ML20196L420
| ML20196L420 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1988 |
| From: | Corley J, Kammerer C, Lubenau J NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | |
| References | |
| NUREG-1311, NUDOCS 8807070455 | |
| Download: ML20196L420 (77) | |
Text
._.
l 6
Funding the NRC Training Program for States 1
U.S. Nuclear Regulatory l
Commission
. Office of Governmental and Public Affairs j
J.O. Lubenau, J.H. Corley, C. Kammerer f "< coy, e
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l NOTICE Availability of Reference Materials Cited in NRC Publicatiorts Most documents cited in NRC publications will be available from one of the following sources:
- 1. The NRC Public Document Room,1717 H Street, N.W.1 Washington, DC 20555
- 2. The Superintendent of Documents, U.S. Government Printing Office, Post Office Box 37082, Washington, DC 20013 7082
- 3. The National Technical Information Service, Springfield, VA 22161 Although the listing that follows represents the majority of documents cited in NRC publications, it is not intended to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Docu-ment Room include NRC correspondence and internal NRC memoranda; NRC Office of Inspection and Enforcement bulletins, circulars, information notices, inspection and investigition notices; Licensee Event Reports; vendor reports and correspondence; Commission papers; and applicant and licensee documents and correspondence.
The following documents in the NUREG series are available for purchase from the GPO Sales Program; formal NRC staff and contractor reports, NRC sponsored conference proceedings, and NRC booklets and brochures. Also available are Regulatory Guides, NRC regulations in the Code of Federal Regulations, and Nuclear Regulatory Commission issuances.
Documents available from the National Technical Information Service include NUREG series reports and technical reports prepared by other federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
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Single copies of NRC draft reports are available free. to the extent of supply, upon written request to the Division of Information Support Services, Distribution Section, U.S. Nuclear Regulatory Commission, Washington, DC 20555.
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NUREG-1311 Funding the l\\ RC Training Program for States Manuscript Completed: March 1988 Date Published: June 1988 J.O. Lubenau, J.H. Corley, C. Kammerer Stato, Local and indian Tribe Programs Office of Governmental and Public Affalls U.S. Nuclear Regulatory Commission Washington, DC 20555
ABSTRACT On February 3, 1988, the Commission received a briefing on the State, local and Indian Tribes Programs of the NRC Office of Governmental and Public Affairs. The briefing included discussion of the Agreement State program and, more particularly, the training provided to State personnel to help them maintain programs which are adequate to protect public health and safety and compatible with the Commission's program.
The Commission endorsed the NRC State training program but questioned the long-standing practice of paying the travel and per diem of State personnel approved to attend the NRC sponsored training. The staff was requested by the Commission to provide a report on this aspect. This report is the staff's response.
It includes an evaluation of the practice of funding State travel and per diem costs for personnel attending NRC courses and other options to make this program more cost effective including utilizing whenever possible minimal cost Federal and commercial training facilities.
l l
l iii
CONTENTS l
Page I
ABSTRACT............................ iii l
FOREWORD............................ vii l
ACKNOWLEDGEMENTS.........................ix 1
1.
EXECUTIVE
SUMMARY
1 2.
INTRODUCTION,.......................
4 1
3.
LEGISLAT'VE HISTORY AND OTHER HISTORICAL PERSPECTIVES....
4 3.1 Legi slative History..................
4 3.2 General Accounting Office...............
9 3.3 National Governors' Association............
10 3.4 Nuclear Regalatory Conmission.............
10 3.5 National Counci on Radiation Protection and Measurements (NCRP),
13 3.6 Historical Summary........
.13 4.
STATE PERSPECTIVES.....................
14 4.1 The Need for TrLining and Funding State Travel and Per Diem Co.cs...................
14 4.2 User Fees.......
17 4.3 Staff Turnover........
19 4.4 State In-House Tr;:ir.ing.................P.9 4.5 fammary of State Ferspectivaa.
.....,20 5.
NRC TRAINING FOR STATES,.................
23 5.1 Past and Present NRC Training.............
23 5.2 Future NRC Training..................
27 5.3 NRC Strategic Plan..................
28 5.4 Summary of NRC Training for States.......
29 6.
THE IMPACT UPON NRC 0F THE AGREEEP.'T STATE PROGRAM.....
29 6.1 The Scope of the Agreement Stet t Program....... 29 6.2 The Agreement State Program and ine NRC Budget
.29 6.3 Other Contributlons of the States........... 32 6.4 Summary - Tlie Importance to NRC of the Agreement States...................
32 e
CONTENTS (continued)
Page 7.
SLITP INITIATIVES TO IMPROVE TRAINING COST-EFFECTIVENESS..
32 l
7.1 Should States Share Travel and Per Diem l
Costs of Training?..................
32 7.2 Utilization of Minimal Cost Federal and Commercial Training Facilities.......,.........
34 7.3 Other Initiatives
..................44 7.3.1 State In-House Training.............
44
- 7. 3. 2 Tra ining Trainers................ 44 7.3.3 State Training of States............ 44 7.3.4 State Participation in NRC State Reviews....
45 7.3.5 Alternative Modalities.............
45 7.4 Summary - Finding Ways to Save Dollars........
45 8.
CONCLUSIONS........
...............45 9.
REFERENCES.........
.............. 47 APPENDIX A - Memorandum, H. R. Denton, to Chairman Zech dated August 7, 1987, "Additional Assistance to States in Regulation of Materials Licensees" TABLE 1.............................
18 T AB L E 2.............................
21 TABLE 3.........................
TABLE 4.............................
26 TABLE 5............................. 33 36 FIGURE 1........................
FIGURE 2........................
30 31 vi
l FOREWORD by Carlton Kammerer On February 3,1988, the Comission was briefed on the status of the State, local and Indian Tribe Programs (SLITP). This was the first time the Commission received a briefing on NRC's liaison activities with State and local governments and Indian Tribes and on the NRC Agreement State program. We appreciate the Commission's interest in these programs.
1 Many positive and complimentary coments were offered by the Comission, first and foremost by the Chairman:
"I appreciate the cooperation and the assistance extended by the State and Indian Tribe representatives in helping us to ensure the
.j public health and safety.
They perform an important service to our
~1 agency and to our country."
1 Commissioner Bernthal followed the Chairman's comment:
"You will undoubtedly hear a great deal about the success of the Agreement State program and of increasing interest on the part of non-Agreement States. Much, if not all, is true.
NRC's Agreement State Program is often cited as one of the finest examples of Federal-State cooperation operative today."
In this context, an observation made by the National Governors' Association (NGA) in its 1983 report on the NRC Agreement State program becomes pertinent:
"Much of the credit for the continuing high per'ormance of State programs is attributed to the training received in the Nuclear Regulatory Commission courses."
In addition to the NGA study, NRC training for States has been reviewed over the years in two reports by the General Accounting Office, in two NRC reports and is addressed in two NRC Policy Statements. NRC training for States is an important factor in maintaining Agreement State programs % ich are adequate to protect public health and safety and compatibie with the Commission's program.
In 1987, we initiated a '.equest for additional funds for NRC training for
~
States.
In FY 82 we presented 21 courses to 286 students, a level that met State needs. There were 26 Agreement States which regulated 13,000 licenses. The State training budget for FY 82 was $540,000.
An increase in the budget for training to keep pace only with inflation would dictate a budget for FY 87 of $693,000 (based on the inflation rate for each yea during the period). The training budget for FY 87 was $522,000,
'le demand for training however, has increased. There are now 29 Agreement i
t Scates regulating 15,700 licenses. As a result, the number of courses prasented has been reduced to 10 and the number of students receiving training was reduced to 187.
vi i
At the briefing the Commission endorsed the NRC training program but questioned the long-standing practice of paying travel and per diem costs of State personnel selected to attend NRC sponsored training and requested a staff report on funding for States' travel and per diem expenses at NRC training courses for States. We examined this aspect and also sought other ways to save dollars.
We believe we have been successful in this.
We have concluded that the long-standing practice of NRC funding travel and per diem expenses for State personnel approved for NRC training should continue.
SLITP can extend the NRC trainin; 'rogram to States within existing budget constraints.
The primary w thod for accomplishing this will be by utilizing, to the fullest extent possible minimal cost Federal and comercial training facilities used by other Federal agencies.
These facilities, in addition to providing excellent training accomodations, offer lodging and food services which are comparable in quality to what is available comercially under prevailing government travel regulations but at significantly lower rates.
The money saved will be used to
)
restore courses which were delet.ed in respnnse to budgetary pressure and fulfill other State trainir.g needs.
For example, we recently visited the FEMA National Emergency Training Center (NETC) in Emmitsburg, Maryland. After evaluating the NETC training facility fer possible use for our State training program, we were convinced the facility could provide s quality training site.
We have scheduled "Inspection Procedures" as a pilot training course for 30 participants from June 6 through 10, 1988.
The cost for a single room lodging and three meals per day is $30.00 per day for each participant, compared to holding similar training at a commercial facility in a major m6tropolitan area with Federally-approved per diem rates of $72.00 to $117.00.
The daily cost savings for food 2nd lodging at NETC translates into a possible savings of several thousands of dollars for the 5-day training session.
We invite others to examine these facilities as we have done. We suggest their use is an opportunity to fulfill Agency needs for training and other activities requiring meeting and lodging accommodations in a manner which conserves limited Federal funds and meets the national coal of protecting the public health and safety.
Car' ton Kammerer, Director State, local and Indian Tribe Programs Office or Governmental and Public Affairs viii l
ACKNOWLEDGEMENTS It is a rare report that is written for which credit can be given to the authors only and this has been no exception. Carlton Kammerer, Sheldon Schwartz, Donald Nussbaumer and Jonn Kendig served as an editorial board and as a source for ideas and concepts.
Sheila Gindes, Janice Hester and Brenda Hill kept it on schedule by meeting typing deadlines and equally important, helping develop format and keeping a vigilant watch to main'ain textual quality.
The SLITP training program is not always easily distinguished as in formal training courses.
It is a constant activity that also evolves to fit changing Agreement State radiation safety regulatory needs.
If SLITP has been successful in this regard, it is because of the excellent State Agreements staff assembled in headeyarters and in the regions.
More than anyone else they de')rve the credit:
Lloyd Bolling, SLITP John McGrath, Region I Donald Mackenzie, SLITP Richard Woodruff, Region II Cardelia Maupin, SLITP William Adam, Region III l
Kathleen Schneider, SLITP Robert Doda, Region IV Jack Hornor, Region V l
Lastly, NRC regional and headquarters staffs and the Agreement States have become integral parts of the NRC trainirg for States by routinely providing guest lecturers, by assisting us in identifying training needs and by helping development of training programs to fulfill those needs.
To them our thanks.
i ix
FUNDING THE NRC TRAINING PROGr1M FOR STATES 1.
EXECUTIVE
SUMMARY
Prior to enactment of the Atomic Energy Act of 1954, nuclear energy activities in the United States were largely confined to the Federal Government. Tne Act made it possible for private comercial firms to enter the field for the first time.
Because of the hazards associated with nuclear materials, Congress determined that these activities should be regulated under a Federal licensing system to protect the health and safety of workers in the nuclear industry and the public. The Nuclear Regulatory Commission is the Federal agency charged with this responsibility.
Although protection of the public's health and safety has traditionally been a State responsibility, the Atomic Energy Act of 1954 did not specify such a role for the States in nuclear matters.
This policy was changed in 1959 when Congress enacted Section 274 of the Atomic Energy Act, "Cooperation With States." Section 274 spells out a State role and provides a statutory basi.e under which the Federal Government can relinquish to the States p, tions of its regulatory authority. The 1959 amendment made it possible for the States to license and regulate byproduct material (radioisotopes),
source material (the raw materials of atomic energy), and small quantities of special nuclear material.
The Commission is required, however, to retain regulatory authority over the regulation of nuclear facilities such as reactor >, exports and imports of nuclear materials and facilities, larger quantities of fissionable material, consumer products, facilities vital to the national comon defense and security and certain types of radioactive wastes. The Atomic Energy Act was amended in 1978 by the passage of Uranium Hill Tailings Radiation Control Act of 1978 which requires Agreement l
States regulating uranium and thorium tailings resulting from l
recovery operations to adopt certain technical and procedural requirements.
The 1978 amendment also requires NRC to periodically review Agreement State programs for adequacy to protect public health and safety and compatibility with the Comission's program.
NRC provides a wide spectrum of training for State personnel.
Examples of formal courses are basic training in health physics and short term courses that provide specialized knowledge and procedural instruction such as radiography radiation safety, nuclear medicine, licensing, inspection procedures, radiological engineering, well
'Ogging, transportation of nuclear materials and project management for lic?nsing low-level waste disposal facilities. Other training activitias include workshops, special meetings and individual instruction.
Historically, travel costs and per diem for State personnel. attending these training sessions have oeen paid by NRC.
Commission training for States was specifically authorized by Congress in 1959 when Section 274 was enacted and signed into law.
Congress recognized such training was needed to assist States to
prepare for entering into Agreement with NRC and to maintain programs that are adequate to protect public health and safety and compatib?e with the NRC's program.
