ML20002B660
| ML20002B660 | |
| Person / Time | |
|---|---|
| Issue date: | 12/09/1980 |
| From: | Lubenau J NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Julie Ward CALIFORNIA, STATE OF |
| References | |
| NUDOCS 8012220417 | |
| Download: ML20002B660 (7) | |
Text
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e,~p ij2 Mr. Joe Ward, Chief j
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,M Radiologic Health Section 7]1 s3 3N Department of Health Services 15 714 P Street, Room 498 N
'co Sacramento, California 95814 J
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-.a DearMr.Wardi'*
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i This is to confirm the comments made to you and your staff by Mr. R. J.
Doda ani Ar. J. M. Brown at the conclusion of the recent radiation control program review.
Based on the results of the review, the staff believes that the California program for control of agreement materials is adequate to protect the public health and safety and is compatible with the NRC's program for regulation of similar materials.
This conclusion is based, in part, on improvements made in the radiation control program, even though some of the improvements are only in initial stages at this time. Accompaniments of five State inspectors, during the review, were also determined to be satisfactory.
As a result of last year's review and subsequent follow-up meetings and correspondence, a number of specific aspects of the California radiation control program evolved as subject areas in need of improvements. We were pleased to find, during our review, that the State had taken some action in nearly all of these subject areas.
Sumary statements indicat-ing the present status of these aspects of the program are contained in an enclosure. A copy of a letter to Ms. Beverlee A. Meyers is enclosed also.
Our current review disclosed that the program's staffing level for agreement materials increased from 15.3 person-years last year to 17.2 person-years this year. This equates to a staff effort this year of.91 person-years per 100 licenses. This is slightly below NRC's recommended range of 1.0 to 1.5 person-years per 100 licenses. The level of training for professional staff greatly improved from.03% last year to 3.0% of professional staff effort this year. This is near NRC's recommended range for training of 5-10% of professional staff effort.
Recommendations and comments resulting from our current program review are stated below.
We recommend that the number of overdue inspections be reduced; par-ticularly, those designated as priority II inspections. We note that of the 46 overdue inspections, 14 are in the priority II category.
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Mr. Joe Ward We recomend that the State reduce the backlog of licensing actions. We found during our review that there were 72 new license applications pending and.173 timely renewals pending, for a total of 245 licensing actions. It' appears that the new health physicists on your professional staff and the posssible addition next year of two more persons for the licensing staff will improve this situation.
We recomend that the State continue efforts to develop its ADP system for the purpose of improving the information management capabilities of the radiation control program.
During our review, we found that several problems existed in recalling certain information; however, these appeared to be readily solvable by recoding and correcting omissions. We believe the use of this system can greatly enhance the program's management function.
We recommend that the State amend its regulations to provide for the inspection of State licensees to the requirements of DOT regarding package preparation and shipping pro:edures for radioactive materials.
This subject, which is a matter of compatibility, was first brought to the State's attention in a letter dated October 31, 1979 to all Agreement States, and again in a letter dated January 18, 1980.
Planning for the training of inspectors and for including DOT requirements during inspec-tions of State licensees is important to consider early during the implementation of this program. Your staff informed us that some efforts have already been expended in these areas during some routine inspections in the past.
If you have any questions concerning our review, please contact me at any time. After your review of our recontrendations, I would like to receive your comments on them.
I appreciate the courtesy and cooperation extended to our-representatives by you and the entire radiation control program staff.
Sincerely, 0 IPL
/1A Jpel 0. Lubenau Ecting Assistant Director for State Agreements Program Office of State Programs
Enclosure:
Letter.to Ms. Beverlee A. Meyers, w/ encl.
cc: Ms. Beverlee A. Meyers NRC Public Document Room State Public Document Room
ENCLOSURE
SUMMARY
STATEMENTS REGARDING CERTAIN ASPECTS OF THE CALIFORNIA RADIATION CONTROL PROGRAM
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November 7, 1980 LICENSING 1.
Review Committee. The Radiologic Health Section (RHS) licensing staff meets periodically to review major licensing actions and sealed source and device approvals.
This policy was implemented by Materials Memo No. 81 Revised, dated February 71, 1980 (copy included in the 1980 California Review Report).
Supervisors review all Type A authorizations and all sealed source and device approvals.
In addition, the State initiated on July 1,1980 the practice of reviewing 10% of other licensing actions for conformance with regulations, policy and good health physics practice.
2.
Procedures Contained in License Applications.
The State is requiring-certain procedures to be contained in license applications, e.g.,
package opening procedures.
Evidence of this practice should be apparent during next year's review of the license files.
3.
Backlog of Licensing Actions. There are 72 new license applications pending and 173 licenses in timely renewal status for a total backlog of 245 licensing actions.
This represents somewhere in the range of 1.0 to 2.0 person-years of effort depending on the complexity of the license mix of this group.
In addition, licensing actions (new licenses plus amendments) were down to 1270 for this year's review period compared to 2011 for last year.
COMPLIANCE 1.
Supervisory Accompaniments.
During the review period, there were 20 supervisory accompaniments performed by contract agency super-visors and 2 performed by the RHS supervisor.of compliance and inspection. We understand that all contract agency inspectors will be accompanied by the appropriate agency supervisor at least once each year and all inspectors will be accompanied by the RHS super-visor of compliance and inspection at least once every two years.
2.
Management Contacts. The State is routinely contacting licensee management during entry and exit interviews for inspections. This was demonstrated during State Agreements Program (SA ) acccmpaniments of State inspectors. The State-has requested by memo, dated September 30, 1980 from C. Mott to the contract agencies (copy included in the 1980 California Review Report) that all inspectors determine the proper management correspondent during inspections.
This individual will be identified on all correspondence dealing with compliance and inspection matters.
3.
