ML20202B337
| ML20202B337 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1998 |
| From: | Hornor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Bailey E CALIFORNIA, STATE OF |
| References | |
| NUDOCS 9802110185 | |
| Download: ML20202B337 (4) | |
Text
I by 9
e Puu M *timg UNIT E D ST ATIS
.bM
[g>
NUCLEAR REGULATORY COMMISSION Mff b
RE GION IV 611 RYAN PLAZA DRIVE. Sulf E 400
[
ARLINGTON, TE XAS 760118064 g
]
9 cu January 29, 1998 h
J-o u>
73 2
Edgar D. Bailey, Chief Radiologic Health Branch Food, Drugs and Radiaton Safety Division
'E State Department of Health Services S!
601 North 7th Street, Mail Stop 178 P.O. Box 942732 Sacramento, CA 94234 7320
' Daar Mr. Bailey:
Since California is not scheduled for an Integrated Materials Performance Evaluation Program (IMPEP) review for FY 38, we request a meeting, no longer than one day, to discuss your
- Agreement State program and share programmatic information. This letter confirms that, after previous coordination, the meeting is scheduled for Wednesday, March 4,1998, b3 ginning at
- 8:15 a.m. In your offices. Mr. Richard Blanton, Office of State Programs, assigned as Project Officer for California, will be the other NRC representatWe in attendance.
The topics to be discussed at the meeting will include:
1.
Your State's actions on previous IMPEP review findings. (We have enclosed pages from Final Report dated June 18,1997 )
2.
Strengths and weaknesses of the California program as identified by the State or NRC.
3.
Status of recently completed State program or policy changes under development including:
a.
Changes in program staff (including pending changes such as scheduled retirements) b.
Program reorganizations c.
Legislative changes d.
Redistribution of responsibilities e.
Changes in program budget or funding.
4.
Status of NRC program changes that could impact Agreement States (such as loss of funding for training, new changes to Part 35, etc.).
I
\\
5.
Any internal program audits or self assessments condented by the Agreement State Radiation Control Program such as QA evaluations, field office audits, inspector accompaniments, financial audits, etc.
9802110185 980129 PDR STP8!G ESGC Qg p ennwr l.lH.H. i.ll.ll.lll< ll ggg4
j Edgar Bailey
- Page 2 6.
Status of allegations referred by NRC to the Califomia radiation control program for action, and methods used to resolve allegations that have been closed.-
Please include all allegations referred since the previous IMPEP review and any other open allegations.
7.
Compatibility of Agreement State reguletions. (Where is the State with regard to regulations that are required for compatibility?)
8.
Nuclear Material Events Database (NMED) reporting. (How is the system -
working?)
9.
- Schedule for th9 next IMPEP review, if there are any additional specific topics you would like to cover, or if you would like to focus on a specific area, please let me know.
If you have any questions, please call me at 510-975-0224, or e-mail to jwh3@nrc. gov.
I Sincerely,
& $ ls
. Jack W. - Homor Region IV State Agreements Officer enclosure: as stated f.
cc: Richard Bangart, Director OSP
- Ross Scarano, Director DNMS, RIV Dean Kunihiro, RSLO,RIV, WCFO Charles Hackney, RSLO,RIV Richard Blanton, ASPO, OSP Linda McLean RASO, RIV
Recommendations from 1996 California IMPEP review 1.
The review team recommends that the State consider keeping a collective staff training record to help formalize technical training as an ongoing requirement for the position and to better allow management to assess the training level of the staff. Waivers granted to individual staff members, from ats ince at specific training courses, based on past education and experience should be cocumented. (Section 3.2) 2.
The review team recommends that the Stats take action necessary (renew the calibration contract) in order to maintain the instrument calibraticn schedule. (Section 3.4) 3.
The review team re%mmends that the State make a concerted effort to adopt regulations which are requ! red 'er compatibility and are overdue for adoption. A special effort should be made to adopt the amendments on Notification of incidents, the irradiator rule and the Definition of Land Disposal and Waste Site QA program amendment. Cue to the safety benefits attendant to the QM rule, the State is encouraged to adopt a compatible QM rule. (Section 4.1) 4.
The review team recommends that the State exert areater management oversight over the SS&D evaluation program. The team believes that such oversight is needed to assure fullimplementation of the recommendations in this area, given that some recommendations from the 1994 followup program review have not been fully addressed. (Section 4.2)
I 5.
The review team recommends that the State consider adopting regulations compatible l
with 10 CFR 30.32 (g) and 10 CFR 32.210. (Section 4.2) l 6.
The review team recommends that the State determitie and document in evaluation certificates whether sealed sources approved for use in well logging applications meet l
the requirement for insoluble as practicable. (Section 4.2) 7.
The review team recommends that the State review and possibly modify the Section 1.8 of ADAC Laboratories' users manual which appears to condone direct hand contact with the sealed source. (Section 4.2) 8.
The review team recommends that the State obtain SS&D training for those staff members that have not yet had or have limited SS&D training either by using training offered by NRC or another Agreement State program. (Section 4.2) 9.
The review team recommends that the State develop a policy position on including information on the usefullife of a product and using operational history data to augment prototype testing when evaluating SS&D. (Section 4.2) 10.
The review team recommends that the State determine the actual use conditions for those gauging sources that do not meet the ANSI standard classification for vibration and evaluate the need to modify SS&D sheets if the condition of use is typical for industrial gemma gauging devices as indicated in ANSI N-542. (Section 4.2)
11.
The review team recommends that the Stste re-evaluate the Nova R&D inc., model Cindi neutron device with special attention to the potential exposure received by the general licensed user. If it is determined that the exposure rate exceeds that which is allowed for persons covered under the generallicense, the device should be reclassified for distribution to persons covered under a specific license and the SS&D evaluation certificate should be amended to reflect any required changes. (Section 4.2) 12.
The review team recommends that the State fully implement a program of peer review of SS&D evaluations as a technical quality assurance measure. (Section 4.2) 13.
The review team recommends that the State amend the appropnate industrial Nuclear Inc., SS&D certificates. (Section 4.2) 14.
The review team recommends that the State f.evelop a checklist er internal procedures to follow when approving products for distribuCon to persons covered under a general license. (Section 4.2) 15.
The review team recommends that the LLRW program consider keeping official records of each staff member's technical training and participation in workshops, conferences, etc., in the individuars training files. (Section 4.3) 3
__