Cash grants to States to operate their radiation control programs under NRC Agreements are not authorized by the Act. When Congress authorized the Comission to provide State training it included with the authorization a statutory intent that the "Comission shall take into account the additional expenses that may be incurred by a State as c consequence of the State's entering into an Agreement with the Comission pursuant to subsection b" (Section 2741, Atomic Energy Act, as amended).
The 29 Agreement States spend approximately $9,000,000 per year to run their materials regulatory programs under Section 274b Agreements. They regulate 15,700 specific licenses compared to 8,100 specific materials licenses regulated by NRC. Had Section 274 not been enacted, NRC would be responsible for licensing and regulating these 15,700 licenses in addition to its current workload. To do so, an estimated net increase of 135 technical FTE would be required.
For NRC, this translates into over $14,00G,000 in annual salary ard fringe benefit costs.
Offsetting this is the comparably small amount sgnt by NRC for State training which in FY 87 was $522,000. About 47% of this covers travel and per diem.
In other words, the NRC Agreement State program saves the NRC over
$13,000,000 annually.
If the $522,000 training budget is viewed in terms of an investment then the $13,000,000 savings represents a return of 2400%.
The NRC Agreement State program has been reviewed by the General Accounting Office, an internal NRC Task Force
.d the National Governors' Association.
In their reports the r:PC training program for States was consistently identified as a key to enabling States to prepare for such Agreements and to maintain Agreement State programs that are adequate to protect public health and safety and compatible with the Comission's program. Their reports also contained recommendations to expand the NRC State training program.
In FY 82, NRC provided training to 286 students in its State training program with a budget of $540,000.
Pecause of NRC budget constraints, coupled with inflationary pressures, only 187 students could be trained in FY 87 with a budget of $522,000. An increase in the budget for training to keep pace only with inflation would dictat? a budget for FY 87 of $693,000.
Yet the need for this training has increased as the number of Agreement States has increased, as more States express an interest in becoming an Agreement State, as changes in radioactive materials use technology and new regulatory initiatives are occurring, and as staff turnover occurs.
Currently, for every 10 State applicants for training who are accepted, another 6 applications must be denied.
Clearly State training needs must be fulfilled if public health and safety is to be adequately protected by the Agreement States.
Equally clear is that NRC budgetary resources are limited. At a 2
1 February 3, 1988 briefing of the Commission on the State, Local and Indian Tribes Program, the Comissioners endorsed the NRC training program for States but indicated that finding additional funding at this time would be a problem.
The Commission counseled the staff to explore ways of extending their program by identifying cost-savings measures, suggesting (as an example) having States share the travel and per diem costs for State personnel selected for NRC training. NRC funding of these costs is a long-standing practice which is authorized by Section 2741 and complies with Congressional intent. Additionally, we found after consultation with several representative Agreement States that such an approach could have adverse consequences on the States' ability to adequately protect public health and safety because they could not assume these costs, either fully or partially.
States believe NRC training is extremely valuable. State attendance at NRC training activities normally involves out-of-state travel. Authorization to travel out-of-state is tightly restricted and is normally controlled outside of the State radiation control program, sometimes by the Governor's office.
in many cases, such authorization is severely limited or refused unless it can be shown State funds are not required for travel expenses.
Most of the Agreement States charge user fees.
States find that raising fees to adequately recover State costs can be difficult because NRC's materials fees, which are used for comparison, are below State needs for full cost recovery. Revenues from fees, however, are normally deposited directly into State treasuries, and funds for operating State radiation control programs come from legislative appropriations. Authorization to spend appropriate monies for out-of-state travel is controlled separately from other radiation control program expenditures.
The States' inability to fully assume funding travel and per diem expenses themselves will prevent them from sending State personnel who need training to attend NRC courses. All the States expressed a concern that lack of access to such training would impact the technical quality of their staffs and this would ultimately have an adverse effect on their abilities to adequately protect the public health and safety.
1 SLITP concluded that the long-standing practice of NRC funding travel and per diem expenses for State personnel approved for NRC training should continue. SLITP found, however, that alternative ways to save training money were possible. Anang the most promising is the utilization of minimal cost Federal and commercial training facilities used by other Federal agencies.
SLITP found that lodging and meal service charges at these centers are significantly less than current allowable Federal per diem rates.
The lodging and food services at these centers are comparable to what can be obtained commercially at Federal per diem rates and their training facilities are excellent.
SLITP believes the savings will enable restoration of some of the training courses which ha.e been recently l
deleted because of budget constraints and will allow us to meet other State training needs.
Agency-wide utilization of these training facilities could also extend other NRC trainina efforts in a similarly cost-effective fashion.
3
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2.
INTRODUCTION In April,1987 as part of a reorganization of NRC the State, local and Indian Tribe Programs (SLITP) was organized within the Office of Governmental uend Public Affairs. One objective was to bring SLITP closer to the Commission. On February 3, 1988, the Commission was briefed on the status of SLITP, (1)(2) The briefing included discussion of the Agreement State program and, more particularly, the training provided to State personnel for which, in 1987, SLITP had requested additional funds (Appendix A). NRC training for States helps them maintain programs which are adequate to protect public health and safety and compatible with the Commission's program. The training program also assists States desiring to assume Agreement State status by preparing the State staffs to carry out regulatory responsibilities. The Commission endorsed the program of providing training to States but questioned the long-standing practice of paying the travel and per diem of State personnel approvr i to attend NRC sponsored training. As a result of the briefing the staff was requested by the Conmission to "provide the Commission with a comprehensive paper discussing funding for Agreement States' travel and per diem expenses at NRC sponsored training seminars." 13)
In response, the staff examined this issue and also sought other ways to save dollars and use the savings to extend the availability of this training.
3.
LEGISLATIVE HISTORY AND OTHER HISTORICAL PERSPECTIVES 3.1. Legislative History The development of Section 274, "Cooperation With States" was summarized by NRC staff in a 1977 report on the Agreement State program:
"Atomic energy activities, prior to 1954, were virtually under a Federal monopoly.
The Federal Government was solely responsible for the production and use of nuclear material, and participation by industry in nuclear technology was limited essentially to performance of Government contracts. With the enactment of the Atomic Energy Act of 1954, it became possible for private enterprise to enter the field and to use nuclear materials and operate nuclear facilities in a manner consistent with our national traditions in other fields of free enterprise.
"Because the uses of nuclear materials involve the use of radiation, they necessarily involve considerations of public health and safety. The Congress, therefore, determined that private activities in this field should be regulated under a system of licensing in order to protect radiation workers and the public against radiation 4
hazards.
The AEC was charged by the Congress with this responsibility.
I "Protection of public health and safety, however, has traditionally been a function of the States. With the development of a private atomic energy industry, organizations which were subject to the laws of the States in other areas of public health became subject to the laws of the Federal Government insofar as radiation safety in the use of nuclear materials was concerned. But under the Federal law it was not at all clear what role, if any, w:s left to the States. Many States were, therefore, concerned as to what their responsibilities, if any, might be; they had a very real interest in seeing that the boundaries of Federal and State authority in this area were more clearly drawn.
"The need to amend the Atomic Energy Act of 1954 to permit increased participation by the States had been a subject of concern to the Joint Committee on Atomic Energy (JCAE) and AEC since its passage. AEC had instituted several specific programs which were designed to assist and cooperate with States and had participated in the activities of local and regional comissions. AEC notified State agencies of licenses issued and invited State officials to participate.in Comission inspections of licensed activities. An Advisory Committee of State officials was set up in 1955 to aid in the preparation of regulations to establish ' Standards for Protection Against Radiation' (10 CFR Part 20).
"In July 1957, AEC proposed a bill which would have permitted dual regulation by both Federal and State governments of byproduct, source and special nuclear material." (4)
The 1957 bill would have authorized the Comission to furnish employee training and other services to the States and this provision was carried over to the 1959 bill. (5)
Section 274, "Cooperation With States" was enacted and signed into law in 1959. (6) Paragraph 2741. states, in part, "The Comission is also authorized to provide training, with or without charge to employees of, and such other assistance to, any State or political subdivision thereof or group of States as the Comission deems appropriate.
Any such provision or assistance by the Comission shall take into account the additional expenses that may be incurred by a State as a consequence of the State's entering into an Agreement with the Commission pursuant to subsection b." (7) 5
t Even prior to enactment of Section 274 AEC had cooperated with and assisted in establishing State and local educational and training programs in the atomic energy field (8), however, the AEC budget did not sp?cify State training as a separate item. (9)
The purpose of specifically providing for State (and local) training in Section 274 was extensively comented upon by Congress. The legislative reports on the House and Senate bills quoted AEC General Manager Luedecke's May 13, 1959 letter to Chairman Anderson:
"To assist the States to prepare themselves for assuming independent regulatory jurisdiction, the new bill (like the 1957 bill) specifically authorizes the Comission to provide trainin employees...g and other services to State offic41s and
"(10)
In an attachment to the letter, Luedecke further stated:
"The training and other services furnished to the States
... would be intended to assist the States to prepare for, and carry out, independent State radiation protection programs." (11) (emphasis added)
In a colloquy on the bill, Rep. Van Zandt, a JCAE member noted:
"In summary, Mr. Speaker, this bill will help the States assume independent regulatory jurisdiction in areas which are now regulated exclusively by the Federal Government under the provisions of the Atomic Energy Act.
It would assist the States to prepare themselves for assuming such responsibility by increased training and programs of assistance for the States. As pointed out in the Joint Committee report, this would increase the protection of the public health and safety 'because most citizens look to their local health officers for advice and protection againsthazardousmaterialsusedinthecommunity'."(12)
In that same colloquy, Rep. Price, also a JCAE member, emphasized that local and municipal government employees were to benefit from this AEC program as well as State employees. (13)
Additional reasons for the training authorization were set out in the House and Senate Reports which noted that "It is not intended that a cash grant shall be provided to pay for administration of State regulatory programs" and, the authorization "shall take into account the additional expenses that may be incurred by the State as a consequence of the State enteringintoanagreementwiththeCommission."(14) The reports noted that such training would also enhance the 6
I l
capacity of State and local health officers to deal with x-rays and radium, "thus, further protecting the public health and safety."(15)
The authorization for State training also received strong, wide support in testimony before the joint committee, e.g.,
William A. Adams, Chamber of Comerce of the United States,(16)
William H. Berman, Atomic Energy Research Project.
The University of Michigan Law School, (17) and Frank Norton, Executive Vice Chaiman, Regional Advisory Council on Nuclear Enargy sponsored by theSouthernGovernors' Conference (18)
Indirect support for State training came from organized labor which opposed creating a regulatory role for States and in well trained staffs. (19) gislation would create a need for doing so noted that the le At the time of the consideration of the 1959 bill, other Federal agencies provided training in radiation protection to Welfare (DHEW)y the U.S. Department of Health, Education and States, notabl DHEW established a Radiological Health Training Section at the U.S. Public Health Service's Sanitary Engineering Center in Cincinnati, Ohio.
In 1959, 18 courses were presented in radiological health, occupational radiation protection, detection and control of radioactive pollutants in air and water, sanitary engineering aspects of nuclear energy, environmental health aspects of nuclear reactor operation, radiological defense monitoring and radiation protection in x-rays. (20) Both the AEC in its analysis of the 1959 bill and the Senate and House Reports made clear that DHEW and other Federal training would not be replaced by AEC training but that AEC training would be correlated with other Federal training.
(21) At the time of the hearings, DHEW was providing matching Federal grants to State radiation control programs part of which was used by the States to offset the travel and per diem costs of State employees attending DHEW courses. (22) DHEW matching grants ended about 1970 and DHEW training in radiation protection was phased out in 1970. (22)
Present DHEW training is limited to specific programatic projects, e.g., training in the testing of diagnostic x-ray (machines for compliance with Federal performance standards. 22)
Thus, NRC training courses have since 1970 become the major training resource for State radiation control programs and it is this fact that underlies the comments on the importance of the NRC training effort that have subsequently been made in reports by the General Accounting Office, the National Governors' Association, and the NRC itself.
7
With respect to cost of NRC training of States, the following exchange occurred on the House floor on September 11, 1959:
"Mr. Price. Mr. Speaker.
I ask unanimous consent for the imediate consideration of the bill (5.2568) to amend the Atomic Energy Act, as amended, with respect to cooperation with States."
"The Speaker pro tempore.
Is there objection to the request of the gentleman from Illinois?"
"Mr. Gross. Mr. Speaker, reserving the right to object, will the gentleman explain this bill?"
"Mr. Price. This is a bill reported unanimously from the Joint Committee on Atomic Energy which would amend the Atomic Energy Act with regard to setting up procedures under which there would be greater participation at the State and local level.
"Lengthy hearings were held on this bill.
It has been supported by the principal State organizations, including the Council of State Governments, the Governors Conference, the National Association of Attorneys General, and the Southern Governors Conference.
"The bill represents months of effort to bring this program a little closer to the States and to have greater participation at the State level."
"Mr. Gross.
Does this provide for an increase in Federal spending?"
"Mr. Price.
No, it does not.."
"Mr. Gross. Nor an increase in personnel?"
"Mr. Price.
No."
"Mr. Grcss.
It does not open the door to more spending by the States or the setting up of a program that will eventually call for ;nore spending on the part of the Federal Government?"
