ML20246Q135

State Cost Sharing of Training.A Task Force Report

ML20246Q135
Person / Time
Issue date:	08/31/1989
From:	Flater D, Hughes D, Lubenau J, Merges P, Mobley M, Jonathan Montgomery, Raglin K NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA)
To:
References
NUREG-1356, NUDOCS 8909110360
Download: ML20246Q135 (117)

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1 NUREG-1356. l L. 1 L { L l 4 .. State Cost Sharing of Training A Task Force Report Manuscript Completed: June 1989 - Date Published: August 1989 - J. M. Montgomery, Chairman D. A. Flater, D. R. Hughes, Sr., J. O. Lubenau P. J. Merges, M. H. Mobley, K. A. Raglin State, I4 cal and Indian Tribe Programs . Office of Governmental and Public Affairs U.S. Nuclear R,.,jilatory Commission Washington, DC 20555 f-s %.....),,

'[ k L i r k' ABSTRACT In March 1988,:the Office of Governmental and Public Affairs (GPA) of the U.S. Nuclear Regulatory Commission (NRC) completed a report (NUREG-1311) entitled " Funding the NRC Training Program for States." This report was prepared in response to a Commission request that a study of NRC's long-standing practice of paying the travel and -per diem costs of State personnel who attend NRC-sponsored training be performed. 'In May 1988, the NRC Chairman endorsed the report.in most respects but asked that the cost sharing of travel and per diem costs be studied further.. As a result, the Director of GPA's State, 'y Local and Indian Tribe Programs (SLITP) established a task force consisting of representatives from the Conference of Radiation Control Program Directors, Inc.. the Agreerent States, and the NRC to examine ways that the States can share the costs of NRC. training, particularly. travel and per dies costs. At the request of the Director, GPA, the task force also examined related cost and quality issues associated with the NRC training program for State personnel. This report includes a discussion of NRC and State perspectives on the issue of sharing travel and per diem costs, a discussion of options, and recommendations for likely cost savings and improvement in the quality of training. iii

i l l l t. CONTENTS Page . ABSTRACT............................................................ iii TASK FORCE CHAIRMAN' S TRANSMITTAL MEMORANDUM........................ v ii EXECUTIVE

SUMMARY

..................................................... I 1. INTRODUCTION..................................................... 7 2. LEGISLATIVE HISTORY.............................................. 8 3. TASK FORCE FINDINGS............................................. 12 4. CONCLUSIONS.......,............................................. 24 5. RECOMMENDATIONS................................................. 26 6. REFERENCES...................................................... 28 APPENDICES A. CHARGE TO THE TASK FORCE B. TASK FORCE MEMBERSHIP C. STATE QUESTIONNAIRE AND RESPONSES 0. STATE FUNDING OF TRAINING E. TRAINING CURRICULUM FOR NRC INSPECTORS F. COST SAVINGS TO THE NRC FROM THE STATE AGREEMENTS PROGRAM G. NRC POLICY STATEMENT GUIDELINES FOR AGREEMENT STATES TRAINING H. OTHER FEDERAL FUNDING OF STATE TRAINING v

- - - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - - ' - - - - ~ ~ - - fif %g - UZlTED STATES - _'y [ NUCLEAR RESULATORY CEMMISSION j i,5 REGION IV I 811 RYAN PLAZA DRIVE, SUITE 1000 - ARLINGTON, TEXAS 70011 g l JUN I 31989 MEMORANDUM FOR: Carlton C. Kansnerer, Director ~ State, Local and Indian Tribe Programs, GPA i

FROM:

John M. Montgomery-Deputy Regional Administrator

SUBJECT:

TRANSMITTAL OF TASK FORCE REPORT Attached you will find NUREG-1356, the report.of the State Cost Sharing for Training Task Force requested by you. I hope you are as pleased with the Task Force product as I am. Our members worked long and hard to address difficult issues and provide you our best advise on schedule. While we have identified a range of options for increasing.the state share of funding training, we do not recommend that NRC modify the balance at this time. Our reasons are outlined in detail in the report. In response to Harold Denton's request for a review of..other aspects of the training program, we have provided a set of recommendations for improving what is aircady a quality program. The task force members are to be commended for their efforts in bringing our work to a successful conclusion. I also would like to recognize.the -substantial assistance of Elizabeth Hayden of Harold Denton's staff; Deborah Dorsey of SLITP, and Connie Spagnoli, Region IV, who provided administrative assistance. / Y$ /duk@%f(' hohnM.Mo6*fAhlstrator "^ Deputy Regiona L vii

STATE COST SHARINC OF TRAINING EXECUTIVE

SUMMARY

From a Federal U.S. Nuclear Regulatory Commission (NRC) perspective, the State Agreements Program is an attractive means of implementing a major portion of the health and safety mission of the NRC as it relates to radioactive materials and low-level waste. The 29 Agreement States regulate approximately two-thirds of the users of radioactive materials in the United States and a major portion of the nation's low-level waste activities. The program is funded and administered individually by the 29 Agreement States except for the NRC oversight function and the NRC training program for the States. Each new Agreement State saves NRC staff and fiscal costs. Although no agreements have been terminated, additional NRC staff and fiscal resources would be requirec for the NRC to assume the regulatory burden if any were terminated. The task force that the NRC established to study State cost sharing of training estimated that savings attributable to salary, benefits, travel, and overhead costs for direct licensing and inspection alone wculd total at least $18 million annually. This may still be a conservative estimate of the total costs, since it does not include capital, contract, and other support costs. The program is viewed as a good contract by all parties with NRC training viewed as an essential part of the contract. Despite the recognized benefits of the existing Agreement States' costsharing arrangements, budgetary pressure has caused the NRC to question many of its longstanding expenditures. The NRC budget has decreased from a peak of $475 million in 1984 to $420 million in 1989. The funding provided for Agreement State training, currently budgeted at $695,000 annually, is just one of those expenditures. Of this amount, $390,500 is associated with travel and per diem expenses of State personnel. From both a budgetary and an appropriateness standpoint, the question has been asked why the States cannot pay a greater share of the training costs, particularly the travel and per diem costs. In March 1988, the Office of Governmental and Public Affairs (GPA) of the NP,C completed a report (NUREG-1311) entitled " Funding the NRC Training Program for States." This report was prepared in response to a Commission request that a study of NRC's longstanding practice of paying the travel and per diem costs of State personnel who attend NRC-sponsored training be performed. In May 1988, the NRC Chairman endorsed the report in most respects but asked that a cost-sharing approach be studied further. As a result, the Director of GPA's State, Local and Indian Tribe Programs (SLITP) established a task force consisting of State and NRC representatives to examine NUREG-1356 f J

( ways that the States can share the costs of NRC training, particularly travel and per diem costs. The Conference of Radiation Control Program Directors, Inc. (CRCPD) and the Agreement States provided I four representatives to the task force: Donald R. Hughes, Sr., j Kentucky; Michael H. Mobley, Tennessee; Paul J. Merges, New York; and Donald A. Flater, Iowa. Kenneth A. Raglin, Director of the NRC Technical Training Center, and Joel 0. Lubenau, Senior Project Manager, SLITP, represented the NRC. John M. Montgomery, Deputy Regional Administrator, Region IV, NRC, chaired the task force. ] The task force held its organizational meeting in March 1989. In addition to its initial assignment of examining the issue of State 4 sharing of travel and per diem costs for NRC training for States, i Harold R. Denton, Director, GPA, also asked the task force to examine { related cost and quality issues associated with the NRC training program j for State personnel. j The task force began its deliberations with the generally accepted premise that States were not funding travel and per diem costs for j NRC-sponsored training. As a result of early discussions, it became clear that this was not true. In addition, the task force found that the question of paying for travel and per diem costs was only one i of a number of important issues that needed to be considered. These additional issues are also addressed herein. The task force sought Agreement States' views on the central issue of sharing travel and per dicm costs and obtained information not previously available on current States' sharing of training costs. The task force members also reviewed the newly developed training standards for NRC health physics personnel, familiarized themselves with the NIC Technical Training Center's capabilities, and held extensive discussions on quality and cost issues related to NRC training for State personnel. The conclusions of the task force are: (1) The State Agreements Program is a model of Federal-State cooperation to protect the public health and safety. The NRC State Agreements Program has been reviewed by the General Accounting Office, an internal NRC task force, and the National Governors' Association. Their reports consistently identified the NRC training program for States as a key to enabling States to prepare for such agreements and to maintain State Agreements programs that are adequate to protect public health and safety and are compatible with the Commission's program. Their reports also contained recommendations to expand the NRC State training program. The program has been relatively stable and trouble I free and has been responsive to both unique regional and State characteristics and to Federal oversight direction. The State Agreements Program differs from most other Federal-State l NUREG-1356 2 I

Il 1 l> =) L cooperative. programs in that there are no Federal grant or contract monies to the States to carry out their programs. Since States receive-no direct Federal funding for their l programs, it is clear that it is not Federal money that causes the effectiveness of this program. The task force believes it is;the support the NRC has supplied through the years by providing training and technical-assistance ~to States. This support has enabled the States to develop professional staffs-that maintain effective radiation control-programs;and has resulted in State good will and' State [ cooperation and competence. ~ (2) With regard to travel and per dies costs, the task force found that States already fund such.on occasion. The task force examined a number of mechanisms for addressing additional L funding by States but found that none were equitable and effective. It is clear that the reduction or elimination ~of funding will have a negative effect on the States' participation .in the training offered by the Commission. (3) For most States,.out-of-State travel is necessary to attend NRC training courses. Authorization for this travel is frequently difficult to obtain by State personnel. In many cases, approval for NRC training is possible only because no State funds (other than salary) are expended. At.any given time, there are some States for whom this is not a problem but this changes from year . to year. There are always some States for whom this is a critical problem. (4) On occasion even NRC funding of out-of-State travel costs does not result in approval. In such cases, State personnel attend training on their own time, at considerable personal' sacrifice. One State member of this task force attended task force meetings under exactly these circumstances and was required to take annual leave to do so. (5) SLITP has already adopted a number of cost-savings measures, including the use of low-cost facilities, presentation of selected courses in the field, and use of videotapes and videotelecommunications. Although such measures should continue to be encouraged, the. task force does not believe ~ that significant additional savings will be realized in these areas.. ($) The respontes of Agreement States to further cost sharing was not ~ favorable. Some Agreement States found it incredible that or had conceptual problems understanding how the NRC could conceive that further restrictions on training of State personnel would result in a benefit to anyone. _ Others would accept additional cost sharing, but this would have a negative effect on their overall programs. A few States would consider turnback of their agreements as a response. The 29 Agreement States NUREG-1356 3-

a, _ i l e l 1. R . administer 16,000 licenses or an average of 550 licenses per-

State. Termination of an. Agreement State program with this average number of' licenses would require 7.7 full-time equivalents and would result in $470,000 in salary and benefit

costs alone if NRC were to replace the. program at the same level of effort._ This exceeds the $390,500 NRC budgeted in 1989 for travel and.per diem costs for training State personnel.

q (7).The' training program administered by SLITP for the. Agreement States appears reasonable in content and scheduling,-although some States believe the availability of courses could be improved. Some changes in this training may be appropriate in light of recently developed NRC training standards for NRC materials and' fuel cycle regulatory staffs. This should be examined. If changes are made_to present courses, care should - be.taken to ensure that' the present quality it maintained. l (8) SLITP needs more information from the States on training needs i when planning the resources' required of SLITP to train State personnel.z Better prioritization and planning of training are essential if. SLITP is to make meaningful projections of training needs for budget purposes. (9) The quality'of training is a. key factor in the continued ability of,the States to provide adequate and compatible implementation of the health and safety mission under the agreements. The task force is unanimous in believing that classroom-style presentations, including instructor-student and student-student interactions and, as appropriate, the use of laboratories, field work and exercises, and class composition r that increases State and NRC personnel interaction, are critical to maintaining and improving quality and compatibility. (10) Special training needs will arise in response to regulatory ~ changes or new regulatory programs 'and must be planned in e advance. In the near term the revisions to 10 CFR Part 20 and effective implementation of the requirements of 10 CFR Part 61 will require additional NRC training for States that will license new low-level radioactive waste disposal sites. ) On the basis these of conclusions, the task force recommends the following: '(1) _. Recognizing that States currently share travel and per diam costs for training courses when possible, SLITP should encourage States to' continue to do so. The fact that a State is not able to share these expenses should not become a factor in selecting nominees to attend necessary courses. l (2) SLITP should encourage the States to develop in-house training including, when feasible, extending invitations to nearby States l 'NUREG-1356 4

I to attend. Such regional training can be very cost effective and should be supported by the NRC, for example, by providing instructors and other training resources. (3) The NRC and the CRCPD should establish a standing review committee to periodically assess NRC-sponsored training provided to States. Examples of functions of this committee include review and evaluate course content, review the feasibility of expanded use of the NRC Technical Training Center, and offer recommendations on maintaining and improving the quality and cost effectiveness of training and the adequacy of meeting training needs. (4) The task force advocates that most of the training continue in a traditional instructor-student environment with emphasis on " hands-on" learning such as through the use of laboratories, field work, and exercises. Therefore, cost savings provided by non-traditional training alternatives vould be limited if the instructor-student and " hands-on" recommendations were followed. (5) SLITP should review and, when appropriate, endorse program-related training courses for which the States can fund the total costs. Such an endorsement could make it easier for State radiation control programs to obtain necessary State approval and funds for these courses, thus supplementing NRC-sponsored courses. (6) The Office of Governmental and Public Affairs should identify special training needs for inclusion in NRC's 5-year plans. Special training needs arise as a result of regulatory initiatives or from other sources. The recent, comprehensive revision to 10 CFR Part 20 is an example. Another example is the Low-Level Radioactive Waste Policy Act and subsequent amendments, which place the primary responsibility for the disposal of low-level radioactive waste on the States. As a result, staffs in Agreement States that will host a disposal site need training pertaining to the requirements of 10 CFR Part 61 and the associated regulatory guidance. (7) Added emphasis should be placed on expansion of opportunities for both NRC and State employees to attend the technical ccurses together. (8) Additional on-the-job training should be encouraged by having the NRC regions provide more opportunities for State inspectors to accompany NRC inspectors, by encouraging more State inspectors to accompany inspectors from other States, and by having more NRC inspectors accompany State inspectors. This cross-training should provide for more efficient and effective inspections by pooling experience and knowledge among the States and the NRC and NUREG-1356 5

i ~ 1 1' l: should help ensure compatible programs to protect the public l health and safety. (9) Given the-level of concern expressed by the States, the Commission should reaffirm its continuing support for the State Agreements Program and its willingness to-continue to be.a reliable partner in efforts to protect the public health and safety. l I NUREG-1356 6

1. INTRODUCTION 1.1 History On February 3,1988,.the Commission was briefed on the status of the State, Local and Indian Tribe Programs (SLITP). During the briefing Lando W. Zech, Jr., Chairman of the Office of the Commissioners said: I appreciate the cooperation and the assistance extended by the State and Indian Tribe representatives in helping us to ensure the public health and safety. They perform an important service to our agency and to our country. Following the Chairman's comment, Commissioner Frederick Bernthal said: You will undoubtedly hear a great deal about the success of the Agreement States. Much, if not all, is true. NRC's Agreement State Program is often cited as one of the finest examples of Federal-State cooperation operative today. The National Governor's Association in its 1983 report on the NRC State Agreements Program noted: Much of the credit for the continuing high performance of State programs is attributed to the training received in the Nuclear Regulatory Commission courses. NRC training for States is an important factor in maintaining State Agreements programs that are adequate to-protect public health and safety and compatible with the Comission's program. At the briefing on February 3,1988, the Commission endorsed the NRC training program but questioned the longstanding practice of paying travel and per dies costs of State personnel selected to attend NRC-sponsored training and requested a staff report on funding for States' travel and per diem expenses at NRC training courses for States. InMarch1988,theOfficeofGovernmentalandPublicAffairs(GPA) completed a report (NUREG-1311) entitled " Funding the NRC Training Program for States." This report was prepared in response to a Commission request that a study of NRC's longstanding practice of paying the travel and per diem costs of State personnel s NUREG-1356 7 - - _ _ _ _ _ _ ~

who attended NRC-sponsored training be performed. In May 1988, the Chairman endorsed the report in most respects but asked that a cost-sharing approach be studied further. As a result, the Director, SLITP, established a task force consisting of representatives from the Conference of Radiation Control Program Directors, Inc. (CRCPD), the Agreement States, and the NRC to examine ways that the States can share the costs of NRC training, particularly travel and per diem costs (Appendix A). 1.2 Task Force. Membership The CRCPD and the Agreement States were asked to nominate representatives to the task force. Donald R. Hughes, Sr., Kentucky, Michael H. Mobley, Tennessee, Paul J. Merges, New York, and Donald A. Flater, Iowa, were appointed to the task force. Kenneth A. Raglin, Director of the NRC Technical Training Center, and Joel 0. Lubenau, Senior Project Manager, SLITP, represented the NRC. John M. Montgomery, Deputy Regional Administrator, Region IV,) NRC, chaired the task force. (Biographies are given in Appendix B. 1.3 Purpose The task force held its organizational meeting.in March 1989. In addition to its initial assignment of examining the issues of States sharing travel and per diem costs for NRC training for States, Harold R. Denton, Director, GPA, also asked the task force to examine related cost and quality issues associated with the NRC training program for State personnel. 1.4 Approach The task force sought Agreement States' views on the central issue l of sharing travel and per diem costs (Appendix C) and obtained I information not previously available on current State sharing of trainingcosts(AppendixD). The task force members also reviewed the newly developed training standards for NRC health physics l personnel (Appendix E); familiarized themselves with the NRC j Technical Training Center's (TTC's) capabilities, including holding j a task force meeting at the TTC; and held extensive discussions on 4 quality and cost issues related to NRC training for State personnel. l l The remainder of this report discusses further the task force's i findings, conclusions, and recommendations. 2. LEGISLATIVE HISTORY Bef' ore the enactment of the Atomic Energy Act of 1954, activities j in the United 1,tates pertaining to nuclear energy were largely confined to the Federal Government. The Act made it possible for private commercial firms to enter the field for the first time. NUREG-1356 8

Because of the hazards associated with nuclear materials, Congress determined that these activities should be regulated under a Federal licensing system to protect the health and safety of workers in the nuclear industry end the public.* The NRC is the Federal agency currently charged with this responsibility. Although protection of the public's health and safety has traditionally been a State responsibility, the Atomic Energy Act of 1954 did not specify such a role for the States in nuclear matters. This policy was changed in 1959 when Congress enacted Section 274 of the Atomic Energy Act, " Cooperation With States." Section 274 spells out a State role and provides a statutory basis under which the federal Government can relinquish to the States purtions of its regulatory authority. The 1959 amendment made it possible for the States to license and regulate byproduct material (radioisotopes), source material (the raw materials of atomic energy), and small quantities of special nuclear material. The Commission is required, however, to retain regulatory authority over the regulation of nuclear facilities such as reactors, exports and imports of nuclear materials and facilities, larger quantities of fissionable material, consumer products, facilities vital to the national common defense and security, and certain types of radioactive wastes. The development of Section 274 w6s summarized by the NRC staff in a 1977 report on the State Agreements Program (NUREG-0388): Atomic energy activities, prior to 1954, were virtually under a Federal monopoly. The Federal Government was solely responsible for the production and use of nuclear material, and participation by industry in nuclear technology was limited essentially to performance of Government contracts. With the enactment of the Atomic Energy Act of 1954, it became possible for private enterprise to enter the field and to use nuclear materials and operate nuclear facilities in a manner consistent with our national traditions in other fields of free enterprise.

