ML20197C604

Transmits State Agreement Program Info (SP-97-081) Re Identification of Good Practices in 1995-1997 Integrated Matls Performance Evaluation Program Reviews & General Recommendations

ML20197C604
Person / Time
Issue date:	11/21/1997
From:	Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP)
To:	GENERAL, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF
Shared Package
ML20197C612	List: ML20197C604 ML20197E103
References
SP-97-081, SP-97-81, NUDOCS 9712240229
Download: ML20197C604 (17)

Text

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.y* I% UNITED STATES l

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NUCLEAR REGULATORY COMMISSION WASHINGTON, o.C. tour 4001 November 21, 1S F l

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l ALL AGREEMENT STATES i OHIO, OKLAHOMA, PENNSYLVANIA  ;

i TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP 97-081)- )

Your attention is invited to the correspondence which contains: ,

1 INCIDENT AND EVENT INFORMATION.........

PROGRAM MANAGEMENT INFORMATION...XX IDENTIFICATION OF GOOD r'9ACTICES IN 1995 1997 INTEGRATED MATERIALS .

PERFORMANCE EVALUATION PROGRAM REVIEWS AND GENERAL' RECOMMENDATIONS TRAINING COURSE INFORMATION.............

TECHNICAL INFORM ATION........................

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OT H E R IN FO R M ATION. . . . . . . . . .. .. . . . . . . . . . . . . . . . . . .

Supplementary information: Enclosed are two reports prepared by NRC staff.~ The first report (Enclosure 1)is on good practices that were identified during the Integrated  !

Materials Performance Evaluation Program (IMPEP) reviews from 19951997 in North Carolina, North Dakota, Georgia, Iowa, Kentucky, Nebraska, Maryland, Loulslana, California, Tennessee, Mississippi, Colorado, Illinois, and NRC Regions I, ll,111 and IV.

NRC staff is making this information available to both NRC Regions and the Agreement  !

States to identify and share innovative and effective practices used to implement the materials licensing and inspection programs throughout the nation. You may find some techniques used elsewhere that can be incorporated to enhance some aspect (s) of your own programs. We plan to continue to identify good practices through IMPEP reviews and to issue similar reports annually.

The second report (Enclosure 2) summarizes in a general manner, recommendations i identified in more than one IMPEP review during 1995 1997. This information is being g

provided for your use in identifying areas in AEA materials programs that may need strengthening I p q q-

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SP 97 081 2- fl0V 211997 No action on your part is required. If you have any questions regarding this correspondence, please contact me or the individual named below.

POINT OF CONTACT: Kathleen N. Schneider TELEPHONE: (301)415 2320 FAX: (301)415 3502 1 INTERNET: KXS@NRC. GOV  ;

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~ (94 Paul H. Lohaus, De'puty Director Offico of State Programs

Enclosures:

As stated

2*

SP 97 081 NOV 21 W e

. I No action on your part is required. If you have any questions regarding this  :

correspondence, please contact me or the individual named below. l POINT OF CONTACT: Kathleen N. Schneider (301) 415 2320  !

TELEPHONE:

FAX: (301)415 3502 INTERNET: KXS@NRC. GOV i 0:iginalSI Dned Dr.  ;

PAULH.LOHAUG Paul H. Lohaus, Deputy Director Office of State Programs {

Enclosure:

As stated 9

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Distribution:

DIR RF DCD (SP03)

SDroggitis - ' PDR (YES_Y_) (NO _)

LRakovan SMoore .GDeegan i

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A/S File -

IMPEP File

'See previous concurrence.

DOCUMENT NAME: G:\KXS\SP97081. KNS; G:\KXS\GDPRAC96.KNS; G:\KXS\TRENDIMP.KNS

- n m . .m .e we e uni.at. **e ih. w.: *c - em winoui .ii. chm.ne.ncio. . e - con nn evi.enm.nv.e. . r - No copy OFFICE .OSP [E OSP:DD l NMSS:D l OSP:p lO[ l NAME KSchneider:nb:kk ~ PLohaus CJPaperiello RLBarpdrF '

DAT'i 08/12/97* 08/15/97* 09/08/97* pp/M/97 via Memo -

OSP File Code: _ SP-A-4. SP-1-2.

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No action on your part is required. if you have any questions regardi this  !

correspondence, pleasc contact me or the individual named below. i POINT OF CONTACT: Kathleen N. Schneider j TELEPHONE: f3011415 2320 .