"Mr, Price.
I do not see how it could open the door to any large-scale spending."
"Mr. Van Zandt. Mr. Speaker will the gentleman yield?"
"Mr. Gross.
I yield to the gentleman from Pennsylvania."
8
l l
l "Mr. Price.
Pennit me to say to the gentleman from Iowa, who mentioned additional personnel, that it could eventually involve some expenditure for training and inspection of personnel who would work with and for State and local governments as they set up their programs, but it would be a negligible amount."
"Mr. Gross. Mr. Speaker.
I withdraw my reservation of objection."
"Mr. Van Zandt. Mr. Speaker.
I should like to ask the gentleman, is it not true that as the atomic energy field is further explored and developed especially in the peacetime uses of the atom that the States and local communities must come into the effort?"
"Mr. Price. That is true."
"Mr. Van Zandt. All we are trying to do here is to authorize the AEC to prepare a set of regulations that will assist the several States and communities in administering their affairs in the peaceful use of the atom."
"There might be some o penses in training personnel and in administering such a program, but it would be minute, compared to the AEC budget as a whole." (23) 3.2 General Accounting Office In 1973, the General Accounting Office (GAO) reviewed the NRC Agreement State program. GA0 reported:
"Radiological health officials from both agreement and non-agreement States told us that AEC's training program had benefitted them considerably in preparing for or administering these Agreement materials programs." (24)
GA0 noted that AEC evaluations of Agreement State programs found on a number of occasions that State personnel "lacked the training and experience necessary to license and inspect the types of licenses for which they were responsible." (25) GA0 recommended:
"AEC should expand its presgreement training program to provide State personnel with on-the-job license experience" (26), and "AEC can improve its assistance and cooperation by...
expanding its training program for personnel of both agreement and non-agreement States." (27) 9
In 1976, GA0 reviewed NRC's materials regulatory program.
After recomending changes to improve NRC's license program, GA0 highlighted the importance of NRC helping the States incorporate NRC revisions to NRC licensing policies and procedures and "insure that the States' licensing policies and practices are compatible with the NRC's revised program." (28) 3.3 National Governors' Association In 1982, the National Governors' Association (NGA) conducted an independent review of the NRC Agreement State program.
Idaho Governor John V. Evans, Chairman of the NGA Subcomittee on Nuclear Power stated in the foreword to the report:
"[this report) was prepared by NGA staff with the assistance of many persons knowledgeable in the field of radiation protection, including the radiation control directors of all fifty states, the NGA's Subcomittee on Nuclear Power - augmented by four state radiation protection officials, and two advisory comittees composed of represertatives of constituencies subject to or affected by state or NRC regulation.
The conclusions of this report, thus, represent a broad consensus of the radiation protection community regarding such areas as funding, training, personnel and regulatory jurisdiction within the Agreement State Program." (29)
The States gave the NRC "uniform and unanimous high marks on the quality and value of the training program.
' Excellent,',
' invaluable' are the most comon adjectives.... much of the credit for the continuing high performance of State programs is attributed to the training received in the Nuclear Regulatory Comission courses. Access to such training is considered one of the chief benefits of Agreement State Program membership."
(30) NGA went on to observe that "states must receive adequate support though training and periodic program evaluation." (31)
NGA recomended:
l "Additional training courses for the Agreement States are needed to help States effectively manage new and changing regulatory programs. The NRC training program for Agreement States should receive additional funding to keep pace with those needs." (32) 3.4 Nuclear Reculatory Comission The NGA study was preceded by an internal NRC review of the Agreement State program in 1977. The NRC study was undertaken in recognition of the changes in interests and responsibilities of the States in nuclear matters since the enactment of Section 10
274.(33) The NRC task fnrce concluded the Agreement State program was a successful one. (34) With respect to State training, the task force took note of Congressional views on this matter as follows:
"In considering the legislation, Congress recognized that the Federal-State amendment would become a dead letter unless the States developed the capability to exercise their regulatory authority in a competent and effective manner. Accordingly, several specific provisions were included in the amendment for the express purpose of enabling the Atomic Energy Comission to assist the States to prepare themselves to exercise independent regulatory authority over agreement materials.
These provisions authorized the Connission:
to provide training and other services to State officials and employees..." (35)
ThetaskforcethenreviewedtheresultsofNRCreviewsdf Agreement State programs:
"There have been two areas of the individual Agreement State programs where NRC connents and recommendations have been most frequent over the years.
The first relates to maintaining and adequ'te staff, both in numbers and a
qualifications.
This appears to be attributable, at least partially, to ger.erally lower salary scales prevailing in State governments when compared with industry and the Federal government. As a result, a backlog in inspections and licensing actions develops when a vacancy occurs. To fill vacancies, the States frequently hire,iunior personnel with minimal formal training and experience in radioloaical health and regulatory control. NRC's training program for State personnel, therefore, becomes an important factor in maintaining State programs that are adequate to protect the public health and safety." (36)
The task force reconnended:
"AEC should expand its State personnel training and on-site assistance programs." (37)
In 1979, the House Subcommittee on Energy and the Environment of the Committee on Interior and Insular Affairs held a hearing on the NRC Agreement State program. The hearing was precipitated by several events involving Agreement State licenses that received wide attention. These included the release of large quantities of tritium and subsequent environmental contamination by a manufacturing plant in Arizona and several incidents involving improper shipments of radioactive waste to the concercial low-level radioactive waste 11
disposal sites licensed by Nevada, South Carolina and Washington. Commissioner Gilinsky testified on behalf of NRC cnd, in partial response to concerns over the effectiveness of Agreement State programs, stated:
"We will place particular emphasis upon developing improved criteria for cuality of State regulatory staffs..." (38)
NRC criteria for States seeking Section 274b Agreements are contained in a NRC Policy Statement. (39) After entering such Agreements States are periodically reviewed by NRC to ensure their programs are adequate and compatible. Guidelines for these reviews have been issued by the Comission in a separate Policy Statement. (40) Both NRC Policy Statements address the matter of qualification for training of State personnel and training.
The guidelines for training of State staff in the latter Policy Statement are clear and specific:
"Senior personnel should have attended NRC core courses in licensing orientation, inspection procedures, medical practices and industrial radiography practices...
The RCP (radiation control program) should have a program to utilize specific short courses and workshops to maintain appropriate level of technical competence in areas of changing technology." (41)
The value of training for materials regulatory staffs was comented upon by the Materials Safety Regulation Review Study Group. (42) This group was formed by NRC in 1986 to review NRC's fuel cycle and materials regulatory program for health and safety and environmental protection and to offer recomendations to improve the program. Among other recomendations, the Study Group recomended "NRC increase significantly the amount of training provided to its fuel cycle and material licensing and inspection staff as well as its manigement staff." (43) While this recomendation was directed at NRC, the Study Group's explanatory discussion included a coment which underscores the importance of staff training to all radiation protection regulatory agencies:
"The greatest resource that NRC has is its people.
To the extent that its employees are well-trained, motivated, and feel that they are developing professionally, the NRC will be able to do a better job. This attitude and this approach to training is the backbone of every maior successful corporation in this country. They should be of no less importance of NRC.
If NRC wishes to retain and attract competent individuals to carry out the government's important work in this area, then it is extremely important that an adequate and comprehensive training program be instituted throughout the agency." (44) 12 i
3.5 National Council on Radiation Protection and Measurements (NCRP)
The foregoing described the legislative origins of the NRC training program for States and subsequent assessments ty GA.0, NGA and NRC which found a continuing need for it. As a final historical perspective it is worth noting the concerns expressed 30 years ago by the National Committee on Radiation Protection, the predecessor of the National Council on Radiation Protection and Measurements.
In the preface to its 1955 report, "Regulation of Radiation Exposure by Legislative Measures," NCRP said:
"Until about 1950 it was the accepted policy of the National Comittee on Radiation Protection that it I
discourage the incorporation of its recomendations into legislative or other similar control acts.
It was felt that better results could be obtained through education and voluntary compliance.
In most respects the committee still feels this way, but also it recognizes that conditions are changing rapidly and that State control may become a necessity with the accelerating growth of radiation uses.
"The National Committee on Radiation Protection has now adopted the policy that it will not recomend or oppose the incorporation of its findings into State code." (45)
NCRP then went on to observe:
l "The shortage of trained personnel will be a problem for many years.
This, if nothing else, should militate against starting an over-ambitious regulation program in which even the minimum requirements cannot be enforced.
Unskillful inspectors can be dangerous through neglect, or very costly to the user through overzealousness.
In many areas, an inadequately trained person will quickly be detected and his presence will breed contempt for the regulations and the whole program." (40) 3.6 Historical Sumary On December 20, 1987, Charles M. Hardin, Executive Secretary, Conference of Radiation Control Program Directors, Inc.
conducted a briefing in Washington, DC for Comissioners' assistants on the Conference's activities and discussed with them items of mutual interest. This discussion included NRC training for States and Mr. Hardin offered the following view:
13
"I would like to give a ' gold star' to NRC for their training services provided to State radiation control programs. These training programs have, in many cases, been the only formal training available to State radiation control programs.
In many, if not all States, their budgetary problems have not allowed for adequate professional training, and the NRC sponsored courses have been ' life saving.'
These courses are well organized, timely, and professionally presented.
They have been vital in keeping a well trained staff at the State level.
Public health and safety at the State level may have been seriously impacted had these training courses not been available." (47) 4.
STATE PERSPECTIVES 4.1 The Need for Training and Funding State Travel and Per Diem Costs State views on the need for training of their staffs and more specifically, the need for NRC training have been reported by NGA and described above. (48) Additional expressions of support for such training have periodically been offered by the Agreement States in their annual meetings with NRC, as the most recent example:
"The Agreement States are ccncerned that training funds may be reduced. We believe that monies saved by the Commission due to Agreement State activities should be used at least partially to provide upgraded training to the Agreement States. The Agreement States thank the NRC for the training already provided." (49)
Historically, NRC has paid travel and per diem expenses for State (and local) personnel attending NRC training activities as well as any contract costs.
This practice recognizes the fact that NRC does not provide cash grants to Agreerrent States to run their programs. As Kentucky Bureau for Health Services Commissioner Rot'ert Slaton put quite succinctly at the 1979 Oversight Hearing:
"We do it [the Agreement program] at our own cost, we do not get Federal funding, we get some trainino assistance and some assistance on our one [ waste burial) site..."
(50)
Attendance at NRC training activities involves out-of-state travel for State personnel (except, of course, State employees in the State where the NRC training activity is held).
To gain some perspective on State views of NRC funding and travel and per diem costs, SLITP staff contacted selected Agreement State radiation control program managers in March, 1988. (51) Since 14
time did not permit a full-scale survey of the States, eight Agreement States, Arizona, Florida, Iowa, Louisiana, Maryland, Texas, Washington and Utah were selected to provide a cross-section of the 29 Agreement States.
Each NRC region was represented.
Experienced and new Agreement States, large and small State programs, uranium mill and low-level radioactive waste disposal sited States were represented.
Current State requirements for obtaining out-of-state travel authorization were reviewed, compared with past experiences and possible future changes; underlying reasons for the requirements were reviewed; and what, if any, effect changing NRC funding of travel and per diem might have on the State RCP was explored.
All of the States reported that NRC funding of travel and per diem expenses is a factor in obtaining State approval to travel out-of-state and two States reported such approval would not be obtainable if NRC were not to fund.
The others reported there would be limitations on the courses attended or numbers of people approved to attend if NRC funding of travel expenses was reduced or eliminated.
In no State is authority to approve out-of-state travel delegated to the State RCP director.
In six States, out-of-state travel for training must be approved by the Department management, usually the Secretary.
Two States require approval of the Governor's office.
In three States, restrictions on I
out-of-state travel have been imposed by Executive Order, in another by State statute.
In the other four States, Departmental policy establishes approval procedures.
In the event NRC were to ask the States to assume these costs, seven States foresaw serious consecuences. Two States felt approval for out-of-state travel would be impossible to obtain.
)
l l
Six others stated there would be severe limitations on the l
numbers of staff who would be approved for out-of-state training. Three States said attendance at the 5-week course in basic health physics would not be approved because of the high l
travel and per diem expenses for this lengthy course. One j
State reported that its personnel could eventually continue to i
attend NRC training if there was adeauate lead time to increase l
user fees to cover the additional costs, but other States which l
charged user fees felt increases in fees to cover this cost i
were not feasible because NRC fees are lower than State fees.
l (This problem is discussed more fully in the following secticn.)
If full NRC funding of State training travel and per diem expenses were not available, five of the States expressed views that their RCP's would be adversely affected because State personnel would not receive approval to attend out-of-state training which is needed to maintain their technical competency. The rate of staff turnover would determine how 15
soon staff technical competency would become a problem.
Some characterizations of the effect of such a change in funding that were volunteered were:
"devastating,"
"very serious,"
"expertise will decrease," and "new procedures and regulatory guidance will not get incorporated into the program."
If NRC were to cease full funding of State training travel and per diem costs, w uld this cause consideration of turning the Agreement back to NRC? Responses ranged from two States which said this would not occur to other States' views that it could lead to consideration of such an alternative, e.g., if necessary to protect public health and safety.