• Readers should note that the Atomic Energy Act docs not apply to most naturclly occurring radioactive materials and to accelerator produced radioactive materials. See NUREG-0301, " Regulation of Naturally Occurring and Accelerator Produced Radioactive Materials,"

and NUREG-0976, " Regulation of haturally Occurring and Accelerator Produced Radioactive Materials, An Update." NUREG-1356 9

l l-l Because the uses of nuclear materials involve the use of radiation, they necessarily involve considerations of public health and safety. The Congress, therefore, determined that private activities in this field should be regulated under a system of licensing in order to protect radiation workers and the public against radiation hazards. The Atomic Energy Comission (AEC) was charged by the Congress with this responsibility. Protection of public health and safety, however, has traditionally been a function of the States. With the development of a private atomic energy industry, organizations which were subject to the laws of the States in other areas of public health became subject to the laws of the Federal Government insofar as radiation safety in the use of nuclear materials was concerned. But under the Federal law it was not all clear what role, if any, was left to the States. Many States were, therefore, concerned as to what their responsibilities, if any, might be; they had a very real interest in seeing that the t>oundaries of Federal and State authority in this area were more clearly drawn. The need to amend the Atomic Energy Act of 1954 to permit increased participation by the States had been a subject of concern to the Joint Comittee on Atomic Energy (JCAE) and AEC since its passage. AEC had instituted several specific programs which were designed to assist and cooperate with States and had participated in the activities of local and regional comissions. AEC notified State agencies of licenses _ issued and invited State officials to participate in Comission inspections of licensed activities. An Advisory Comittee of State officials was set up in 1955 to aid iti the preparation of regulations to establish " Standards for Protection Against Radiation" (10 CFR Part 20). In July 1957, AEC proposed a bill which would have permitted dual regulation by both Federal and State governments of byproduct, source and special nuclear material. Section 274, " Cooperation With States" was enacted and signed into law in 1959. Paragraph 2741. states, in part: The Comission is also authorized to provide training, with or without charge to employees of, and such other assistance to, any State or political subdivision thereof or group of States as the Comission deems appropriate. Any such provision or assistance by the Comission shall take into account the additional expenses that may be incurred by 1 State as a consequence of the State's entering irt-an Agreement with the Comission pursuant to subsect 5 b. NUREG-1356 10

Even before the enactment of Section 274, AEC had cooperated with and assisted in establishing State and local educational and training programs in the atomic energy fields. However, the AEC budget did not specify State training as a separate item. The purpose of specifically providing for State (and local) training in Section 274 was extensively comented upon by Congress. The legislative reports on the House and Senate bills quoted AEC General Manager Luedecke's letter of May 13, 1959 to Chairman Anderson: To assist the States to prepare themselves for assuming the 1957 bill)gulatory jurisdiction, the new bill (likespecifically authorizes the C independent re provide training and other services to State officials and employees....The training and other services furnished to the States...would be intended to assist the States to prepare for, and carry out, independent State radiation protection programs. Additional reasons for the training authorization were set out in the House and Senate reports, which noted that "it is not intended that a cash grant shall be provided to pay for administration of State regulatory programs" and the authorization "shall take into account the additional expenses that may be incurred by the State as a consequence of the State entering into an Agreement with the Comission." The reports noted that training would also enhance the capability of State and local health officers to deal with x-rays and radium, "thus, further protecting the public health and safety." With respect to the costs of Comission training for States, Representative Van Zandt noted during a House floor discussion of the bill that led to Section 274 that "there might be some expensesintrainingpersonnelandinadministeringsuchaprogram, but it would be minute, compared to the AEC budget as a whole. Section 274 was subsequently amended in 1978 by the Uranium Mill Tailings Radiation Control Act of 1978, which requires Agreement States regulating uranium and thorium tailings resulting from recovery operations to adopt certain technical and procedural requirements. The 1978 amendment also requires NRC to periodically review Agreement State programs for adequacy to protect public health and safety and compatibility with the Comission's program. In 1980 Congress added a new subsection to Section 274 to permit the NRC to temporarily suspend all or part of an agreement without notice or hearing in certain emergency situations where the State has not undertaken an adequate response. (However, notice to the Governorisrequired.) This is in addition to existing authority, which permitted the NRC to terminate or suspend an agreement after reasonable notice and opportunity for hearing. NUREG-1356 11

3. TASK FORCE FINDINGS

3.1 Background

From a Federal (NRC) perspective, the State Agreements Program is an attractive means of implementing a significant portion of the health and safety mission of the NRC pertaining to radioactive materials and low-level waste. The 29 Agreement States regulate approximately two-thirds of the users of radioactive materials in the United States and a major portion of the nation's low-level waste ectivities. ~ According to SLITP data, the States currently accomplish this mission using a total professional staff of approximately 210 full-time equivalents (FTEs). The professional staff size in individual States q ranges from 1.1 to 28.3 FTEs. State staff turnover averages about 8 percent, although in individual States it can range up to 75 percent. This creates a continuous need for training.* = The program is funded and administered entirely by the 29 individual Agreement States primarily through a combination of State general revenues and fees. This funding includes such things as salaries and benefits for the staff, travel, management, and clerical support. This all constitutes cost savings from a Federal perspective with the following exceptions. The first is the NRC oversight function. The NRC maintains a relatively small oversight group in its Office ofGovernmentalandPublicAffairs(GPA),oneStateAgreements officer in each of the five regions, and some additional resources in the NRC to provide technical assistance to the States. The costs incurred are for a total of 16 technical FTEs plus overhead and travel costs. The primary responsibilities of the GPA and the regional staffs are to monitor State program implementation to ensure that minimum standards are met, ensure compatibility is maintained among and between the Agreement States and the NRC, and determine when technical assistance is needed and arrange for or provide it. The second exception involves training. The NRC funds and administers a training program for the States that provides both the training and most of the funding for travel and per diem costs to attend the training sessions. In FY 1989, $695,000 is budgeted for the State training program and approximately $390,500 of that is associated with travel and per diem expenses of State personnel. It is the $390,500 in travel and per diem expenses that is the principal focus of this task force review.

• State staff turnover is discussed in more detail in NUREG-1311

" Funding the NRC Training Program for States," pages 19-20. NUREG-1356 12

It is also useful to recall.that the State Agreements Program has the image of being a "model" of Federai-State cooperation to protect the public health and safety. By all accounts, its actual implementation lives up to this image. Those familiar with the program and its history recognize that it has lived up % its goals. The program has been relatively stable and trouble free and responsive to both unique regional and State characteristics and Federal oversight and direction. It remains a prime example of the public policy philosophy that shifts program delivery closer to the constituent in the belief that both effectiveness and efficiency will benefit. This program exemplifies the best of that philosophy. Although the t6sk force would not say that State implementation of this mission is necessarily better than it would be if delivered by the NRC, it can conclude that it is less costly with no discernible difference in quality. Therefore, the State Agreements Program can be described as one that is of vety special value to the taxpayer cnd one in which Congress, the NRC, and each Agreement State can take justifiable pride. Despite the recognized benefits of the existing Agreement States' costs-sharing arrangements, budgetary pressure has caused the NRC to standing expenditures. The NRC budget has question many of its long$475 million in 1984 to $420 million in decreased from a peak of 1989. The funding provided for A;;reement States' training, particularly the travel and per diem portion, is just one of those expenditures. From both a budgetary and an a >propriateness standpoint, the question can be asked as to w1y the States cannot pay a greater share of the training costs, particularly the travel and per diem costs. From an NRC budgetary perspsetive, any further savings in the State 5 training program area could be used for other important NRC responsibilities. As budget pressures have continued, the funding for the State training program has remained under scrutiny, as a function that could be funded by non-NRC monies. From the States' perspectives, there are a number of responses to the question of why further cost sharing on the States' part would not be acceptable. In addition to responding to specific questions asked on bel.i of the task force, tabulated in Appendix C, the States found it incredible that or had conceptual problems understanding how the NRC could conceive that further restrictions on training of State personnel would result in a benefit to anyone. The present NRC-sponsored training program is absolutely essential for an effective State Agreements program. It provides training that would not otherwise be available to most States. It provides a ferum for interaction between State staffs that enhances the NUREG-1356 13

l transferability of important regulatory experiences and therefore improves compatibility. It provides a mechanism for ensuring continuity between State programs, as well as ensuring that the programs are compatible with the NRC's. Although there may be actions that can be taken to make the training more cost effective, such actions should ensure that training continues at the current {' level of excellence and that adequate opportunities for State training remain available. If the concern relative to Agreement States' training is purely on the basis of cost or cost savings, the States can only suggest a review of NUREG-1311, where it was noted that for a training expenditure of $520,000 in FY 1988 (47 percent of which is for travel and per diem costs), the Agreement States save the NRC more than $13 million annually. The only further ccament in this regard the States would make is that the $13 million saving is a very conservative estimate. (SeeAppendixFwhich onthetaskforce'supdatedfigureof$18million.)providesdetails Furthermore, States pursue a great amount of NRC activity as part of their routine i operations that cannot be directly accounted for; for example, assisting l the NRC in responding to national emergency situations without cost to the NRC. The States' perspectives are the following: (1) They entered into their respective agreements with the understanding that the NRC was to provide such training as part of a contractual obligation. (2) Resources (e.g., dollars per student, dollars per Agreement State, dollars per numbers of State personnel) for this training already have decreased. Further reduction or elimination would be cause for a State or States to reconsider their part in the agreement. (3) The reduction of funding for training is a unilateral action by the NRC with negative consequences for the Agreement State partnership. A number of Agreement States have indicated t1ey would consider giving up the agreement if the NRC reduced its share of funding for training (see AppendixC). A number of factors make some States unable to hire persons with health physics backgrounds. Therefore, training after a person has been hired is essential. In many cases, health physics positions are covered by broader job descriptions that allow hiring of personnel without any basic health physics training. State affirmative action programs also open opportunities for persons not having training specific to health physics to move into this field. These factors, along with NUREG-1356 14

the State's inability to arovide adequate salaries to attract persons having a health p1ysics background, have created a greater demand for health physics training at the State level than that which existed previously. As noted earlier, turnover in staff creates a continuing need for training. The States already contribute a significant share of the staff training costs. States pay for some of thei 7.aff members to attend NRC training (AppendixD). States provide on-the-job training to new staff members. (Appendix D). In many cases, States provide training that is supplementary to the NRC-supplied training lsee Appendix D). The cost to States to ~ assume the travel and per diem costs would directly affect the ability of. States to provide the augmented training. The costs of picking up the travel and per diem costs that the NRC currently pays would be significantly higher for the States because they cannot take advantage of Federal contract rates. States also find that additional training is needed because of changes made at the Federal level that require institutional retraining for effective implementation. The new comprehensive revision to 10 CFR Part 20 and the existing Part 61 are current examples. Part 20 revisions will affect every technical staff member in the States. In addition, with the current proliferation of planned low-level waste sites, many States have a great need to have their technical staff trained in Part 61 requirements and associated guidance. The NRC has provided formal training and technical assistance and played a supportive role in the development of compatible independent radiation control programs within the Agreement States. This " nurturing" is quite different from that of most other Federal agencies that deal with States by providing large amounts of money, little professional or technical support, and a vast amount of oversight, even to the point of having oversight staffs for a State that are larger than the State program staffs. Such Federal programs are more expensive than the NRC's and probably less productive from a cost and protection viewpoint. By encouraging the development of professional State program staffs and actively supporting the development of a professional State program, the NRC has established a large local health physics presence in many States that would not otherwise exist. Consequently, the NRC has realized the benefits of its efforts many times during emergency or other unusual situations (e.g., the incident involving the contaminated steel from Mexico and the 3M leaking static eliminator) when States through their programs have been able to operate independently and aggressively to address a crisis on behalf of their Federal partner in carrying out its mission to protect the public health and safety. NUREG-1356 15

e The States believe:it is much more cost effective to make a srall,upfrontinvestment(e.g.,trainingcosts)forprevention than to risk inadequate regulation and then have to pay an extraordinary amount to clean up a situation that could have been prevented. Without NRC-sponsored training, State programs will become less effective, which translates over time into less effective licensee programs or emergency response activities. This can create problems related to radiation control, environmental contamination, facility closures and so forth. Such a situation would not be in the best interest of the States, the NRC, and the public. g l Finally, it may be totally immaterial whether States have the funding for travel to attend training. In many cases, the fact that training requires out-of-State travel may preclude a State from expending any funds because out-of-State travel is prohibited or severely discouraged. In some situations, it is difficult to obtain permission to send personnel even when the NRC is paying for the travel. When the NRC does pay for the travel, it is much easier to deal with such administrative constraints. Although these constraints may vary from year to year, they remain a reality for some States at any given time. 3.2 Training Needs The task force examined the curriculum for the training of State personnel and considered a number of factors including the following: (;) existing curriculum content (2) the logical progression through a curriculum (3) scheduling fitxibility for a curriculum (4) thenumberofstudentsaccommodated(throughput)withina curriculum (5) available resources to implement a curriculum (6) the cost effectiveness of implementing a curriculum (7) training considered necessary for State personnel e (8) comparison of existing (or desired) State training guidelines with those for NRC materials personnel ' D NUREG-1356 16

(9) the potential advantages of utilizing existing or planned NRC training programs The NRC guidelines on training for States' staffs are provided by the Commission in its 1981 Policy Statement on criteria for States seeking agreements and'its 1987 Policy Statement on reviewing State Agreements programs (see Appendix G). This training of State personnel is implemented by NRC's State, Local and Indian Tribe Programs (SLITP) and is primarily administered through program support funds provided as part of the NRC budget. The typical curriculum and the budget values to support it are documented in NUREG-1311, " Funding the NRC Training Prog $490,000 ram for States." Since 1981, this training budget has averaged per year and has varied from a low of $345,000 to a high of $600,000 over the period 1981 to 1988. The amount budgeted for FY 1989 was $695,000. Of this budgeted amount,$304,500 is associated with contract costs and $390,500 is associated with travel and per diem costs of State personnel. The typical curriculum is organized into two groups of courses, those that are considered minimum " core" training for State regulatory staffs and those that are additionally recommended. In NRC technical training terminology, these groups could be considered " required" and " supplemental." These courses are listed below. Also included are the number of presentations of the courses in FY 1989. The latter data include courses not offered at all because of budget restraints. Required Core Training Course Nunber.of. Presentations Health Physics 2 Nuclear Medicine 2 Safety Aspects of Industrial Radiography 1 Licensing Orientation 1 Inspection Procedures 2 Supplemental Recommended Courses Course Number of. Presentations Transportation of Radioactive Materials 1 Safety Aspects of Well Logging 1 Radiological Engineering 1 Radiochemistry Not offered Teletherapy Calibration Not offered Management Not offered Biological Effects of Radiation Not offered Nt! REG-1356 17

The student throughput.for the minimum core training varied from 24 to 50, and the student throughput for the supplementary courses varied up to 25. The majority of these students were state personnel, but SLITP training also accommodates NRC headquarters and regional staffs, when requested, and personnel from the U.S. Navy and U.S. Air Force who administer very large broad-scope licenses issued by the NRC to these two agencies. Factors influencing student throughput are physical constraints imposed by the training facility and the nature of the training activity, which affects the maximum size of a class that can be effectively managed. As currently constructed, States are not asked to formally establish training qualification goals. Reaching these goals qualifies a State person to do particular tasks. The task force believes this should be done. Under current NRC practice, the NRC goal is to permit individuals to conduct independent inspections only after formal technical training requirements as well as other requirements listed in regional qualifications journals have been completed. There should also be a program for refresher training. Since the issuance of the current policy statements regarding training for Agreement States (Appendix G), the NRC has developed formal training requirements for NRC regulatory staff. The task force agreed that there are.a number of common subject areas in which training is usually necessary for State and NRC regulatory staffs to adequately perform their duties. Examples are fundamentals of licensing, nuclear medicine, industrial radiography, inspection procedures, transportation of radioactive materials, and well logging. There was a consensus that training in all areas may not always be appropriate for every member of State or NRC staffs. On the other hand, there are many areas of common training needs. The task force concluded that the NRC policy statement on training should be reexamined in light of the recently developed training specifications for NRC regulatory staff. Such an examination should focus on training needs that are common to NRC and State staffs. In such cases, SLITP and the NRC Technical Training Center (TTC), when feasible, could utilize common training courses while retaining the flexibility to respond to the special training needs of each group's constituencies. Such curriculum convergence could offer advantages of economy of scale. Additionally, by ensuring a mix of NRC and State staffs in classes, the program can take advantage of professional exchanges by NRC and State students in the same courses. Such an arrangement could also allow substantially more scheduling flexibility for both the NRC staff and the States' staffs. There could typically be multiple opportunities to attend a given course during a given year, rather than the more limited opportunities currently available. Of the $695,000 in the FY 1989 training budget, $331,500 (48 percent) is associated with a single course that is normally offered twice a year. This is the health physics course conducted by Oak Ridge Associated Universities (0RAU) over a period of 5 weeks. As discussed elsewhere in the report, training provided by this course is absolutely essential to States. Of the $331,500 budgeted for two presentations of the health physics course, $238,500 is associated with the contract costs for the courses and $93,000 is associated NUREG-1356 18

with the travel and per dies costs for State personnel to attend the courses. This course has an excellent reputation, but the task force examined whether other more cost-effective ways to provide this training could be found. Primarily because of better salaries, the NRC can typically hire persons to fill health physics positions who have education and experience specific to radiation protection while the States typically cannot. Provision must continue to be made in training plans to accommodate this difference in background before scheduling NRC and State personnel as students in the same courses. State experience has been, and the task force agrees, that the aforementioned 5-week health physics course by ORAU reduces the disparity in qualifications between Agreement States and NRC entry-level personnel, although the ORAU course is certainly no substitute for a health physics degree. A revised curriculum that provides a shortened version of the ORAU course (to save contract costs) coupled with supplementary TTC courses may also meet these requirements. A detailed analysis of this option or variations of it particularly with respect to overall cost savings, including travel and per dies costs, was beyond the scope of the task force study, but it is recommended for future i.ensideration by SLITP, The task force explored various ways to save money within the NRC budget or at least optimize the use of money that has been budgeted. The most promising idea is modifying the existing SLITP curriculum to converge the NRC and State curricula as much as possible. The current use of low-cost facilities, which was done in response to a Commission request to make the training more cost effective, is effective considering all factors and should be expanded where possible. NUREG-1311. " Funding the NRC Training Program for States," identifies Federal and commercial training facilities that are available at minimal e.ost. The task force noted that, although not mentioned in NUREG-1311, the NRC's own Technical Training Center in Chattanooga, Tennessee (which is centrally located among 10 Agreement States), corpares very favorably with most of the identified sites. The task force concluded that a more objective means to rank in priority order State personnel who require NRC training is needed. As examples some requests for State training are for the purpose of supplementing other skills or responsibilities (e.g., those of supervisors and persons proposed by State programs for cross-training). For others, whose primary duties are licensing and inspection, the training is much more critical. More definitive data on critical or essential training needs of States would greatly enhance SLITP's ability to plan the training for States and protect the resources needed to implement HUREG-1356 19

it. More realistic training projections would enable the NRC to conserve its resources, would make the training program for States more cost effective, and could result in additional cost savings. If States were to improve their planning for training including setting priorities for app 1tcants, a more stable training schedule and student population would result, allowing better long-term use of limited training resources. 3.3 Training Methods Several methods of conducting the State training were considered. These methods include classroom instruction, laboratories, field work and exercises, workshops, videotapes, computer-based training or interactive videodisc applications, teleconferencing,-and other l alternative training methods. The task force recommends the use of l videotapes for training courses as a substitute for classroom instruction I only as a last resort. These "talkinD head" videos allow no interaction by the student and typically become boring very quickly. Professionally done videotapes generally require the use of carefully followcd scripts l-and actors and are resource intensive. Use of computer-based training or l interactive videodisc products for these specific problems are not considered feasible; first, because of normally high costs to produce quality applications, and second, because of the uncertain availability and high costs of requisite hardware at State locations. l The potential use of teleconferencing or satellite broadcasting is considered promising, particularly for situations in which information needs to be disseminated to large numbers of people or to multiple locations. (SLITP is planning such a teleconference in September 1989 to provide training to States on the revision to 10 CFRPart20.) Use of laboratory or field facilities is necessary and appropriate for certain courses such as the health physics course by ORAU and the courses on safety aspects of well logging and safety aspects of industrial radiography; however, this places limitations on course location and class size. The use of classroom instruction (lecture and discussion) or workshop activities, including instructor-student and student-student interactions and as appropriate, field work and exercises, is considered highly preferable to maintain quality training. 3.4 Cost Sharing of Travel and per Diem Expenses The task force identified several options for increasing the Agreement States' share of the training program. These include: (1) assessing each State some specific percentage of the travel and per diem costs of each training course l attended t NUREG-1356 20