FAX: (301)415 3502 l INTERNET: KXS@NRC. GOV Paul H. Lohaus, eputy Director Office of State rograms

Enclosures:

As stated 1

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e Distribution:

DlR RF - DCD (SP03)

SDroggitis PDR (YES.y_') (NO._)

LRakovan

- SMoore JPiccona DCool A/S File IMPEP File <

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' DOCUMENT NAME: G:\KX,8\SP970ZZ KNS; G:\KXS\GDPRAC96.KNS: G:\KXS\TRENDIMP.KNS u *. . . , .: m e.com.ni, ine.ea. in ih. w.: *c' .c wv enovi eti. chm.nt!.ncio.u . *t - copy wein .et ch=.aii.ncio.ur. *w - No copy --

OFFICE OSP- / {E OSFjf Q[ l NMSS:D ] OSP:D l l NAME KSchneider:nb #J/> Pi.0% ut,J \ CJPaperiello RLBangart DATE 08/g/07' 08/R/97 08/ !97 08/ /97 .

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i OCTOBER 1995 APRIL 1997 INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM (IMPEP) REVIEWS INTRODUCTION

' The Integrated Materials Performance Evaluation Program (IMPEPl is usea by the Nuclear Regulatory Commission to review Agreernent State and NRC Regional materials regulatory programs. It provides a uniform approach for review of such programs and is based on five performance indicators that are common to Agreement State and Regional materials radiation control programs. The basic concept in IMPEP is that use of common performance indicators will allow NRC to conduct consistent reviews of Regional and .

Agreement State materials programs that focus on performance These indicators are as followra Status of Materials inspections Technical Staffing and Training -

Technical"Juality of Licensing Technical Quality of Inspection Reeponse to incidents and Allegations Certain non-reactor functions tha' continue to be conduc.ted from NRC Headquarters, such as fuel cycle licensing, uranium and thorium milling licer'. sing, sealed source and device i revirvs, and low-level radioactive waste disposal licensing, are excluded from the set of '

common indicators oecause they are not common to Regional and Agreement State activities. These are incorporated, as appropriate, as non-common indicators contributing to a performance-based evaluation of the program.

- For Agreement States, the non-common indicators are legislation and regulations, sealed source and device evaluation program, low-level radioactive waste disposal program and uranium recovery program.

PURPOSE This report provides a summary of good practices identified in conducting IMPEP reviews of the nuclear materials programs from October 1995 to April 1997 of four NRC Regional offices, and thirteen Agreement States.

This summ-- is being shared with Repional and Agreement State program managers throughout ine nation for your consideration as to whether your programs might be enhanced by adopting the good practices of other regulators.

z-ENCLOSURE 1  !

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I 2 a STATUS OF INSPECTIONS - GOOD PRACTICES North Carolina utilizes a license condition (Attachment A) that requires alllicensees autnorized to use radioactive material at temporary locations to notify North Carolina of work being performed in the State and provide information on when and where tb3 work will take place. This information is posted on a bulletin board along with requests for reciprocity. This allows the staff to select field inspections as needed and perform the inspections in an efficient manner.

North Carolina contact: Aaron Padgett Telephone: 919 571 4141 TECHNICAL QUALITY OF LICENSING - GOOD PRACTICES Rlli developed a document entitled "Information that Should be Submitted to the NRC Staff for Decommissioning and Termination of Licensed Facilities" (Attachment B). The document is provided to licensees intending to request authorization for release of a room or building for unrestricted use or for termination of licensed activities.

NRC contact: Roy Canlano Telephone: d30 829 9801 TECHNICAL QUAllTY OF INSPECTIONS - GOOD PRACTICES North Dakota inspectors included photographs of licensee operations in the inspection files.

Thi:, practice is not widely used by NRC Regions and other Agreement States. The photographs help supervisors and future inspectors have a visualindication of licensee f acilities, equipment, and operations.

North Dakota contact: Kenneth Wangler Telephone: 701 328-5188 California uses a " Review Alert Form," Form 2033 (Attachment C), to communicate inspection findings to licensing staff.

California contact: Edgar Bailey Telephone: 916 322-3482 California also uses a " User's Declaration Form" (Attachment D) to establish a legally binding agreement between California and a license. The form can be executed by an inspector in the field to cause a licensee to discontinue a serious non-complaint activity.

California contact: Edgar Bailey Telephone: 916 322 3482 l . . .

