ML20211L900
| ML20211L900 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/1986 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Ellis M IOWA, STATE OF |
| References | |
| NUDOCS 8607020186 | |
| Download: ML20211L900 (6) | |
Text
[
UNITED STATES
[PHigf9,1 NUCLEAR REGULATORY COMMisslON hp g S REGION lli l 7e o 4 f 799 ROOSEVELT ROAD GLEN ELLYN, ILLINots 60137 June 26, 1986 Mary L. Elli:, Acting Comissioner of Public Health Iowa Department of Health Lucas State Office Building Des Moines, Iowa 50319
Dear Comissioner Ellis:
This is to confirm the discussion Messrs. Joel Lubenau and Roland Lickus held with you and your staff on June 6,1986 following our review of the Iowa radiation control program.
The results of our review indicate that the Iowa radiation control program is adequate to protect the public health and safety and is compatible with the NRC and other Agreement States for regulating agreement materials.
Enclosure 1 contains coments regarding technical and administrative aspects of the review. We would appreciate a review and a response to our coments. If you wish, Mr. John Eure, Director, Environmental Health Section, may respond to these comments. Enclosure 2 contains an explanation of our policies and practices for reviewing Agreement State programs. Also enclosed is a copy of this letter for placement in the State's Public Document Room or otherwise to be made available for public review.
I appreciate the courtesy and cooperation extended by your staff to Mr. Lubenau and Mr. Lickus during the review.
Sincerely, mb Na24tehow James G. KeppTdf Regional Administrator
Enclosures:
As stated cc w/ enclosures:
J. Eure, Director, Environmental Health Section -
G. Wayne Kerr, Director, OSP NRC Public Document Room 8607020186 860626 PDR STPRG EsGIA PDR Seo-\ I (
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i l
1 Enclosure 1 1
Comments and Recommendations on Technical and l Administrative Aspects of the Iowa Radiation Control Program for Agreement Materials 1
Managenent and Administration I.
- 1. Administrative Procedures is a Category II Indicator. The I following comment is made with our recommendation.
Comment The radiation control program shculd establish written internal procedures to assure that staff performs its duties as required and to provide a high degree of uniformity in regulatory practices.
The staff has begun development of an administrative procedures manual but additional procedural guidance needs to be developed and documented.
Recommendation We recommend establishing a schedule for drafting and approving the administrative procedures needed for the Agreement program.
Suggestions fe" the content of an administrative procedures manual and examples of such procedures were provided to the staff during the review.
- 2. Quality of Emergency Planning is a Category I Indicator. The following connent of minor significance is made with our recommendation.
Comment While the State understands its role and is prepared to respond to radiological incidents in Iowa, the State should have a written plan for response to such incidents as spills, overexposures, i
transportation accidents, fire or explosion, theft, etc. The State has a radiological emergency plan, but it is specific to nuclear power plant emergencies and portions of it are not appropriate for j other types of radiological emergencies. The radiation control program has taken administrative steps to assure that reports of radiological emergencies not involving nuclear power plants are routed at all times to program staff.
i Recommendation The staff should develop a radiological emergency plan that addresses non-nuclear power plant radiological emergencies and i distribute copies to appropriate persons and agencies.
t II. Personnel L
Staff Supervision is a Category II comment. The following comment is r.ede with our recommendation.
L
y Comment Supervisory personnel should be available to prov'ide guidance, review applications and inspect licensees independently, monitor the work of junior personnel and participate in the establishment of policy. We were pleased with the improvements in the quality of the inspection work we observed in this review (compared to that observed in our orientation meeting in March,1986) and believe it is due, in significant part, to the increased roles of Mr. Flater and Mr. Eure in supervising and otherwise providing guidance to staff, however continued supervisory effort is required.
Recommendation As noted in the following sections on Licensing and Compliance, improvements are needed in these areas. The continued participation of senior and supervising staff are essential to assure that improvements are enacted. In addition, we recommend that non-routine developments, such as the need to assess the radiological implications of the radioactive waste generated at the Wellman-Dynamics site in Creston, receive appropriate review by senior staff. Plans for responses and actions in such cases should be reviewed and approved by appropriate senior and management staff.