(2) developing a "needs test," that is, using a formula to determine which States "need" NRC funding and which could either pay their own way or pay some greater share of the training program and requiring well-financed States to pey a greater share (3) increasing the number of courses taught "in-State" and requiring the States to pay for all in-State travel expenses (note that many States voluntarily cover their own in-State travel expenses for training purposes already) (4) adopting an arrangement similar to that used by the Federal Emergency Management Agency (FEMA), whereby air fare and lodging are paid by FEMA and ground transportation and meals are paid by the States (see Appendix H) (5) having the NRC pay for all courses required for States to meet " core" program requirements and having the States pay for any supplemental or recommended training (6) "grandfathering" training for existing Agreement States and requiring any new Agreement States to fund all of their training costs (7) encouraging Agreement States to fund a greater share of the travel and per diem expenses if they have the financial and administrative means to do so The first option would have the effect of eliminating or reducing the training attended for those States whose administrative and policy practices do not allow approval of out-of-State travel funding or whose budgets cannot support any additional expenditures on training. Such an option could increase the administrative workload for SLITP. Under this option every State would be treated the same; therefore, it might be viewed as a fairer solution than some of the other options, but there is a risk that some States may decline to absorb these costs and return the agreement or experience significant program degradation. The second option, use of a "needs test," is designed to place the greatest burden on those States best able to pay (much like the graduated income tax). The task force recognized the potential difficulty in developing and administering such a scheme. This l option could be expected to generate considerable controversy regarding fairness, and the task force believes it could result in an unhealthy competition between States for training slots. The third option, increasing the number of courses taught "in-State" (otherwise referred to as "taking training to field sites"), does provide a limited opportunity to have those States where such NUREG-1356 21

1 l training is conducted pick up their local travel costs and thereby increase their share of the training costs. Although overall travel of students from that State would be reduced, travel for trainers would be increased and only States with large numbers of students could make this option cost effective. Additional presentations of courses also might be needed. Inviting adjacent States to send students, thereby making the training conform to a regional approach, might enhance the cost effectiveness of this alternative; however, out-of-State travel restrictions might prevent fully successful implementation of this option. The fourth option, adopting the FEMA approach, would increase the State's share by requiring that ground transportation and meals be funded by the State. The costs resulting from this option would be shared equally by all States, therefore minimizing the fairness issue between States. This option might attract minimal resistance from the States, since it is a mechanism they are already used to in their dealings with the Federal Government. Again, since expenditure of State funds is required, out-of-State travel restrictions may affect this option. The fifth option, like the first, would have the effect of eliminating or reducing the training attended for those States whose administrative and policy practices do not allow approval of out-of-State travel or whose budgets cannot support additional expenditures for training. Because of the direct cost implications for States, this option could complicate the development of a training curriculum for States that distinguishes required or " core" courses from supplemental or " recommended" courses because of the financial implications of the category into which a course falls. This option may result in the eventual elimination of supplementary j courses. j In all of the preceeding options, actions by the State Governors or State legislatures would probably be needed. Assuming agreement to 1 make the necessary budget or policy changes, implementation could take 1 to 3 years. The sixth option would address the existing Agreement States' concerns that the rules of the game would have been unilaterally ) changed by the NRC, but this option would not result in any immediate cost savings. Negative reaction by existing Agreement l States could be expected to be minimal because they would be grandfathered out of cost increases. However, such an approach might result in the perception of second-class treatment of new Agreement States and could complicate any supplemental amendments to j existing agreements. Therefore, the task force does not recommend this option. j NUREG-1356 22 l J

The last option, which would not mandate any additional cost sharing, but instead would encourage a greater share, would probably be the least objectionable to the States and would be in keeping with the existing SLITP informal policy in regard to the Agreement States. As the task force documented, many of the Agreement States have voluntarily paid for out-of-State NRC training, in-State training, and other forms of s technical training when and where possible. The task force believes periodic communication of this option to States is needed, especially L to remind States that cost savings obtained this way can be used to extend the training effort. This would encance as well as continue existing cost savings resulting from this established practice. After reviewing these options and a number of related variations, the task force debated whether or not to recommend any further cost sharing of training by the States. In recognition of the fact that the States already contribute to both NRC-supported and other relevant technical training, a fact not widely known by the task force members when they started this effort, the task force questioned the appro-priateness of further burdening the States and what the probable consequences might be. In addition, the fact that no two States' programs, administrative constraints, or budget conditions were alike made it difficult to reach agreement on a "best" or " preferred" alternative. Most importantly, the task force shared a concern that any further NRC mandate for State funding in the training area could result in additional'NRC administrative costs, a serious decrease in the amount of training obtained by State personnel (with a resultant adverse effect on program quality), a reduction in today's high level of cooperation with and free State assistance to the NRC, potentially destructive political pressure and criticism, and the possible return of some number of agreements for NRC implementation of the program. Although the task force is unanimous in believing that the present cost-share mix is appropriate from a public policy perspective, that is not to say that ccnditions might not change, making greater State cost sharing a more appropriate policy alternative. For the present, however, the task force does not support any NRC action otherthan(1)encouragingStatestoacceptagreatershareof training costs when they can and (2) enhanced use by the NRC and the States of more cost effective alternative training approaches, such as State in-house training. HUREG-1356 23

1 4.- CONCLUSIONS The conclusions of the task force are: (1) The State Agreements Program is a model of Federal-State cooperation to protect the public health and safety. The NRC State Agreements Program has been reviewed by the General Accounting Office, an internal NRC task force, and the NGA. In their reports, the NRC training program for States was consistently identified as a key to enabling States to prepare for such agreements and to maintain State Agreements programs that are' adequate for protecting public healt;. and safety and that are compatible with the Comission's program. Their reports also contained recommendations to expand the NRC State training program. The program has been relatively stable and trouble free and has Fcen responsive to both unique regional and State characteristics and to Federal oversight direction. The State Agreements Program differs from most other Federal-State cooperative programs in that there are no Federal grant or contract monies to the States to carry out their programs. Since States receive no direct Federal funding for their programs, it is clear that it is not Federal money that causes the effectiveness of this program. The task force believes it is the support the NRC has supplied through the years by providing training and technical assistance to States. This support has enabled the States to develop professional staffs that maintain effective radiation control programs and has resulted in State good will and State cooperation and competence. (2) With regard to travel and per diem costs, the task force found thet States already fund such, on occasion. It examined a number of mechanisms for addressing additional funding by States, but found none that were equitable and effective. It is clear that reduction or elimination of funding will have a negative effect on the States' participation in the training offered by the Commission. (3) For the majority of States, out-of-State travel is necessary to attend NRC training courses. Authorization for out-of-State travel is frequently difficult to obtain by State personnel. In many l I State funds (other than salary)g is possible only because no cases, approval for NRC trainin are expended. At any given i time, there are some States for whom this is not a problem, but this changes from year to year. There are always some States for whom this is a critical problem. l l (4) On occasion even NRC funding of out-of-State travel costs does not rcsult in approval. In such cases, State personnel attend training on their own time, at considerable personal sacrifice. One State member of this task force attended task force meetings f under exactly these circumstances and was required to take annual l' 1 eave to do so. NUREG-1356 24

o 7 - (5) ;SLITP has al' ready; adopted a~ number of cost-savings-measures, including the use'of.Iow-cost facilities selected courses:1n the field, ~and use of presentation of.. l videotapes and of= videotelecommunications. Although such measures should continue to be' encouraged, the task force does not believe that significant additional costs savings will be' realized in these areas. -(6)L The res'ponse of Agreement States' to further cost sharing was not favorable. Some Agreement States found'it incredible that or.had conceptual' problems understanding how NRC.could conceive that further restrictions on training of State personnel would' - result in a benefit to anyone.. Others would accept additional cost sharing, but this.would have a negative effect on their (overall programs. Some other States would consider turnback of 'their agreements'as a response. The 29 Agreement: States administer 16,000ilicenses or an average of 550 licenses per State. Termination of an Agreement State program with this average ' number of.Iicenses would require 7.7 full-time equivalents and would result in'$470,000 in salary and benefit costs alone if the NRC were to replace the program at the same level of effort. This exceeds the $390,500 the NRC budgeted in 1989 for' travel and per diem costs for training State personnel. . (7) The' training. program' administered by SLITP for the Agreement States appears reasonable in content and scheduling, although some States believe the availability of courses could be improved.. Some changes in this-training.may'be appropriate in light of recently developed NRC training standards for NRC materials and fuel cycle regulatory staffs. This should be examined. _If changes are made to present courses,. care should be taken to ensure that the present quality is maintained. (8). SLITP needs more information from the States on training needs when planning the resources required of SLITP to train State personnel. Better prioritization and planning of training are essential if SLITP is to make meaningful projections of training needs for budget purposes. (9) The quality of. training is a key factor in the continued ability of the States to provide adequate and compatible implementation of the health and safety mission under the agreements. The task force is unanimous in believing that classroom-style presentations, -including instructor-student and student-student interactions and, as appropriate; laboratories, field work and exercises, and class composition that increases State and NRC personnel interaction, are critical to maintaining and improving quality and compatibility, (10) Special training needs will arise in response to regulatory changes or new regulatory programs and must be planned in advance. In the near term the revisions to 10 CFR Part 20 and effective implementation of the requirements of 10 CFR Part 61 will require additional NRC training for States that will license new low-level radioactive waste disposal sites. NUREG-1356 25

i I 5. RECOMMENDATIONS On the basis of these conclusions, the task force recomends the following: (1) Recognizing that States currently share travel and per diem costs for training courses when possible, SLITP should encourage States to continue to do this. The fact that a State is not able to share these expenses should not become a factor in selecting nominees to attend necessary courses. (2) SLITP should encourage the States to develop in-house training including, when feasible, extending invitations to nearby States to attend. Such regional training can be very cost effective and should be supported by the NRC, for example, by providing instructors and other training resources. (3) The NRC and the States should establish a standing review comittee to periodically assess NRC-sponsored training provided to States. This comittee should review and evaluate course content and offer recommendations on maintaining and im) roving the quality and cost effectiveness of tie training and the adequacy of meeting training needs. Examples of tasks that should be assigned to such a comittee are: (a) Review the current guidance on Agreement State training in light of.the recently developed NRC training goals for NRC materials and fuel cycle regulatory staffs, and, as appropriate, recomend new State guidance for core, supplementary, and refresher training courses for State personnel. The comittee should also examine the desirability of recommending standards for States for determining when State inspectors or license reviewers become qualified to carry out their duties and for consideration of requalification standards for State personnel. The goal will be to maximize the number of comon courses for NRC and State personnel. (b) Review the feasibility of expanded use of the NRC Technical Training Center (TTC) resources for training of State personnel. Such use could help meet some other recommendations of the task force, may provide more flexibility for the scheduling of training courses for both States and NRC, and may be more cost effective for some courses than present options. While this review is being undertaken, the task force encourages expanding States' participation in TTC training. NUREG-1356 26

l j (c) Review the criteria used by States to nominate ) students. Use of more consistent selection criteria by the States is needed for training planning purposes. The use of more consistent criteria would i significantly improve the basis used by SLITP to make projections of training needs for budgeting and scheduling purposes. (4) The task force advocates that most of the training continue in a traditional instructor-student environment with emphasis on " hands-on" learning such as through the use of laboratories, field work, and exercises. Therefore, cost savings provided by non-traditional training alternatives would be limited if the instructor-student and " hands-on" recommendations were followed. (5) SLITP should review, and when appropriate, endorse program-related training courses for which the States can fund the total costs. Such an endorsement could make it easier for States' radiation control programs to obtain necessary State approval and funds for these courses, thus supplementing NRC-sponsored courses. (6) The Office of Governmental and Public Affairs should identify special training needs for inclusion in NRC's 5-year plans. Several training needs arise as a result of regulatory initiatives or from other sources. The recent, comprehensive revision to 10 CFR Part 20 is an example. Another example is the Low-Level Radioactive Waste Policy Act and subsequent amendments, which place the primary responsibility for the disposal of low-level radioactive waste on the States. As a result, staffs in Agreement States that will host a disposal site need training pertaining to the requirements of 10 CFR Part 61 and the associated regulatory guidance. (7) Added emphasis should be placed on expansion of opportunities for both NRC and State employees to attend the technical courses together. (8) Additional on-the-job training should be encouraged by having the NRC regions provide more opportunities for State inspectors to accompany NRC inspectors, by encouraging more State inspectors to accompany inspectors from other States, and by having more NRC l inspectors accompany State inspectors. This cross-training should provide for more efficient and effective inspections by pooling experience and knowledge among the States and the NRC and should help ensure compatible programs to protect the public health and safety, i (9) Given the level of concern expressed by the States, the Commission should reaffirm its continuing support for the State NUREG-1356 27 i

i i i j i Agreements Program and its willingness to continue to be a reliable partner in efforts to protect the public health and' -{ safety. l 6. REFERENCES l L The-primary reference used by the Task Force was NRC NUREG-1311, " Funding the NRC Training Program for States," available from the National Technical Information Service, Springfield, Virginia 22161. Section 9 of this report contains an extensive reference section. This should be useful for readers desiring further background e information on the NRC. training program for States, i I 1 i NUREG-1356 28

APPENDIX A CHARGE TO THE TASK FORCE NUREG-1356 1 Appendix A

f '# N "% UNITED STATES NUCLEAR REGULATORY COMMISSION 7,, i wAssincrow. o.c.rosss January 27', 1989 HEMORANDUM FOR: John M. Montgomery Deputy Regional Administ egio I FROM: Carlton Kamerer D ector State, Local and In iePrhrm Office of Governmental and Public Affairs

SUBJECT:

STATE TRAINING COST-SHARING TASK TORCE Thank you for accepting the Chairmanship of the Task Force to review the question of States sharing the costs of NRC sponsored training for State radiation protection staff. The Task Force's assignment is to respond to the expressed desire of the Commission to look at ways that the States can share the costs of NRC training particularly travel and per diem. The origins of this program and recent history were examined by SLITP staff and reported in NUREG-1311 which is enclosed. The Conference of Radiation Control Program Directors, Inc. (CRCPD) and the Agreement State Comittee have provided two individuals from each group to serve on the Task Force: { CRCPD - Donald R. Hughes, Manager, Kentucky Radiation Control 1 Branch, and Chairman, CRCPD Agreement State Committee (502)564-3700 CRCPD - Michael H. Hobley, Director, Tennessee Division of Radiation Health and Treasurer, CRCPD (615)741-7812 A.S. - Paul J. Merges, Director, New York State Departmtnt of Environmental Conservation, Bureau of dergy and Radiation (518)457-2225 A.S. - Donald A. Flater, Chief, Iowa Bureau of Radiological Health (515)281-3478 NRC Task Force members are Kenneth Raglin from the AEDO and Joel Lubenau, SLITP. The Task Force has a great deal of experience and hands-on knowledge regarding the important relationship between proper training of State personnel and the quality and importance of the program to protect public health and safety. 2 Appendix A 1

Johr. M. Montgomery 2 JAN 2 719B9 The Comission strongly supports our training program, while at the same tine questions the long stantling practice of paying travel and per diem of State personnel selected to attend NRC sponsored courses. We must'be good stewards of the scarce resources for which we have responsibility. It is therefore appropriate to reevaluate current practicer to see what changes may be warranted. I have asked you to chair this endeavor because of the unique management, policy and budget work you have done at the highest level both at Headquarters and the region. I look forward to your report to me not later than June 1989.