Cutbacks in Federal support of State regulacory programs which l
support Federal safety regulatory activities carry with them the risk of State cJtbacks of their programs. As a recent l
example of this, in 1987, the General Accounting Office (GA0) was asked to %stigate the effect of eliminating Federal l
support funds on the number of State railroad safety inspectors. (52) GA0 polled 48 State rail safety administrators and reported that most saw a likelihood of a reduction of State railroad safety inspection activities if reductions in Federal funding occurred.
Three States said it would result in ehmination of their railroad safety inspection activities. (53)
In our limited survey of eight States, we found that if cessation of full NRC funding of State training travel costs were to occt;r, this action would not imediately cause turn-backs but six States reported if there became a need to consider a turn-back of the Agreement, NRC funding of training travel and per diem expenses could become a factor in the decision making. We also received a coment that in States which have actively sought to turn back programs to the Federal government as a ccit-savings measure, such NRC action would make the Agreement program a candidate for State legislative review for turn-bar.k.
In the course of our survey one State RCP director remarked that in his Department the NRC Agreement State program is always cited to other Federal Agencies as the best model for Federal-State relations and he questioned the wisdom of a change that would diminish this perception and create a risk of Agreement State program turn-backs.
As shown by this survey, State restrictions on out-of-state travel expenditures for its employees are separate from State RCP budgets for Agreement State regulatory programs which include in-state travel for State inspections. Funding for the latter is monitored by NRC regional staff during their reviews 16
of Agreement State programs to assure NRC guidelines for budget are met:
"Operating funds should be sufficient to support program needs such as staff travel necessary to the conduct of an effective compliance program, including routine pre-licensing visits)p or special inspections (including inspections, follow-u
, and responses to incidents and other emergencies, instrumentation and other equipment to support the RCP, administrative costs in operating the program including rental charges, printing costs, laboratory services, computer and/or word processing support, preparation of correspondence office equipment, hearing costs, etc. as appropriate." (54) 4.2. User F_ees NRC has also established guidelines for funding Agreement State programs:
"Principal operating funds should be from sourcis which provide continuity and reliability, i.e., general tax, license fees, etc. Supplemental funds may be obtained through contracts, cash grants, etc." (55)
Agreement State materials budgets range from less than $100,000 to $2,000,000.
In the aggregate the 29 Agreement State programs for materials regulation require funding of about
$9,000,000 per year.
Twenty-four of the 29 Agreement States charge user fees [ Table 1). Several State user fees are tied to the NRC fee schedule. As examples Iowa's fees by law cannot exceed NRC's and Alabama's fees are set at 75% of NRC's. Cost recovery percentages range up to 100%.
Some Agreement States who fund their programs through fees are encountering resistance to raising their fees because of unfavorable comparisons with NRC materials fees. (56) NGA reported that one State considered leaving the Agreement program when it encountered intense industry pressure "because its fee structure exceeded that of the Nuclear Regulatory ConTnission." (57) NGA went on to say:
"The size of user fees currently imposed by states was not considered onerous by most users.
Some noted that fees varied among states, but not sufficiently to cause industries to locate or relocate facilities because of the cost differences.
The differences between state user fees and those established by the Nuclear Regulatory Connission in non-Agreement State Program states was mentioned as an irritant.
Outdated NRC fees cause two problems.
Either users complain that the state fee is too high, or they resist state efforts to raise user fees above the NRC 17
TABLE 1 AGREEMENT STATE MATERIALS FEES A.
States With Fees 1.
Alabama Fees are set at 75% of NRC's.
2.
Arizona Recovers 78% of materials budget.
3.
California Recovers about 58% of materials budget.
4.
Colorado Very close to NRC, also charge GL's fees.
5.
Florida Recovers 88% of materials budget.
6.
Illinois Very close to NRC, recovers 26% of program costs.
7.
Iowa Recovers about 80% of program costs, statute limits fees to no more than NRC's, 8.
Kentucky Recovers about 10% of radiocctive materials budget.
9.
Louisiana Recovers about 60% of radioactive materials budget.
10.
Ma ryland Limited to hazardous materials f acilities which involve radioactive materials.
Fee is split with another Departmental program.
- 11. Mississippi Recovers about 63% of program cost.
12.
Nevada Recovers about 57% of program cost.
- 13. New Hampshire Less than NRC, structured differently.
Statute requires 100% recovery of costs.
14.
New Mexico Fees authorized.
15.
New York City Structured differently from NRC.
',uthorized to collect fees.
- 16. North Carolina Recovers about 35% of program cost.
17.
North Dakota Recovers about 14% of program cost.
- 18. Oregon Recovers about 81% of program cost.
19.
Rhode Island Similar to NRC, recovers 31% of program costs.
20.
South Carolina 78% recovery.
21.
Tennessee 100% recovery.
22.
Texas 50% recovery.
23.
Utah Recovers about 23% of RAM budget.
24 Washington 100% cost recovery through fees B.
States Without Fees 1.
Arkansas 2.
Georgia 3.
Idaho 4
Kansas 5.
Nebraska Note:
Data is representative for the years 1983-1986.
Some State fee systens have since changed.
18
i level. The Nuclear Regulatory Commission has provided briefings to both the National Governors' Association and the Agreement State Program directors on proposed changes in the Nuclear Regulatory Commission's fee structure. The adoption of a revised schedule should minimize some of the gaps between fees charged or proposed by states and by the Nuclear Regulatory Comission. States have expressed dissatisfaction with the outdated NRC fees currently in place."(58)
NRC last revised its materials fees in 1984. (59)
In 1986, the Consolidated Omnibus Budget Reconciliation Act of 1985 was signedintolaw.(60) A target of 33% recovery of costs through fees was set for NRC.
In response, NRC decided -)
increase fee charges for nuclear power reactors. (E1) the initial NRC staff response, however, was to include abolishment of materials fees, a potential disaster for those Agreement States whose fees are tied to NRC's fees (Table 1). This nas withdrawn after objections from NRC State Agreements Program staff. Materials fees were left unchanged.
As a result, the disparitics between NRC and Agreement State fees remain. This continues the problem for Agreement States which charge fees, particularly for those attempting full cost recovery.
Adjusting NRC's fees to mitigate the unfavorable comparison with State user fees will not necessarily make State funding of out-of-state tray?1 easier.
In many States, user fees go to the State treasury and not directly to the RCP. As noted above, authority for expenditures for out-of-state travel is often outside the RCP and its agency and is obtainable only in cases where outside funding is available.
4.3. Staff Turnover In 1959, the AEC reported that turnover of contractor and AEC personnel engaged in radiation protection and biological research was about 14.6% per year. (62)
In a study conducted j
by the Conference of Radiation Control Program Directors, Inc.,
l it was found that State RCP technical staff turnover was 8.2%
in FY 84 and 7.9% in FY 85 for radiation protection program staff.(63)
Individual State turnover rates ranged up to 75%.
I I
NRC turnover for scientific staff was about 11% in FY 87 and about 6% for engineering staff. Despite the improvement in l
retention of technical personnel by NRC and the comparability of Agreement State experience, NRC staff is aware of Agreement State concerns about hiring and retaining trained personnel:
"But on the training question I think in talkins to the non-Agreement State people, the perspective of Agrament States, one of the greatest apprehensions the prog om directors have is being able to maintain an adeouate staff once they enter into the agreement, because competition is l
19
very severe for qualified health physicists, and they are not able to hire people with health physics in their academic background, so they must hire people with the proper science, like biologists or chemists, and then put them through some kind of a training prog:am so they can dothejob."(64)
The matter of retaining qualified personnel was a major concern reported by States to NGA with salary differences between States and private industry, academia and the Federal government cited as the cause. (65)
NRC guidelines for reviewing Agreement State programs include one for salaries:
"Salary levels should be adequate to recruit and retain persons of appropriate qualifications.
Salaries should be comparable to similar employment in the geographical area."
(66)
When necessary, for example when sustained high turnover rates occur in a State, NRC has offered recommendations to States to seek improvements to their salary schedules for radiation protection personnel. Nonetheless, as NGA has observed:
"There are national shortages of the radiation protection specialists needed for State programs. This results in the escalation of salaries in excess of what States can pay... There are, however, impediments to States offering competitive salaries... With funding shortages affecting all State agencies both the executive and legislative branches are likely to resist making an exception for the radiation control program in the absence (sic) of a highly publicized crisis." (67)
One impact of State turnover is to create a continuous need for NRC training.
The 29 Agreement States employ approximately 200 FTE technical staff in materials. (68) The 8% State average turnover rate is comparable to NRC's and is equivalent to 16 persons. As noted earlier, typical State hiring is of persons with engineering or science backgrounds who will need training in radiation protection and regulatory practices.
They will need to attend a health physics course, the four NRC "core" courses in regulatory practices and three other recomended NRC specialized regulatory courses (wel! logging, radiological engineering and transportation).
This translates into an annual training load of up to 16x8 or 128 student slots.
This is 687 of the 187 course slots that were available in FY 87 (Table 2).
Competing with this training need are the needs to train staffs of States seeking Agreement State status and non-Agreement State staff, training of existing Agreement State staffs in new regulatory programs and procedures and training of NRC staff and U.S. Navy and Air Force personnel who also attend these Courses.
1 20
F Table 2 1
GPA/SLITP Stata Training Data FY 1975-1987 Training No. of No. of No.of A/S No. Students Per 2
FY Budget Courses Students A/S's Licenses 100 Licenses 3
7 131 25 10,500 1.2 75 3
6 134 25 10,700 1.3 76 3
3 213 25 11,000 1.9 77 3
78 8
117 25 11,500 1.0 3
4 4
8 138 25 11,800 1.2 79 3
11 185 26 12,000 1.5 80 81 345,000 12 195 26 12,500 1.6 82 540,000 21 286 26 13,000 2.2 83 390,000 16 226 26 13,200 1.7 84 530,000 17 257 27 13,100 2.0 85 600,000 18 304 27 13,800 2.2 5
86 471,000 12 244 28 14,000 1.6 87 522,000 10 187 29 15,700 1.2 88 520,000 10 NOTES:
1/ Information sources:
AEC/NRC Annual Reports, 1975-1986 and SLITP Budget Data 2/ A/S= Agreement State 3/ No data available 4/ One course was cancelled due to TMI 5/ Represents a 22% reduction 21 a
4.4 State In-House Training Agreement States do not depend exclusively on NRC for trainir.o of staff. As the NGA study showed, States provide on-the-job and other training for their staffs. (69) NGA examined four Agreement State programs in detail, including the training of staff in those States.
Those States were Florida, Texas, New York and Washington.
Training courses provided by the Environmental Protection Agency (EPA), Food and Drug Adntinistratior. (FDA) and the Federal Emergency Management Agency (FEMA) are used by State RCP's when possible and as appropriate to specific program needs.
However, other Federal Agancy training has limited applicability to State Agreement programs:
FEMA provides training in radiological emergency response, EPA's training is mostly related to radon problems and FDA's training is limited j
to programs to determine compliance with diagnostic x-ray equipment perfortnance standards and monitoring patient exposure to diagnostic x-rays.
FDA does not pay State travel and per diem costs but FEMA does pay for State travel and lodging costs and EPA's courses are conducted by contractors who pay the travel and per diem costs of State attendees. (70, 71)
Florida provides orientation training in administrative practices and a one-week course in radiation control. Special training by consultants and universities are used to fill gaps in staff expertise.
Persons ccmpleting courses are expected to trainothers.(72)
At the time of the NGA study, Texas had undergone a rapid staff expansion. The Texas RCP contracted with the University of Texas to give c four-week graduate level course in radiological health to new staff.
In-house short courses are used on a routine basis. (73)
The New York RCP agencies provide in-house training and i
radiological emergency training is provided by the New York Office of Disaster Preparedness. (74) j The Washington RCP staff "makes extensive use of administrative personnel and management training operations" offered by the State. (75)
More recently, Illinois arranged for outside consultants to prepare Illinois Department of Nuclear Safety staff for carrying out the Agreement (which became effective June 1, 1987) particularly in specialized areas such as low-level radioactive waste disposal. (76) 22
State in-house training efforts are neither substitutes nor duplications of NRC training.
They are mutually complementary.
Taken as an integrated whole, the training helps assure that State staffs are suitably qualified to carry out Agreement programs in accord with the Comission Policy Statement for adequacy to protect public health and safety.
a.5 Sumary of State perspectives The States view NRC training as essential to their ability to maintain programs which are adequate to protect public health and safety. NRC funding of traval and per diem costs for State personnel approved to attend NRC training is a critical element in many States to obtaining approval to travel out-of-state to NRC training. Any change that would reduce or eliminate such NRC funding will, in sorte States' view, lead to a significant reduction of State staff attending NRC training, and this will eventually impact upon the States' abilities to adequately protect public health and safety.
Increasing State user fees to enable State funding of these costs is not always a feasible alternative.
User fees do not normally 90 to State RCP's budget but go to State treasuries.
State RCP funds are then appropriated but control and approval of expenditure of funds to pay out-of-state travel necessary to attend NRC training is outside the RCP and sometimes outside the State Agency.
Even when increased fees could be used to fund these costs, NRC's comparably lower materials fees create a ceiling on what Aoreement States can realistically propose.
