ML20207P868
| ML20207P868 | |
| Person / Time | |
|---|---|
| Issue date: | 01/13/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Jarrett M SOUTH CAROLINA, STATE OF |
| References | |
| NUDOCS 8701200348 | |
| Download: ML20207P868 (4) | |
Text
,d 4 N M: l t
mi a m Nd Mr. Michael D. Jarrett Consnissioner South Carolina Department of Health and Environmental Control J. Marion Sims Building 2600 Bull Street Columbia, South Carolina 29201
Dear Commissioner Jarrett:
This is to confirm the discussion Mr. Richard L. Woodruff, NRC State Agreements Representative, held on November 21, 1986, with you and Mr. Heyward G. Shealy following our review and evaluation of the State's Radiation Control Program.
As a result of our review of the State's program and the routine exchange of information between the Nuclear Regulatory Commission ands the State of South Carolina the staff determined that overall the South Carolina program for
. regulation of agreement materials is adequate to protect the public health and safety and is compatible with the Commission's program. However, the staff also noted the need for improvement as noted below.
One area of concern is staff continuity.
Staff continuity is a Category II Indicator.
Since June 1983, the Division of Licensing and Compliance has lost nine trained, senior technical persons to other jobs.
The reason given for these turnovers was career advancement.
We are concerned that such a turnover rate could affect adversely the quality of the program and we would encourage taking steps to provide more continuity.
We also noted that the State does not have specific' job positions for the supervisors of the three technical sections within the Division.
However, the Bureau has proposed that new job positions be established for each technical section supervisor.
We fully support the estab-lishment of supervisory positions for each section with the increased salary
. ranges as appropriate. We believe this action will help minimize the turnover of your trained, senior people.
We would appreciate receiving your plans and comments regarding staff continuity in the Bureau of Raditlogical Health.
' contains comments regarding the technical aspects of our review of the program.
These comments were discussed with Mr. Shealy and his staff during our exit meeting with him. Mr. Shealy was advised at the time that a response to these findings would be requested by this office and you may wish to have Mr. Shealy address the Enclosure 1 comments.
An explanation of our policies and practices for reviewing Agreement State programs is attached as Enclosure 2.
Also, a copy of this letter is included for placement in the State Public Document Room or otherwise to be made available for public review.
MO<
i n 8701200348 870113 PDR STPRG ESGSCPDR
Michael D. Jarrett 2
I appreciate the courtesy and cooperation extended by your staff to Mr. Woodruff during the review.
1 Sincerely C'
J. Nelson Grace Regional Administrator
Enclosures:
1.
Comments and Recommendation on Technical Aspects of the South Carolina Radiation Control Program 2.
Application of " Guidelines for NRC Review of Agreement State Radiation Control Programs" cc w/encls:
Heyward G. Shealy, Director-Bureau of Radiological Health G. Wayne Kerr, Director Office of State Programs, NRC NRC Public Document Room bec w/encls:
R. L. Woodruff pocumentControlDesk(SP01) 4 e
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'NO 86
y ENCLOSURE 1-COMPENTS AND RECOMMENDATIONS ON TECHNICAL ASPECTS OF THE SOUTH CAROLINA RADIATION CONTROL PROGRAM FOR AGREEMENT MATERIALS LICENSING Licensing Procedures is a Category II Indicator. The following comment with our recommendation is made.
COMMENT Standard license conditions and procedures comparable with those of the NRC should be used to expedite and provide uniformity in the licensing process.
1.
The standard " user" condition utilized for " private practitioners" stipulates that material shall be used by, or under the supervision of (the individual physician)." The phrase "...under the supervision of..." should be reserved for institutional licensees who may be authorized to train other physicians.
2.
Some of the State's " fixed gauge" licensees do not have an inventory requirement in their license.
The NRC uses a standard license condition (number 78, dated November 1985) on all fixed gauge licenses to require six month inventory of all sources and devices received by the licensee.
RECOMMENDATION We recommend that the State utilize the following procedures:
1.
Licenses issued to individual physicians or practitioners should clearly indicate that the license does not authorize the individual user to train other physicians or practitioners in the use of the material.
2.
Licenses authorizing the use of " fixed gauges" should have a standard requirement to inventory all sources and devices received under the l
license.
~
4 o
ENCLOSURE 2 APPLICATION OF " GUIDELINES FOR NRC REVIEW 0F AGREEEMENT 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 two categories.
Category 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 ene 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 perfonn a follow-up 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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