Enclosures:

1. NUREG-1311 2. Transcript, 1988 All Agreement State Meeting, Commissioner Carr's Remaris 3. Ltr 1/73/88 Lando W. Zech, Jr. to Harold R.~Centon cc w/encls: Harold R. Denton, GPA Task Force Members 3 Appendix A

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i APPENDIX B TASK FORCE MEMBERSHIP John M. Montgomery, Chairman John M. Montgomery has been Deputy Administrator of Region IV of the U.S. Nuclear Regulatory Commission (NRC) since October 1987. Region IV is responsible for NRC regulatory activities in the States of Arkansas, Colorado, Idaho, Kansas, Louisiana, Montana, Nebraska, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, Utah, and Wyomieg. Dr. Montgomery, who is originally from Madera, California, is a graduate of the University of California, Davis, where he received his bachelor of science degree in zoology. He received his master's degree in industrial and organizational psychology at the University of New Haven and his doctorate in business administration at George Washington University. He joined the NRC in 1978, with assignments in the Office of Standards Development and later in the Office of Policy Evaluation. Other NRC assignments included service on the Regulatory Reform Task Force, the Performance Review Board, and the Executive Resources Board. At the time of his appointment as Deputy Administrator of Region IV, he was executive assistant to Chairman Lando W. Zech, Jr., and Director of the NRC Office of Consolidation. Before coming to the NRC, Dr. Montgomery worked on the corporate staff of United Technologies Corporation in Hartford, Connecticut, and served in the U.S. Coast Guard with assignments in electronics operation and maintenance, search and rescue, and intelligence. Dr. Montgomery is also a part-time Professor of Management at Texas Christian University and previously taught at George Washington University. Donald A. Flatrr Donald A. Flater is Chief of the Iowa Bureau of Radiological Health. Iowa is one of the newest Agreement States having entered into an agreement in 1986. He has been with the State of Iowa for over 8 years. Mr. Flater received a certificate in radiologic technology from the l University of Iowa in 1966 and a bachelor of science degree in radiology l sciences and administration from George Washington University in 1978. His experience includes positions with the States of Illinois and Kentucky radiation control programs and with the U.S. Food and Drug Administration's Bureau of Radiological Health. NUREG-1356 1 Appendix B

p 7 He is registered with,the American Registry of Radiologic Technologists and is the Iowa representative to the Conference of. Radiation Control Program Directors, Inc. He has served on a number of conference committees and currently chairs the Nationwide Evaluation of X-Ray. Trends-(NEXT) Committee. Mr. Flater also serves as a member of the Iowa Citizens Advisory Committee on Low-Level Radioactive Waste.. ' Donald R. Hughes. Sr.. Donald R. Hughes, Sr., is Manager of the Kentucky Radiation Control . Branch. Kentucky became the first Agreement State in 1962. Mr. Hughes has been with the Kentucky radiation control program for 22 years. ~ Mr. Hughes is' a graduate of Kentucky Wesleyan College where he received a p bachelor of science degree in chemistry. Mr. Hughes is the Governor's Designee - Commissioner, Central Midwest Low-level Waste Compact; Governor's Designee - Member, Southern States Energy Board Task Force on High Level Radioactive Waste Transportation; l l and Governor's designated official for advance notices concerning i-transportation of nuclear waste. He is a member of the Kentucky L ' Hazardous Materials Committee. He is the Kentucky representative to the Conference of. Radiation control Program Directors, Inc.. and has chaired several conference committees, most recently, the Agreement States Commiittee. Mr. Hughes also has been active in the Bluegrass Chapter of the. Health Physics Society. Joel 0.'Lubenau Joel.0. Lubeanu is Senior Project Manager for Health Physics in the'NRC's Office of Governmental and Public Affairs where he is responsible for managing NRC's oversight of the 29 Agreement States radiation control programs. Mr. Lubenau graduated in 1961 from The Cooper Union with a bachelor of civil engineering degree. From 1963 through 1965, he attended Rutgers ~ University's Nuclear Science Ceriter and Brookhaven National Laboratory as a U.S. Pubile Health Service Fellow and received a anster of science degree in radiological health. After a short term as an engineer in the private sector in 1961, he accepted a commission in the U.S. Public Health Service as a health physicist. He has 'since been employed in a variety of public health and regulatory positions, including heading the Division of Radiation Control in Pennsylvania's Bureau of Radiation Protection. In IM 9 he received certification in comprehensive health physics from the American Board of Health Physics. He has served as a member of the American Board of Health Physics and chaired its Panel of Exeminers. He is an associate member of the Conference of Radiation Control Program j 4 NUREG-1356 2 Appendix B 3

Directors, Inc., and serves as a member and technical resource for several conference committees. He was recently appointed to Georgia Governor Joe Frank Harris' task force to review the 1988 Radiation Sterilizers, Inc. irradiator incident. Mr. LuSenau is a member of the Health Physics Society and the American Acadeg of Health Physics. Paul J. Merges Paul J. Merges is the Director, Bureau of Radiation, at the New York State Departnent of Environmental Conservation. He has directed both the energy and radiation programs for this department. In 1962, New York became the fourth Agreement State. The States radiation control program is administered by four agencies, the New York State Departments of Health, Labor, and Environmental Conservation and the New York City Department of Health. Dr. Merges graduated with a bachelor of science degree from Siena College, Loudonville, New York, in 1965. He also received a master of science degree (1978) and his doctorate (1983) from the Rensselaer Polytechnical Institute, Troy, New York, where he has been an adjunct associate professor in several of their graduate schools. Dr. Merges was a staff member of the former New York State Atomic Energy Counsel from 1970, until he joined the New York State Department of Environmental Conservation in 1973. Before that he worked at Knolls Atomic Power Lab as a nuclear engineer. He is a representative from New York to the Conference of Radiation Control Program Directors, Inc. Michael H. Mobley Michael H. Mobley is Director of the Tennessee Division of Radiological Health. Tennessee was one of the earlier Agreement States (1965) and is one of the larger Agreement States in terms of the number of licensees (approximately 700). Mr. Mobley received a bachelor of arts degree in physics and mathematics from Austin Peay State University in 1968. In 1972 he received a master of science degree in physics from the University of Tennessee, and in 1983 he was awarded a master of public administration degree from Tennessee State University. Mr. Mobley has been with the Tennessee radiation control program for 21 years. He has been appointed by the Governor as Commissioner representing Tennessee to the Southeast Low-Level Waste Management Compact Commission and as State Liaison Officer to the NRC. He is a member of the American National Standards Institute N 14 - Standards Committee and the Limited Scope Examination Committee of the American Registry of Radiologic Technologists. review of U.S. Department of Energy (DO He plans to develop alternative disposal methods for DOE wastes and was a member of a select panel of 21 national experts chartered by Tennessee to evaluate the DOE proposal for a monitored retrievable storage facility for high-level waste. I NUREG-1356 3 Appendix B i .j

i i He is the Tennessee representative to the Conference of Radiation Control Program Directors, Inc., and has served as that organization's Treasurer and Chairman of its Agreement State Committee. He is an active member of the Health Physics Society. Kenneth A. Raglin Kenneth A. Raglin is Director of the NRC Technical Training Center in Chattanooga, Tennessee. The center's staff is-responsible for develtping and presenting technical training for the NRC staff. .Mr. Raglin graduated from the U.S. Naval Acadewy in 1968 with a bachelor of science degree in applied mathematics. He also received training at the U.S. Navy Nuclear Power School and Nuclear Power Training Unit and the Federal Executive Institute. Before joining the NRC in 1977, Mr. Raglin had extensive U.S. Navy experience as a nuclear trained officer during tours of duty on three nuclear-powered surface ships, including qualification for the position of Engineer Officer for nuclear-powered surface ships. Mr. Raglin joined the NRC in the capacity of a nuclear engineer (instructor) with responsibilities pertaining to boiling-water-reactor designs. In 1981 Mr. Raglin was appointed to the position of nuclear engineer (lead instructor) within the Boiling Water Reactor Technology Branch. Mr. Raglin served as the Chief. Boiling Water Reactor Technology Branch, from 1984 to 1986. He has served as the Director of the NRC Technical Training Center since 1986. i i NUREG-1356_ 4 Appendix B

APPENDIX C STATE QUESTIONNAIRE AND RESPONSES In an effort to obtain the views of the Agreement States, Donald R. Hughes, Sr., of Kentucky, at the task force chairman's request, issued a letter requesting information from the Agreement States. Responses were received from 25 of the 29 Agreement States. In addition to responding to Mr. Hughes' specific questions, the responders found it incredible that or had conceptual problems understanding how the NRC could conceive that further restrictions on training of State personnel would result in a benefit to anyone. A second major theme pervasive in most responses was that the money aspect was not as important as the "out-of-State" travel aspect. With the NRC paying an individual's travel cost, there is considerable flexibility in sending personnel for training. However, if the State is paying, even if the money is budgeted, approval may not be forthcoming simply because it is out-of State travel. Mr. Hughes' questions, the summarized responses, and the States that provided the responses are given in the section that follows. In the next two sections, additional comments and possible solutions as provided by the States are given. Questions and Responses (1) What immediate reaction do you believe your State would have if the NRC stopped funding the travel and per diem costs associated with State training?

• Consideration would be given to discontinuing participation in the State Agreements Program.

(RhodeIsland,NewHampshire, Idaho, South Carolina)

• The nunber of State personnel attending training courses would be reduced or possibly there would be none.

(Florida, Colorado, Tennenee, California, Louisiana North Carolina, Arizona, North Ockota, City of New York, Kansas, Utah, Nevada, Kentucr.y) l

• Participation primarily Lould be limito1 to training provided within one's own State.

(Maryland, Texas)

• Participation primarily would be limited to training provided within one's own region.

(Oregon) l

• No short-term reaction was given.

(Georgia, Illinois, Nebraska, Arkansas, Iowa) NUREG-1356 I Appendix C

ji -i (2) _ If you believe there would be a different long-term reaction, what p do you think it would be?

• Consideration would be given to discontinuing participation in the State Agreements Program.

(Utah, Idaho,SouthCarolina, Rhode Island, Iowa)

• Staffs' technical skiils end development would deteriorate.

(Florida,1111ncis,NorthCarolina, Nevada)

• Attendance would be limited to training courses.provided within-i one's own State.

(Arkansas)

• Restrictions would be placed on which courses one would receive approval.to attend. This would apply to courses such as the 5-week l

I health physics course and Radiological Emergency Response Operations. (Nebraska, Louisiana, Kentucky)

• There would be delays in' quality training.

(City of New York, l Kentucky) l _.

• States would need to replace funding of NRC training courses,

'however, approval would be unlikely. (Colorado, Maryland, California, Texas, Louisiana, Oregon, Arizona, North Dakota, Kansas, South Carolina)

• NRC should-retain responsibility for training that it feels is necessary.

(Georgia) (3) How much lead time would be required in your State to obtain i additional funding for training travel? (Presuming it would be approved?)

• Up to I year. (Florica Maryland, Rhode Island), California, Louisiana, Arizona,
• 1 to 2 years.

(North Carolina, City of New York, Nebraska, Oregon. Georgia, Kansas, Utah)

• A minimum of 2 years.

(New Hampshire, South Carolina, Texas, Nevada)

• Up to 3 years.

(Colorado, Arkansas, North Dakota, Iowa, Kentucky)

• Granting of additional funding is unlikely.

(Tennessee, Idaho) (4) Would the loss of NRC funds for travel and per diem l

• eliminate your_ ability to provide training? (Colorado, Georgia,RhodeIsland,NewHampshire, Kansas, Utah, Idaho) l 1

NUREG-1356 2 Appendix C

• r2 duce your ability to provide training?

(Florida, Tennessee, Maryland, Nebraska, California, Arkansas, Texas, Louisiana, North Carolina, Arizona, North Dakota, The City of New York, South Carolina, Iowa, Kentucky)

• have no impact? (Illinois, Oregon)

Additional Coments (1) As pointed out in NUREG-1311, the savings to the NRC through the State Agreements Program is more than $13 million. Federal money-saved because of this program far outweighs the NRC funds invested in State training. (Georgia, Idaho, Maryland, Nebraska, Arkansas. Idaho) (2) NRC's influence over State programs may be reduced,(ano existing Federal-State relations possibly may deteriorate. Florida. febraska) (3) The NRC possibly would be forced to resume regulatory authority in some current Agreement States, thus increasing expenses. (Illinois) (4) Training for State personnel has been one of the most persuasive selling points used by the NRC to encourage participation in the State Agreements Program. (Idaho) (5) The NRC has jurisdiction over agreement materials; therefore, it is more beneficial to the Commission when Agreement State personnel are well trained. (Louisiana,NorthCarolina) The State Agreements Program and th1t results obtained are considerably ) (6) more cost efficient than the State / Environmental Protection Agency (EPA cooperative programs. (Utah) However, EPA provides funding to the States for %plementation of EPA's programs and EPA duplicates some of the States work. (Colorado) (7) Because of "out-of-State" travel, the cost itself may not be the single issue involved. Simply, "out-of-State expenditures" may restrict a State from sending employees to even free training. (New Hampshire) (8) States entered the agreement with the understanding that while theNRCprovidedcertainspecifics(g.,staffandprogramfunding), the State provided certain items (e. e.g., training and technical assistance). (Nevada, Kentucky) NUREG-1356 3 Appendix C

p ) I t .i Possible Solutions (1)'ChargeNRClicenseesthefullcostoftheir-licensing' activities. (Florida) (2). Conduct courses at the Federal Emergency' Management Agency facility in Emmitsburg, Maryland, or at other Federal training facilities with the NRC paying for lodgin North' Carolina, Maryland)g and local transportation costs.(Colorado,. (3). Conduct courses:over the weekend, thereby considerably reducing transportation and lodging costs. (Colorado) (4) Screen course applicants carefully to ensure NRC funding is provided only to those who need ~it. (Colorado) (5) Have the NRC send its training personnel to'the various States. (California, Oregon) 4 I i NUREG-1356 4 Appendix C

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4 C. . NET FOR HUMAN RESOURCES .n, /*" $ COMMONWEALTH OF KENTUCKY 1 l f T FRANKFORT 40621 sM V - DEFALTMENT FOR HEALTH SERVICES ME-M2E&EEEH TO: Agreement State Program Directors, l FROM: Donald R. Hughes, Sr.,. Manager Kentucky. Radiation Control

SUBJECT:

State Training Cost-Sharing DATE: March 7, 1989 As some of you may already know a. Task Force has been established by the U. S. Nuclear Regulatory Commission (NRC) to look at ways the states can share the cost of NRC training particularly in the areas of travel and per diem. Paul Merges (New York) and' Don Flater (Iowa) were selected at .the:1988' annual Agreement States meeting. Mike Mobley (Tennessee) and I were chosen to represent the Conference of Radiation Control Program Directors. The three NRC members of the Task Force include John Montgomery (Deputy Regional Administrator, Region IV) who will serve as chairman, Kenneth Raglin from AEDO, and Joe Lubenau with SLITP. It is my understanding the Commission strongly supports our training program, but have questioned the long standing practice of paying travel and per diem for state personnel selected to attend NRC sponsored courses.- My purpose in writing this memorandum is very simple. As one of your representatives on this Task Force I need your input. I need you to supply me with innovative ideas that are practical, reasonable and logical. I feel confident you can provide me with a multitude of responses; however,'I would like for everyone to respon'd to the following four (4) questions:' 1. What immediate reaction do you believe your state would have if the NRC stopped funding the travel and per diem costs associated with State training? 2 If you believe there would be a different long-term reaction, what do you think it would be? l t 5 Appendix,C

• An Equal Opportunity Employer MrF/H"

MEMO to Agreem2nt Stk.OD-Page Two . March 7. 1989 3.' How much lead time would be required in your state to obtain additional funding f.or training travel (presuming-it would be approved)? 4. Would the loss of NRC funds for travel and per diem: a) eliminate your ability to provide training: b) ' reduce your ability to' provide training: c )- have no impact? In addition to the above questions, please feel free to provide'any other comments you deem appropriate. If you have not read NUREG-1311, I:would suggest you do so as it will definitely. Provide additional insight to the tark at hand. This is your program. The final decision will rest with the NRC and that decision, whatever-it may be, may effect your program!for many. years to come. The first-meeting of the Task Force is scheduled for March

28. 1989.-

TIME IS SHORT AND I NEED YOUR RESPONSES BY MARCH 22, 1989 WHICH WILL GIVE ME A FEW DAYS TO COMPILE THE DATA. Your responses will-become part of the Task Force report to the NRC. 'Please give this your undivided attention. Personally speaking, I believe the Agreement States program is probably unparalleled relative to any organization involving the federal government.and the states. Aside from establishing-and maintaining a high' standard throughout the years, the primary essentia11 ingredient has been the level of training and education provided by the NRC. Send responses to: Donald R. Hughes, Sr. Radiation Control Cabinet for Human Resources 275 East Main Street Frankfort, KY 40621 Thank you in advance for your cooperation. 'DRH/ns 6 Appendix C

Rise MSittrd Gonmor -f Charles F.Tedford t h m' RADIATl0N REGULATORY AGENCY 4814 S:n th 40 Stroci Phoenix, Arizona 85040 (C2) 255-4845 March 16, 1989 l a i Donald R. Bughes, Sr., Manager Radiation control Cabinet for Human Resources 275 East Main Street Frankfort, Kentucky 40621

SUBJECT:

State Training Cost-Sharing Dear Mr. Hughes The memorandum dated March 7, 1989, was received and reviewed by Mr. Tedford before his departure for out-of-state travel yesterday. He prepared responses to the questions, and asked that they be finalized and sent to you without delay, as follows: 1. Ouestion: What immediate reaction do you believe your state would have if the Nuclear Regulatory.CommSssion (NRC) stopped funding..the travel and per diem costs associated with state training? Additional funding could not be provided

Response

to attend required training courses during the fiscal year. Attendance would cease. 2. ouestion: If you believe there would be a different long-term reaction, what do you think it would bei Due to' lack of funds at the present time,

Response

the State is not approving any new legislation with money requirements or increasing state program requests. This might improve within the next few years. 3. ouestion: How much lead time would be required in your state to obtain additional funding for training travel (presuming it would be approved)? Responsel In Arizona, funding requests are submitted in September for the acxt fiscal year (starting in July). 7 Appendix C

4; -. l- -1 ir. ] 2 4; Quistiont would the loss of NRC funds for travel -j and per dies: a) eliminate your ability to provide trcinings b) reduce your ability to provide c training; c) have'no impact?

Response

The loss of'NRC funds for travel and per dien would SUBSTANTIALLY reduce the ability to provida-training. Please contact the Agen_cy if further information or assistance is required. Sincerely gg Richard L'. Blanton Acting Director /J8 Copy to: C. Tedford 1 i l 1 1 i J l i 8 Appendix C

V: 1 2

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dr4anea# DEPARTMENT OF HEALTH' 4815 WEST MARKHAM CTREET Lff7LE ROCK. ARKANSAS 72205 ] TELEPHONE AC 5016612000 BILL CitNTON M 2CEM mRS. M D. ' GOVERNOR DRECToA L1 P. arch 20,1985 Donald R. Hughes, Manager K:ntucky Radiation Control Ccbinet for Human Resources 275 East Fein Street Frankfort, Kentucky 40S21

Dear. Don:

'In response' to your mernorandum on " State Training Cost-Sharing" I'm pleased to offer the following responses and comments: 1. What immediate reaction do you believe your state would have if the NRC stopped funding the travel and per diem costs associated with state training? Response: -None.. Currently'I have adequate travel funds in my budget and there is a liberal. policy toward out-of-state trav'el. 2. If you believe there would be a different long-term reaction, what do you think it would be? Response: If state revenues fall short of' predictions, state agencies have funding cut even in the middle of a fiscal year. When funding is Cut, out-- of-state travel paid by the state is one of the first items eliminated, re-gardless of the purpose (or need) for the travel. If this were to happen, we could not get our people trained unless the course was in the state. 3. How much lead time would be required in your state to obtain additional funding for training travel (presuming it would be approved)? Response: One to three years. We have a biennial legislature and a biennial budget with each budget process starting at least one year before the biennial budget goes into effect. " Emergency" funtling changes are possible through the Legislative Council. However, legislators are prone to ask how much the NRC pays 3Ls, to administer their (NRC) program in Arkansas. When they learn it costs the state to be an Agreement State, they are' prone to consider giving the Agreement back. You can see why I'm reluctant to go to the Legislative Council. '4 WoJ1d the loss of NRC funds for travel and per diem: a) eliminate your ability to provide training; b) reduce your ability to provide training; c) have no impact? " jaw 69% MF~ 9 Appendix C ]

A) Resconse: It umulo reduce our ability to provide training. Potentially, the only training we could provide if funding is cut is "in house" training which, whils effettive for our procedures, does not provide the broader base given i i by natier.al courses. Loss'of training courses on technical subjects or the less frequently encountered problems / subjects would have the more negative

impact, I would also like to offer the following comments.