Uniform Inspection Format. Uniform documentation practices for inspections was initiated on February 8,1980 by use of a uniform inspection forget (UIF).
VIFs were used by inspectors during SA accompaniments and this use appeared to produce complete inspections, in general.
The State plans to assess the effectiveness of the UIFs and make modifications, if needed.
4.
Overdue Inspections. There were 46 overdue inspections, 14 of which were priority II inspections.
This is an increase from the 17 overdua inspections listed last year.
5.
Inspection Reports.
Inspection reports are routinely reviewed and documented by the contract agency supervisors. However, documenta-tion of review by the RHS supervisor of compliance and inspection was not apparent.
Four inspection reports (License No. 0441-30, dates of inspection - January 21-22, 1980; License No. 0015-59, dates of inspection - April 3-4, 1980; License No. 2713-30, date 1
of inspection - November 20, 1979; License No. 0372-70, date of inspection - October 4, 1979) were not signed-off as being reviewed by the RHS supervisor of compliance and inspection.
6.
Previous-Items of Noncompliance.
During SA accompaniments, State inspectors were observed to satisfactorily follow-up previous items of noncompliance.
7.
Interviewing Employees.
During SA cccompaniments, State inspectors were observed to interview employees concerning work habits, i
operating procedures, training received, certain health physics practices, and other general work-area activities.
8.
Instrument Calibration. A uniform instrument calibration protocol was issued by the RHS in October 1980. The purpose of this protocol is to provide RHS staff and the contract agencies with guidance for calibration of survey instruments, which are used by inspectors in independent measurements made during compliance inspections of State licensees. A copy of this procedure is included in the 1980 California Review Report.
ADMINISTRATION 1.
Task Tracking System. The State has a task and correspondence l
tracking system which is used to monitor progress, target dates, revious problems with unanswered corres-and completion dates.
v pondence and overdue tasPs appeared to be caused by an unfilled-vacancy on the staff. Now, the status of all tasks and correspondence may easily be determined and the responsible staff member for any particular task may readily be i.dentified.
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2.
Staff Meetings.
Staff meetings are held regularly by the RHS.
Discussion topics and the responsible staff members are indicated on forms for this purpose. The meeting is conducted using a fixed agenda and with a defined time schedule.
Following the meeting, any decisions, actions, or follow-up assignments are recorded on the staff meeting forms. One staff meeting was held on October 30, 1980 during the SA review (copies of forms as a result of this meeting are included in the 1980 California Review Report).
3.
Administrative Services. The RHS has been assigned one new individual (L. Casaleggio) by the Department of Health Scrvices to act as a consultant in administrative services. His duties will include an examination of the management and administrative procedures of the RHS and the submission of recommendations for improving those procedures.
4.
ADP System.
The RHS uses an ADP system for licensee fee notices.
In addition, a systems analyst from the Department of Health Services has been assigned to work with the RHS in the agreement materials
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program to further develop a managment information system. During the SA review, use of the ADP system produced mixed results, e.g.,
a complete list of licensees had a number of coding errors and omissions, and a list of all inspections performed in 1980 was not readily available for SA reviewers.
The list of 1980 inspections had to be completed by hand.
The State is continuing to develop the capabilities of this data retrieval system.
STAFFING 1.
Person-Years Available. The RHS has added four new health physicists.
The Department of Health Services was delegated authority to hold an examination for these health physicist positions and results were announced during the SA review meeting - all four passed the examination. The staffing level for the agreement materials program is 17.2 person-years (vs.15.3 person-years last year).
This equates to.91 person-years per 100 licenses (vs. 80 person-years per 100 licenses last year).
Five new technical staff positions are being filled immediately. These positions are primarily in environmental activities, however, there may be some overlap in agreement materials regarding transportation of radioactive materials.
In addition, the Department of Health Services has submitted a budget change proposal for two additional health physicists for the RHS licensing staff exclusively. These positions are very important to the program, particularly with regard to Item 3 of the Licensing Section above, which indicates the existence of a substantial backlog of licensing actions.
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TRAINING l.
Out-of-State Travel. The granting of out-of-state travel to attend training programs was greatly improved over last year.
During the review period, out-of-state travel for training was granted on 19 different occasions.
2.
Training Effort. Professional staff effort devoted to training was 3.0% of the total effort available.
This is greatly improved over last year where the staff training effort was only.03% of the total effort available.
REGULATIONS 1.
Revised Regulations. Tne State's revised radiation control regula-tions are well into the revision process, having been sent from the Regulations Unit to the Budget Office for fiscal review.
Even though, it appears the revised regulations will not be published for a number of months yet.
The State's radiation control regulations were last revised in 1974.
2.
Reference to DOT Regulations. The State's radiation control regu-lations do not presently provide a reference to DOT's regulations for the packaging and transportation of radioactive material, except for intrastate shipments. The adoption of amended regulations on this subject is a matter of compatibility.
It should be noted, how-ever, that the State recently passed legislation (Assembly Bill No.
2747, Wray.
Radioactive Materials, September 10,1980)which provides broad State authority with respect to the transportation of radioactive material.
TECHNICAL ADVISORY COMMITTEES 1.
Nuclear Medicine Technology Advisory Committee. This committec has met six times during the review period.
2.
Medical Advisory Committee. This committee met once, January 18, 1930, during the review period.
There were no minutes of this meeting available.
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INCIDENT FILES 1.
Incident Files.
During the SA office review, 56 " closed" incident files were delivered to the Sacramento office by the RHS supervisor of compliance and inspection.
The files that were reviewed appeared complete and orderly, and the background information concerning each
-incident was clearly stated.
M A.
Robert J. Ooda State Agreements Program 1
[ rub',u ]v.h (t-ius sic u Kathleen N. Schneider -
State Agreements Program 1
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