State turnover, while not significantly different from NRC's, creates a continuing need fer NRC training for replacements.
State in-house training is extensively used but is not a substitute for NRC training.
5.
NRC TRAINING FOR STATES 5.1 Past and Present NPC Trainina For FY 69-73, the AEC cnnually budgeted monies ranging from
$72,400 to $105,400 for State training. (77)
In FY 82 NRC State training budget was $5d0,000 and peaked in FY 85 at
$600,000 (Table 2).
In FY 87, $522,000 was budgeted. An increase in the budget for State training to keep pace only with inflation would dictate a budget for FY 87 of $693,000, yet the need for training continues to increase.
Table 3 lists formal training courses only.
The anual All Agreement States meeting, a 21 day meeting of senior State staff with NPC is also a training activity.
Certified Health Physicists attending the meeting receive Continuing (Education Credits from the American Board of Health Physics.
78)
Invitational travel orders are also issued by NRC to 23 V
appropriate State personnel to attend wotkshops, special meet W s addressing s peific regulatory issues and to visit NRC headq;arters or regional offices for one-on-ona training in licensing aN! inspection proceduras. Some examples:
Workshop on large Irradiator Radiation Safety, September 4-6, 1985, New Brunswick, NJ (79)
Iowa RLP staff to NRC Region III Office, I week,1985, for training in NRC licensing practices.
NRC Region I sponsored a broad license workshop in 1985 and plans a large Irradiator Radiation Safety workshop in April, 1988. While these meetingy are open to the public and Agreerant State attendance wculd be beneficial, funds are net sufficient to offer to pay travel and per diem costs.
A list of typical fonnal courses given each year is described in Table 3.
Most of the courses integrate "hands-on" lab and field exercises, casework review and conventional classroom instructional techniques. Tests and homework assignments are also nomally required. Some courses utilize contractors to serve as instructors. NRC and State experts are used extensively to present the material. The cottses are ;.rovided without charge to the States.
(One course, well-logging, is presented without chtrge by the well-loggirig industry.
This is s unique arrangement which exists at the request of the industry, The course has been well received and NRC stsff has been appreciative of tnis contribution by the regulated industry. NRC staff is, however, conscious of the potential for conflict of interest when industry trains regulators and eachcoursepresentat?onisaccordinglymunitoredbyNRCstaff.)
T5e State governments pay the salaries of their employees who attend, and SLITP pays the travel and per diem of attendees.
The training has been r ovided to both Agreement and non-Agreement States. Because of the continuing budget constraints, priority is now givsn to applicants from Agreement States and those non-Agreemert States actively seeking Agreement State status.
The training program had increased in both numbers of courses and studeni.s from FY 75 to FY 85.
Eighteen courses were presented to 304 students in FY 85.
In FY 87 the numbers of courses and students has decreased to 10 courses and 187 students (lable 3).
24
State training needs are a direct function of the number of Agreement State program inspe tions, license reviews, and staffing level. This, in turn, is a direct function of the number of Agreement State licenses.
Since FY 75, the number of Agreement State licenses has increased 45% (Figure 1). One way to measure how effectively we are meeting State training i
needs is to consider the number of State students receiving training in proportion to the number of Agreement State licenses. This allows a measurement of the training effort dgainst need, which is independent of the numbers of Agreement States and Agreement State licenses.
This figure (per 100 Agreement State licenses) grew steadily from 1.2 in FY 75 to yeaks of 2.2 in FY 82 and FY 85, but dropped 45% to 1.2 in FY 87, the same value as in FY 75.
The value of 2.2 State students per 100 Agreement State licenses has no significance of and by itself.
It does, however, reflect the level of training extended in FY 82 and FY 85 which were fiscal years that, in the considered judgment of SLITP staff, the NRC training effort for States was commensurate with State needt. As discussed earlier, State turnover creates an annual need of 128 student slots to which must be added slots to m ommodate training of staffs from States seeking Agreements; non-Agreement State staffs, and slots for training to upde.te existing Agreement State staffs in new procedures and materials use technology. The current NRC budget limits the State training level tc 1.2 students per 100 Agreement State licenses. To meet this reduced budget five formal courses have been deleted and cutbacks made in two others (Table 3).
Presently, for every 10 persons accepted for NRC courses, another six cannot be accepted because of a lack of space and money.
In some courses, the number of slots available to the States has been reduced to acconnodate urgent needs of NRC, U.S. Navy (USN), and U.S. Air Force (USAF) personnel, although USN and USAF do pay the per diem and travel costs for their personnel attending NRC courses. The continued growth of licenses regulated by the Agreement States creates an increase in the need for NRC training. Training to maintain technical competence as materials use technology and regulatory practices change is needed.
Inflation has had the effect of reducing the training fiscal resources.
For these reasons in 1986 SLITP requested additional funds for State training (Appendix A).
25
Table 3 TYPICALGPA/SLITPFORMALTRAIyINGCOURSES FOR STATE PERSOLSEL Subject No. Students Frequency Cutbacks Inspection Procedures 25 2/ year 2/, 4/, 5/
Licensing Orientation 20-25 1/ year Health Physics 20 2/ year Well Logging 20 1/ year Radiological Engineering 20 1/ year Transportation 20 1/ year Deleted Special Topics 20 1/ year Industrial Radiography 16 2/ year Reduced to 1/ Year 3/4/
Medical 20 2/ year Reduced to 1/ year Radiochemistry 20 1/ year Deleted Teletherapy Calibration 12 2/ year Deleted Management 20 1/ year Deleted Harvard Biological Effects 5
1/ year Deleted of Radiation i
C 19/ year 10/ year = 145 slots 1,/
Excluding Mill Tailings and LLW.
~/
Some reduction in slots available to States have occurred to 2
accomodate Navy, Air Force, and Army "soper-broad" license representatives.
These have ranged from two to four slots.
In addition, in FY 1987 five NRC inspectors attended the course, leaving for FY 1987 only 18 slots for State students.
3/
The Navy has requested slots for the FY 1988 Medical course.
~/
There is no compensation for slots provided to the Armed Forces or 4
NRC staff.
5/
The second presentation of this course has been usually at a State site to train personnel from the host State and nearby States, thus conserving travel funds.
26
5.2 Future NRC Training NRC training for States has two aspects: first, basic training in the fundamentals of roliation protection and secondly, procedural instruction in licensing, inspection and other radiation protection regulatory activities.
As described earlier, Agreement Sta;es hiring is typically limited, because of salary considerations, to persons having engineering or science backgrounds but no training or experience in radiation protection. Hence, there is and will be a continuing need for the first aspect of training, i.e., in the fundamentals of radiation protection.
NRC provides such training in a 5-week health physics course presented twice a year by Oak Ridge Associated Universities (0RAU). A total of 40 students per year ceceive this training.
The se:ond aepect of NRC training for States is accomplished by the remainder of NRC's training program for States.
This includes the other fonnal training courses (Table 3), special workshops and meetings, the annual All Agreement State meeting, and when appropriate one-on-one training which may be given at NRC headquarters and regional offices or in the States. As pointed out earlier State staff turnover and the consequential need to train replacement together with the need to train staff of States seeking Agreements, results in a continuing need for formal NRC courses in licensing, inspection and regulatory practices for materials users.
State staffs also will need training to maintain up-to-date knowledge in fields of changing technology and instructions to implement new regulatory initiatives. Attendance by Agreement State staffs at workshops and special meetings is critically important to meet these objectives. Training for this purpose has been recommended by GA0 and NGA and is a guideline for Agreement States in NRC's Policy Statement. A specific example of such need in the near future will be to provide training to States in implementation of the proposed revision to 10 CFR 20, "SiandardsforRadiationProtection."(80)
In addition, improvements and new initiatives in the NRC materials program translate into increased need for training of Agreement State staff as well as NRC staff.
Examples include tredical misadministration and follow-up, qu6lity assurance for medical therapy and fire protection and chemical safety.
The nnual All Agreement State meeting represents a forum in which State RCP senior staff and managers discuss with their NRC counterparts items of mutual regulatory concern in radioactive materials radiation safety. These discussions have significantly helped to focus NRC and State regulatory program planning. As the number of Agreement States grow anc as the technological and managerial challe gas increase, the annual meeting will become increasingly importa t.
27
One-on-one training is needed when other NRC trainiin alternatives either do not fill the specific State need or there is a critical time element for such training.
Occasional needs for this type of training will continue to occur.
The NGA identified a regulatory area that will ceate a need for new NRC training courses:
"The increased responsibilities for low level waste disposal, delegated to states by the Low Level Radioactive Waste Policy Act, occasioned the most frequent suggestions for new courses.
State staff, disposal site operators and utilities alike recommended courses on inspection of vehicles arid packages used for low level waste transport and on emergency respanse to transportation accidents. A course on the Nuclear Regulatory Commission's low level waste licensing procedures was advocated by several members."(81)
In response SLITP funded one-time presentations of geology /
hydrogeology courses and produced - ' videotape for RCP directors which provided an introduction to geology terminology. A course for persons who would be responsible for managing the review of an application for a low level radioactive waste disposal license was dweloped and presented in FY 87. A course in waste manifest and other transportation aspects was developed and has been presented, but the FY 88 budget for State tr:.ining is not now sufficient to fund the course again.
5.3 NRC Strategic Plan The NRC Strategic Plan establishes a specific goal for NRC to:
"Ensure that the regulatory programs of the NRC and Agreement Statec are designed and implemented to achieve compatibility to protect the public health and sVety."
(82)
To achieve this goal, NRC will, among other things:
"Initiate a program to active'v encourage States to join the Agraement State program." l83)
Training for States is an essential part of an NRC effort to meet the specific NRC goal of compatibility of Agreement State programs.
Increased training needs will occur and must be met if an NRC program to encourage more Agreement States is to
- succeed, i
28 l
l
5.4 Summary of NRC Training for States In summary, NRC training for States is a key factor in. assuring continued adequacy and compatibility of Agreement State radiation control programs.
New regulatory issues, e.g. LLW disposal, the revision to Part 20, and nuclear medicine improvements will increase training needs. Additional Agreement States will expand the training needs.
6.
THE IMPACT UPON NRC 0F THE AGREEMENT STATE PROGRAM l
6.1 The Scope of the Agreement State Program The growth of radioactive materials usage has been remarkable.
I., 1959, there were 4,700 byproduct materials licenses, 1,550 source materials licenses, and 180 special nuclear material licenses possessing less than formula quantities, a total of 6,230. (84) Today, the 29 Agreement States (Figure 2) alone regulate more than twice that, about 15,700 specific materials licenses (Figure 1). This represents over 65% of the total of 23,800 specific materials licenses in the United States.
The increase of all U.S. materials licenses has somewhat paralleled the increase in the number of Agreement State licenses (Flgure 1).
In other words, despite the national increase of materials licenses since 1961 when the first Agreement became effective, the number of NRC licenses has remained relatively constant.
6.? The Agreement State Program and the HRC Budget Had Section 274 not been enacted, NRC would be responsible for licensing and inspecting 15,700 specific materials licenses in addition to the current 8,100 workload. NRC staff have estimated that a net additional 135 technical FTE would be required to handle this add'.tional workload. (85)
For NRC, this translates into over $14,000,000 in annual salary and fringe benefit costs. (86) Offsetting this is the comparably small amount spent by NRC for State training, which in FY 87 was $522,000, 47% of which was for travel and per diem costs of State personnel.
In other words, the NRC Agreement State Program saves the NRC over $13,000,000 annually.
This savings to the NRC was recognized by the NRC Materials Safety Regulation Review Study Group in its 1986 report when it discussed the advantages of attracting more Agreement States:
"The principle (sic) benefit accruing to the NRC in attracting more States to the Program is to reduce the number of employees necessary to continue the regulatory responsibilities that would be transferred to the States.
This, in turn, would either reduce the total resources needed by NRC to conduct its programatic activities or 29
AGREEMENT STATE PROGRAM (As of August 1987) m
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make available additional staff and funds to concentrate in those regulatory areas which are considered by the NRC to be of greater importance to the agency's primary mission of protecting the public health and safety." (87) 6.3 Other Contributions of the States The States are a reservoir of radiation protection expertise which NRC often taps. During the contaminated Mexican steel incident, all 50 States agreed te NRC's request to assist NRC in surveying, locating, and controlling cobalt-60 contaminated rebar and iron table legs. (88) They contributed a total of 7.9 technical FTE and incurred $223,J00 in out-of-pocket expenses for this response. (89) This represented a significant diversion of critical, limited State resources from other scheduled RCP activities.
Two States requested NRC reimbursement but Federal statutes do not authorize monetary payments to States for these cooperative State efforts. (90)
Currently, the 29 Agreement States are actively involved in assisting NRC in the recall of 48,000 Po-210 static eliminators distributed by 3M Corporation. (91) The Agreement States performed a large number of surveys of users of these devices and their survey results were a significant contribution to the NRC evaluation which led to the recall decision. The Agreement States, to date, have expended 8,220 hours0.00255 days <br />0.0611 hours <br />3.637566e-4 weeks <br />8.371e-5 months <br /> on this effort. (92)
NRC has hired 30 people who have come from State radiation control programs (Table 4). Of these, 23 have come from Agreement States.