I am seriously concerned about i l the issue. I ar, also baffled as to why the Commission continues to consider this j l measure. The amount of money spent by the NRC on these training programs is insig-1 nificant in relation to their overall budget. Agreement States regulate a larger number of licensees than the NRC, which, if the Commission had to reassume regula-tory responsibility for these licensees, the impact on their budget would be signi-ficant. While I doubt any states will give back their agreements over this issue, the conceptual argument is not without merit. Agreement States bear a major responsibility to protect the public health and safety. Due to salary restrictions, state programs fregaently have difficulty hiring well qualified, trained individuals to carry out this function. Staff turnover rates also continue to be fairly high in many programs. Cu sequently, programs are frequently dependent on the availability of NRC tre2nin; +- develop and maintain staff competency. If adequate training is not aveAlable, the level of staff capability may drop which could have a negative impact on the public health and safety. The success of the NRC-Agreement State Program is well documented. I believe the effectiveness of the NRC dollars spent on training is high ?nd that should be considered in evaluating the success of this program. I appreciste the opportunity to provide these comments. If there are any questions, give me :. call. Sincerely, osuctJc(RJ[CLD,UTL LW l reta J. Dieus, Director j Division of Radiation Control & Emergency Management GJD:ji l 10 Appendix C l

9ftW STATE OF CEEIGNIA DEPAR&!DC CF HIEDI SERVICES j D NN March 16, 1983-714 P Street, Roam 616 ) P.O. EcK 942732 -l Sacramento, California 94234-7320 Donald R. Hughes, Sr. . Manager, Kentucky Radiation Control Department for Health Services ' Frankfort, Kentucky 40621

Dear Mr. Hughes:

This is in response to your letter regarding states sharing the cost of Nuclear Regulatory Commission (NRC) training. The following is in response to your faur questions: '1. If the NRC stopped' fundina travel and per diem costs, the number of individuals attending training courses would drop from the current 8 to 10 per year to 1 or 2. This would severely affect California's program, which has a staff of approximately 40 people. 2. The long-term reaction might be an increase to.3 or 4 individuals per year traveling for training. An increase would result from negative findings by the NRC during a generic review. This would prompt increased, A1beit perhaps temporary, funding for training. 3.. The lead time required for obtaining additional funding depends on the stage of the budget cycle during which the need is identified. Travel funding is requetted each Kerch for the following fiscal year which runs from July through June. Therefore, if the need for additional travel funding is identified during the spring, the lead time would be 3 to 4 months. However, if the need is identified in April (or later), it would s ~ take up to 15 months to receive additional funding. 11 Appendix C 4

Donald R. HuGhes, Sr. Page t 4. The lose of NRC funds would reduce our ability to provide training. We already. provide internal training; however, the NRC provides specialized l training which California does not. I An alternative to cutting costs by eliminating or reducing travel funds is for NRC to send. their training personnel to the states. With 40 people, California could provide a good sized class on its own. or regional training could be provided which would reduce travel costs. Thank you for the opportunity.to provide my coments on this important issue. Sincerely. Jack S. McGurk, Chief Environmental Health Division I 1 l i l 12 Appendix C L

STATE O? CO'JJMJO COLORADO DEPARTMENT OF HEALTH I 4210 f ast 11th Avenue oerwee, colorado s0220 Phone (303) 320 8333 Roy Romet Governor Thomas M. Verno't. M D-March 22, 1989 ! "'("' ** D '" ' Donald R. Hughes, Sr. Radiation Control Cabinet for Human Resources 257 East Main Street Frankfort, KY 40621 ' Dear Mr. Hughes in response to your March 7, 1989 memorandum regarding NRC's proposal to require states to share the cost of training, the .following is offered with respect to the few questions you raised: 1. The immediate reaction would be for Colorado to suspend sending staff to NRC training. Several years ago when FEMA required states to cover part of their training costs, t*is division stopped sending staff to FEMA courses. 2. -The long term reaction would be to attempt to obtain state funding to attend these training courses. It is expected that this would be difficult. General Funds are not readily available.for training, and the ability to factor such costs into a cash-funded portion of the program is not guaranteed. 3. If Colorado had to obtain additional funding for training, two to three years would be a reasonable estimate IF it could in fact be obtained. 4 Loss of NRC funds for travel and per diem wo"uld in the short term eliminate Colorado's ability to provide training for NRC-related topics. In the long run, at best this ability would be reduced, and at worst would be eliminated. In come respects the EPA has e ain:ilar relationship with states as does the NRC. EPA receires that states provide some of the costs for EPA sponsored training. There are, however, two oloments of the EPA-state relationship which are different from the NRC-state relationship: 13 Appendix C

= l + CO l 1 I , (, la. EPA'provides funding to the states to implement EPA's i programs;.and .b.- It'has.been Colorado's' experience that EPA, through its oversight role,-duplicates.some of the state's work.- LThe:EPAEmodel~ clearly lhas'its positive and negative aspects. The NRC trainig program produces a mechanism.to assure a level of-competency within states. It-is one of the mechanasims whereby. 'the NRC.can judge the performance of Agreement States. WithLthe lack of alternative _ training available locally.to otates. there'can not help but be a gradual decline in the level of-competency. The NRC should consider alternative mechanisms.to

meet-theirLfunding problems with respect to training.

Examples -include: ~ Conducting courses at FEMA's Emittsburg, MD facility or at other federal training facilities with NRC picking up'the ' lodging.and local transportation costs; Conducting.cources over weekends which considerably reduces transportation.and lodging costs; and Careful screening.of course applicants to: assure that'NRC funding is provided'only to those who actually need the training. .The-Agreement' States program is unique in that it is an~ effective working relation between the federal Government and the states. It'is also' cost-effective.- There'are more radioactive materials-licenses: issued in Agreement States. It is not uncommon for the Agreement States to lead the way for the NRC in areas of " radiation-safety. It would be unfortunate, not to mention expensive, if such I Loffective,. efficient program as the Agreement States program were toLfail because of a change-in NRC's policy regarding the j funding of'its training programs. l Si grel koartQu111in, j Director cc: T. Looby C. Harden i Agreement States j 14 Appendix C E

STATE OF FLORIDA DEPARTMENT OF HEALTH AND REHABIUTATIVE SERVICES - March 20, 1989 Donald R. Hughes, Sr. . Radiation Control Cabinet for Human Resources 275 East Main Street' Frankfo t, KY 40621

Dear Mr. Hughes:

This is in response to your March.7 memorandum requesting input on ways states can share cost of NRC training. Our responses to your four questions are: 1. The imnediate reaction would be a request for an explanation of why NRC no longer funded travel and per diem costs. I also anticipate there would be a reduction or possibly elimination of people from Florida attending the training. 2. The long term reaction would be that fewer of our people would have an opportunity to attend NRC sponsored training. This could result in some degradation of our professional skills. 3. It normally takes at least one year to justify additional training funds. Unfortunately when faced with many I competing demands.for funding, training often receives a low priority. 4. The loss of NRC training funds for travel and per diem would clearly. reduce our ability to provide adequate training. The single most valuable assistance from NRC in the agreement it has with agreement states is the providing of training and training funds. To eliminate or even reduce this arrangement would cause a serious reduction in our ability to provide trained staff. The NRC i. training of most concern is the 5 week Oak Ridge course. I do not believe we could afford to send anyone to the course if NRC did not pay per diem and travel costs. I suggest that NRC consider charg-ing their licensees the full costs of their licensing activities. This might be the best way for NRC to resolve their funding short-1317 WINEWOOD BLVD.

• TALLAHASSEE, FL 32399-0700 mos MARDNEZ, GOVERNOR GREGORY L COLER, SECRETARY l

15 Appendix C

FL March 20, 1989 l Page Two l .i . Another aspect of reduced NRC training would be that NRC. j -ages. 1 would be less able-to.. standardize procedures, etc. Essentially 'NRC'sfinfluence over' state programs would be reduced. With the enormous benefits that.NRC gets from agreement state pro-grams, I~ feel it needs to continue to increase training opportuni-j ties;for state staff. I appreciate the. opportunity to comment. Sincerely,. Jarrett Chi Office of Radiation Control l I l l 16 Appendix C

l i 'Ah RADIOLOGICAL HEALTH SECTION - ROOM 600 James G. Ledbener, Ph.DJ Ccmm ss;ener OFFICE OF REGULATORY SERVICES 878 PEACHTREE STREET, N.E. / ATLANTA, GEORGIA 30309 March 22, 1989 Mr. Donald R. Hurhes. Sr., Manager Radiation Control Cabinet of Human Resources -[ 5 -? {j '2 275 East Main Street g" Frankford. Kentucky 40621 ,4 ~ -o -2 y., D ar Mr. Hughes: The following respond to your request in memo dated March 7, 1989: .;g g ;]x a; L 1. What. immediate reaction do you believe your state would have if the NRC stopped funding the travel and per diem costs associated with State training? Very little reaction as~'long as State travel funds were adequate. 2. If you believe there would be a different long-term reaction, what do you think it would be? As travel funds become tight I believe our State's reaction would be that if NRC vants our staff to have the training then NRC can pay all cost .,sociated with the training, including travel and per diem. Other federal agencies (for example) Health Care Finance Administration (HCFA) of Health and Human Services (HHS) pay not only for training state staff but also for salaries.and equipment. .3. How much lead time would be required in your state to obtain additional funding for training travel (presuming it would be approved)? hro years (2). 4. Would the loss of NRC funds for travel and per diem: a. eliminate your ability to provide trainings b. reduce your ability to provide trainings c. have no impact? In the long term the loss of NRC funds for travel and per diem would eliminate our ability to provide training. The loss of funds would reduce our ability to provide training in the short term. 17 Appendix C

8,A Page 2 of 2 March 22, 1989 1!r. Ih:ghe s, S r. I believe NPC should continue to pay for training of state regulatory personnel and associated travel and per diem. The savings to the NRC through the Agreenent Program, as stated in NUREG-1311, is over $14,100,000.00 for technical staff alone. And the NRC only spends approximately $522,000.00 on training of state persor.nel! Sin e ely, A. Thomas E. Hill, Acting Director Radioactive Materials Unit Radiological Health Section i TEll/dv I l 1. l l l 18 Appendix C

l. Sta'siof IdancL DEPARTMENT OF HEALTH AND WELFARE '

Division of Environmental' Quality 450 W. State Street

< CECi6 D. ANDAUS. 7DCHARDyNOVAN : e i Marchi14',19891 rs ' Donald R.' Hughes, Sr., Manager

Kentucky Radiation Control-l Cabinet for Human, Resources L

?275' East Main Street 4 . Frankfort, Kentucky 406211

Dear'Mr. Hughes:

SUBJECT NUCLEAR REGULhTORY COMMISSION AGREEMENT STATES' FUNDING-a i This. letter, is to express the views - of the Idaho Department' of Health and Welfare,; Hazardous Materials Bureau,-Radiation Control ' Program'in response to the questions raised'in.your letter. -1. The State would, in all probability,. reassess the value of. participation in the Agreement States Program since training, in effect, would no longer be available to Idaho Radiation Control staff. 2.- The long-term reaction would not be significantly different from item (1. Additional funding -for training would, most likely, 3.. 'not be approved. 4.' Loss of NRC funding for travel-and per dien would-effectivel . training. y eliminate the State's ability to provide - One of the persuasions NRC has used to " sell" participation in the - Agreement States Program has been-NRC funded training for State staff. .Actually, this expenditure of funds by NRC has been a terrific : bargain for the, federal government. The federal money eaved!by-states conducting state funded licensing and inspection . cetivities in. Agreement. States where those activities would ctherwise' require NRC funding, no, doubt far outweighs the NRC funds vested in state training. AO MFrTTnTN N i a t.199a* Printed on Recycled Paper ) 19 Appendix C 1&-

. Donald.R. Hughes, Sr. -March 14, 1989 Page 2 In summary, the Idaho Radiation Control Program would be seriously, ~ i adversely impacted should NRC funded training be withdrawn.' NRC i should look elsewhere to cut overhead. Sincerel, d ~ Michael. Mays-( Senior Radiation Physicist Radiation Control-Program Hazardous Materials Bureau MM/ mil' 1 i ) i 1 l i I l 4 l 1 l i 20 Appendix C I l

} ,,s l STATE OF lLUNOIS i DEPARTMENT OF NUCLEAR SAFETY 1035 OUTER PARK DRIVE SPRINGFIELD 02704 (217) 785-9900 7tRRY R. LASH 0*tema March 22, 1989 Mr. Donald R. Hughes. Sr. Radiation Control Branch @iF 7 Cabinet for Human Resources Q d.'] 275 East Main Street Frankfort, Kentucky, 40621 s

Dear Mr. Hughes:

4 Il . ;y, Thank you for your memorandum of March 7,1989, regarding NRC trlfriing. O The Illinois Department of Nuclear Safety (IDNS) considers,tlIeG - courses. courses to be an important part of its radioactive materials regulato(y M ~ program and welcomes the opportunity to express its position in favor of not' diminishing the availability and accessibility of these courses to people in state government. The Department fears that eliminating or reducing federal reimbursement for travel and per diem would initiate a downward trend in course accessibility and then availability because many states would be unable to participate enough to ensure an adequate demand for courses. The effect would be a reduced level of training for all state regulatory programs. IDNS believes a consistent and effective national regulatory system requires qualified personnel in all jurisdictions; a requirement that would become more difficult if access to federal training were restricted. Overall consistency is especially important now, as licensees and regulators prepare to implement changes required by revised 10 CFR 20. It is significant also that many states rely upon the promise of training to recruit new technical staff members. If forced to make training cuts, the recruiting difficulties experienced by these states would add further to a problem of declining regulatory quality and effectiveness. In response to the four specific questions in your memorandum, Illinois probably would be less affected than many states if NRC stopped subsidizing travel and per diem for its courses. This is because the Department of Nuclear Safety is fortunate to have funds for these expenses should federal money become unavailable. Tuition-free, high qua.'ity courses are of great value to the Department even if travel and tuitio6. costs are not reimbursed. IDNS, therefore, would continue its present level of participation regardless of whether federal travel and per diem funds were available. Although IDNS would not reduce its attendance at NRC courses, loss of federal funds for travel and per diem would drain money away from its other 21 Appendix C

DON 1d R. Hughes, Sr. ."TL 'Page 2 March 22, 1989 professional'developraent activities. For example, less money would be availabic for professional meetings and courses on advanced topics such as internal dosimetry, instrumentation, computer science, and management development. Over time this would impact Illinois programs by lowering the levels of training and professional development of the Department's staff. As implied above, the Commission should continue to examine ways to reduce the cost of its courses rather than transferring part of their cost to the states.. The recent decision to conduct courses at inexpensive federal 1 training centers is an example. 'New developments in teleconferences should be explored as alternatives to bringing students to courses. In conclusion, the Department believes that as an important part of the national radioactive materials regulatory system, federally-funded training for state regulatory personnel should continue. The alternative is reduced levels of training in state programs and ultimately a reduction in the quality and effectiveness of radioactive materials regulation nationwide. In the end, decreased training levels could result in the NRC having to resume regulatory authority in some current Agreement. States. Such a development would certainly increase NRC's expenses overall. Thank you for the opportunity to comment on an important matter to the State of Illinois. Sine rely, / err R. Lash Director TRL: bas b \\ i 1 1 1 ) 22 Appendix C

I. N s, m.IO'WPL mf te==v c. e=aecn e. c:eer DEPARTMENT OF PUBLIC HEALTH MARY L. CLLIS, Dmtctost May 4, 1989 Donald R. Hughes, Sr., Manager Kentucky Radiaticn Control Cabinet for Human Resources 275 East Main Street Frankfort KY 40621 Dear Mr es: Reference is made to your memorandum of March 7,1989, in which you request response to four questions relative to possible changes in training funds allocations by NRC to Agreement States. Iowa's responses to your questions are as follows: 1. Question: What immediate reaction do you believe your state would have if the NRC stopped funding the travel and per diem costs associated with state training?

Response

In my opinion, we in Iowa radiation control are quite fortunate because of our upper management's attitude toward training. I am sure they would be somewhat negative on raising additional funding for training, but if the need is there, they would address it. Our budget is set prior to entering into the. budget year. If we were not allowed to phase into funding reductions, more serious problems may be encountered. In conclusion we would not like a funding reduction but can deal with it if totally necessary because of the importance placed on our regulatory program and the liability the state could be subjected to if we could not get the necessary training for whatever reason. 2. Question: If you believe there would be a different long-term reaction, what do you think it would be?

Response

Worst case would be that we would cancel our agreement because we could not afford to send persons to training. More realistically, we would have to look seriously into establishing a special training fund created by an increase in fees. 3. Question: How much lead time would be required in your state to obtain additional funding for travel (presuming it would be approved)? Response: One to three years. 4. Question: Would the loss of NRC funds for travel and per diem: a) eliminate your ability to provide training? b) reduce your ability to provide training? c) have no impact? 23 Appendix C LUCAS STATE OFFICE BUILDING / DES MOINES. lOWA 50319 0075 / 515 281 5787 i

-R. Hughesk-May 4._1989--page two o Response:~!b..

v.

l Don.thyouhaveanyquestionsregardingtheabove,pleasecontactme. Sincerel,

Dona A. Flater,. Chief Bureau of Radiological Health 515/281-3478 '

DAF/bf: .n a 3 m ~g S ~. q g. '* ? ~' ~ ?' $ 57 t. l q 1 1 24 Appendix C g. f-.

STATE OF KANSAS

b. ;, 5:!':.'0 i

M iWKg I

c. Q V.**; J

'h DEPARTMENT OF HEA1,TH AND ENvinoNurNT Torbes Fueld Topeka, Kansas 66620 0001 &ne t913) 2961500 %b Ha3 den, Coterner stanley C. Grant, Ph.D., Sceretary Cary K. Hulett, Ph.D., L'nder Secretary March 13, 1989 I Donald R. Hughes, Sr. Radiation Control, Cabinet for Human Resources 275 East Main Street Frankfort, KY 40621

Dear Mr. Hughes:

This letter is a reply to yours of March 7th asking a series of Questions about NRC funded training. The following are brief answers and comments based on 25 years in an Agreement Program. 1. The immediate reaction of this state if NRC stopped funding the travel and per-diem for training of state personnel would be to stop sending personnel to training. The program is operated on state general funds (ssf's) and there is a specific limitation on the use of state general funds for out-of-state travel. 2. The long term reaction is not so easy to predict since the program could ask for relief from the restriction which would need to be approved by the department administration, the governors office and finally confirmed by the legislature as a line item expenditure. Considering the fact that no federal dollars exist to assign to that budget request the odds are very poor that it would be approved. This state does have a license fee system and x-ray registration fee which collects approximately 80% of the program costs but this money goes directly to the sgf and is reappropriated each year. Since it has no tag identifying the source it is difficult to' defend the program as a self supporting program. 3. The state budget cycle is 18 months and begins in April or May therefore if a change is needed it must be entered in May for use in the. fiscal year which begins in June of the following year. 4. a) The loss of NRC funds would eliminate the states ability to attend the training now provided by the NRC. b) The state would continue to provide in-state training and where possible (DHHS X-ray contract) that training provided under other contracts. 25 Appendix C

F'S l c) The impact would be large since the state has recently lost the i only health physics program at the University level and therefore l l has a very limited access to the type of resources needed to j l-provide basic training. Finally, just a note to provide some insight into the workings of the state organization. This agency has in the past been denied the opportunity to send a new employee to federally sponsored training even when the per-diem and travel was being paid by the NRC because it was considered too great an expense to pay an employee who was not at his work station. This is not the current stand of the a p.ncy but it has occurred and could again. New administrators sometimes have a very low opinion of the training provided by federal agencies. The training provided by NRC has always been described as excellent by the trainees and their supervisors but the expenditure of time for training in this program compared to the expenditure in other programs in terms of sgf dollars is very noticeable. New administrators briefings tend to highlight such differences. It seems likely that the current situation which has the state paying all the direct and indirect costs from state tax money and the federal contributing only the direct costs for training is likely to be less costly than the other model (for example EPA programs) where the federal government pays a part of all costs and the state purchases training a> pece ary. T-Sincdrely, 19 ~ ~ '"heraldW.ATlerr[ c1 L I' Public Health Physicist Bureau of Air Quality and Radiation Control G';fA/psw i l I ) 26 Appendix C .a

CABINET FOR HUMAN CESOURCES %{ COMMONWEALTH OF KENTUCKY FRANKFORT 40621-0001 g' 5....., ? DEFARTMENT FOR HEALTH $ERVtCES John M. Montgomery, Ph.D. Deputy Regional Administrator U. S. NRC, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

Dear Dr. Montgomery:

g I am writing this letter in response to my own memorandum dated March 7, 1989, which was directed to all Agreement State Program Directors. As a member of the U. S. Nuclear Regulatory Commission'<, (NRC) Task Force on " State Sharing of Costs of NRC Sponsored Training," I want to provide Kentucky's input as responses from individual states may be included in the final report. The following are our responses to the questions presented in the memorandum: 1. What immediate reaction do you believe your state would ~ have if the NRC stopped funding the travel and per diem costs associated with State training?