3 Rlli conducts a "querterly inspection self assessment" program. Each quarter, a senior inspector and a GG 13 inspector from each inspection Branch spend a day reviewing one area of inspections. Topics to date have Mcluded documentation using the field notes, completion of Inspection Follow-up System (IFS) data, and inspection of misadministrations and events. The inspectors selected appropriate documents for review and presented their findings in writing to the inspection branch chiefs. Findings have resulted in development of additional written guidance in the form of memoranda to the staff, as well as additional in-house training.

NRC contact: Roy Canlano Telephone: 630-829 9801 RESPONSE TO INCIDENTS AND ALLEGATIONS - GOOD PRACTICES In Maryland, all complex events or allegations or those with the potential fa impacting public safety are evaluate <1 by the radioactive materials (RAM) supervisor, the manager, and staff,in order to determine an appropriate response. The response varies based on the safety significance of the event, from resolution through telephone discussion, to immediate response by a team of two health physicists, and, in some cases, issuance of a press release to the media, in many instances, the RAM supervisor participated in investigations of complex or high media interest events. Although Maryland's practice is not unique, this is a sound practice that provides effective response actions.

Maryland contact: Roland Fletcher Telephone: 410 631 3300 NON-COMMON PERFORMANCE INDICATORS - GOOD PRACTICES Region ll has developed forms and checklists which are used to verify that allinformation on decommissioning licensing actions has been incorporated into license files.

NRC contact: Bruce Mallett Telephone: 404 562-4700 Region ll conducts a formal self-assessment program. This program is very effective in providing the Regional management with information on Regional performance.

NRC contact: Bruce Mallett Telephone: 404-562-4700 Regional 11 maintains a Facility Integration Matrix for each fuel cycle f acility to help identify trends and patterns of licensee performance with regard to violations and reported incidents. This information is also used in managing and planning fuel facility inspections.

NRC contact: Bruce Mallett Telephone: 404-562-4700

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CONCLUSION b

The IMPEP review teams plan on identifying good practices during future reviews and we plan to continue to prepare and distribute summaries of good practices that have been identified to both Regions and Agreement States.'

NRC contact: Kathleen Schhsider, Office of State Programs Telephone: 301-415 2320

. Attachments:

As stated P

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RAD 20ACTZYE MATE post.it'Faz Ncis 7671 0**

• CIVISION CF RADIAT g g-D.C. DRPARTMENT CF EN cess, AND NATURht. Co AADICACTIVE NATE purevant to Nort.h Carolina Regulations int protect v., s.

ct:tements and representations heretofore made by c thorising the lisensee to receive, seguire, own, '

met: rials listed belows and use such radioactive materama zor too purposets; ans ac see p10 n (s) designated below. This Lieoase is subject to all applicable rules and regulations cf the North Carolina Department of Environment, Nealth, and Natural Resources now or h rm iter in 3ffect and to any sonditions specified below.

Licensee

1. .Nemen

3. Aioense No.:

3. Addres s :

4. 2spiration Dates AMENDS TN ITS EN!'IRETf

5. Amendeamt No. .

6. Cadioactive Material 7. Chemical and/or (element and mass ao.) Physical Form

8. ht== Amount of Radioactivity and/or Quantity of Radienttive

, Material which 1.icensee may Possess at any one time.

A. Iridium 122 A. sealed sources A. No single source to exceed (Amersham Corp. 100 curies Model No. A424-9) -

D. Cobal' 60 '

B. sealed Sources (Amersham corp. 3. No single source to exceed Model A 4-A or 100 curies

, S 16)

, C. Iridium 192 C. sesled Sources C. No single source to exceed (Amersham Corp. 100 curies Model No. 424 9)

3. Authorised Use:

A.

, To be used in Gama Industries Models, Century 8, Century S Universal, Century SA, Century, SA Universal and Amersham Model 660s exposure devices for industrial radiography Cnd in Gamma Industries Model C 10 and Amersham Models 650 and 500EU and O'11f Nuclear U-110 and Amersham Models 650L source changers for storage and source exchange.

B.

To be contained in a Gama Industries Model 200A exposure device for storage only.

C.

To be contained in an Amersham Corp. Model 650 radiography exposure device for storage only.

10. CONDITIONS Cadioactive material may be stored and used at licensee's facility located at it.

The licensee protection A shall comply with the provisions of 15A NCAC 11.1600, ' Standards for Inspections. "gainst Radiation,' and 15A NCAC 11.1000, " Notices, Instructions, Reports and

('Ihe North Carolina Regulations for Protection Against Radiation are contained 'in 15A NCAC 11.)

