ML20236E531
| ML20236E531 | |
| Person / Time | |
|---|---|
| Issue date: | 10/22/1987 |
| From: | Kammerer C NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Ledbetter J GEORGIA, STATE OF |
| References | |
| NUDOCS 8710290261 | |
| Download: ML20236E531 (7) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 gg Q$
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881 OCT 29 A 9 51 1
00T t 21987 1
James G. Ledbetter, Ph.D.
' Commissioner Georgia Department of Human Resources State Office Building 47 Trinity Avenue Atlanta, GA 30334
Dear Commissioner Ledbetter:
This is to confirm the discussion Mr. Richard L. Woodruff, NRC State Agree-ment Representative, held on September 2,1987, with Mr. Martin J. Rotter, Ms. Marjorie F. Smith, and Mr. Thomas E. Hill following our review and evaluation of the State's radiation control program.
We are pleased to find that the State has responded to our comments made following our 1986 review.
In particult.r, we noted that the Georgia Rules and Regulations for Radioactive Materials, Chapter 290-5-23 were updated and became
-l effective on May 26, 1987. Also, the State has continued to make progress on the overdue inspections plan that was implemented following our 1983 review, and the overdue inspections are scheduled to be eliminated by the end of this fiscal year.
As a result of our review of the State's program and the routine exchange of information between the Nuclear Regulatory Comission and the State of Georgia, the staff determined that overall, the Georgia program for regulation of agreement materials is adequate to protect the public health and safety and is compatible with the Comission's program. contains coments regarding the technical aspects of our review of the program. These comments were discussed with Mr. Hill and his staff during our exit meeting with him. Mr. Hill was advised at the time that a response to these findings would be requested by this office and you may wish to have Mr. Hill address the Enclosure 1 comments.
An explanation of our policies and pract. ices for reviewing Agreement State programs is attached as Enclosure 2.
/. iso, a copy of this letter is included for placement in the State Public Document Room or otherwise to be made available for public review.
On April 12, 1987, NRC reorganized its staff. The State Agreement Program is now a part of the new Office of Governmental and Public Affairs, which reports to the Comission. One purpose of this organizational change was to provide an improved focus for NRC relationships with the States. Our regional offices 8710290261 071022 g$
PDR STPRG ESGG
OCT 111987 l
James G. Ledbetter, Ph.D.
2 will continue to administer and implement NRC's regulatory programs. We encourage you and your staff to continue to look to the Regional Administrator and his staff as the primary contact with NRC.
I appreciate the courtesy and cooperation extended by your staff to Mr. Woodruff during the review.
}
Sincerely, original si2acd by Carlbn Kammeror Carlton Kammerer, Director State, local and Indian Tribe Programs
Enclosures:
1.
Comments and Recommendations 2.~
Application and Guidelines cc w/encls:
Victor Stello, Executive Director for Operations, NRC i
J. Nelson Grace, Regional Administrator, RII Marty Rotter. Director Office of Regulatory Services Thomas E. Hill, Acting Director Radiological Health Section NRC Public Document Room
}
bec w/encis:
R. L. Woodruff Document Control Desk (SP01)
SA R/F Dir R/F Georgia file (1c) w/encls D. A. Nussbaumer
- See previous concurrence.
C. Kammerer RII RII RII RLWoodruff:tj RETrojanowski JNGrace 10/14/87 **
10/14/87 **
10/14/87 **
SLITP:SA SLITP DD SLI 30 EDO DANussbaumer C
rer VSt 10/14/87 **
/ /87 10/g/87 10/zr-/87 Official Record Copy L-
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ENCLOSURE 1 COMMENTS AND RECOMMENDATIONS ON TECHNICAL ASPECTS OF THE GEORGIA RADIATION CONTROL PROGRAM FOR AGREEMENT MATERIALS 1.
MANAGEMENT-Management is a Category II Indicator. The following coment with our recommendation is made.
1 Coment Supervisory review of inspections, reports and enforcement actions should be performed. The inspection report review should nonna11y be conducted prior to_ the dispatch of any enforcement action which is taken. This management tool provides incentives for timely inspection reports and also helps to assure that the enforcement action adequately reflects the inspection findings. We noted during our review of the inspection-files that an inspection report requiring enforcement action was missing from a file, and several inspection reports were not reviewed by supervision until after the enforcement action was taken.
Recommendation We recomend that all inspection reports be reviewed prior to the issuance of enforcement letters.
II. LICENSING Licensing Procedures is a Category II Indicator. The following coment with our recommendation is made, p.
Coment Standard license conditions and procedures comparable with current NRC standard license conditions and procedures should be used to expedite and provide uniformity in the licensing process.
A.
The NRC uses a standard license' condition Number 43 on nuclear pharmacy licenses for the " pick up" of waste from customers. This condition is tied specifically to the licensees procedures which are evaluated in accordance with the licensing criteria outlined in our Policy and Guidance Directive FC 85-14, Section 10.9.
The license condition used by the state for the return of waste to the nuclear pharmacies is too general in scope and could permit collection of other waste that is outside the intent of the NMSS Policy and Guidance Directive FC 85-14.
l 4
2 B.
Proce.dures used by NRC to evaluate the safe use of strontium-90 eye applicators require the license applicant to provide information on the type of personnel monitoring devices.used and how they are worn (e.g. whole body film badge and/or TLD finger badge worn with the TLD i
on the palm-side of the hand). The State's procedures also require the same personnel monitoring information; however, the eye applicator sample selected for review needed more_information to' fully _ document the use of personnel monitoring devices.
