ML20209A813
| ML20209A813 | |
| Person / Time | |
|---|---|
| Issue date: | 06/18/1999 |
| From: | Mclean M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Snellings D ARKANSAS, STATE OF |
| References | |
| NUDOCS 9907060153 | |
| Download: ML20209A813 (8) | |
Text
.* *. 1 0 '*% UNITED STATES l p g NUCLEAR REGULATORY COMMISSION I
$ ,E REGloN IV k, 611 RYAN PLAZA DRIVE, sulTE 400
~* ARUNGToN, TEXAS 76011-8064 yj June 18,1999 l
1 Mr. David Snellings, Director l Division of Radiation Control and Emergency Management Department of Health ,
4815 West Markham Street, Slot 30 I Little Rock, Arkansas 72205-3867 I
Dear Mr. Snellings:
This year's annual meeting with Arkansas was held on May 25,1999. The purpose of this meeting w'as to review and discuss the status of Arkansas's Agreement Stato program. The NRC was represented by Dwight Chamberlain, Mark Shaffer, and myself from NRC's Region IV's office, and Lloyd Bolling from the NRC's Office of State Programs. '
I have completed and enclosed a general meeting summary, including any specific actions that will be taken as a result of the meeting.
i If you feel that our conclusions do not accurately summarize the meeting discussion, or if you have any additional remarks about the meeting in general, please contact me at (817-860-8116) or e-mail mim1 @nrc. gov to discuss your concerns.
Sincerely, l
4 A m&~
M. Linda McLean l
Regional State Agreements Officer .
Enclosure:
As stated r cc w/ encl:: Paul Lohaus, Director, OSP 3
9907060153 990618 PDR STPRO ESGAR PDR ,
I AGREEMENT STATE ANNUAL MEETING
SUMMARY
FOR ARKANSAS Date of Meeting: May 25,1999 ATTENDEES:
NRC Dwight Chamberlain, Director, Division of Nuclear Materials Safety
. Lloyd Bolling, Agreement State Project Officer, Office of State Programs (OSP)
Linda McLean, Regional State Agreements Officer Mark Shaffer, Regional State Agreements Officer ARKANSAS DEPARTMENT OF HEALTH David Snellings, Director, Division of Radiation Control and Emergency Management Jared Thompson, Supervisor, Radioactive Material and Mammography Section Bernard Bevill, Supervisor, Quality and Evaluation Section i DISCUSSION The following is a summary of the meeting held in Little Rock, Arkansas, on May 25,1999, between representatives of the NRC and the State of Arkansas. During the meeting, the topics
- suggested in a letter dated March 30,1999, from Mrs. McLean to Mr. Snellings were discussed. The discussion pertaining to each topic is summarized below.
Action on Previous IMPEP Review Findinas The previous Integrated Materials Performance Evaluation Program (IMPEP) review was conducted during the period March 23-27,1998, with the findings discussed in a meeting between the State and the IMPEP Management Review Board (MRB) on June 16,1998. The results were issued in a final report dated July 8,1998. At that time the MRB found that Arkansas' radiation control program was adequate to protect public health and safety and compatible with NRC's program. The recommendations made in the final report are listed below followed by a summar9 of the State's actions in response to each recommendation and the staff's recommendation as to closure of the item. .
RECOMMENDATIONS-
- 1. The review team recomrnends that the Division continue to develop and implement the civil penalty of the updated escalated enforcement procedure in or to enhance its compliance program. -
l CURRENT STATUS Arkansas' Division of Radiation Control and Emergency Management (Division) implemented Procedure RAM-03.8," Escalated Enforcement Actions"in 1998. In addition, the Division has continued its use of management conferences as an effective L.._.
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Arkansas Periodic Meeting Summary !
es::alated enforcement practice. Since the March 1998 IMPEP review, six management conferences have been conducted.
It is recommended that this item be closed at the next IMPEP review.
- 2. The review team recommends that the Division continue efforts to move its reciprocity inspection program towards the guidelines established in IMC 1220.