12.

Radioactive morth material may only be used at tesqporary jobsites of the licensee anywhere in Carolina.

The Ncrth Carolina Division of Radiation Protection shall be notified of the location (s) of such use no later than three (3) days prior to the first day of use.

This condition does not prohibit use in the United States where the United States Nuclear R:gulatory Commission maintains jurisdiction for regulating the use of radioactive by the Nuclear Regulatory Connaission and/or the respective Agreement If for a State upon application to the agency obtain permission to proceed sooner. specific case the

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ATTACHMENT A

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Information that Should be Submitted to the NRC Staff for Deco aissioning and Termination of: Licensed Facilities The following information is.needed from licensees who request authorization from the NRC for the release of a room, building or outdoor area for unrestricted use:

1)- ~ A list of the radiological isotopes that were actually used at the site.

To-the extent possible (and reasonable), the quantities and dates of use of.these isotopes should also be provided.

2) The physical form of each isotope. i.e., was it a sealed source or was the isotope used in a loose form.

-3) - Information regarding major radiological spills of any licensed isotopes

- such as the location of the spill (s) and pertinent radiological information about the spill (s). (Major spills for the purpose of this document means a spill that resulted in off-site contamination or any other spill where more than minimal decontamination effort is required, e.g. s) ills requiring assistance in cleanup and monitoring from persons other_ t lan the user.)

4) Information on any leaking sealed source used or stored at the site being released including isotope, amount of leakage, contamination of

other areas or personnel, description of cleanup, and dis)osition of the source. If no sources were determined to be leaking at t1e facility, the licensee should state this fact.

5) The results of the licensee's final surveys as required by 10 CFR Parts 30.-36(j)(2). 40.42(j)(2), and 72.54(1)(2). This includes submitting data in the following units: gamma radiation in units of mSv/hr2(pR/hr) at one metp)r (dpm/100cnt from surfaces, (removable radioactivity and fixed) in units for surfaces. of MBq/100cm MBq/ml (mC1/ml) for water, and Bq/g (pC1/g) for soils and concrete. (See Attachments 1 and .

2) 6)_ The survey instrumentation used for the final survey along with the certification that each instrument bas been properly calibrated and tested and the minimum detectable activity.(MDA) for each instrument.

' This information is needed for instruments used for measuring exposure rates;and for those used for analysis of wipes soil and water samples, etc. (See' Attachment-3)

7) Maps and/or drawings-which clearly indicate the locations where wipes ,

~

and fixed measurements were taken. If contaminated drain lines (or other buried or inaccessible pipes) are an issue. blueprints-or drawings-should be included that show the locations of the drain lines. including where they originate and end.

ATTACHMENT B

8) If other than minimal contamination efforts are necessary, both the before and after decontamination survey data should be provided as part of the final survey report including the locations of these areas.

9) The release criteria used as a basis for demonstrating the site can be released for unrestricted use. (See Attachment 4)

10) -If the licensee intends to leave certain portions of the site contaminated in excess of the release guidelines, a risk assessment of the potential dose consequences.

11) The disposition of radioactive waste resulting from any remediation efforts. Under normal circumstances the NRC will not conduct a. closeout or confirmatory ins)ection until all waste (and other licensed materials / sources) lave been removed from the site. If these materials have not been removed prior to the licensee's submittal of the final survey data, then the5e areas will have to be surveyed following removal of the waste and the data submitted and reviewed before an onsite inspection and/or license termination, Attachments: -(1) 10 CFR Part 30, 40 or 70 (as applicable) *

(2) Survey Information to Support License Termination (3) Section 5.0, NUREG/CR-5849. Manual for Conducting Radiological Surveys in Support of License Terminations *

(4) Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Tennination of Licensas for-Byproduct. Source or Special Nuclear Material *

• Contact Roy Caniano (630-829-9801) for irformation on Attachments 1, 3, and 4.

u.

ATTACHMENT 2 SVRVEY INFORMATION TO SUPPORT LICENSE TERMINATION in performing the decommissioning of its facility the licensee should first identify any areas in the facility that were involved in licensed material use by reviewing facility records and conducting a survey of the licensed material use area. This survey should be similar to the routina contamination surveys conducted under the licensee's radialogical safety plan. The licensee should then remediate all surfaces in the areas at the facility that were involved i; licensed material use cr storage and dispose of all radioactive material and waste as discussed in the NRC regulations at 10 CFR 20 Subpart K.