This list includes a Deputy Regional Admini:,trator and three branch and section chiefs as well as senior staff members.
6.4 Summary'- The Importance to NRC of the Agreement States NRC could not confidently seek and obtain State assistance to respond to radioactive materials events urless State personnel were qualified. Equally apparent is the fact the NRC hires only the best available qualified staff and has hired 30 State RCP personnel. NRC reaps significant benefits directly and indirectly from its State training program.
7.
SLITP INITIATIVES TO IMPROVE TRAINING COST-EFFECTIVENESS 7.1 Should States Share Travel and Per Diem Costs of Training?
At the briefing of the Comission on the status of SLITP, Chairman Zech, in speakir.g of NRC State training, counseled the staff to "be as innovative and as imaginative as we could" to find ways to make the training more cost-effective, (93) 32
Table 4 Former State Radiation Control Program Employees Employed by NRC Name NRC Office State 1.
C. G. Amato RII NJ, AZ 2.
J. B. Baird RIV C0 3.
H. J. Bicehouse RI PA 4.
R. F. Brich URF0 SD 5.
R. Brown RIV WA(leftNRC)
GA (DNR) (left NRC) 6.
W. E. Cline RII Br. Chief GA DHR) 7.
P. M. Chambless RII 8.
C. Connell RII GA DHR) 9.
J. W. Cooper RIII Il returned to Ill.)
10.
J. S. Davis RI PA 11.
M. Elliott RII NC 12.
G. M. France RIII OK 13.
A. Gooden RII GA(DNR) 14.
J. Hufham RII AL (left NRC) 15.
P. H. Lohaus GPA, RI, NY NMSS, Br. Chief 16.
J. O. Lubenau RI, GPA PA 17.
D. N. Mackenzie NMSS, GPA NC 18.
G. M. McCann RIII IL 19.
J. L. Montgomery RIV, RV Br. Chief CO 20.
B. Murray RIV KS 21.
C. J. Paperiello RI, RIII Dep. R.A.
NY 22.
J. P. Patterson RIII IL 23.
J. M. Pelchat RI NV 24.
K. Pendergrast RV WA 25.
L. T. Ricketson RIV TX 26.
M. E. Wangler NRR NY (left NRC) 27.
B. H. Weiss AEOD KS 28.
J. E. Whitten RIV OK 29.
D. G. Wiedeman RIII CA 30.
R. L. Woodruff RII AL 33
l 1
The FY 87 NRC budget allotted $522,000 for State training (Table 3).
In 1987 and again in 1988, SLITP suggested increased funding to restore courses which have been cancelled because of inflationary pressures and outright reduction of budgets for State training (Appendix A).
(94)
In response, Comissioner Bernthal remarked at the February 3, 1988 briefing:
"For reasons that have become far more obvious since then, I guess, the Commission was not prepared at that time, and probably less prepared today, to provide additional funding."
(95)
Chairman Zech and Comissioners Carr and Bernthal suggested shifting the travel and per diem costs to the States as a cost-savings measure. (96)
We believe there are compelling reasons to continue to pay these costs:
o Legislative history - It is clear that Congress recognized that there would be increased costs to States who elect to enter Section 274b Agreements and Congress intended Comission sponsored training to be, among other things, an offset to these costs.
Consistent with this, the Comission's practice has been to fund State travel and per diem.
o The uncertainty of whether the States will be able to fund travel and per diem - There is no assurance that all States will be able to assume this funding. As we have seen, most training requires out-of-state travel authorization for State attendees, and such authorizations are often difficult to obtain even under the best of conditions, i.e. when NRC pays travel and per diem.
Indeed, in many cases it is NRC's funding of these costs that enables obtaining the necessary approval.
All State staffs must have access to training that is essential to maintaining staff competence necessary to operate programs that are adequate to protect public health and safety.
7.2 _ Utilization of Minimal Cost Federal and Comercial Trainino Facilitig We have sought to be innovative and imaginative in finding ways to make NRC State training more cost-effective.
SLITP's principal strategy is to find ways to save dollars and use the savings to extend the training program. As one response, SLITP is performing a study to determine the most cost-effective methods of providing NRC training for the States with emphasis 34
on using lower cost training locations. The scope of the study is to determine, without sacrificing existing instructor competence and training facility and course quality, if any of the current State training courses could be relocated to other training facilities which could provide on-site food and lodging accommodations at minimal cost.
We have explored with other Federal agencies (e.g., Department of Energy, Department of Transportation, Federal Emergency Management Agency, Environmental Protection Agency, and Department of Labor) that also assist the States, local governments, and Indian Tribes in carrying out their I
responsibilities that are similar to NRC, to utilize their technical training facilities, if available, on a cost-reimbursement i
agreement. Presently, we have identified over 32 potential training site facilities available to NRC at minimal cost that range from a low of $15.00 per day (includes lodging and three meals) to a high of $101.00 per day (Table 5).
We have had extensive discussions with the identified training site facilities.
We realize that some of the identified training site facilities available to NRC at minimal cost are not located in areas that have major airports and airline hubs, which might increase travel costs. This aspect will need to be monitored closely. However, travel for training savings can be realized by conducting training at low-cost training facilities that are geographically located in areas where the largest number of trainees reside. The geographical mix of the training site facilities available to NRC at minimal cost are divided between the Northeast, Southeast, Central, and Rocky Mountain States.
One of the identified training sites visited was the FEMA National Energency Training Center (NETC) located in Emmitsburg, Maryland.
The purpose of the visit was to evaluate the NETC training facility for possible use by NRC for our State training program. The tour included an inspection of NETC's classrooms, lodging, and dining facilities.
After the tour, we were satisfied that the NETC facility could provide a quality training site for our State training program. We have identified "Inspection Procedures" as one of the current SLITP training courses for State employees that is conducive for the NETC. The course is scheduled for June 6 through 10, 1988 for 30 participants.
An evaluation will be made after the June training to determine if future training should be held at NETC. The cost for single room lodging and three meals per dey at NETC is $30.00 per day for each NRC participant compared to holding similar training at a commercial facility in a major metropolitan area with Federally-approved per diem rates of
$72.00 to $117.00.
Specifically, this cost savitgs for food and lodging is further demonstrated when comparing the same course, "Inspection Procedures," to be taught at NETC, and when it was taught last year in Atlanta, Georgia.
The average daily cost incurred for each participant in Atlanta was $92.47 for food and lodging (the maximum prescribed Federal per diem rate for Atlanta is
$102.00). The daily cost at NETC for food and lodging for each 35
TABLE 5 NATIONWIDE MINIMAL COST TRAINING SITE FACILITIES Combinction Name and Location Lodging Food Classroom Lodging / Food /
Cos Per Total Lodging CosgjPer Classroom of Training Site Cost Per Day {j and Food Cost Day Cost Package Remarks Faci]ity Night CBN University
$55.00
$20.00 (Off-Site)
None None No lodging Chesapeake, VA
$75.00 facilities Attp: Ms. Neidon at the CBN (804) 424-7000 University.
Cost for food and lodging are for close by Holiday Inn.
l Harpers Ferry, W.VA None Single Occup.
One hour travel Cliffside Inn
$68.50 time fraa l
Attn: Ms. Price Double Occup.
Washington (304) 535-6302
$101.00 National Airport.
I w
Federal Emergency
$19.00
$11.00
$30.00 None We have scheduled Management Agency the "Inspection National Emergency Procedures" training Training Center course to be held Emmitsburg, MD June 6-10,1988 at Attn: Ms. Riley the FEMA training (301) 447-1161 center.
4-H, The f.ational None Single Occup..All group reservations Center
$60.40 require a signed 7100 Connecticut Ave.
Double Occup.
contract. A non-Chevy Chase, MD 20815
$94.80 refundable deposit (301) 961-2809 is required.
1/ Cost includes three meals per day, unless noted otherwise.
{/Allclassroomsarefurhishedwithaudio-visualequipment.
Combination Name and location Ledging Food Classroom Lodging / Food /
Cos Per Total Lodging CosgjPer Classroom of Training Site C
- Per Day}j and Food Cost Day Cost Package Remarks Facility N19nt Department of Labor Free Free Free None None Cost for food, Mine Safety and lodging, and Health Administration classroom National Mine Health facilities are and Safety Academy free on a space Beckley, W.VA available bases for Attn: Ms. Ford Federal government (FTS) 930-3250 employees. For no r -government emt loyees the cos t is $38.03 per day for food, lodging and classroom facilities.
Airport is i mile from site.
El National Oceanic and
$30.00
$23.00
$53.00 None None Special hotel Atmospheric Adm.
rates have been Department of Ccmmerce obtained by NOAA.
National Weather Free transportation Service Training Center from hotel to Xansas City, M0 training center, Attn: Mr. Richard Meyers and airport.
(FTS) 758-6263 T7 tost includes three meals per day, unless noted otherwise.
2/Allclassroomsarefurhishedwithaudio-visualequipment.
Combination Name and Location Lodging Food Classroom Lodging / Food /
of Training Site Cost Fer Cos Per Day {j Total Lodging CosgjPer Classroom Facility Night and Food Cost Day Cost Packace Remarks Norbert S. Hill Center $25.00
$11.00
$36.00
$50.00 None The center is Oneida, Wisconsin fully owned and l
Attn: Ms. Teller operated as a 1
(414) 869-2214 major business enterprise by the Oneida tribe of Indians of Wisconsin.
Meals are provided at the center, but no lodging is available.
Office of Personnel OPM training l
o>
Management centers space Training Centers:
is extremely Days Inn limited for Lancaster, PA None
$47.00 OPM training Denver, C0 None
$52.00 only.
Kings Point, NY None
$45.00 Oak Ridge, TN None
$48.00 Attn: Walter Proznick (202) 632-3282 1/ Cost includes three meals per day, unless noted otherwise.
}/Allclassroomsarefurhishedwithaudio-visualequipment.
Combinaticn Name and Location Lodging Food Classroom Lodging / Food /
of Training Site Cost Per Cost Per Total Lodging CospjPer Classroom fj Facility Night Day and Food Cost Day Cost Package Remarks None
$15.00 DOE has a Reynolds Electrical contract with Engineering Co.
Environmental Sciences Reynolds to manage this Training Department (Department of Energy) training facility.
Nevada Test Site Space avail-Las Vegas, NV ability for NRC Attn: Dennis Vetter (FTS) 575-6820 training at this facility is excellent.
Department of
$20.00 to
$8.00 The Transportation None Transportation
$30.00 Safety Institute (TSI),was
$8 Safety Institute established in Oklahoma City, OK 1971 to promote Attn:
Dr. Gillespie and support the (FTS) 749-2153 DOT training programs in transportation safety and security. No cost to NRC for l
using TSI classrooms, labs audio-visual /
equipment, or mock-ups. Free l
bus transportation is provided between motels and TSI. The service airport is in Oklahoma City.
j 1/ Cost includes three meals per day, unless noted otherwise.
2/ All classrooms are furhished with audio-visual equipment.
Combination Name and Location Lodging Food Classroom Lodging / Food /
cf Training Site Cost Per Cos Per Total Lodging CosgjPer Classroom Day}j Facility Night and Food Cost Day Cost Package Remarks The University of
$100.00 Plan I $42.95 USM is located Southern Mississippi Plan II $31.45 3 miles west Long Beach, MS Plan III $36.95 of Gulfport, Attn: Ms. Chenault 75 miles east (601) 865-4508 of New Orleans, 75 miles west of Mobile, and is accessible to airports in those cities.
U.S. Postal Service None
$30.00 The Postal Office of Training Management and Development Academy is Postal Manaaement about a 20 di Academy ~
minute drive Potomac, MD from White Flint Attn: Mr. James Howell One. NRC would (301) 983-7001 be the first non-postal group entity allowed to use the Academy.
Fort Sam Houston
$12.00
$10.00
$22.00 None Academy of Health Classroom space is Sciences available.
San Antonio, TX Food and Attn: Ms. M. Camarillo lodging (512) 221-4141 provided on Fort premises.
1/ Cost includes three meals per day, unless noted otherwise.
7/ All classrooms are furhished with audio-visual equipment.
Combination Name and location Lodging Food Classroom Lodging / Food /
of Training Site Cost Per Cos}jPer Total Lodging CosgjPer Classroom Facility Night Day and Food Cost Day Cost Package Remarks University of Boston
$37.00
$19.00
$56.00 None Single rooms Boston, MA with private bath and air Attn: Gary Briggs (617) 353-4199 conditioning.
Uniformed Services
$10.00 None Facility cannot University of the provide lodging.
Health Sciences Excellent facility School of Medicine To hold meetings.
4301 Jones Bridge Road Auditorium capacity Bethesda, MD for 650 people.
Attn: Ms. Corbin (301) 295-3301 e;
University of Vermont
$12.00
$17.20
$5.00 per The University offers 460 South Prospect St.
to person a a full range of Burlington, VT day services to suit
$25.00 Attn: Serge Gart special training (802) 656-2088 needs, e.g.,
flexible meeting room space, modern audiovisual aids, and transportation to and from training sessions, and the airport.
1/ Cost includes three meals per day, unless noted otherwise.
