ML19203A162

Letter to K. Steves Kansas FY19 Impep Periodic Meeting Scheduling Letter for August 14, 2019

ML19203A162
Person / Time
Issue date:	07/22/2019
From:	Jackie Cook Division of Nuclear Materials Safety IV
To:	Steves K State of KS, Dept of Health & Environment
Cook J
References
Download: ML19203A162 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E LAMAR BLVD ARLINGTON, TX 76011-4511 July 22, 2019 Kimberly Steves, Director Radiation Control Program Department of Health and Environment Bureau of Community Health Systems 1000 SW Jackson, Suite 330 Topeka, Kansas 66612

Dear Ms. Steves:

In order to help the Agreement States and the U.S. Nuclear Regulatory Commission (NRC) remain knowledgeable of each others program, the NRC conducts one-day periodic meetings with Agreement States between IMPEP reviews. This letter confirms that, through previous coordination, the meeting has been scheduled for August 14, 2019, and will be held in your offices. The meeting will be conducted in accordance with Office of Federal and State Materials and Environmental Management Programs Procedure SA-116, Periodic Meetings Between IMPEP Reviews. The likely topics for discussion at this meeting are listed in the enclosed agenda. If there are any additional specific topics you would like to cover, or if you would like to focus on a specific area, please let me know. If you have any questions, please contact me at (817) 200-1132 or via e-mail at jackie.cook@nrc.gov.

Sincerely,

/RA/

Jacqueline D. Cook Regional State Agreements Officer Division of Nuclear Materials Safety

Enclosure:

Agenda for August 14, 2019 Periodic Meeting with Kansas

SUBJECT:

Kansas FY19 IMPEP Periodic Meeting Scheduling Letter Distribution:

D. White, NMSS A. Koch, NMSS P. Michalak, NMSS R. Johnson, NMSS K. Meyer, NMSS K. Williams, NMSS R. Erickson, RIV DNMS L. Roldan-Otero, NMSS L. Howell, RIV DNMS V. Gaddy, RIV DNMS S:\DNMS\!SAO\Periodic Meetings\2019\New Mexico\Notification of 2019 New Mexico Periodic Meeting.docx ML19203A162 X SUNSI Review ADAMS X Publicly Available X Non- Keyword:

By: RRE X Yes Non-Publicly Sensitive No Available Sensitive OFFICE RIV:RSAO NAME JDCook SIGNATURE DATE 7/22/19 OFFICIAL RECORD COPY

Agenda for Periodic Meeting with the Kansas Department of Health and Environment August 14, 2019 Topic areas for discussion during the meeting may include:

1. Program challenges.

2. Program reorganizations:

3. Changes in program budget/funding.

4. Status of the States program, including:

a. Technical Staffing and Training (2018 IMPEP Rating: Satisfactory)

• Number of staff in the program and status of their training and qualifications.

• Any program vacancies.

• Staff turnover since the last IMPEP review.

• Adequacy of FTEs for the materials program.

• Status of implementation of IMC 1248

b. Status of the Materials Inspection Program (2018 IMPEP Rating:

Satisfactory)

• Number of inspection performed overdue since the last IMPEP review.

• Number of inspections currently overdue.

• Number of initial inspections completed on time and overdue since the last IMPEP review.

• Status of reciprocity inspections since the last IMPEP.

IMPEP Finding: Candidate licensees working under reciprocity were not consistently inspected in accordance with the criteria prescribed in NRCs IMC 1220.

2

c. Technical Quality of Inspections (2018 IMPEP Rating: Satisfactory but needs improvement)

• Status of inspector accompaniments

• Management review process

• Significant inspection activities/challenges IMPEP Finding: Inspection procedures are not equivalent to NRC Inspection Procedure 87100 series.

IMPEP Finding: When preparing to inspect, the programs inspectors did not routinely review the relevant inspection procedures.

IMPEP Finding: Inspection findings not well founded or properly documented in reports and root causes were not properly identified. Issues of non-compliance did not always have specific regulations clearly documented. There was inadequate management oversight of inspection reports. Inspection findings did not always lead to appropriate or prompt regulatory action.

IMPEP Finding: Inspections do not consistently address previously identified open items.

d. Technical Quality of Licensing (2018 IMPEP Rating: Satisfactory but needs improvement)

• Number of licensing actions and types performed since the last IMPEP review.

• Large, complicated, or unusual authorizations for use of radioactive materials.

IMPEP Finding: Essential elements of license applications were not consistently submitted or consistent with regulatory guidance.

License action reviews were not sufficiently thorough, complete or of acceptable technical quality.

e. Technical Quality of Incidents and Allegations (2018 IMPEP Rating:

Unsatisfactory)

• Status of allegations and concerns referred by the NRC for action

• Significant events and generic implications 3

• Event reporting, including follow-up and closure information in NMED IMPEP Finding: Response actions were not always appropriate or timely. Procedures for onsite responses were not always followed when incidents of potential health, safety, or security significance were reported or suspected. The NRC was not always notified of incidents, as appropriate. There was inadequate management oversight of reactive inspections and reporting.

IMPEP Finding: Follow up action not always taken to ensure prompt compliance, including follow up inspections to investigations.

f. Compatibility Requirements (2018 IMPEP Rating: Satisfactory but needs improvement)

• Discussion of States regulatory process

• Discuss status of States regulations and actions to keep regulations up to date, including the use of legally binding requirements

• Legislative changes affecting the program IMPEP Finding: Several regulations adopted by Kansas for the purposes of compatibility were adopted later than three years after the effective date of the NRC regulation.

5. Information exchange and discussion:

a. Current State initiatives

b. Emerging technologies

c. Large, complicated, or unusual authorizations for use of radioactive materials

d. States mechanisms to evaluate performance

e. NRC current initiatives

6. Additional Topics 4