If the licensee elects to demonstrate that its facility is suitable for unrestricted use by conducting a Final Status Survey, the licensee should design the survey so as to be of sufficient scope and quality to make this demonstration. In preparino for the Final-Status Survey, the licensee should establish a method to identify individual measurement / sampling points, such as establishing reference grids on each surface in the indoor area that was involved in licensed material. At a minimum, the licensee's termination survey should consist of:

1) 100% scanning of all surfaces in the area at the facility where licensed material was used or stored using an appropriate radiation detection instrument (including scan sensitivity):

2) evaluations for total and removable radioactive material at each area exhibiting elevated radiation levels or at a frequency of one wipe 2

comprising 100 cm per grid; and

3) evaluations of radiation levels at one meter above surfaces Particular attention should be afforded any drains, air vents or other fixtures or equi) ment that may have become contaminated during licensed material use. T11s is especia'ly significant in situations where renovations have occurred and potentially contaminated areas may be inaccessible under current conditions.

The information that should be submitted to the NRC to support the final status survey should consist of:

1) a brief description of the remediation activities undertaken by the licensee:

2) a detailed drawing of the licensed material use areas indicating the sampling locations:

3) a table showing the results of the rediation levels and removable contamination surveys keyed to the detailed drawing (organized by survey unit):

4) the training and qualifications of the individual (s) performing the

decontamination and surveys: and

- 5) a description of the type of equipment used by the licensee to evaluate the wipes and perform the surveys. This description should '

include all information required to determine the appropriateness of the-equipment for determining the radiological status of the facility such as last calibration date, type of radiations detected, sensitivity of

- detection, efficiency, etc.

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Depertment at Heeien s.< vices C siete es neernie-Heenth one watere Aseacy Radiologic Hoolth Branch 744 P Street .

. Sectamonto. CA 96814 Docket No.

Applicant Lic/Applic. No. ,

1. INFPECTION AGENCY APPLICATION REVIEW We have no problems regarding this application.

We have the following comments regarding this application:

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O Continued on 1 attached Please hold action on this application pending the By:

results of our inspection scheduled for - - -

Agency:

Date:

Inspection agency review for this license or amendment hours.

2. REVIEWEli'S JUSTIFICATION / FEE CALCULATIONS / NOTES 17 CAC 3019 criteria satisfied O Continued on 2 attached Docket Numbers closed out by this Amendment:

Date of issue: Drafted by: Typed by: Checked by:

Ucensing effort hours for this license or amendment hours.

ATTACHMENT C CH 2033 (4/42)

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Notice of Violation >

-and Radiation User's Declaration-

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Q a.ee. oa Q Lnen awneer s= m ema oc u u m uu.a cor Th s inspection was an examination o' your activibes and equipment as they reiste to radiaton safety and compliance with the Nuclear Medicine Technology Law (California Health and Safety (CA H&S) Code Chapter 7.2. Sections 25625, et seq.), the Radologic Tec*mology Law (CA H&S Code. Chapter 7.4, Sectens 25660, et seg ), the Radiation Control Law (CA H&S Code Chapter 7.6, Sectons 25800, et seq.) a .d regulatons adopted pursuant thereto.- The inspecten consisted of selecove examination of procedures and representauve records, interviews with personnel, and observations by the ins,.4ctor. Certam of your activites were found to be in viotauon of Califomia requirements.

- Serious Violations Specified-Use(s) In Violation Suspended Vlotabon(s) described below shall be immediately corrected to prevent or mitigate radiation exposure. Radiation sources identr6ed in the description of violaten(s) shan be voluntarity secured and will not be used unts the violations (s) are corrected. Sirnitsrty, staff identmed in this Notice as lacking spectned cert:5 cation will not be allowed access to radieuon sources unless property cert 6ed.

. DESCRIPTION OF VIOLATION (S):

ACKNOWLEDGMENT AND USER'S DECLARATION (PLEASE INITIAL):

The inspection Agency Representattve has explained, and I understand the item (4 noted above. Radiation sources identr#ed in this Notice win not be used un64 velmoon(s) specded above are corrected. Staff identrAed in this Notice as lacking specified certr6cabon will ;mt be allowed access to radiation sources in violabon of certficabon requirements. Corrective action and suspensen of use are voluntary and a heanng pursuant to Section 11500 et seq., of the Cairfornia Govemment Code on the lasues is waived contingent on satisfactory resolution through this

- process.

