ML20154P685
| ML20154P685 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Myers I ALABAMA, STATE OF |
| References | |
| NUDOCS 8603200395 | |
| Download: ML20154P685 (3) | |
Text
SCwritP M! % kd MAR 121986
( una)
Ira L. Myers, M.D.
State Health Officer State Department of Public Health State Office Building Montgomery, AL 36130
Dear Dr. Myers:
We appreciated the opportunity to meet with you and Dr. Fox on February 10, 1986, to discuss regulatory matters of mutual interest and concern. The following is a synopsis of the major areas which we discussed.
Regarding the personnel contamination incident which occurred on November 13, 1985, we have reviewed the State's Incident Report on this matter and conclude that there are several areas which warrant further consideration. For example, we note that the highest level of management approval for the use of unsealed radioactive material in the Browns Ferry exercise was the Director, Bureau of Radiological Health. We believe that such a proposed scenario should have been reviewed and approved at the Departmental level.
We also note that the Incident Report does not specifically preclude the use of exempt quantities of similar materials in future exercises. This concerns us since, even with the application of small quantities of radioactive material in which no significant health hazard is likely, these actions, if improperly controlled, can result in major adverse media and public sector credibility perceptions. These perceptions can be particularly detrimental since a regulatory agency would be expected to handle all materials in an exemplary fasion. Further, we do not believe that use of exempt quantities in unsealed form for other than spiking environmental samples is necessary for the conduct of these exercises. In the near future, we will provide you with a copy of the NRC policy dealing with the use of radioactive material in exercises. Overall, we do not feel that sound principles and practices, consistent with the ALARA concept, were effectively utilized during the exercise.
Finally, we feel that the report may be incomplete since it does not fully address all facets of the spiked environmental samples which were also utilized to add realism during the Browns Ferry exercise.
In view of these concerns, and as we discussed, we recommend that the following actions be taken:
. A supplemental report should be prepared which specifically addresses the handling, packaging, transportation, storage and disposition of spiked environmental samples, including the results of all surveys, as related to the recently conducted exercise.
. A policy should be developed and implemented to ensure that appropriate management of all participating organizations; i.e., State, utility, local government; review beforehand and specifically approve, or disapprove, the use of all forms of radioactive materials in exercises.
8603200395 s60312 PDR STPRG ESG
Ira L. Myers, M.D. 2
. The State should reevaluate its position and revise its policy, as appropriate, governing the use of radioactive sources in future exercises so that it conforms to NRC policy.
As you know, the results of our recent review of the Alabama Agreement State Program identified a deficiency in a Category I Indicator, " Status of Inspection Program. " We have reviewed the actions which you have outlined in your letter of January 21, 1986, and we feel that the goals which you have established to make improvements in the inspection program are appropriate. Members of my staff also had the opportunity to discuss the details of your action plan with Mr. Godwin on February 10, 1986. We would like to receive the inspection tracking plan which you intend to establish which will ensure that the goals are being met, and receive assurance that it receives appropriate management review. Upon receipt of this plan, we will be in a position to consider a statement of adequacy and compatibility for the Agreement State Program.
As we discussed, we do plan on conducting a follow-up review after July 1986 to determine the effectiveness of the State's overall corrective actions.
We feel that our meeting with you and Dr. Fox in Montgomery was beneficial and we look forward to working closely with Dr. Fox in the future. I would like to extend best wishes for success in your future endeavors.
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.
Please do not hesitate to contact us if we can be of further assistance in this regard.
Sincerely, (Original signed by J. Nelson Grace)
J. Nelson Grace Regional Administrator Enclusure:
Letter to Ira L. Myers, M.D.
from J. Nelson Grace, dated 3//a/86 cc: G. Wayne Kerr, Director Office of State Programs James W. Cooper, Director Environmental and Facility Standards Administration Aubrey V. Godwin, Director Bureau of Radiological Health NRC Public Document Room 1
I ra L. Myers , M.D. 3 bec: R. L. Woodruff R. E. Trojanowski s ,, Document Control Desk (SP01) l I
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