Response

Our immediate reaction would be the reduction in the amount of training that is provided out-of-state. The effect on the radioactive materials program would depend on the current staffing level and the amount of training each radioactive materials staff had already received. 2. If you believe there would be a different long-term reaction, what do you think it would be?

Response

I believe the Agency would see the need for selective out-of-state training and authorize such to maintain Agreement State status.

However, other training activities within the Radiation Centrol program would probably be compromised until additional training funds could be requested and granted.

l 3. How nuch lead time would be required in your state to obtain additional funding for training travel (presuming it would be approved)? 27 Appendix C I An Equal Opportunity Employer M/F/H" 1

k lohn 7L Montgo:aary, ph.D. Paga Tw3 March 21, 19S9 j l Reccence: Two to three years as we have a biennial budget. During an emergency or unforeseen situation, selected funds could be rea*1)cated;

however, the procedure for routine budget u; quests and/or planning would normally take place approximately one year prior to a designated biennium.

4. Would the loss of NRC funds for travel and per diem: A. eliminate your ability to provide training: B. reduce your ability to provide training: C. have no impact.

Response

Loss of funds would definitely reduce our ability to provide adequate training. This Agency recognizes the importance of the Agreement State program and the service we provide to our licensees and the citizens of the Commonwealth. In view of this, I believe the Agency would eventually provide the required funds for out-of-state training. I would also like to offer the following comment. Unless the unexpected

happened, I

do not believe Kentucky would ever dissolve the Agreement State program. On the other hand, I am somewhat disturbed at the Commission's inability to grasp the benefits and savings that are provided to the NRC as a result of the Agreement State program. The old addage of " straining at a gnat and swallowing a camel" certainly applies in this situation. In -conclusion, I believe that federally-funded training for state regulatory personnel should continue. This was the understanding as to how the training would be provided more than twenty-five years ago. That process has not changed during that time and I see no reason to make a modification at this date. ncerely r?f Donald R. Hughes Sr., Manager Radiation Control Branch Division of Radiation & Product safety DRH/ns l l i 28 Appendix C

gf$gl ytaic of Kanisian-GRS by DEPARTMENT OF ENVIRONMENTAL QUALITY W DP' 00E"ED. March 21,1989 PAUL H. TEMPLET, Ph. I Mf!NCR $tcRgt4Ry Donald R. Hughes, Sr. Radiation Control Cabinet for Humen Resources 275 East Main Street Frankfort, KY 40621

Dear Mr. Hughes:

In reply to your memorar.dum of March 7,1989, relative to NRC sponsored training, i am pleased to provide a response to your questions in the order posed. In edditiors I shall offer a few opinions which you did not request but, hopefully, can use. iv;y responses are in the order listed. J. Tne immediate reaction would be to reduce the amount of training we could provide at state expense, it takes considerable time to (1) convince upper management at the governor's staff level that such is worthwhile and necessary when so many other things have higher priority in this day of austerity in Louisiana's revenue projections, and then (2) to increase the budget to cover these expenditures. There is no question that there would be immediate cutbacks and ef fects which would be felt over a period of several years.

2. Long-term (5 years or more) effects are difficult to predict with any degree of certainty. 'However, if I may gaze into my crystal ball, I should say that we would no longer be able. to provide courses to new employees in the nature of the 5-week course in radiological health at Oak Ridge or the RERO course in Nevada. These types of projections are subject to much variability as the state of any state's finances change.

We hope that Louisiana's will improve significantly by 1994 or sooner, but I cannot give that assurance. I would make the assumption that most states would attempt to shore up the deficit in training over en extended period of time. - Allow me to interject here that it is not without cost to the state now, as salaries must continue to be paid while an employee is in training.

3. In Loule!ana, the budget process begins in the fall for the fiscal year beginning July 1 of the next calendar year. Therefore, assuming that approval is automatic, it wouM take a minimum of 9 months. However, I would suggest that the deficit would be difficult to make up in one budget year if staff turnover is high.

4. At best, the loss of NRC funds for travel and per diem would reduce Loulslana's ability to provide training, and it would result in staf f less equipped to perform the job or take longer for all to be trdned to the same extent as they are now.

Now,.I should like to offer a few observations and opinions whlch may not necessarily be reflected in my responses above. You will probably glean some of this by compiling responses of other states, and I apologize if I seem to get on the " soapbox" on this one. OFFICE OF AIR QUALITY AND NUCLEAR ENERGY P.O. BOX 14630 B ATON ROUGE, dix 0 LOUISIANA '/0E98 29 Appen AN EQUAL OPPORTUNITY EMPLOYER J

~ - --_ - __ _ _ -____-__ - - _ _ _ _ _ _ - _ _ - _ = _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ - .' b g r ' Mr. Donald R. Hughes, Sr. March 21,1989 Page 2 As you are aware, historically training has been provided by a number of federal agencies, but this has been cut back for reasons which probably include budget cuts, etc. Our commendation should go to the NRC in their efforts to increase the training available to the state, both in quantity and quality. 1 i With most state-federal relationships, there is quid pro que, and many other i federal agencies provide grants in exchange for services performed. I believe there is such here, although it is not quite as obvious. The states have relieved the NRC of considerable effort in the area of agreement materials. The states have come to the assistance of the NRC cn a number of occasions where,in my opinion, the resources of the NRC would have been severely strained, or else, assistance could not have been j provided in as timely a manner. Typical of the latter is the type of response coastal .j states provide in handling offshore incidents in federal jurisdiction when requested. i'l No bill is rendered to the NRC, and it appears obvious to me that as long as the NRC has overall control over agreement materials, it reaps greater benefits when state program personnel are well-trained. Another example is the assistance states give the NRC in putting on training programs by providing quallfled instructors, a In addition, you will probably note a great variability in the ability of states to provide training if travel and per diem are reduced or eliminated. I understand some state programs cannot get permission to travel out-of-state unless underwritten by another entity. This may be highly variable and dependent on a given state's ability to pay from year to year. We have had freezes on out-of-state travel in the past, and it - would not surprise me to see it again. -1 Finally, the answer to question //4 may also be highly variable from year to year l as the finances of each state change. I am not sure a set answer for this question is possible, but I suspect answer b) will be the choice for most programs. I think the bottom line you will find here is a high degree in variability in abilities of states to provide a continued high-level of trained staff, depending primarily on the financle' condition of the program and the degree of staff turnover. Thank you for the opportunity to provide input to the work of this important committee. In my opinion, this is the most important thing the NRC does for the states on a routine basis. We need to encourage the NRC to provide more support for states in this manner. I hope you receive adequate response to make this task easier. Since ely yours, r J/ William H. Spel Administrator Nuclear Energy Division /whs 30 Appendix C

fl DEPARTMENT OF THE ENVIRONMENT 2500 Broening Highway, Baltimore. Maryland 21224 Area Code 301

• 631 William Donald Schaefer Martin W. Walsh, Jr.

Governor Socratary MDORANIU!4 20: Danald R. ltr#es, Sr., Manager Fentucky Radiation Centrol 9 HGi: Rolard G. Fletcher, khinistrator / 9 /. e Center for Radiological Health DATE: March 20, 1989 SUa7ECT: State Training Cast-Sharirg c************************************************************************* In response to your March 7,1989 me::c, my ansers to the four specific questions are: 1. Apprrnal for State funds for cut-of-state travel and per diem is extremely difficult to get. I anticipate Maryland's respc:ene would be to seek more in-state training and rely upon supervisors to enharce that trainirg. 7b improve trainire availability for my staff, I weald reoxneni to the IRC that they use in-State facilities sudi as the FDR trainirg institute in Duitsburg, Marylard. Other states ray have their own in-State training facilities to re:xx: mend. 2. There is a possibility, that if current legislation to establish a radiatico user's fee is apprtread scre 1mc trainirg could be furded but far less than we currently receive. If this is rot the case, it normally takes three years before a significant.badgetary ircrease is favorably considered. Even then,100% approval is unlikely - 50% of request is more realistic. 3. Marylard cperates on a July 1 - June 30 fiscal year basis ani budget preparation is normally ocupleted in the fall w,Mrg the ne:1 fiscal year. Optimistically, a regaest for training travel could be considered within a year ard, dependirg upon justification, approved. 'lhis would be the exception, rather than i the rule. 31 Appendix C a

p Dorald aghes Maren 20,1%9 Page 2 \\ I y ' 4. > !he' loss of NRC funds for' travel and per diam would reduce our ability to acquire and enhance staff training and proficiency. j! 'the old sayirg "2he. squeaking Waal gets the.greese" applies here. . If we "aqueak" loud enough about maintaining staff proficiency, we might receive scxne favorable state funding support. However, there would be an overall declins in staff performance while _ ' alternative' fundirg scuroes azu investigated. .l 1 I find it difficult to acom State trainirg program funding. pt the necessity.for an NRC reduction of As section 6.2 of aN 1311 points out, the Apa.

d. States Fwesuu saves the NRC over $13,'000,000. I believe any.

investor would, unquestionably, rectanmend a $500,000 irrrwbu t if a $13,000,000 return was guaranteed. RGF/anc i I .c ,g". i l 32 Appendix C l w

l 3 4 ' [41 STATE OF NEBRASKA DEPARTMENT OF HEALTH 'a o : ll l EAY A. ORR GREGG E WRIGHT, M.D., M.ED. I l coscason DIRMOR IJEI!! h. 2Ri N y l March 22,'1989 g*N Donald R. Hughes, Sr. Radiation Control A*g Cabinet for Human Resources 275 East Main Street TN W . /s ' 1 Frankfort, KY 40621 3,,,i.d' N;,< Dear Mr. Hughes This is in response to your March 7, 1989 memo concerning state training cost-shar.ing for Agreement State programs. I will address your items in the order you presented them. 1. If the NRC stopped funding the travel and par diem costs associated with State training there would pr2 ably be no immediate reaction (12 months) on oM 4,rogram. 2. The long-term reaction would depend on whether or not NRC stopped funding all of the travel and per

• diem costs associated with State training.

If NRC stopped funding all of the costs the impact may be significant, because we may be unable to send individuals to some of the training courses, i.e., the five week health physics course. We would'also need to evaluate which training courses we would attempt to have our personnel attend. Instead of sendii.1 our personnel to all of the training courses we may pick out certain specific ones and then provide the additional training via on-the-job within our program. If on the other hand NRC Vould pay the majority of the costs it would have much less of an impact on our program. We would be able to have our personnel attend the training courses and could pay for the remainder of the costs. We are fortunata in that we have the luxury of having sufficient travel funds to be able to send personnel to various meetings, etc. for training purposes. I anticipate that this will remain in the future. I would rather see NRC fund the costs of the training, however, if it comes to the poine that changes are necessary and the states need te, 301 CENTENNIAL MALL SOUTH E O. BOX 95007. LINCOLN, NEBRASKA 68509 5007 AN EQUAL oPPORTUMTY/ AFFIRMATIVE ACTION EMPLOYER 33 Appendix C

,7 pr Dar.61d.R. Hughes, Sr. March 22, 1989 Page 2 l i shoulder part of the burden we are in a position I to do so. 3. We are not. locked in on specificity within our budget. I am able to utilize my budget for the overall functions'of the Division. In other words, I have flexibility in the way the budget is impicmented. However, since we will.be adding staff and will need training for these new personnel the fundit.3 would need to be increased. We would need 12-18 months to obtain additional funding for training travel if funded through general. funds. The fee structure that we are attempting to implement has training expenses incorporated into it, but this would only cover those individuals covered by the fee system.. 4. The loss of NRC funds for travel and per

• diam would reduce our ability to provide training for any staff.

If you have any quartions, please contact this office at '402-471-2168. Sincerely, g. Harol R. Borchert, Director Division of Radiological Health HRB HEStein 34 Appendix C

WV l Harry zuggested I (Ellis Simunons) make some comments. ) 7 would like to quote from Representative Mr. Van Zandt, a JCAE member in 1959. "There'might be'some expenses in training personnel and in administering such a program, but it would be minute, coacpared.to the AEC budget as a whole. " Things have not changed in 30 years, it is still minute. The training funds provided by N.R.C. for State personnel is one'of the biggest bargains the federal government has_ever had. If the training cost were ten times what they are now, it would still be a bargain. It would be a-grave mistake to deny this small contract with the states. There would be~a deteriorating ~of federal-state relations and the state's program will suffer immensely by this separation., The commission would be very short-sighted if they reduce this contract, eventually, you would eliminate the need for review of'the Agreement States program. 35 Appendix C

1 ROs Mfu.En STATE OF NEVADA MwA C. FLontNCE Administreser Assi,ngIGeeerner D JEARY Ghi&EN14 TOG JO$LPH Q. J ARVI$, M.D. Heatsk Offseer. Dereeser DEPARTMENT OF HUMAN RESOURCES HEALTH DIVISION Radiological Health Section 505 East King Street. Room 203 Carson City. Nevada 89710 (702) 885 5394 r April 26, 1989 l Donald R. Hughes, Sr., Manager Kentucky Radiation Control Branch Cabinet for Human Resources 275 East Main Street i Frankfort, KY 40621 l 1

Dear Don:

The U.S. Postal Service has'a peculiar way of delaying mail to Neva % 1 for some reason, therefore my response to you is rather late for. I incorporation into the Task Force report to the NRC. I will answer your primary concerns in the order'of your letter: 1. The Nevada Health Division is traditionally no_t_ successful -in obtaining out-of-state travel funding for all progctms due to the conservative nature of the Nevada Legislature. The raciation. control programs, therefore, do not have funding for out-of-state travel. You should also be aware that the Nevada Legislature meets in odd- . numbered years and is currently in session. If NRC should terminate funding for travel and per diem associated with required training, my staff would not be able to attend out-of-ctate NRC training courses for at least 2 years (earliest that I could request new funding for this shortfall). Although'the NRC has indicated that the courses are requirements for Agreement State Program staff, they are yet to indicate to this office in writing that staff must atteni the courses before participating in licensing, inspection and other activities in the program. Without cuch written requirements to specifically address the requirement, the Nevada Legislature and other review processes are not likely to provide funding for these training activities to maintain compatibility with the NRC. 36 Appendix C

2. The State reaction in item 1 would likely continue until the NRC dccuments that the courses are required prior to staff participation or are necessary to correct ir. adequate performance by staff. 3. As indicated, af the funding were cut off today and NRC documented that the courses were required prior to new participation, additional funding might be obtained during the 1991 legislative session (Funding available on July 1, 1991). Funding might also be obtained through the State Interim Finance committee prior to the next legislative session, provided that NRC has documented that radiation control in Nevada is compromised without it. 4. Currently, the only other training method for orientation of new staff and training for additional job responsibility includes on-the-job tqhining experience by accompaniment with senior staff members. Because, the NRC has held the courses as requirements for Agreement State staff, the loss of Federal support for travel and per diem will significantly reduce the State's ability to maintain adequar-1v trained personnel. As you'know, staff turnover and the loss of NRC funding for travel and per diem is extremely damaging to the State's ability to conduct adequate programs. In a small program, staff turnover can deplete in-house expertise quickly and run the programs aground with notice. As an employee and program

director, I would be reluctant to consider employment with an agency which appeared to be unable to provide skills and training for job assignments which I may be unable or untrained to perform.

I believe that Nevada became an Agreement State years ago, at least in part, because limited specific resources would be made available to the State in exchange for the State's prevision of

staff, program

funding, enabling legislation and regulations, etc.

If you have any need for further input, please give me as much lead time ac possible. The ?ony Express works, but not too well. Sincerely, StarAey R. Marshall, Supervisor Radiological Health Section Bureau of Regulatory Health Services rf/krebltr 37 Appendix C _ = - = _ _ _

STATE OF h.d HAMPSHIRE DEPARTMENT OF HEALTH AND HUMAN SERVICES DIVISION OF PUBLIC HEALTH SERVICES ' M. Mary Mongan Commissioner - Winism T. Wallace, Jr., M.D., M.P.H. Director-Division of Public Health Services Health & Welfare Eldg. 6 Hazen Drive . Concord, NH 03301 6527 i Ts!. (603) 271 4588 March 14, 1989 l Donald R. Hughes, Sr. Radiation Control Cabinet for Human Resources 275 East Main Street' Frankfort, KY 40621

Dear Mr. Hughes:

This' is in response to your letter of March 7,1989, which requests comments relative to the suggestion of States sharing costs of NRC training. The numbered responses correspond to your questions. 1) Probably that there is little incentive to continue with the Agreement State Program. New Hampshire has found it increasingly difficult to adequately budget and provide sufficient FIEs for the licensing program. Frequently, the budget battle for dollers elicits the question of what the advantages are for us to continue with the Agreement State program. We always cite the excellent training provided by NRC as a prime advantage. It seems to me that the cost to NRC to continue to provide training to State programs would be far less than would be the hiring of sta'ff, etc., to assume the regulatory duties in states which may decide to terminate the Agreement due to lack of adequate incentives. 2) Can't think of one at thic time.

3) At least two years.

Our budget is a biennial one and already prepared for FY 90 & 91. PUB E *, g LTH L l 38 Appendix C l lE

pn . ci

Donald R. Hughes, Sr. - 3/l'l/8 9 -

4) The loss of funds would completely eliminate our ability.to provide training. Our total oudget for FY 90 for out-of-state-travel for the-entire Bureau is $1,000. We also note that this amount could even be reduced to zero should the rumored budget cuts go into effect. Lastly, just a coment on-the often discussed idea that training should-b2 provided within the regions in order to reduce costs. Khile_this cuggestion may' assist NRC in reducing its' costs I believe it would have little effect on the States. It would matter little to us whether we traveled to King of Prussia, PA;, Maine or California--it is all still out-of-state travel. Only a course l presented in New Hampshire would afford us attendance under the proposed .eystem. I' thank you for the opportunity to comment and wish you much success in relaying our concerns. l Very truly-yours, CS I . Diane'E. Tefft Administrator Bureau of Radiological Health DET:em 39 Appendix C

L; F . aEs hm. re t L DEPARTMENT OF HEALTH BUREAU FOR RADIATION CONTROL g 111 Livingston Street (20th Fir.) Brooklyn, N.Y.11201 -(718) 643 7967 l J. 1 March 14, 1989 Donald R. Hughes, Sr., Manager Kentucky Radiation Control Cabinet for Human' Resources 275 East Main Street Frankfort, Kentucky 40621

Dear Don:

Pursuant to your memorandum of March 7, 1989 on ' State training cost sharing with the NRC, your four (4) questions are answered below: 1. If the NRC stopped' funding travel and per diem costs associated with State training, the immediate result would be to drastically restrict training of our Agreement Materials staff. 2. One could anticipate a protracted delay in quality training of indeterminate duration if the NRC discontinued its cost subsidies. 3. There is no way, at least for this program director, to

p. edict the lead' time required to obtain additional funding for training, travel and per diem.

