December 11, 2003 

Ms. Beverly O. Hall, Chief 

Radiation Protection Section 

Department of Environment and Natural Resources 

3825 Barrett Drive 

Raleigh, NC 27609-7221 

SUBJECT: PERIODIC MEETING 

Dear Ms. Hall: 

A periodic meeting with the North Carolina Radiation Protection Section was held on 

November 6, 2003. The purpose of this meeting was to review and discuss the status of North 

Carolina’s Agreement State Program. Specific topics and issues of importance discussed at 

the meeting included program strengths, staffing and training, performance of licensing and 

inspection activities, incidents and allegations and the updating of regulations for compatibility. 

I have completed and enclosed a general meeting summary. There were no specific actions 

identified during the meeting. 

If you feel that our conclusions do not accurately summarize the meeting discussion, or have 

any additional remarks about the meeting in general, please contact me at 404-562-4704 or 

e-mail to rlw@nrc.gov to discuss your concerns. 

Sincerely, 

/RA by Duncan White Acting For/ 

Richard L. Woodruff 

Agreement State Officer 

Region I - Atlanta Office 

Enclosure: North Carolina Meeting Report 

cc w/encl: 

R. Trojanowski, RII 

G. Pangburn, RI 

J. Piccone, STP 

L. Rakovan, STP 

J. Myers, STP 
PUBLIC DOCUMENT (circle one): YES X NO 

OFFICE RI:DNMS RI:DNMS 

SIGNATURE RLW GCP 

NAME RWoodruff GPangburn 

DATE 12/9/03 12/ 8 /03 

E-MAIL YESNO YES NO YES NO YES NO YES NO 

OFFICIAL RECORD COPY DOCUMENT NAME: 

C:\ORPCheckout\FileNET\ML033500271.WPD 

AGREEMENT STATE PERIODIC MEETING SUMMARY FOR NORTH CAROLINA 
DATE OF MEETING: November 6, 2003 

ATTENDEES: 

NRC


Richard L. Woodruff, SAO, Region I - Atlanta


James Myers, ASPO, STP 


STATE


Michael A. Kelly, Acting Director, Division of Environmental Health (DEH)


Beverly O. Hall, Chief, Radiation Protection Section (RPS), DEH


Lee Cox, Manager, Radioactive Materials Branch, (RMB), RPS


Gerald Speight, Health Physicist, RMB


Robin Haden, Special Projects and Mammography Supervisor, RPS


DISCUSSION: 

A meeting was held with the North Carolina representatives on November 6, 2003 in Raleigh, 

North Carolina. The topics listed in NRC letter dated July 30, 2003 (ML 032110252), to Ms. Hall 

were discussed. Details for each area are discussed below. 

Action on Previous Review Findings 

The previous IMPEP review was conducted during the period of September 18-20, 2000. The 

Management Review Board (MRB) met on December 8, 2000 and determined that the State 

was satisfactory in all indicators, adequate to protect public health and safety, and compatible 

with NRC’s program. A periodic meeting was held with the State on March 14, 2002, during 

which the State’s actions in response to the IMPEP team recommendations were reviewed and 

closed. 

Status of Program and/or Policy Changes 

The program has been reorganized into the Radiation Protection Section under the Division of 

Environmental Health, North Carolina Department of Environment and Natural Resources. 

Beverly O. Hall is the Section Chief, and Lee Cox is the Radioactive Materials Branch Manager. 

The Section has five major technical Branches: Radioactive Materials Branch; Registration and 

Enforcement Branch; X-Ray & Tanning Inspection Branch; Environmental Radiation Branch; 

and Mammography and Special Projects Branch;. All of the branches report to the Section 

Chief. All of the Radiation Protection staff are in the same Section. The Section has a total of 

41 full time staff members (eight in the Materials Branch) and two part-time staff. 

All materials licensing and inspections are performed out of the Raleigh office. The Radioactive 

Materials Branch currently has 639 specific licenses of which 266 are core licenses under NC 

inspection criteria (32 inspection Priority 1's, 140 inspection Priority 2's, and 94 inspection 

Priority 3's). The program also has approximately 900 general licenses. 

There have been no legislative changes to the program since the last periodic meeting. 

Program Strengths and/or Weaknesses 
In general, the North Carolina representatives related that their program has adequate 

administrative support, legislative support, stable sources of funding, adequate instrumentation, 

and fully trained staff. No performance issues under the IMPEP criteria were identified but the 

program representatives acknowledged that additional support was needed for Information 

Technology, high profile legal cases in the materials program, and for laboratory support. 

Specific areas were discussed as follows: 

1.	 The Section Chief related that North Carolina has a comprehensive radiation control 

program that includes not only agreement materials, but also NORM and NARM, 

electronic products, environmental surveillance, emergency preparedness, and a mobile 

laboratory. 