J/Allclassroomsarefurnishedwithaudio-visualequipment.
i Combination Name and Location Lodging Food Classroom Lodging / Food /
of Training Site Cost Per Cos}jPer Total Lodging CosgjPer Classroom Facility Night Day and Food Cost Day Cost Package Remarks Washington State
$65.00 per Cost includes University person a meeting room 208 Van Doren Hall day for up to 30 Pullman, WA people with -
Attn: Ms. Rayburn various audio-(509) 335-3530 visual equipment, twice a day refreshment breaks, and the use of all campus recreational facilities.
A Purdue University
$36.00
$14.00 Training room Lafayette, IN to facilities are Attn: Ms. Meyer
$48.00 conveniently (317) 594-7221 surrounded by the cafeteria, and lodging facility.
1/ Cost includes three meals per day, unless noted otherwise.
l/Allclassroomsarefurnishedwithaudio-visualequipment.
Combination Name and Location Lodging i ;od Classroom Lodging / Food /
of Training Site Cost Per Cos},Per Total Lodging CosgjPer Classroom Facility Night D?"
and Food Cost Day Cost Package Remarks Defense College
$ $7.00 Minimum We have a and Schools to $25.00 to Cost listing of
Contact:
John Corley
$20,00 over 50 military GPA/SLITP defense training installations (301) 492-0332 nationwide that are available for training or meeting purposes. Many offer a complete package of ledging, food, and classrooms.
Others can provide a combination of facilities.
,s w
$60.00 Approximately 65 Hilltop House Hotel P.O. Box 930 minutes from Baltimore and Harperferry, WVA Attn: Ms. Ballenger Washington beltways.
The hotel is (304) 535-5321 undergoing extensive restoration and renovation, and is under new management.
1/ Cost includes three meals per day, unless noted otherwise.
Y/ All classrooms are furnished with audio-visual equipment.
of the 30 participants will be $30,00 a day.
The daily savings realized when comparing the Atlanta training with the upcoming NETC training is $62.47 for each of the 30 participants. This translates into a possible savings of several thousands of dollars for the 5-day training session.
ine "Inspection Procedures" training course is not the only SLITP course that is conducive for training at other minimal cost training site facilities.
While other SLITP courses may not necessarily produce savings as large as the example, we will identify other SLITP training courses (e.g., "Introduction to Licensing," and "Special Topics") that are conducive for other minimal cost training site facilities, thereby realizing additional savings, and the reallocation of these savings to expand the SLITP tuining programs to accommodate more NRC and State employees, and add more courses to keep pace with changing nuclear technology.
7.3 Other Initiatives 7.3.1 State In-House Training We are encouraging the States to develop more in-house training. To further this end, we hnve r.upported such training by providing NRC staf1 as instructors to the extent that resources permit.
Such a program was discussed this past January by Mr. Denton in a routine review exit meeting with Commissioner Word of the Tennessee Department of Public Health and was confirmed in our review comment letter to Dr. Word.
In this regard, we will encourage such States to make their courses available to personnel from other neighboring States.
7.3.2 Training Trainers In selecting applicant students for NRC training, we will, when possible, give greater preference to individuals who will be in a position to subsequently train others. We will also discuss with, and emphasize to, the States the overall cost advantages of nominating students who can then train their colleagues.
7.3.3 State Training of States We will explore with the States the possibilities of using experienced Agreement States to train State personnel from nearby States.
This would be a particularly useful approach when one-on-one training is needed.
It has the added advantage of making more visible the expertise and valued experience presently residing in Agreement States.
44
7.3.4 State Participation in NRC State Reviews
~
In 1987, we invited the Agreement States to par ;icipate in NRC reviews of other Agreement State prog rams.
In addition to providing technical support to NRC staff during the reviews, this activity will also serve to acquaint the State participants with other State programs and the administrative and managerial approaches used by other States to solve common problems.
It is, therefore, an excellent training opportunity for senior State staff and RCP l
managers.
The Agreement States have responded positively to this idea. (97) A pilot program was successfully completed in 1987 and we will be j
expanding this initiative in 1988.
7.3.5 Alternative Modalities The Conference of Radiation Control Program-Directors, Inc. (CRCPD) Committee on Training and Communications is exploring the use of alternative training modalities.
NRC will continue to support and work with the Committee as it examines alternatives such as slide / tape packages and video teleconferences. We will continue to be alert for opportunities to use videotapes as a supplement to the present "hands-on" approach to training.
7.4 Summary - Finding Ways to Save Dollars The identification to date of 13 training site facilities availaBle to NRC at minimal cost will produce savings to expand the State training program to accommodate more NRC and State employees and add some more courses.
Per diem training costs will be reduced when training is held at minimal cost sites that are geographically located in areas of the largest number of trainees.
We will also encourage States to develop more in-house training, to use students who attend NRC courses as trainers of other State staff, and to work with nearby States for mutual training of their staffs. SLITP will work with the CRCPD, Inc.
to explore alternative training modalities.
8.
CONCLUSIONS The NRC Agreement State program has become a recognized success story in Federal-State relations.
It has met Congressional intent to carve out a meaningful role for States in the nuclear field. The 29 Agreement States conduct programs which are adequate to protect public health and safety and compatible with the NRC program.
45
If the Agreement State program did not exist, NRC would be responsible for regulating 15,700 additional materials licenses. To do so would require an estimated net increase of 135 FTE which would cost over $14,000,000 in annual salaries and fringe benefits.
Offsetting this is the comparably small amount spent by NRC for State training which in FY 87 was $522,000.
In sum, the NRC Agreement State program saves the NRC over $13,000,000 annually, By all accounts, NRC training for State radiation control program i
l staffs is a key to enabling Agreement State programs to maintain j
programs adequate to protect public health and safety.
Past cuts in funding this training coupled with inflationary pressures have caused reductions in available training courses. We have sought to be innovative and imaginative to find ways to extend the training program by adopting as a major trategy the finding of ways to save dollars and using the savings to restore some deleted courses and meet other pressing training needs.
NRC funding of State travel and per diem costs has been a long-standing practice which is authorized by Section 274 and complies with Congressional intent.
Because of State restrictions on unfunded out-of-State travel, asking States to share these costs will have the undesirable result of reducing the numbers of State personnel attending NRC courses.
This will adversely affect the technical quality of their staffs which will ultimately affect the States' abilities to adequately protect public health and safety.
For these reasons, NRC funding of State travel and per diem expenses should continue.
Alternative ways to save training money can and have been found.
The most promising is utilization of minimal cost Federal and commercial training facilities used by other Federal agencies.
Lodging and meal service charges are significantly less than maximum allowable Federal per diem rates and the accommodations and food services are comparable to that available at Federal per diem rates.
Other measures to increase the cost-effectiveness of the NRC State training program which deserve exploration include encouraging and supporting more State in-house training, relying more on students becoming trainers when they return to their States, encouraging development of State training of other State staffs and developing alternative training modalities.
46
- 9. REFERENCES Note:
U.S. Nuclear Regulatory Commission (NRC) NUREG reports are available for purchase from the National Technical Information Service, Springfield, Virginia 22161.
Other referenced NRC documents are available in the NRC Public Document Room at 1717 H Street, N.W.,
Washington, D.C. for inspection and copying for a fee.
1.
NRC NUREG-1309, "NRC Program With State and Local Governments and Indian Tribes." NTIS, Springfield, VA 22151(March,1988).
2.
Nuclear Regulatory Commission (NRC).
Unofficial transcript of the meeting of the Comission held on February 3,1988 in Washington, D.C. entitled "Briefing on Status of State, Local and Indian Tribe Programs."
3.
Samuel J. Chilk, NRC. Memorandum dated March 2, 1988 to Harold R. Denton,
Subject:
Staff Requirements - Briefing on Status of State, Local and Indian Tribe Programs..."
4.
NRC NUREG-0388, "Final Task Force Report on The Agreement States Program." NTIS, Springfield, VA 22151 (December,1977).
5.
JCAE, "Federal-State Relations in the Atomic Energy Field,"
Hearings before the Joint Committee on Atomic Energy, May 19, 20, 21, 22 and August 26, 1959.
Letter dated May 13, 1959 from A. R. Luedecke, General Manager, AEC to Chairman Anderson, pp 293-4, 6.
42 U.S. C. sec. 2021.
7.
Ibid.
8.
JCAE, op. cit., Statement of AEC Commissioner John S. Graham, p.26.
9.
JCAE, op. cit., A.R. Luedecke, AEC General Manager, p.28.
- 10. House Report No. 1126, 86th Congress, 1st Session, p.3.
See al u Senate Report No. 870, Congress, 1st Session which tracks House Report No. 1125.
- 11. JCAE, op. ci t., p '.'.
- 12. Congressional Record - House, 1959, p.17635, 13.
Ibid, p.17634,
- 14. House Report No. 11?5, op. cit., p.12.
The last sentence in Sec. 274c. was added as a result of a letter from Oliver Townsend, Director of the State of New York Office of Atomic Developtrent to JCAE Ch. Hollifield. See JCAE, op. cit., p.392.
- 15. House Report No. 1125, op. cit., pp. 8-9 47
i
]
- 16. JCAE, op. cit., p.384.
17.
Ibid., p.405.
18.
Ibid., p.360.
- 19. JCAE, op. cit., Statement of John Curran, AFL-CIO, pp.339-354.
- 20. JCAE, op. cit.,
Statement of David E. Price, Chief, Bureau of State Services, U.S. Public Health Service, pp.102-113.
- 21. NRC NUREG-0388, op. cit.. See pp. A-6 and A-7, text, accompanying footnotes and citations of the AEC analysis and Senate Report 870.
- 22. Memorandum to Training File dated March 24, 1988 from J. O.
Lubenau, SLITP, "HHE/DHEW Training for States."
- 23. Congressional Record - House, 1959, p.17633.
- 24. General Accounting Office (GA0), "Opportunities For Improving AEC's Administration of Agreements With States Regulating Users of Radioactive Materials," June 12, 1975, p.42.
Available from the GAO, Room 6417, 441 G Street NW, Washington, DC 20548.
25.
Ibid., p.21, 26.
Ibid., p.2.
27.
Ibid., p.3.
- 28. GAO, "Management of the Licensing of Users of Radioactive Materials Should Be Improved," February 11, 1976, p.17.
Available from the GA0 Distribution Section, P.O. Box 1020, Washington, DC 20013.
- 29. Brown, H., The Agreement State Program: A State Perspective,"
National Governors' Association, Washington, DC 20001, January, 1983.
30.
Ibid., p.17.
31.
Ibid., p.41.
32.
Ibid., p.5.
- 33. NRC NUREG-0388, op. cit., p.1-1.
34.
Ibid., p.1-1.
36.
Ibid., pp.A-4 and A-5.
36.
Ibid., p.A-36, 48
37.
Ibid., p.A-39.
- 38. House Comittee on Interior and Insular Affairs, Subcomittee on Energy and Environment Oversight Hearing," Nuclear Regulatory Comicsion's Agreement States Program," July 19, 1979. Statement of NRC Comissioner Gilinsky, p.18, 39.
See especially Criterion 20, 40, 52 FR 21132.
See especially the Indicators and Guidelines for Training under the program element, personnel.
41.
Ibid.
42.
51 FR 45122 (December 17,1986).
43.
Ibid., p.45128.
44.
Ibid., p.45128.
45.
National Comittee on Radiation Protection, "Regulation of Radiation Exposure by Legislative Means," Handbook 61, U.S.
Department of Comerce, National Bureau of Standards, GP0, Washington,DC(December 9,1955).
46.
Ibid., p.13.
47.
C.M. Hardin, "A Discussion of the Conference of Radiation Control Program Directors, Inc.," Conference of Radiation Control Program Directors, Inc., Frankfort, KY 40601 (December 15, 1987) p.17.
48.
Brown, H.,
op. cit.
49.
Letter dated November 16, 1987 from F.J. Bradley, NY to D.A.
Nussbaumer, NRC, see attachment, Hotion No. 7.
- 50. House Comittee on Interior and Insular Affairs, Subcommittee on Energy and Environment Oversight Hearing, op. cit. Statement of Robart Slaton, Comissioner, Bureau for Health Services, Comonwealth of Kentucky, p.23,
- 51. Memo to Training File dated May 13, 1988 from J.0. Lubenau, "NRC Funding for Training."
- 52. General Accounting Office, "Rail Safety - States' Reaction to Proposed Elimination of Inspection Funding," GA0 Report RCED-87-84FS, GP0, Washington, DC (February,1987).
53.
Ibid., p.1.
54.
52 FR 21132 (June 4,1987).
49
55.
Ibid.
- 56. NRC, Unofficial transcript of the meeting of the Commission held on February 3,1988, op. cit., p.30.
- 57. Brown, H., op. ci t., p.11.
58.
Ibid., p.25.
59.
49 FR 21293 (May 21, 1984).
60.
P.L.99-272.
61.
51 FTR 33224 (September 18,1986).
- 62. JCAE, op. cit., pp.77-78.
- 63. Conference of Radiation Control Program Directors, Inc.
(CRCPD), "State Program Staff Retention Committee Report,"
CRCPD, Inc., Frankfort, KY 20601 (April 30,1987).
