ML20197H701
| ML20197H701 | |
| Person / Time | |
|---|---|
| Issue date: | 05/13/1986 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dandoy S UTAH, STATE OF |
| References | |
| NUDOCS 8605190243 | |
| Download: ML20197H701 (5) | |
Text
l' MAY I ? 1906 Suzanne Dandoy, M.D., Executive Director State Department of Health 288 North 1460 West P. O. Box 16700 Salt Lake City, Utah 84116-0700
Dear Dr. Dandoy:
This confirms the discussion Mr. R. J. Doda held with Messrs. K. E. Alkema, L. Anderson and A. Peart on April 11, 1986, following our current review of the Utah radiation control program.
Mr. P. S. Check, Deputy Regional Administrator, Region IV, NRC, and Mrs. C. Maupin, Office of State Programs were also present at this meeting.
As a result of our review, comments and recommendations were developed including one in a significant Category I indicator (Enclosure 1). The State's Radiation Emergency Response Plan needs to receive appropriate I
approvals and practice drills held to familiarize Bureau of Radiation Control staff with it.
In our discussion with Mr. Alkema, the problems with these particular program areas appeared to have ready solutions. In view of these findings, however, we cannot offer a staff opinion on the adequacy and compat-ibility of the program until after we have reviewed and evaluated the State's responses to our comments and recommendations. Therefore, I would appreciate your review of our recoamendations and receiving your plans to address these program areas. You may wish to have Mr. L. Anderson respond directly to the enclosed technical comments. contains an explanation of our policies and practices for reviewing Agreement State programs.
Also, I am enclosing a copy of this letter for placement in the State Public Document Room or to otherwise be made available for public review.
I appreciate the courtesy and cooperation extended to Mr. Doda during the review meeting.
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r Suzanne Dandoy, M.D. I wish you and your staff success in the continuing development of this program and look forward to our cooperative working relationship.
Sincero y,
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Robert D. Martin Regional Adminstrator
Enclosures:
1.
Comments and Recommendations on the Technical Aspects of the Utah Radiation Control Program for Agreement Materials 2.
Application of " Guidelines for NRC Review of Agreement State Radiation Control Programs" cc: w/ enclosures:
Mr. Kenneth L. Alkema, Director Division of Environmental Health Mr. Larry Anderson, Director Bureau of Radiation Control Mr. G. W. Kerr, Director Office of State Programs State Public Document Room NRC Public Document Room (DMB for Dist. SP01)>#
bec w/ enclosures:
VStello, EDO WLBrown RDMartin RSHeyer-PScheck GFSanborn RLBangart DANussbaumer, SP CEWisner Utah File R. J. Everett
v-ENCLOSURE 1 Technical Comments and Recommendations on-the Utah Radiation Control Program for Agreement Materials I.
Management and Administration A.
Quality of Emergency Planning (Significant Category I indicator) 1.
Comment
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We found that the State's Radiation Emergency Response Plan has not been signed off as an official document as yet.
In reviewing the document for adequacy and completeness, we found it to be acceptable, except for the lack of an NRC emergency telephone number. Other off-duty telephone numbers listed in-the plan were current. Also, no. practice drills had been scheduled by the Bureau of Radiation Control to establish familiarity with the plan's procedures, among staff members.
i Recommendation We reconnend that the State's Radiation Emergency Response Plan be made an official State document and include an NRC l
emergency telephone number. We also recommend that the plan-be tested periodically, at least by the Bureau of Radiation Control, so that all Bureau staff members are thoroughly familiar with the plan's procedures and' requirements.
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B.
Administrative Procedures (Category II indicator) 1.
Comment The Bureau does not have a written procedure for decontamination and termination of licenses. It was noted, however, that the l
Bureau uses the decontamination values' listed in the NRC's document, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses, July 1982."'
Recommendation
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We recommend that the Bureau develop written procedures for.
decontamination and termination of licenses and that staff members become familiar with their use and application.
e II.
Compliance A.
Status of Inspection Program (Category I indicator of minor significance) 1.
Comment Our review disclosed that 29 licenses in Priority I and II were overdue for inspection. Of these, 15 licenses were overdue by more that 50% of the State's inspection frequency for the specific categories of licensees involved. We believe this comment is of minor significance because the Bureau has a written inspection plan with projected due dates to bring these licenses up to a current status. Also, the Bureau has been coordinating this activity with our Region IV office for the past 5 months, over which time the inspection backlog has dropped from 64 to the present 29 overdue inspections.
Recommendation We recommend that the Bureau continue their plan for completing all overdue inspections and continue to keep our Region IV office apprised of progress.
B.
Inspection Frequency (Category I indicator of minor significance) 1.
Comment During the review of the Bureau's policy regarding inspection frequencies for various categories of licensees, we found one category where an inspection frequency was not specified, similar to NRC's inspection frequency. This category was for initial inspections of new licensees. We believe this is a minor comment since the Bureau's practice is to conduct initial inspections of new licensees at approximately a 6-month period, even though not specified as a written policy. The NRC inspect-ion priority system is contained in IE Manual Chapter 2800. A copy of the current version was furnished on April 10, 1985.
Recommendation We recommend that the Utah program provide a written statement in its inspection priority system so that all categories of licensees receive initial inspections at intervals at least as frequent as under the NRC system. Initial inspections of new licensees should occur within 6 months or 1 year after radio-active materials are received and operations under the license have begun, depending on their priority.
W ENCLOSURE 2 Application of " Guidelines for NRC Review of Agreement State Radiation Control Programs" The " Guidelines for NRC Review of Agreement State Radiation Control Programs,"
were published in the Federal Register on December 4, 1981, as an NRC Policy Statement. The Guide provides 30 indicators for evaluating Agreement State program areas. Guidance as to their relative importance to an Agreement State program is provided by categorizing the indicators into 2 categories.
Cdtegory I indicators address program functions which directly relate to the State's ability to protect the public health and safety. If significant problems exist in several Category I indicator areas, then the need for improvements may be critical.
Category II indicators address program functions which provide essential technical and administrative support for the primary program functions. Good performance in meeting the guidelines for these indicators is essential in order to avoid the development of problems in one or more of the principal program areas, i.e., those that fall under Category I indicators. Category II indicators frequently can be used to identify underlying problems that are causing, or contributing to, difficulties in Category I indicators.
It is the NRC's intention to use these categories in the following manner.
In reporting findings to State management, the NRC will indicate the category of each comment made.
If no significant Category I comments are provided, this will indicate that the program is adequate to protect the public health and safety. If at least one significant Category I comment is provided, the State will be notified that the program deficiency may seriously affect the State's ability to protect the public health and safety and should be addressed on a priority basis. When more than one significant Category I comment is provided, the State will be notified that the need of improvement in the particular program areas is critical. The NRC would request an immediate response, and may perform a followup review of the program within six months.
If the State program has not improved or if additional deficiencies have developed, the NRC may institute proceedings to suspend or revoke all or part of the Agreement. Category II comments would concern functions and activities which support the State program and therefore would not be critical to the State's ability to protect the public. The State will be asked to respond to these comments and the State's actions will be evaluated during the next regular program review.
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