CURRENT STATUS t The Division has developed Procedure RAM-03.9, " Guideline for Compliance inspection Frequency of NRC/ Agreement State Reciprocity Licensees'." In 1998, the Division
. performed 10 priority I and 11 reciprocity inspections of 17 notices, and 9 priority lli
~ inspections of 22 notices.
It is recommended that this item be closed at the next IMPEP review.
- 3. The review team recommends that the Division proceed expeditiously with its review and updating of compliance program guidance.
CURRENT STATUS The Division has been working on reviewing and updating its compliance program guidance for its materials program as well as for its X-Ray program. Four materials' procedures have been written and are in the process of being reviewed. An action plan that addresses the Division's completion of the guidance documents.has been developed. The Plan's completion date is December 31,1999.
' It is recommended that this item remain open.
- 4. The review team recommends that the Division staff revise the license reviewer guidance, including checklists, to address comprehensive radiation protection program reviews, annual program audits, and the need for financial assurance. -
CURRENT STATUS .
Following the 1998 IMPEP Review, the license reviewers were instructed to give special attention to the licensee's or applicant's comprehensive radiation protection program reviews, annual program audits, and the need for financial assurance. Four license reviewer procedure revisions have been drafted and need only final review and sign-off.
An action plan has been developed and has a completion date of July 31,1999.'
It is recommended that this item remain open.
- 5. The review team recommends that the State adequately document and closely follow i the progress of investigations of incidents through close out.
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Arkansas Periodic Meeting Summary CURRENT STATUS The Division stated that they have performed appropriate and thorough investigations when deemed necessary, and that they have been documented adequately. During 1998, the Division responded to 77 different incidents and/or radiation events and 32 events in 1999. Most of these events involved NORM. Three of the events required NMED entry.
It is recommended that this item be verified at the next IMPEP review.
- 6. "he review team recommends that the State continue to report events and participate in the NMED system by providing event information and close-out status to be added to the NMED system or by providing compatible information in accordance with the guidance contained in the " Handbook on Nuclear Event Reporting in the Agreement States.
CURRENT STATUS The Division has developed internal policies and procedures for the use of the NMED systern. Staff training has been provided on the implementation of these procedure and the Division has successfully submitted event information into the NMED system.
It is recommended that this item be closed at the next IMPEP review.
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- 7. The review team recommends that any events involving a defective device or source in a device, be evaluated for possible generic implications and such information passed on to the manufacturer and NRC.
CURRENT STATUS Since the last IMPEP review, the Division has not investigated any events that involve defective devices or sources in a device. The Division stated that they are very sensitive to these issues and in the event an apparent defective device is discovered, the NRC and the vendor will be promptly notified.
It is recommended that this item be closed at the next IMPEP review.
Strenaths and Weaknesses of the Proaram The Division identified the following program strengths:
High technical quality of licensing actions, Significant management oversight since the 1998 IMPEP review by the supervisors and the Quality and Evaluation Section staff, L
Arku..Jas Periodic Meeting Summary Demonstration of strong department management support for the Division's budgetary and programmatic actions, Ability to hire experienced, qualified technical personnel at above entry level salary, Ability to manage emergency response activities and incident investigations with limited number of experienced staff, Competent, hard working technical staff.
The Division identified the following program weaknesses:
Regulation revision process is cumbersome and lengthy. It can take 8-13 months to get ,
regulations promulgated, Division operating procedures and administrative processes and practices are outdated, Limited training opportunities for professional staff because of reduced funding for training (individual promotion / advancement is dependent upon attending training courses),
Staff resistance to the adoption of a questioning attitude and to change its approach in identifying and solving problems, Existing resources are challenged by a wide variety of responsibilities, including radiological and non~-radiological emergency response.
Recent or Pendina State Proaram Chanaes Chanaes in Proaram Staff
- To date in 1999, two health physicists (HP) and one administrative assistant left the radioactive materials (RAM) program. One HP transferred from mammography to RAM.
The second HP position will be posted after 7/1/99. An HP (X-ray) and the administrative assistant positions have been filled. -
Proaram Reoraanizations/ Redistribution of Responsibilities in May 1998, all of the RAM program activities was placed under one Division supervisor.