With conjectured possible approval, the budget planning apparatus probably would take at least one or two years to be effective in this time of fiscal retrenc* ment for our jurisdiction. 4. The loss of NRC funds for travel and per diem would i importantly reduce our ability to provide training. Of t course, we could not permit abrogation of our responsibility to provide suitable training but it would influence the i cretall radiological health program in a seriously negative l way for an unacceptable period. ) I 40 Appendix C

'p1 - e 1 i i l l' Please advise me what steps (short of violence) we can take to prevent this threatened inappropriate action by the NRC from taking place. We may have some ideas to furnish subsequent to your initial meeting next week.- Sincerely, Leonard R. Solon, Ph.D. Director LRS/1p/2:6513 3 cc: Barbara L. Reissman, Dr. P.H., Deputy Commissioner (thrcush Gerald Flanders, Assistant Commissioner) Francis J. Bradley, Ph.D., N.Y. State DOL Dr. Paul Merges, Ph.D., N.Y. State DEC Karim Rimavi, Ph.D., BERP, N.Y. State DOH John McGrath,-Regional State Agreements Officer, NRC Joel Lubenau, NRC, SL1TP-Charles Hardin, Executive Secretary, CRCPD 41 Appendix C

North Carolina Department of Hurnan Resources Division of Facility Services 701 Barbour Drive o Raleigh, N. C. 27603 2008 James G. Manin, Governor

1. O. Wilkerson, Jr., Director David T. Flaherty, Secretary Telephone919/733-4283 March 13, 1989 Donald R. Hughes, Sr., Manager Radiation Control 275 East Main Street Frankfort, Kentucky 40621

Dear D:

rt: This is in reply to your Inemoranium of Parth 6,1989, con rning state trainirg cost-sharir,J. As has been pointed cut on numerous cer-mions, one of the outstanding features of the NRC agreement states prtgram has been the high gaality training and the Comission's financial support to alls the states to participate in that training. We would like to provide the following information in response to the four questions you raised in your zne::orandum. 1. Should imC stop furriing travel and per diem for our training there would be a drastic reduction in our training ~of nes inspectors and license reviewers which would be likely to cause greater inconsistencies and increased errors in such work. ] 1 2. 'Ihe long term difference to such a charge would result in an overall redoced l level of competency resulting in poorer ability to make decisions and l necessitate a much greater degree of supervision. ~ 3. Sirce we work on a two year hxiget cycle, it would require from one to two { years for additional funiire to be acquired through the apg.wiatations j process. 4. 'Ibe loss of Imc funds for travel and per diem would reduce significantly our I ability to provide the r-en training. j It might be helpful to give some attention to the way travel costs are shared in training prcgrams with the Federal Emergency Panagement Agency where a portion of the travel and per diem costs are paid by EE2% and the remain $er, primarily reals, are paid for by the state. 42 Appendix C

l. n 1

AFL Page 2; The stx: cess' of' the NRC Agreement' States Frugaru tends to a. large degree to be - Etwdibul.ai i.o i.he quality of personnel in the program and the outstanding trainfrg

that they have been given. The challenge for all of us is:ta ensure that'this

-le'.cl of..cn pete:ry continues to maintain a high ' quality radiation protection Lcffort for all involved.. ~ Sirarely, +. Dayne H. Brown, Chief Radiation Prtfdon Section DIB:ws 43 Appendix C

L I NORTH D,.OTA L / y; b o L STATE DEPARTMENT OF HEALTH } - AND CONSOLIDATED LABORATORIES !l l State Capitol M MA Blsmarck, North Dakota $6505 March 15, 1989 1200 Missourt Avenue P.o. Box 5520 Bismarck, North Dakota 58502 5520 L Mr. Donald R. Hughes, Sr. Manage r Kentucky Radiation Control ] Cabinet for Human Resources Department'for Health Services . 725 E Main Street Frankfort, KY 40621 l

Dear Mr. Hughes:

On March 13, 1989, I received your memorandum rega rding State training cost-sharing dated-March 7, 1989. The issue of State Radiation Control Programs from Agreement States funding the cost of staff members to attend NRC-sponsored training is an extremely critical issue for the State of North Dakota. The North Dakota Radiation Control Program is primarily funded by legislative appropriations and fees charged to radioactive material licensees and X-ray registrants. The current fee structure does not cover. costs associated with the X-ray or radioactive material' inspection programs. In order to adequately cover costs of these these critical programs, current fees would need to be nearly tripled in order to adequately fund the overall radiation control program. Therefore, the issue 'of NRC reimbursing state program attendees at NRC-sponsored courses becomes an even more critical issue. In response to your survey questions, the following information is provided: 1. What immediate reaction do you believe your state would have if the NRC stopped funding the travel and per diem costs associated with state training?

Response

Critically needed background training for inspectors and licensing personnel would be set back by several years, based upon the current funding situation in North Dakota. Based upon legislative resistance to adjust the salary schedules for State employees in the past several

years, the North Dakota Radiation Control Program has experienced a

nearly complete turnover of staff members within the last two years. Therefore, the idea of additionally burdening Agreement States with the costs of NRC-sanctioned and approved training would place the Radiation Control Program into a critically deficient system 44 Ap'pendix C Environmental Environmental IN Waste Management Enforcement Engineering Allotion controt 4-22 701-224 3234 701-224-2345 701 224 2354

d l-Mr. Hughos March 15, 1989 L for properly reviewing and inspecting radioactive material licensees and X-ray registrants. Essential courses such as the 5-week Basic Health Physics Course would be ve ry expensive for per diem and would be too expensive to attend. 2. If you believe there would be a different long-term reaction, what do you think it would be? Fesponse: Based upon current resist.ance to increase fees or levy additional taxes, the short-term outlook for funding travel and per diem costs of State attendees at NRC-sponsored courses appears to be very remote.

However, long-term forecasts for the State's economic recovery may allow additional adjustments to increase the fee structure and/or the legislative appropriation for the Radiation Control Program.

It is too late to go to our present legislative session which adjourns' by April 1. Our next session is not until January 1991. t l 3. How much lead time would be required in your state to obtain additional funding for training travel (presuming it would be approved)? Responses Although the outcome of the current legislative session ~ is not known at this time, the Radiation Control Program in North Dakota is not currently authorized to fill one of five positions within the Radiation-and X-ray Licensing and Inspection Programs. Therefore, anticipation of additional funding to support training travel for Radiation Control Program staff is not feasible for at least 2 1/2 years. A minimum of 2 1/2 years would be required to appropriate additional travel funding into the Radiation Control Program and/or significantly increase X-ray and radioactive material licensing and inspection fees to cover this requirement. 4. Would the loss of NRC funds for travel and per diem: a) eliminate your ability to provide training; b) reduce your ability to provide training; and c) have no impact?

Response

Loss of NRC funds for travel and per diem would essentially severely reduce the ability of the North Dakota Radiation Control Program to provide significant training to newly hired licensing and inspection personnel. The North Dakota Radiation Control Program is aggressively attempting to reduce the present licensing and inspection backlog of work through a systematic work review process and by selectively sending program personnel to NRC-sponsored training courses. Each staf f member's current work products are carefully reviewed to ensure prioritization of required 45 Appendix C s

ns-b .Mr. Hughes. . March'15, 1989 licensing and inspection. actions - to attempt to bring the North Dakota ' Radiation Control Program up-to-date on both -1icensirg' and ' inspection. required time - tables. Currently, both' the. X-ray and Radioactive Material Licensing. Programs are approximately. 95% current on licensing actions by aggressive reviews and updating all required license files during the past 12 months. However, because of significant i etaployee 1 turnover and understaffing.in the North Dakota Radiation Control ' Program, X-ray and radioactive material inspections are currently 18 to 24 months behind proposed i schedulese i Based upon the above information,. consideration for. discontinuing. funding by NRC of Agreement State personnel travel and per diem a at NRC-sponsored courses.would have a severe impact on our i program. It would take us a minimum of 2 1/2 years to develop a j replacement source of funds. ] If you ' nave. any questions regarding this information, please-j contact me directly at (701)224-2348. l

incerely,

^ A O Dana.K. Mount, P.E. Director, Division of Environmental Engineering .I DKM/TDL:saj cc: Gene A..Christianson, Chief 46 Appendix C

@' ~. ' Depatinent of Human Resource 1 HEALTH DIVISION M *"" P00 SY! 5th AVENUE, PORTLAND, OREGON 97201 VOICE: (503)229-5797 i TDD-NONVOICE:(503) 229-5497 March 15. 1989 Hr. Donald Hughes, Sr. Radiation Control Cabinet for Human Resources 275 East Main Street ' Frankfort, Kentucky 40621 es:h Dear Mr. Hu This is n response to your memo dated March 7, 1989, regarding NRC training. The following are Oregon's answers to the four questions in the memo: 1. What immediate reaction do you believe your state would have if the NRC stopped funding the travel and per diem costs associated with state training? ANSWER: Oregon would not be able to send Radioactive Materials Program staff to any training beyond 150 miles of the state border (e.g., regional travel limit). 2. If you believe there would be a different long-term reaction, what do you think it would be? ANSVER: It ma.y be possible in the long-term to convince the i Governor's Office that this training is so crucial that the radiation health and safety of Oregonian's is jeopardized without i l it. Therefore, out-of-state travel dollars from the General Funds would have to be allocated. It may have to get to a point where some licensee has an over-exposure due to lack of a trained inspector who could identify problems, (e.g., ' closing the barn door after the horse is out' syndrome). 3. How much lead time would be required in your state to obtam additional funding for training travel (presuming it wouln br. approved)? ANSWER: This would depend on when the funding concept was initiated in the budget cycle. It could be anywhere from six months to two years. 4. Would the loss of NRC funds for travel and r,er diem: AN EQUAL OPPORTUNITY EMPLOYER l Malhng Address:P.O. Box 231.Portlarc OR 97207 Emergency Phone Voce (503) 229-5599 - TDSNonvoice (503) 252-7978 a+2s m.s/se 47 Appendix C

'b 0.8 - Mr; Donald Hughes, Sr.. - Radiation. Control. Cabinet for liuman Resources Page'2 March 15, 1989 a) eliminate your ability to. provide training? b) reduce your ability to provide training? c) have no impact? I ANSWER: Oregon' provides very little training 'other than in-house staff training. -Therefore, loss of NRC funds would have very little impact on training provided to outside individuals or agencies.. If the NRC eliminates'out-of-state training travel and per diem for the states, the Commission must look at alternative methods to assist the i states with training needs. One alternative would be to change job descriptions.of-NRC Regional Representatives to include training responsibilities. Another cost-cutting option would be to conduct training courses within respective regions. If you have any further questions please write or call me. Sincerely', Ray D. aris Manage Radiation Control Section ( l j RDP/ss l L 48 Appendix C

istate of Jilgeb'c Jalanb anb prouibenre plantations I Department of Health 3 CANNON BUILDING Davis Street - Providence, R.I. 02908 5097 i Mr. Donald R. Hughes, Sr. Radiation Control Cabinet for Human Resources 275 East Main Street l Frankfort, KY 40621 Dear % Atagfes. This letter is in response to your letter dated 7 March 1989 with regards to State Training Cost-Sharing. Our answers to you.- four questions are as follows: 1. If the N.R.C. stopped funding travel and per diem, our immediate reaction would be that a commitment made at the time that the agreement was signed had been breached. We would therefore need to reconsider our commitment to the agreement. 2. I believe our long term reaction would be the same. However, we may decide to renegotiate the agreement based upon less effort' frcm our agency for the agreement program. 3. Unlikely that such funding would be approved. However-the State . procedures normally require travel requests to be submitted at leastfour(4)weekspriortotravel. 4. (A) Not entirely. However, the quality of the training would be greatly diminished and the credibility of staff without formal N.R.C. training would be greatly damaged. I hope these comments are. helpful to your task force group. If you have any further questions, please do not hesitate to contact me at (401) 277-2438. Sincerely, James E. Hickey, Chief Divisic. cf Occupational and Radiological Health lip HEALTH-A WAY OF LIFE .ekcsenmunica:lons Device for the Deaf (TDD): 277 2506 49 Appendix C

r -South Cerclina Department of Hecith and Environmental Control 260p Imn Street Board Columbia. 5.C. 29MI - Toney Graham,Jr M.D., Chairman Henry S. Jordan M.D.,% Chairman Job B. Pate, M.D 5ecretary Commissioner Wi!!iam E. Applegate Michael D. Jarrett Oren L Brady,Jr. John Hay Burries Euta M. Colvin, M.D. April 3, 1989 J Donald R. Hughes, Sr., Manager Kentucky Radiation Control Cabinet for Human. Resources Commonwealth of Kentucky Frankfort, KY 40621

Dear Don:

In response to your memorandum-of March 7, 1989, concerning state training, the following is provided. i '1. What immediate reaction do you believe your state would have if the NRC stopped funding the travel and per diem costs associated with State training?

Response

Our radiological program depends heavily on NRC funded training (travel, per diem etc) for our staff. As part of our state agreement, NRC pledged its support to assist in our-training needs. This withdrawal of training funds could jeopardize the agreement program. This state does not have sufficient funds appropriated at this time to cover all training costs associated with the agreement program. 2. If you believe there would be a different long-term reaction, .what do you think it would be? ' Response: Long_ term, the radiological program would have to seek funds to provide for training. This agency would have to compete with.other agencies for a larger portion of state funds that our currently dwindling. The possibility of getting additional funds is extremely remote at this time. 3. How much lead time would be required in your state to obtain additional funding for training travel (presuming it would be approved)?

Response

At least two years would be required to get additional funding. This would be required to be submitted as a budget request item with full justification. This process would require state legislature action. 50 Appendix C

i Donald R. Hughes Kentucky Radiation Control Page 2 l 4. Would the loss of NRC funds for travel and per diem: l l a) eliminate your ability to provide training: b) reduce your ability to provide training: c) have no impact? a. Training would not be eliminated since in house training is now provided which arguments the NRC sponsored training. However, the type and quality of training would be effected significantly such as the five-week HP course at Oak Ridge which is funded by NRC. b. NRC's withdrawal of training funds will have considerable impact on our program's capability and will severally jeopardize our ability to properly regulate the use of radioactive material. Thank you for the e,pportunity to provide our comments.- Should .you have any ques'.; ions, please do not hesitate to contact me. 'very truly yours, yw G. Sh al $ If rdeu of Radiological Health VRA/ac i 51 Appendix C

!~ . TENNESSEE DEPARTMENT OF HEALTH' AND ENVIRONMENT Bureau of Environment T.E.R.R.A. BUILDING 150 NINTH AVENUE NORTH . NASHVILLE, TENNESSEE 3721:4404 Don Hugher, *fanager Radiation Contro1' Branch l. Cabinet for Human Resources 275 East Main Street -l ~ Trankfort, KY. 40621 - j Deer Don. ) I I appreciate your ef fort to.get in front of.- the situation for the NRC/ State J Training Task Force. My responses to your: questions are. ) 1. It vould make it increasing difficult to pursue training. It is very dif ficult eventwith-NRC paying the bill. -I would estinste 50% of the out-of-state training would be curtailed -because of the cost i or because of the lengthy process necessary to obtain approval. 2. No difference. 3. Training is not a ' priority of the current administration. In.tset every effort has been made to curtail training as much -as possiele. Obviously this flys in the face of the fact that Radiological Health ' is unable ' to be competitive in the. job market. For example the state of Tennessee's starting. salary in 1989 is $15.012 while in 1987 the average starting. salary for all states was $19,961, and the average starting salary for all regulatory and non-regulatory health physicists was $27,000. Thus we are forced to hire an individual with no training or education in the field and provide training through some mechanism.- We are considering using " magic". ~ 4. 1. See you on the 28th. Sincerely, Michael E. Mobley l Director i Division of Radiological Health NHM:E8079074 52 Appendix C om

0 Texas Department of Health Robe 71 Bernstein, M.D., F.A.C.P. 1100 West 49th Street Robert A. MacLean, M.D. Commissioner Austin, Texas 7875fr3189 Deputy Commissioner Professional Services (512)456 7111 Hermas L Miller Radiation Control Deputy Commissioner (512)835-7000 Managementand Administration March 20, 1989 Donald R. Hughes, Sr. Radiation Control Cabinet for Human Resources 275 East Main Street Frankfort, KY 40621

Dear Hr. Hughes:

In answer to the questions you posed in your memorandum dated Harch 7, 1989, ve offer the following responses: 1. The immediate reaction in Texas if the NRC stopped funding the travel and per diem costs associated with state training would be to limit our staff's participation to only those courses held in our state. Out-of-state travel is more restrictive due to higher airfares and out-of-state per diem rates. Since our program operates on a fixed budget, travel outside of Texas vould be prohibitive. 2. The long-term reaction vould depend on the amount of money appreptiated to us by the state legislature. Ve certainly would request funds for this purpose. Bovever, the current state of our economy has dimmed our optimism for receiving additional money. 3. In Texas, it vould take a minimum of two years to obtain additional r'unding for training travel. 4. The loss of NRC funds for travel and per diem would severely reduce our ability to provide training, and consequently, our efforts to competently perform the duties ve assumed under the Agreement States Program. Staff turnover, coupled with a long waiting list for training, already forces some of our staff'to wait years before they receive the l necessary training. Lack of training support fromthe NRC certainly seems contrary to the philosophies embodied in the states agreement program. 53 Appendix C

I' l '/ ( (

?.

1 y .h LDonald R. Edghes, Sr. Page:Two.. March 20., 1989- .u Ve are very interested in NRC?s finalidecision, and ask that you

contact us at 512/835-7000 if've can provide any additional

'information or assistance to your task force. Sincerely, (. Ga ' Jana?ee K.. Ice-Office of Information, Education D and Administration. i -Bureau'of. Radiation Control i ,s.. l 54 Appendix C _ = _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _.