Recommendation i
A.
We recommend that the State revise their standard license condition.
that allows nuclear pharmacies to pick-up specific waste from customers,-in accordance with the NRC standard condition Number 43 i
and the Policy and Guidanca Directive FC 85-14..
i B.-
We recomend that " eye applicator" license files have complete l
documentation of the personnel monitoring devices and procedures used by the licensee.
j III. INSPECTION REPORTS Inspection Reports is a Category II Indicator. The following coment with i
Our recommendation is made.
Coment A.
Findings of inspections should be documented in a report describing i
the scope of inspections. The documentation should include specifi-callywhatwasinspected(e.g.personsinterviewed,facilitiesor rooms visited, specific records reviewed and sampled, procedures reviewed, and confirmatory and independent measurements).
In some reports, the section on scope of inspection was incomplete and did not fully describe the scope of the inspection activities.
B.
Reports should show the results of confirmatory and/or independent measurements conducted by the inspector. Additional information was needed in some reports to adequately document the results of surveys performed by the inspector.
Recommendation A.
We recomend that the inspection reports be reviewed for details that will adequately describe the scope of the inspections and that inspectors receive appropriate instructions to fully record their insection activities.
B.
We recomend that inspection reports document the results of confirmatory / independent surveys in sufficient detail to establish compitance,
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s I
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ENCLOSURE 2 APPLICATION OF " GUIDELINES FOR NRC REVIEW 0F AGREEMENT STATE RADIATION CONTROL PROGRAMS" The " Guidelines for NRC Review of Agreement State Radiation Control Programs,"
were published in the Federal Register on June 4,1987, as an NRC Policy Statement. The Guide provides 29 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 1 indicators address program functions which directly relate to the r
State's ability to protect the public health and safety.
If significant L
problems exist in one or more 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,nrogram 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.
l 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 and is compatible with the NRL's program.
If one or more significant Category I comments are provided, the State will be notified that the program deficiencies may seriously affect the State's ability to protect the public health and safety and that the need of improvement in particular program areas is critical.
If, following receipt and evaluation, the State's response appears satisfactory in addressing the significant Category I comments, the staff may offer findings of adequacy and compatibility as appropriate or defer such offering until the State's actions are examined and their effectiveness confirmed in a subsequent review.
If additional information is needed to evaluate the State's actions, the staff may request the infonnation through follow-up correspondence or perform follow-up or special, limited review.
NRC staff may hold a special meeting with appropriate State representatives.
No significant items will be left unresolved over a prolonged period. The Comission will be informed of the results of the reviews of the individual Agreement State programs and copies of the review correspondence to the States will be placed in the NRC Public Document Room.
If the State program does not improve or if additional significant Category I deficiencies have developed, a staff finding that the program is not adequate will be considered and the NRC may institute proceedings to suspend or revoke all or part of the Agreement in accordance with Section 274j of the Act.
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j James G. Ledbetter, Ph.D.
Commissioner Georgia Department of Human Resources State.0ffice Building 47 Trinity Avenue Atlanta, GA 30334 4
-i
Dear Commissioner Ledbetter:
This is to confinn the discussion Mr. Richard L. Woodruff, NRC State' Agree-ment Represen'itive, held on September 2,1987, with Mr. Martin J. Rotter, Ms. Marjorie F. Smith, and Mr. Thomas E Hill following our review and evaluation of the State's radiation control program.
We are pleased to' find that the State has responded.to our coments made following our 1986 review.
In particular, we.noted that the Georgia Rules and j
Regulations for Radioactive Materials, Chapter 290-5-23 were updated and became
)
effective on May 26, 1987. Also, the State has continued to make progress on i
the overdue inspections plan that was implemented following our 1983 review, i
and the overdue inspections are scheduled to be eliminated by the end of this fiscal year.
.As a result of our review of the State's program and the reatine exchange of l
.infonnation between the Nuclear Regulatory Comission ant' the. State of Georgia, I:
the staff determined that overall, the Georgia program 'or regulation of agreement materials is adequate to protect the public health and safety and is compatible with the Comission's program. contains comments regarding the technical aspects of our review of
)
the program. These coments were discussed with Mr. Hill and his staff during j
our exit meeting with him. Mr. Hill was advised at the time that a response to these findings would be~ requested by this office and you may wish to have j
Mr. Hill address the Enclosure I coments.
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.
On April 12, 1987, NRC reorganized its staff. The State Agreement Program is now a part of the new Office of Governmental and Public Affairs, which reports to the Comission. One purpose of this organizational change was to provide an improved focus for NRC relationships with the States. Our regional offices
i
)..
l James G. Ledbetter Ph.D.
2 l
l will continue -to administer and implement NRC's; regulatory programs. We J
encourage you and your staff to continue to look to the Regional Administrator and his staff as'the primary contact with NRC.
I appreciate the courtesy and cooperation extended by'your staff to Mr. Woodruff during the review.
Sincerely, Carlton Kamerer, Director.
State, Local and Indian Tribe Programs
Enclosures:
1.
Coments and Recommendations 2.
Application and Guidelines e
cc w/ enc 1s:
Victor Stello, Executive Director for Operations, NRC J. Nelson Grace, Regional Administrator, RII Martin Rotter, Director y
Office'of Regulatory Services
-)
Thomas E. Hill, Acting Director Radiological, Health Section NRC Public Document Room i
i
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