III. Licensing Technical Quality of Licensing Actions is a Category I Indicator.
The following connent of minor significance is made with our recommendation.
Comment The radiation control program should assure that essential elements of applications meet current regulatory guidance and are sufficient to establish the basis for licensing actions. While the technical quality of license files that were selected for review were adequate overall, some deficiencies were noted, such as instances where current regulatory guidance was not fully met by the applicants.
Recommendation !
Staff should routinely use available regulatory guides, standard review plans and other appropriate technical references when reviewing applications for adequacy. Supervising staff should monitor-licensing actions for completeness and adequacy. In cases where applications are deficient, applicants should be requested to provide additional information as is necessary to meet current regulatory guidance.
r IV. Compliance
- 1. Enforcement Procedures is a Category I Indicator. Inspection Procedures is a Category II Indicator. ~The following comments of
, minor significance and our recommendations are made.
Comment The Iowa Administrative Code outlines regulatory considerations for escalated enforcement actions. . Additional, implementing procedural guidance is needed. For example, guidance is needed for identifying those who may sign emergency orders and how to obtain such signatures during non-routine work hours. Technical guidance for conducting inspections has been provided to staff but supplemental guidance is needed to address and document practices to be followed by inspection staff. Our accompaniments of inspectors and reviews of inspection reports indicated that, performance was satisfactory, however, additional guidance is needed for:
o Conducting and documenting entrance and exit meetings with license management representatives, o Categorizing the seriousness of violations, o Issuing notices of violations, and o Preparing and fully completing inspection reports.
Recommendation We recommend establishing written procedures for these areas as appropriate. NRC procedures may be used and examples of these'were provided to the staff during the' review.
l 2. Independent Measurements is a Category'11 Indicator. The following
! comment with our recommendation is made.
l Consnent l
Confirmatory Measurements should be sufficient in number and type
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l to confirm the adequacy of the 11censee's control program and
! validate the licensees' measurements. Inspections of nuclear- ,
! medicine programs should -include surveys for removable i contamination and should be performed by taking smears of
! potentially contaminated surfaces. This' technique _is especially
- needed for low energy beta emitters.and to detect surface contamination in the presence of elevated gansna levels.
! Reconsnendation ,
We recommend smear surveys for. removable contamination be routinely
, - performed during inspections of licensed nuclear medicine programs i and of other licensed programs where there is a potential. for contamination.
1 l
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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.
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 one significant Category I comment is provided, l
the State will be notified that the need of improvement in the particular program areas is critical. The liRC would request an immediate response, and may perform 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 l 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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,,, pa rato UNITED STATES g *g NUCLEAR REGULATORY COMMisslON
[ S REClON111 5 f 799 ROOSEVELT ROAD
% GLEN ELLYN, ILUNOIS 60137 June 26, 1986 Mary L. Ellis, Acting Commissioner of Public Health Iowa Department of Health Lucas State Office Building Des Moines, Iowa 50319
Dear Commissioner Ellis:
This is to confirm the discussion Messrs. Joel Lubenau and Roland Lickus held with you and your staff on June 6,1986 following our review of the Iowa radiation control program.
The results of our review indicate that the Iowa radiation control program is adequate to protect the public health and safety and is compatible with the NRC and other Agreement States for regulating agreement materials.
Enclosure 1 contains comments regarding technical and administrative dSpects of the review. We would appreciate a review and a response to our comments. If you wish, Mr. John Eure, Director, Environmental Health Section, may respond to these comments. Enclosure 2 contains an explanation of our policies and practices for reviewing Agreement State programs. Also enclosed is a copy of this letter for placement in the State's Public Document Room or otherwise to be made available for public review.
I appreciate the courtesy and cooperation extended by your staff to Mr. Lubenau and Mr. Lickus during the review.
Sincerely, James G. Keppler Regional Administrator
Enclosures:
As stated cc w/ enclosures:
J. Eure, Director, Environmental Health Section .
G. Wayne Kerr, Director, OSP NRC Public Document Room
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