. Leaislative Chanoes Three new acts are currently in progress that will impact the Division: 1) the Radiologic Technologist Licensure Program,2) the appropriation for the Radiologic Technologist Licensure Program, and 3) the Department of Health's Appropriation Bill.
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Arkansas Periodic Meeting Summary Channes in oroaram budaet or fundina.
The basic Division budget has remained static except for an increase in salaries.
Registration and license fees have not changed.
Internal Proaram Audits or Self Assessments The Division's Quality and Evaluation Section is responsible for performing internal program audits. New RAM inspectors' qualifications have been evaluated to assess the individual's ability to perform material compliance inspections. Division management have also performed many inspector accompaniments.
Status of Alle .ations Referred by NRC to the Arkansas Radiation Control Proaram There were no allegations forwarded to the Division during this time period.
Compatibility of Aareement State reaulations Since the 1998 IMPEP Review, the Division has not revised its Rules and Regulations.
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An action plan has been implemented to address the required revisions. The action plan starts June 1999 and should be completed by April 2000.
Nuclear Material Events Database (NMED)
After the 1998 IMPEP Review, the Division aggressively worked on the development of intemal NMED policies and procedure. Division staff found that the NMED system is difficult to use. The Division requested additional training on NMED.
Other issues The State contacted licensees identified as having activities that may be impacted by Y2K problems. The licensees included accelerator, teletherapy, and high-dose rate afterloader facilities. In addition, the Emergency Management Section reviewed and evaluated the alert and notification system associated with Arkansas Nuclear One and found it to be compliant. .
The Division requested further information regarding the allegation forwarded to the NRC Region i Office.
The Division mentioned that a pool irradiator facility may initiate activities again in Arkansas and, if so, will be applying for a radioactive materiallicense. Specific
- concems relating to mechanical and electrical engineering reviews were discussed. In addition, in anticipation of a license application, the Division requested to be provided
' with any NRC information or guidance documents on radiation induced concrete embrittlement.
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l Arkansas Periodic Meeting Summary The Division briefly discussed: 1) the NRC's handling of the Division's medical misadministration at St. Edwards Medical Center, 2) the VA Little Rock inspection,3) and the need for NRC's support for out-of-state training funds.
Schedule for next IMPEP Review The next IMPEP review is scheduled for FY2002.
Action items identified Durino Meetina
- 1. The Division requested additional NMED training for 'he entire staff. (L Bolling and L. McLean)
- 2. The Division requested a copy of the 10 CFR Part 35 compatibility chart.
(L. Bolling) A copy of the Part 35 compatibility chart has been mailed to the Division. This item action can be closed.
- 3. The Division requested future assistance on adopting the new Part 35 regulation.
(L. Bolling) l
- 4. NRC committed to review the handling of the medical misadministration event with regards to informational requests from NRC. (L. Bolling)
- 5. NRC committed to finding out the status on the requested Region l's Office of Investigation (01) report regarding an allegation forwarded from the Division to Region IV. ( L. McLean) On June 11,1999, Region i forwarded a copy of the Ol report to Arkansas. This action item can be closed.
- 6. The Division requested that NRC's Regional training courses, specifically the
" Inspecting for Performance" course to be made available to the States. NRC !
committed to evaluate the ability to offer course slots to States by sponsoring a course in Region IV (L. McLean)
- 7. The Region committed to send a videotape copy of the installation of a gamma knife. (L. McLean) On June 8,1999, information on obtaining a videotape from a vendor was e-mailed from RIV to the Division.
- 8. The Division requested to be provided with any information or NRC guidance on engineering concerns such as radiation lnduced embrittlement of concrete ,
structures. (L. Bolling) J O
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l DOCUMENT NAME: S:\DNMS\SAO\99ARrpt.wpd To receive a copy of this document, indicate in the box: "C" = Copy without
, attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy l OFFICE RIV:SAO D:DNMS g g l f NAME MLMcLean MA' DDChanfe"rlain DATE 06/14/99 06/t y'/99 Distribution: w/enci SPO1 E-mail DCD DChamberlain LMcLean KSchneider, OSP MShaffer Arkansas File LRakovan, OSP CHackney LBolling, OSP LHowell
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