64.
NRC, Unofficial transcript of the meeting of the Coninission held February 3,1988, op. cit., p.32.
- 65. Brown, H., op. cit., pp.18-20, 66.
52 FR 21132, op. cit.
67.
Brown, H.,
op. cit., pp.19-20.
68.
Based on staffing data collected by NRC during routine reviews of Agreement State programs.
69.
Brown, H.,
op. cit.
70.
Memo to Training file dated May 16, 1988 from J.H. Corley, SLITP, "FEMA and EPA Training."
71.
Memo to Training file dated March 25, 1988 from J. O. Lubenau, op. cit.
72.
Brown, H.,
op. cit., p.61.
73.
Ibid., p.67.
74.
Ibid., pp.91, 99.
75.
Ibid.,.p.119.
76.
Illinois Department of Nuclear Safety, "Application 'or Agreement State Status," Vol. I, October 1,1986.
77.
GAO, June 12, 1973, op. cit., p.41.
50
- 78. A listing of Continuing Education Credits approved by the American Board of Health Physics (ABHP) is available from the ABHP, 8000 Westpark Drive, Suite 4J0, McLean,VA 22102,
- 79. A conference report on this workshop was published by NRC, see NUREG/CP-0073 "Workshop on large Irradiator Radiation Safety,"
prepared by J.0. Lubenau and D. A. Nussbaumer, March,1986.
- 60. 51 FR 1092 (January 9, 1986).
- 81. Brown, H.,
op. cit., p.20.
- 82. Memorandum dtd. July 29, 1987, S.J. Chilk, Secretary to V. Stello, Jr., Executive Director for Operations, approving NRC Strategic Plan.
83.
Ibid.
- 84. JCAE, op. cit., pp.303-304.
- 85. NRC NUREG-1309, op. cit.
In NUREG-1309, the number of Agreement State license was estimated would be 15,000 in FY 87.
The actual figure was 15,700.
This would increase NRC FTE needs by 1 to 136.
Rather than recalculate on account of this relatively small change, the estimated FTE figure in NUREG-1309 was used.
86.
Ibid. An annual profession salary and fringe benefit cost of
$104,000 per FTE was used.
87.
51 FR 45122 (December 17,1986).
- 88. NRC Press Release II-84-13 (February 8,1984).
89.
Lubenau, J. O. & Nussbaumor, D. A., "Radioactive Contamination of Manufactured Products," Health Physics, Vol. 51, No. 4 (October,1986).
90.
Ibid.
- 91. NRC Order dated February 18, 1988 to Minnesota Mining and Manufacturing Co. signed by R. Bernero, NMSS.
- 92. Memorandum to file dated March 25, 1988 from L. A. Bolling, SLITP, "3M Static Eliminator Case."
93.
NRC, Unof ficial transcript of the meeting of the Commission held on February 3, 1988, op., cit. p.53, t
94.
Ibid., pp. 23 & 24.
95.
Ibid., p.24 51
f i
- 96. 17id., pp. 24 and 28.
97.
Letter dated November 16, 1987 from F.J. Bradley, NY., op.,
cit.
=
h a
5 52
APPENDIX A DISTRIBUTION:
HDenton Agree. St. S/F CKamerer SA R/F SSchwartz /
Dir R/F DNussbaumer AUG 0 71987 PA MEMORANDUM FOR:
Chairman Zech y up g y E.s teeton FROM:
Harold R. Senton, Director Office of Governmental and Public Affairs SL'BJECT:
ADDITIONAL ASSISTANCE TO STATES IN REGULATION OF MATERIALS LICENSEES In view of the recent Comission meeting on medical misadministrations, and racomendations of the Materials Safety Regulation keview Study Group, I l
recomend that you consider additional resources for training assistance to I
the States.
Technical training of State licensing and inspection staff is authorized by Section 2741 of the Atomic Energy Act. Currently, only about half of the State personnel applying for NRC-sponsored training can be accomodated because of budget constraints. Enclosure 1 is a suuntry of how additional funding of $350,000 for training assistance for the States would be used to nelp assure competent and coordinated State programs end further our strategic objecthe to reduce putlic risk from uses of nuclear materials. Enclosure 2 ccunents on a recent training course.
Beth NRC and the public benefit from this training. The NRC benefits by having the States administer about 655 of all the materials licenses in the U..(. In addition, the training courses are made available to the NRC materials staff as necessary. The States benefit by being able to maintain qualified staffs necessary to run adequate and compatible programs and to prepare for Agreement State status.
I an available to discuss this request should you desire more informatio,1.
]
Enclosures:
l As stated j
cc: "cumiss 4ner Roberts Casuissiocer Bernthal Consissioner Carr SECY 06C ED0 (REQUEST FOR ADDITIONAL FUNDS ~ DAN)
- See previous concurrence (ENCL 2 TO AIQU FOR ADOTL FVMOS. DAN) a'5A
- 5LITP DD
- 5LITP:D
- EPA A
..:.........................:............:..d.......:............:............:...........
E :DNussbauner :SSchwartz
- CKammerer
- .1tDenton E :8/6/87
- 8/6/87
- 8/6/87 8/~//87 53
Trainino for States Section 1741 of the Atomic Energy Act, Os amended, authorizes the Comission, among other things, to provide training to the States "as the Comission deems a ppropriate. " The 5 tete Agreements prtgram has provided training to State personnel through various programs for more than 20 years.
Currently, the State Agreements program conducts comprehensive training programs for State and local personnel. This training consists of short-term courses in health physics, the safety aspects of radioactive materials usage, and the principles of regulation.
Fors FY 1975 through FY 1986, more than 2.400 State and local radiation control program students have attended NRC-sponsored training courses. Training courses encompass both technical and management subjects and range in duration from li days to 5 weeks.
A list of typical courses given each year is attached as Table 1.
The courses utilize contractors as well as NRC and State experts to present the material.
We provide the courses to the States and localities without charge. The State and local governments pay the salaries of their employees who attend, and we l
pay the travel and per diem of attendees. The training is provided to both
)
Agreement and non-Agreement States.
The training program has increased in both numbers of courses and numbers of students from FY 1975 to FY 1982, when 21 courses were presented to 286 students.
In FY 1986, the training budget decreased by 22 P, and in FY 1987 the numbers of courses and students have decreased to 10 courses and an estimated 187 students.
State perscnnel must be trained so State staffs can develop the expertise they need to perfom State radiation control program functions.
Personnel in States seeking Agreement status need training, and in Agreement States, both replacement personnel and persons hired to respond to program growth (increased numbers of licenses and more complex licenses) must be trained.
New State employees typically possess bachelor's degrees in engineering or science but little or no training nor experience in health physics. The NRC Policy Statement for review of Agreement State programs (52 FR 21132, June 4, 1987) contains guidelines for training that reference NRC-sponsored courses technical competence in areas of changing technology.propriate level of s and re ossmands a training program "to maintain (an) a Although other training is available, as a practical matter, the NRC program is the sole source of this type of training for the States.
'The training budget covers travel and per diem costs for students and the f.ests of contract instructors.
54 1
1 Attachment Table 1 TYP! CAL SPA: SLITP TRAINING COURSES g
FOR STATE PERSONNEL M
ho. Students h
Cutbacks o
Inspection Procedures 25 2/ year 2, 4, 5 Licensing Orientation 20 25 1/ year ORAU Health physics 20 2/ year Well Logging 20 1/ year Radiolosteal Engineering 20 1/ year Transportation 20 1/ year Special Topics 20 1/ year
,o Industrial Radiography 16 2/ year Reduced to 1/ year
- . Medical 20 t/ year Reduced to 1/ year '4 3
Radiochemistry 20 1/ysar Deleted i
Teletherapy Calibration 12 2/ year Coleted Management 20 1/ year Deleted Harvati Stologial Effects 5
1/ year Deleted of Radiation 331 15/ year 3/ year = azs slots 1.
Excluding Milt Te111ngs and U.W.
2.
See raductica in slot; available to States have occurred to accommodate Navy, Air Ferce and Arsty "super-broad" license representatives.
These have 7499ed frem two to four slots.
In addition, in' FY 1987 four NRC inspectors will ettend the toum leaving for FY 1987 only 17 slots for State students.
3.
The havy has requested slots for the FY 1988 Medical course.
4.
There is nc cweensation for slats provided to the Armed Forces er NRC staff, i
S.
The second presentation of this course is usually at a State site to train l
personnel from tha host State and marby States, thus conserving travel funds.
' Courses that could be reinstated or brought back up to previout levels for $350%.
55
/
'q, UNITED STATES NUCLEAR REGULATORY COMMISSION g
s
,a 54ASMisu4704, D. C. 20644 July 29,1987 NOTE FOR: Glen Sjoblom Yandy Miller John Hickey FROM:
Jack R. Metzger and Harriet Karagiannis
SUBJECT:
MATERIALS INSPECTION COURSE - PRESEhTED AT ATLANTA, GEORGIA July 20 - 24, 1987 BY STATE AGREEMENTS PROGRAM, GPA We are taking this opportunity to inform you of the subject course that we audited, and, to some degree, teck active part.
1 In our opinion, the course was outstanding. None of the 26 students could have left the course without some idea of how inspections are accomplished. The instructors did an excellent job of preparing and coordinating the course.
The preparation, the day-to-day logistics of getting speakers on time, homework assignments, and handing out study materials for the students, required a lot of work and the instructors should be cossnended for their exemplary efforts.
Of particular interest was the ongoing feedback frem the students, an important element in class participation. N exercises (one was held in the Regional office) were e/cellent and represented real-world situations. The students had to think abt the problems presented to them, as they would during inspections, and the so19tions were not simple, but represented scenarios that inspectors face all tlee time. Inspectors must be prepared to expect the unexpected. To develop a course that is interesting from the standpoint of taking ei active part is not easys it requires skills and experience.
An excellent contribution to the course were invited speakers that were specialists in their areas of expertise and able to respond to a variety of specific questions asked by the students.
The exercise in the Regional office consisted of a private medical practitioner, who did not read the license or application.
These docustnts were prepared by a consultant. The physician's technologist had no training; yet, they were using tritium, carbon-14, and todine-125. Surveys were essentially necentstent, postings were inadequate, and the outcome apparently resulted in extensive contamination spread, inadequate instrumentation, lack of bioassays, records,and so forth. The analysis of the exercise that was presented by each of 5 student teams following the scenario was informative; f.e., each team had their own f ^as of the consequences of the "mock" inspectien. However, the students, overall, reached a consensus and were left with another s2t of circumstances -- what to do about the situation.
i 56
Note for Addressees.
We propose that new NRC inspectors be required to take the course whenever opanings are available. Also, it would not be inappropriate for inspectors Shd have had some small experience to take the course.
Yhere will be a further update after our meeting on July 30th at 9:00 a.m.
Jack R. Me r
l' k_
ci~
arr et Karagiannis cc:
D. Nussbuemer, GPA R. Cunningham, NMSS 57
1 s
. I.EPoT4T NUMBE A Hss,pma by DDC)
U.S. NUCLE AR REGULATORY CoMMISSloN
- p. y,
BIBLIOGRAPHIC DATA SHEET NUREG-1311
- 4. TITLE AND SUBTI Mdd VoAime No., sf appropna ref
- 2. (Leere 3/mi/
Funding the NR Training Program for States
- 3. RECIPIENT *$ ACCESSION N
- 7. AUTHOR (S)
- 5. DATE REPORT COYPLE[
i J.0. Lubenau and J.
Corley umm I naa liarch
/
1963
- 9. PERFORMING ORGANIZATION N A E AND MAILING ADDRESS (/nc/voe 2>p Covel OATE REPORT IS[ED Office of Governmental a.
Public. Affairs "J$ne" [
I "l988
^
U.S Nuclear Regulatory Cc.,ission
** Y Washington, DC 20555 8 (Lear dwkl
- 12. SPONSORING ORGANIZATION NAME AND A ILING ADORESS (Ine/voe 2,0 Cooel 10.MOJECTITASK/ WORK UN:T NO.
Office of Governmental and Publ Affairs
/
U.S. Nuclear Regulatory Commissi 1
- 6. CONTRACT NO.
Washington, D.C.
20555 4
- 13. TYPE OF REPORT PE RICO EV E RE D (/nclusere casest 3
Final
- 15. SUPPLEMENTARY NOTES f'
14 (Leave o/rel
- 16. ABSTR ACT Q00 words'or less)
(
On February 3, 1988, the Commission received ) riefing on the State, local and Indian Tribes Programs of the NRC Office of Governme al and Public Affairs. The briefing included discussion of the Agreement State g o am and, more particularly, the training provided to State personnel to help them plaintal programs which are adequate to protect public health and safety and compatible 4th the ommission's program. The Comnission endorsed the NRC State training program'6ut quest.1 ned the long-standing practice of f
paying the travel and per diem of Statp personnel a oroved to attend the NRC sponsored training. The staff was requested by/the Comissior, to provide a report on this aspect.
This report is the staff's response g It includes an valuation of the practice of funding State travel and per diem 46sts for personnel ttending NRC courses and other options to make this program moreyost effective includ g utilizing whenever possible minimal cost Federal and ccamercial training facilities, y
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