I ackriowledge receipt of this Notice of Vtolabort.

' usee a Signatore: hte:

Agency Representative: Date:

Note: A fut report of inspecton 6ndings will be sent to you wnthan 30 days and tr'ay cito addtbonal vioiations which win also require correctrve action. This Nohce is also r ubject to further orders of the Department.

ATTACHMENT D om e.= coon

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• Padiation Chapter Control 7.6 Division 20 La Article 14 Penalties

-Section 25865_ Violation; rnisdemeanor; penalties i

j Any.p~crson Tvho. violates any of the provisions of this chapter or -

rules, regulations, or = orders in effect pursuant thereto is guilty of a

.misdemeatior and snall, upon conviction thereof, be punished by a fine not to exceed one thousand dollars (S1,000), or by imprisonment in the

'cotmty jail lur a period not to exceed 180 days or by both such fine and-Imprisonment.

Section' 25866. Civil penalties; violations of this chapter; cumulative remedics (af. A'ny person who intentionally or thirugh gross negligence violates'any_-provision of this chapter, or who falls or refores to comply with a cease and desist order or other order of the department issued thereunder, which action causes a substantial danger to the health of  !

others, shall be liable for a civil penalty not to execed five thousand

-_ dollars (S5,000) for each separate violation or, for continuing intentional violations, for each day that violation continues.

(b) The remedics under this section are in addition to, and do not supersede or liinit, any and all other remedies, civil or criminal.

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4 RECOMMENDATIONS IDENTIFIED IN MORE THAN ONE REVIEW FROM THE OCTOBER 1995 - APRIL 1997 INTEGRATED MniERIALS PERFORMANCE EVALUATION PROGRAM (IMPEP) REVIEWS INTRODUCTION The Integrated Materials Performance Evaluation Program (IMPEP) is the Nuclear Regulatory Commission's (NRC's) approach to review Agreement State and NRC Regional materials radiation control programs. This report provides a summary of recommendations identified in more than one iMPEP review conducted from October 1995 to April 1997 of four NRC Regional offices, and thirteen Agreement States. This summary is being shared with Regional and Agreement State program managers for your consideration as to whether these weakness may be present in your programs, Reports of the completed IMPEP reviews conducted during FY 1996 and to date for FY 1997 for the Agreement States can be located on the Office of State Programs Home Page (HTTP://WWW,hSRD.ORNL. GOV /NRC/). Both the Regional and Agreement State reviews are available through the NRC public document room, STAYUS OF MATERIALS INSPECTIONS Recommendations to issue repo ts of findinqs of the inspection to the licensee within 30 days were made.

Recommendations to conduct initialinspections within 6 months of license issuance or withia the provisions of NRC Inspection Manual Chapter (IMC) 2800 were made.

Recommendations to conduct reciprocity inspections according to the provisions of NRC IMC 1220 were made.

Technical Staffino and Trainina Recommenoations were made to several States to devebp a training plan for training and qualifications of license reviewers and inspectors.

Recommendations were made to fill existing vacant positions.

TECHNICAL QUAllLY, OF INSPECTION Recommendations were made that a policy of Nnual supervisory accompaniments of all materials inspectors be adopted or implemented ENCLOSURE 2

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2 BESPONSE TO INCIDENTS AND ALLEGATIONS Recommendations were made to several States that they use the' draft " Handbook l on Event Reporting in the Agreement States (Handbook)," published March 1995,-

for review and reporting of material events to NRC.

Recommendations were made that States begin reporting current material events to NRC and that they send in information on past events identified that were not previously reported to NRC.

LEGISLATION AND REGULATIONS Recommendations were made to several States to promulgate compatible regulationc within the secommended three year time frame, d

- SEALED SOURCE AND DEVICE (SS&D) EVALUATION PROGRAM Recommendations were made regarding need for review of the Quality H Assurance / Quality Control (QA/QC) Programs of SS&D manufacturers.

Recommendations were made to several States to adopt raguladons compatible with !O CFR 30.32 (g) and 10 CFR 32.210 in order to maintain an effective SS&D evaluation program.

LOW-LEVEL RADIOACTIVE WASTE DISPOSAL PROGRAM ,

Recommendations were made to States to keep records of the staff members'- '

training. '

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