Il c Q L State 0Eitah 9 i Dt.r'ARTMENT OF HEALTH { I DIVISICN OF ENVIRONMENTAL HEALTH ] Norma-H Bargerur r:d3 )"r::;r"' r>- .l La'r Lane Ch Utah 68116 Ot90 oennem 1. Mbem, ewvm March 14,1989 Donald R. Ilughes, Sr., Manager Radiation Centrol Cabinet for Human Resources 275 East Main Street Frankfort, Kentucky 40621

Dear Don:

With respect to the questions posed in your memorandum of March 7,1989, please be advised of the fo!!owing: 1. Utah would be forced to stop attendance at NRC training courses. State funds are not available for that purpose. 2. In the long-tenn,I believe that a reassessment of the State's position with respect to the Agreement States Program would occur. It wouid be hard tojustify Agreement State status and doing the NRC work without some financial support from the NRC for this effort. 3. Should the State choose to continue Agreement status, several years would be necessary in order to arrange for funding for training. 4 Loss of NRC trainMg funds would eliminate our ability to provide training as required by the NRC. As this is apparently a compatibility issue, the program may fail. I believe the NRC Agreement States Program to be the showcase of Federal / State cooperative effons. Certainly the NRC gets more bang for the buck from this program than any sunilar Federal / State cooperative proprams. The Agreement States Program snd the results obtahied make the State / EPA cooperative programs resemble a money incinerator. Sincerely, i r/ Larry. i erso'n, Director Bureau 4(adiation Control 55 Appendix C .--I

v' r --w.we.7s "p_ rv-. - - - - - --m-,. n ,a,-, .g. -, a,, ? 1'cou.,., c y 's h . t y*n. '.i a ' if ' s 'd .( 4's',~:, '. r:'.(.'.. J f p g n ' t f %.g 1 '-h 1 _\\ 4' ' 7,p ~ i 3 ,; r.* _4 1C I L . i l-.a) - I L I i.6 l, *'\\ g 1., s I, i i l l. l l l' I - ~ i i I 'l i i .i .3 '6 f 1 1 J l 1 i 1 I .i 1 i 1 l.- 1. l. ,i 1 i 1 3 );

l APPENDIX D STATE FUNDIBG OF TRAINING The task force sought information on current levels of State funding of training for its staffs. Information was gathered from two sources: State, Local and Indian Tribe. Programs (SLITP) of NRC's Office of Governmental and Public Affairs and the State members of the task force. In both cases the data were exemplary, although not complete. The data however, help form a better understanding of State training efforts and, in particular, the degree to which States are already sharing a significant portion cf the training costs for their staffs. SLITP DATA Data on students who attend NRC-sponsored training courses under State I funding are not normally recorded per se. Togainsome. insight,SLITP l reviewed training files for 1985-1988 for the core" courser and for some othercoursesforwhichthesought-afterdatawereavailable-(seeTables 'D.1andD.2). If any errors exist, they are conservative. From time to time SLITP has allowed State personnel to audit a course when the location of the course is convenient and classroom space permits. In such cases, the students ccamute from a nearby State office or home and there is no cost to the ITC. Such students may not be able to fully participate in homework and other portions of the course and hence are not carried on the course roster. Nonetheless, some training benefit accrues to the State at no cost to the NRC. NUREG-1356 1 Appendix 0

f fi Table D.1 Core Courses All State State Students ** - No Cost Course Location Students

• Students Number **

Percent ** Inspection Procedures HQ,RIII 129 116 3 3 l Field 68 67 54 81 Nuclear Medicine Oak Ridge 80 3 4 5 Industrial Radiography Baton Rouge & Boston 97 86 6 7 Licensing HQ 80 77 2 3 Oak Ridge Oak 120 117 0 0 5 Week Ridge Health Physics Totals 574 543 69 13 Totals Excluding Field Presentations 386 359 15 4

• Includes State, RRC, U.S. Navy, and U.S. Air torce personnel.

~~

• • State paid travel and per diem costs.

If the course was a contracted course, the NRC funded the student share of the contract course. Notes: HQ = NRC headquarters; RIII = NRC Region III. NUREG-1356 2 Appendix 0

i Table D.2 Examples of other SLITP training courses All State State Students - No Cost Course Location Students

• Students Number **

Percent ** i Well Houston Logging 125 100 0 0 Agreement liq N/A 65 3 s State Meeting Field R/A 80 17 21 i Trans-Field 1 01.1 N/A 19 18*** portation Regional Field 100*** 20 20+ 100 Workshops Irradiator (1988) Broad. Field 200ff 6 3+ 100 Scope License (1937)

• Includes State, IIRC, U.F. Navy, and U.S. Air Force personnel.
  • State paid travel and per diem costs. If the coirse was a contracted course, NRC funded the student share of the contract cost.
    • Estinated

+NRC announced regional NRC licensee workshops to the States but did not fund travel and per diem costs for State attendees. Note: HQ = NRC headquarters; N/A = data not available. NUREG-1356 3 Appendix D

STATE DATA The State members of the task force (Iowa, Kentucky, New York Department of Conservation, and Tennessee) reviewed the training received by their staffs in formal training courses. ~(The New York member of the task force also obtained data from the other New York programs that participated in the State Agreements Program so that a complete picture was obtained for New York). All Agreement States under their radiation-contr31 programs are responsible for more than just the regulation of materials covered under the agreement. Other responsibilities include . medical and industrial x-ray sources, naturally occurring and. accelerator-produced material, radon, environmental monitoring, emergency response to nuclear power plant incidents, and nonionizing radiation. The training provided by the States for their employees reflects these diverse responsibilities.. The periods covered by each of. the States varied somewhat (2 to 5 years), but overall the data show the extensive investments made at j the State level using State funds to provide technical, administrative, and j other professional training for the States' radiation control program staffs.

j When taken as a whole, this State training combined with NRC training results j

in a. highly trained radiation protection specialist who can responsibly tackle the wide variety of work assignments that typify the States' radiation control programs. - The training provided by these four States is summarized in Table D.3. : Table D.3 Training provided by four States Period Total Total Partial or total non-NRC funding State covered courses students Courses (%) Students (%) Iowa 3 years 13. 36 10(77) 29(81) Kentucky 3 years 11 35 4(36) 26(74) New York 3 years-100* 150* N/A N/A Tennessee 5 years 63 179-57(90) 134(75) Note: N/A = not available.

• Estimated.

l NUREG-1356 4 Appendix D

APPENDIX E TRAINING CURRICULUM FOR NRC INSPECTORS r 1 Appendix E NUREG-1356

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< ^ ) v j ec il l APPENDIX F D COST SAVINGS TO THE NRC FROM THE STATE AGREEMENTS PROGRAM l (1) ' NUREG-1309 assumes an NRC staffing level of 1.0 full-time equivalent (FTE) per 100 licenses. Further review by the task force led it to conclude that this was unrealistically low. -(2) In FY 1989,' the NRC staffing level for'the direct' license and compliance effort for low-level waste, uranium mill, and materials is 115 FTEs which is applied to approximately 8,000 licenses. This works out to 1.4 FTEs. per 100 licenses.- (3) To regulate the 16,000 licenses'in the Agreement States, the NRC would require' x 115 FTEs or 230 FTEs. (4) In FY 1989, the current NRC oversight of the State Agreements Program requires 16 professional FTEs; therefore, the net savings 'to the NRC in staff is 230 - 16 or 214 FTEs. (5) Salaries and benefits for the NRC professional stdf total about $61,000 per year in FTEs. The 214 FTEs would then ust about $13 million per year in salaries and benefits. (6) Regional travel expenditures for 16,000 additional licenses are estimated at $2.4 million. (7) Management. clerical, and overhead costs at the NRC are estimated to be 20 percent of professional salary and benefit costs or $2.6 million. (8). Adding salaries, t Enefits, travel, and overhead costs, $18 million would be required for the.NRC to regulate the licenses currently controlled by the Agreement States and is a savings to the NRC resulting from the State Agreements Program. NUREG-1356 1 Appendix F

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APPENDIX G NRC POLICY STATEMENT GUIDELINES FOR AGREEMENT STATES TRAINING The Commission has issued two Statements of Policy regarding Agreement States. The first, " Criteria for Guidance of States and NRC in Discontieaance of NRC Regulatoty Authority and Assumption Thereof by States ' arough Agreement," was initially published in the Federal Register on July 16, 1981 (46 FR 7540). An editorial correction was published on I July 16,1981 (46 FR 36969), and an amendment relating to waste disposal was published on July 21, 1983 (48 FR 33376). Two criteria in this Policy Statement relate to training. Under Criterion 20, " Qualifications of Regulatory and Inspection Personnel," it states: The regulatory agency shell be staffed with sufficient trained personnel. Prior evaluation of applications for license or authorizations and inspection of licenses must be conducted by persons possessing the training and experience i relevant to the type and level of radioactivity in the proposed use to be evaluated and inspected. This requires competency to evaluate various potential radiological hazards associated with the many uses of radioactive material and includes concentrations of radioactive materials in air and water, cmditions of shielding, the making of radiation measurements, knowiec,e of radiatior, instruments - their selection, use and calibrc+,1or - laboratory design, contamination control, other general principles and practices of radiation protection, and use of management controls in assuring adherence to safety procedures. In order to evaluate some complex cases, the State regulatory staff may need to be supplemented by consultants or other State agencies with expertise in geology, hydrology, water quality, radiobiology and er.gineering disciplines. To perform the functions involved in evaluation and inspection, it is desirable that there be personnel educated and trained in I the physical and/or life sciences, including biology, chemistry, physics and engineering, and that the personnel have had training and experience in radiation protection. For example, the person who will be responsible for the actual performance of evaluation and inspection of all the various uses of by-product, source and s)ecial nuclear material which might come to the regulatory body siould have substantial training and extensive experience in the field of radiation protection. It is desirable that such a person ) have a bachelor's degree or equivalent in the physical or life l sciences, and specific radiation protection training It is recognized that there will also be persons in the program performing a more limited function in evaluation and inspection. These persons will perform the day-to-day work of the regulatory i NUREG-1356 1 Appendix G

( program and deal with both routine situations as well as some which w;11 be out of the ordinary. These persons should have a bachelor's degree or equivalent in the physical or life sciences, training in health physics, and approximately two years of actual work experience in the field of radiation protection. The foregoing are considered desirable qualifications for the staff who will be responsible for the actual performance of evaluation and inspection. In addition, there will probably be trainees associated with the regulatory program who will have an academic background in the physical or life sciences as well as varying amounts of specific training in radiation I protection but little or no actual work experience in this field. ihe background and sgcific training of these persons will indicate to some extent their potential role in the regulatory program. These trainees, of. course, could be used initially to evaluate and inspect those applications of l radioactive materiais which are considered routine or more standardized from the radiation safety standpoint, for example, l inspection of industrial gauges, small research programs, and diagnostic medical programs. As they gain experience and l competence in the field, trainees could be used progressively to deal with the more complex or difficult types of radioactive material applications. It is desirable that such trainees have a bachelor's degree or equivalent in the physical or life sciences and specific training in radiation protection. In determining the requirement for academic training of individuals in all the foregoing categories, proper consideration should be given to equivalent competency which has been gained by appropriate technical and radiation protection experience. It is recognized that radioactive materials and their uses are so varied that the evaluation and inspection functions will require skills and experience in the different disciplines which will not always reside in one person. The regulatory authority should have the composite of such skills either in its employ or at its command, not only for routine functions, but also for emergency cases. The Policy Statement contains additional criteria for States regulating source material recovery operations and wastes. For these Sthtes, under Criterion 34, " Personnel" it states: In addition to the personnel qualifications listed in the " Guide for Evaluation of State Radiation Control Programs," Revision 3, February 1,1980, the regulatory staff involved in the regulatory process (Radiation) should have additional training in Uranium Mill Health Physics and Environmental Assessments. Note: The reference to the 1980 Guide is superseded by the 1987 Policy Statement cited below. NUREG-1356 2 Appendix G

After States enter into an agreement, NRC reviews for adequacy and compatibility are conducted in accordance with the Commission's Poliqy Statement, " Evaluation of Agreement State Radiation' Control Programs, Final General Statement of Policy," published on June 4,1987(52FR21132). This Policy Statement contains a specific indicator for training under which are the following guidelines: Senior personnel should have attended NRC core courses in licensing orientation, inspection procedures, medical practices and industrial radiography practices. (For mill States, mill training should also be included). The RCP should have a prog [ ram to utilize specific short courses and workshops to maintain an] appropriate level of staff and I technical competence in areas of changing technology. 1 o I i I NUREG-1356 3 Appendix G

1 APPENDIX H OTHER FEDERAL FUNDING OF STATE TRAINING Department of Labor, Occupational Safety and Health Administration (05HA) OSHA provides partial funding to States for the administration of programs implemented on behalf of OSHA by the States. It provides two Hnds of training to States: (1) consultation and (2) compliance. For consultation training within the States, OSHA pays 90 percent of the training costs and the States pay 10 percent. For out-of-State consultation training, OSHA pays all the training costs. For compliance training, the cost is split 50-50 by the States and OSHA. The costs include training courses, travel, and per diem; it excludes salaries and benefits. The primary means of providing these training funds to States is through grants. Each year OSHA trains about 7,800 people of which about 1,700 are State personnel. It offers 76 different courses with over 250 offerings, all of which include State perscnnel. This training is not available from alternative sources. About 85 percent of these courses are provided in the field (e.g., Atlanta). States idtatify their training needs, which range from 0 to $32,000 each year; the average is about $4,000 to 5,000. OSHA's estimate of its annual training budget for the technical training of consultants is $320,618, which does not include any conferences that it sponsors for the States. This represents about 13 percent of total consultation funding. Department of Enerqy (DOE) DOE does not administer Federal-State cooperative regulatory programs. It does provide funding to States for certain other specific purposes. It does not provide formal training for State personnel. It has activities for educating State and local government personnel and the public in certain areas such as high-level waste, low-level waste, and transportation. In 2 years it will begin training pertaining to the transportation of radioactive waste for law enforcement personnel in accordance with the requirements of the Nuclear Waste Policy Act. DOE has held various workshops on certain issues such as transportation. It provided some grants to States and has several regional cooperative agreements. Recently, DOE had $1 million added to its congressional authorization for use by corridor States participating in the Waste Isolation Pilot Program NUREG-1356 I Appendix H

I (Carlsbad, New Mexico) for studying several transportation issues. DOE will work with the Department of Transportation in administering the funds. Currently, DOE funds trainers, instructional materials, l and classrooms for training State' personnel and local governmental organizations in understanding the radioactive aspects of certain transportation accidents. This training is provided locally; however, l States and local governmental organizations pay their own travel and l per diem costs when necessary. Three segments of training for 26 States are under way; these will be complets d in FY 1990 and cost DOE about $175,000 for-each segment (for training materials and classrooms). Trainers are usually DOE employees who are not specifically hired just to instruct these courses. The cost for trainers is approximately $175,000, bringing the total training costs to about $700,000. l Environmental Protection Agency (EPA) l l With respect to radiation protection regulatory activities, EPA does not j currently previde funding to the States. It does provide grants to i States under legislation for other program areas including resource { conservation and recovery, toxic substances, clean air, and clean whter. Monies from these grants can be applied to training. With respect to radiation protection, EPA provides States with courses on accident assessment, writing emergency plans, and radon diagnostics and mitigation, There are 15 offerings per year, although similar courses are provided by the private sector. Most courses are provided through the Federal Emergency Management Agency with EPA supplying materials only. Training is also provided by way of host States for the 3-day radon course. It is up to the States to send personnel to attend courses that are announced in a training booklet. Approximately 30 State employees attend these courses each year. EPA does not pay for the tuition, travel, or per diem costs for State employees who attend these courses. In 1988, approximately $180,000 was budgeted by EPA for providing the courses; an additional $150,000 was used for course development per year. Thisbudget($330,000 total)hasbeen l increasing over the years and will likely continue to grow. ] Federal-Emergency Management Agency (FEMA) FEMA provides training for almost 85,000 State employees annually. About 8,000 to 9,000 State and local employees are trained at FEMA's Emmitsburg training facility; about half of these are fire inspectors. The remaining 76,000 to 77,000 are trained in the field. FEMA offers over 100 different ] courses, most of which are not provided elsewhere. Some private or academic j institutes (e.g., Harvard) offer similar courses. States, however, have to pay all course costs; therefore, there is little State attendance at these i courses. The training includes that pertaining to radiological protection, accident evaluation, and emergency plan exercise assessment. FEMA uses the " train-the-trainers" concept and produces its own videotapes for supplemental training only. It also sponsors about 20 teleconferences a year. Its budget NUREG-1356 2 Appendix H

l l l 1 I is about $5.4 million for exercises, exercise training, and national J hazards training.. An additional.$5 million 'comes from the Superfund, which may no longer be available. All costs for courses, travel, and lodging are paid by FEMA; States pay for meals and ground transportation only. ) Department of Transportation (DOT) i DOT provides to States about 70 courses each year which are taught at the Transportation Safety Institute in Oklahoma City, Oklahoma and in the field. Approximately 1,800 State and local government participants are trained; and the number continues to increase each year. DOT spends about $500,000 on training courses, materials, videotapes, and teleconferences. States pay up to 50 percent of the tuition and all travel and per diem costs necessary to attend the courses. Food and Drug Administration (FDA) FDA is involved in contract and voluntary training. It no longer provides basic radiological health courses. Most training pertains to x-ray diagnostic equipment and sanitation practices. For the latter training, FDA works with States who spor.sor about 40 courses a year. Most often FDA trainers travel to States where courses are provided. State sponsors make arrangements and pay for the training facilities. Participants come from all over the State; very few participants come from out of State. FDA provides trainers, outside speakers, and instructional materials for which participants are charged about $15 each. The States pay the travel and per diem costs. For training on the use of x-ray diagnostic equipment, one course is offered in Fort Houston, Texas, and two are provided in field hospitals. This training is not available from other sources. Videotapes made as part of in-house studies are used where appropriate. About 50 State and local government employees are provided with contract training, and about 25 are provided with voluntary training each year. States are paid indirectly through contracts, part of which goes for training cours.es and transportation to the courses; no salaries are paid by FDA. Training budgets have decreased over the past 10 years; however, over the last 5 years they have remained fairly level. The FY 1989 budget for sanitation-type training was about $150,000, which did not include the time and salaries of FDA instructors. National Institute for Occupational Safety and Health (NIDSH) In the past, NIOSH used to provide training free of charge; however, all training is now paid for by participants including those from the States. As a result of the loss of free training, State participation has declined sharply over the years. Most of the courses involve industrial and hygiene training, although one to two radiation health radiation courses NUREG-1356 3 Appendix H

are also offered. Courses last about I week and cost from $400 to $500 each per student. Sone grants are provided to universities and colleges, which form education resource centers to teach certain courses such as that on practical radiation shielding. NIOSH does not pay for any travel or per diem costs. It is flexible as to the course location, including overseas, only "if the price is right." I i l 1' l l l NUREG-1356 4 Appendix H

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m. *m BIBLIOGRAPHIC DATA SHEET t$er unstrucsoons on the er.orse) 2.T TLE ANo susintE IURD3-1356 State Cost Sharing of Training 3

DATE REPORT PUBU5wED wonies j stan A Task Force P.eport August 1989 3 .. fin OR cRANT NvMeE R l (

b. AUTHORtS)

6. TYPE OF REPORT J. M. Montgomery, Chairman Final D. A. Mater, D. R. Hughes, Sr., J. O 1.ubenau

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10. $UPPLEME NT ARY NOTES

n. Asst RacT m,., *=' In March 1988 cmpleted a report (IUREG-1311)The Office of Governmental and Public Affairs (GPA) entitled, " Funding the IEC Training Program for States." This report responded to a Cm mission's request for study of IEC's long-standing practice of paying the travel and per diem of State personnel who attend IRC sponsored training. In May 1988, the Chairman endorsed the report in most respects but asked for further study of a cost sharing of travel and per dim costs. As a result, the Director of GPA's State, Local and Indian Tribe Programs (SLITP) established a Task Force ccrnprised of representatives frm the Conference of Radiation Control Program Directors, Inc., the Agreement States and the IRC to look at ways that the States can share the costs of lac training, particularly travel and per diem. At the request of the Director, GPA, the Task Force also Io')ked at related cost and quantity issues associated with the IRC training program for State personnel. This report includes a discussion of lac and State perspectives on the issue of sharing travel and per diem costs, a discussion of options, and rcmmendations for likely cost savings and quality of training improvement..

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