2.	 The Section Chief related that the program has a well trained and dedicated staff that 

utilizes team work on all projects. However, the staff reportedly is being stretched to the 

limit with the addition of security issues, homeland security expectations, and the need 

to interface with more agencies, involving both personnel and monetary resources. One 

health physicist is involved full time in the training of first responders. This realignment 

has impacted the program’s policy of hand delivery of initial licenses which was cited by 

the MRB as a good practice following the previous IMPEP. 

3.	 The Materials Branch reported that the program has good radiation survey equipment 

and commercial calibration services are utilized. The manager reported that inspection 

kits were being developed for each inspector that would include Ludlum 14C 

instruments, pancake probes, a micro-R meter, a digital camera, and a laptop computer. 

The Branch also has equipment for analyzing gamma spectrums in field environments. 

4.	 Managers related that the materials program has no inspection or licensing backlogs at 

this time. 

5.	 The program formerly had inspection priorities that were more frequent than NRC 

priorities; however, the program is adopting the NRC inspection priorities, and the 

inspections were reported to be more performance oriented, with a streamlined 

enforcement policy. 

6.	 The program has a good web page that includes guidance on licensing, security, fines 

and administrative penalties, and organizational information. 

7.	 The Section has implemented a Basic Recognition and Awareness Training (BRAT) 

program for training first responders and others on how commonly used radioactive 

materials are transported around the State, and reactions to radiological events. 

8.	 The Branch has a general licensing (GL) program to track all GL distribution in the 

State. 
9.	 The State currently funds the program partially (80%) by annual fees with the rest 

coming from the general fund. The 2001 General Assembly directed the Division of 

Radiation Protection to develop a Self Sufficiency Plan to become self supporting by FY 

2004. The Division has developed a plan which would make the program selfsupporting by July 1, 2004. The plan would increase fees in general, and the fees 

would include the cost of registration, licensing, environmental surveillance, and some 

emergency response activities which are not covered under the current fee structure. 

The plan will require legislative approval and new legislation, and has been delayed until 

the 2004 legislative session. 

10.	 The Section Chief related that the program has a LAN manager and their system is 

utilized for tracking incidents, allegations, reciprocities, licensing information, and 

inspection data. Some electronic files were lost in recent months and the program 

acknowledged the need for additional Information Technology resources (position) 

within the Section. 

11.	 The Managers also acknowledged that the Environmental Laboratory was located in a 

different Department which is a potential problem if needed to analyze samples, and 

that no funding had been worked out for contract services. 

Feedback on NRC’s Program and Status of NRC Program Changes 

The NRC representatives discussed NRC program changes that could impact the State, such 

as the National Materials Program, control of radioactive material (accountability, orphan 

sources, physical protection), doses to the public, clearance, evolving material processes (risk 

assessment, resources, management reviews, priorities, safety goals), and the need for more 

input from the Agreement States on IMPEP procedures and criteria. 

Internal Program Audits and Self-assessments. 

The managers reported that self-assessments were being accomplished through the use of 

tracking systems for incidents, reciprocities, licensing actions, and inspection activities. The 

Branch manager has participated on several IMPEPs, and related that a self audit would be 

conducted in December in preparation for the next IMPEP. 

Status of Allegations Previously Referred 

The NRC allegation program was discussed in general with the State representatives. The 

Branch Manager related that allegations were processed on a case-by-case basis, follow-ups 

were conducted as needed, a separate file is maintained on each allegation, the allegation is 

tracked, and the issues are closed out with documentation and notification to the alleger as 

appropriate. A review of the allegations referred to the State by the NRC Region II office 

indicated that there had been four referrals to the State since the last periodic meeting, and all 

had been closed. 
Nuclear Material Events Database (NMED) Reporting 

A general discussion was held with the representatives concerning the NMED reporting system.

 A current NMED listing of North Carolina events posted since the previous periodic meeting 

was generated for discussion, with emphasis on complete data and closure of events in 

preparation for the next IMPEP. The State has been very responsive and cooperative in 

providing event information and as requested from NRC, and has taken the initiative in 

reporting information to other States and jurisdictions when appropriate. 

Compatibility of State Regulations 

The compatibility policy was discussed in general with the State representatives, including 

STP’s procedures for reviewing proposed State regulations. Regulation amendments needed 

for adequacy and compatibility were discussed as taken from the State Regulation Status data 

sheet. The Section Chief related that the rulemaking process had been shortened by several 

months, and that all of the rules currently needed for compatibility had been drafted, and the 

package will be sent to the Radiation Protection Commission for adoption in February of 2004. 

The SAO confirmed that the program is receiving NRC regulation changes as published and 

distributed. 

Schedule for the Next IMPEP Review 

The State was informed that the next North Carolina review is currently scheduled for 

September, 2004. 

CONCLUSION: 

The North Carolina program has effective management, equipment, and trained, experienced 

staff. Based upon this meeting and discussions with the program staff, the program appears to 

be adequate to protect public health and safety, and compatible under the IMPEP criteria. All of 

the IMPEP Indicators were discussed and there were no performance issues identified during 

the meeting, 

ACTION ITEMS: 

None