indicators for evaluating Agreement State program areas. Guidance as to their relative importance to an Agreement State program is provided by categorizing the indicators into 2 categories.
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 11 indicators address program functions which provide essential technical and administrative support for the primary program functions. Good perfomance in meeting the guidelines for these indicators is essential in order to avoid the development of problems in one oi more of the principal program areas, i.e., those that fall under Category I indicators. Category II indicators frequently can be used to identify underlying problems that are causing, or contributing to, difficulties in Category I indicators.
It is the NRC's intention to use these categories in the following manner. In reporting findings to State management, the NRC will indicate the category of each coment made. If no significant Category I coments are provided, this wil) indicate that the program is adequate to protect the public health and safety and is compatible with the NRC's program. If one or more significant Category I coments are provided, the State will be notified that the program deficiencies may seriously affect the State's ability to protect the public health and safety and that the need of improvement in particular program areas is critical. If, following receipt and evaluation, the State's response appears satisfactory in addressing the significant Category I coments, the staff may offer findings of adequacy and compatibility as appropriate or defer such offering until the State's actions are examined and their effectiveness confirmed in a subsequent review. If additional information is needed to evaluate the State's actions, the staff may request the information through follow-up correspondence or perfonn a follow-up or special, limited review.
NRC staff may hold a special meeting with appropriate State representatives.
No significant items will be left unresolved over a prolonged seriod. The Comission will be informed of the results of the reviews of t1e individual Agreement State programs and copies of the review correspondence to the States will be placed in the NRC Public Document Room. If the State program does not improve or if additional significant Category I defic 0ncies han developed, a staff finding that the progran is not adequate will be considered and the NRC may inttitute proceedings to suspend or revoke all or part of the Agreement in accordance with Section 274j of the Act, as amended.