UNITED STATES 

 NUCLEAR REGULATORY COMMISSION 

 REGION I 

 475 ALLENDALE ROAD 

 KING OF PRUSSIA, PENNSYLVANIA 19406-1415

May 27, 2011 

Cynthia Long, Manager 

Radioactive Materials Program 

GA Department of Natural Resources 

4220 International Parkway, Suite100 

Atlanta, GA 30354 

Dear Ms. Long: 

A periodic meeting was held with you on April 26, 2011. The purpose of the meeting was to 

review and discuss the status of the State of Georgia’s Department of Natural Resources’ 

Radioactive Materials Program. The NRC was represented by Raymond Lorson, Donna Janda, 

and me. Topics and issues of importance discussed at the meeting included a detailed 

discussion of recommendations from the 2008 IMPEP review. 

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 (610) 337-5214, or 

email to Monica.Orendi@nrc.gov to discuss your comments. 

Sincerely, 

/RA/ 

Monica Orendi 

Regional State Agreements Officer 

Division of Nuclear Materials Safety 

Enclosure: As stated 

 
 

May 27, 2011 

Cynthia Long, Manager 

Radioactive Materials Program 

GA Department of Natural Resources 

4220 International Parkway, Suite100 

Atlanta, GA 30354 

Dear Ms. Long: 

A periodic meeting was held with you on April 26, 2011. The purpose of the meeting was to 

review and discuss the status of the State of Georgia’s Department of Natural Resources’ 

Radioactive Materials Program. The NRC was represented by Raymond Lorson, Donna Janda, 

and me. Topics and issues of importance discussed at the meeting included a detailed 

discussion of recommendations from the 2008 IMPEP review. 

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 (610) 337-5214, or 

email to Monica.Orendi@nrc.gov to discuss your comments. 

Sincerely, 

 /RA/ 

Monica Orendi 

Regional State Agreements Officer 

Division of Nuclear Materials Safety 

Enclosure: As stated 

Distribution: 

M. Beardsley, FSME 

L. Dimmick, FSME 

K. Meyer, FSME 

R. Lorson, RI 

D. Collins, RI 

D. Janda, RI 

SUNSI Review Complete: MLO (Reviewer=s Initials) ML111510911

DOCUMENT NAME: S:\State Agreement Files\Kentucky\PERIODIC MEETING SUMMARY FOR KY 02-10-11.doc 

After declaring this document AAn Official Agency Record@ it will be released to the Public. 

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with 

attachment/enclosure "N" = No copy 

OFFICE DNMS/RI E 

NAME MOrendi/MEO 

DATE 05/27/11 

OFFICIAL RECORD COPY
Enclosure 

AGREEMENT STATE PERIODIC MEETING SUMMARY FOR GEORGIA DEPARTMENT OF 

NATURAL RESOURCES (DNR) 

DATE OF MEETING: April 26, 2011 

NRC Attendees Georgia DNR 

Raymond Lorson, Director, Division of 

Nuclear Materials Safety, Region I 

Jac Capp, Branch Chief, Air Protection Branch 

Donna Janda, Region I RSAO Chuck Mueller, Senior Policy Advisor 

Monica Orendi, Region I RSAO Cynthia Sanders Long, Manager, Radioactive 

Materials Program 

DISCUSSION: 

During the 2008 Integrated Materials Performance Evaluation Program (IMPEP) review of the 

Georgia Agreement State Program (the Program), the review team found the State’s 

performance satisfactory for three performance indicators: Technical Quality of Incidents and 

Allegations, Compatibility Requirements, and Sealed Source and Device Evaluation Program; 

and satisfactory, but needs improvement, for four performance indicators: Technical Staffing 

and Training, Status of Materials Inspection Program, Technical Quality of Inspections, and 

Technical Quality of Licensing Actions. Two recommendations were made by the IMPEP 

review team, and two recommendations were carried over from the 2004 IMPEP review. On 

December 4, 2008, the Management Review Board (MRB) met to consider the proposed final 

IMPEP report on the Georgia Agreement State Program. The MRB found the Program 

adequate to protect public health and safety, but needs improvement, and compatible with 

NRC’s program. The MRB directed NRC staff to initiate a period of monitoring, requested that 

calls between the Georgia DNR and NRC staffs be conducted quarterly, and directed that a 

periodic meeting take place approximately one year from the 2008 IMPEP review. On 

October 28, 2009, a periodic meeting was held to discuss the status of the Program and the 

recommendations made during the 2008 IMPEP review. On January 7, 2010, the MRB met to 

discuss the results of the periodic meeting. The MRB concluded that the next IMPEP review of 

the Program should take place as currently scheduled in Fiscal Year 2012. 

The following is a status summary of the four recommendations that were identified in the 2008 

Georgia final IMPEP report: 

1. The review team recommended that Georgia develop, document, and implement a 

formal qualification program for licensing and inspection activities that includes 

written documentation and supervisor endorsement of competency in each program 

area. 

Status: The Program has developed and implemented a policy and procedure for 

formal qualification of staff. Efforts are ongoing with respect to licensing qualification 

for staff. Staff licensing actions are undergoing review by Ms. Long, and peer 

reviews of licensing actions have also been implemented. Efforts on the inspection 

qualification program are also continuing. Ms. Long is conducting training 

accompaniments with staff as part of the inspection qualification program. Georgia 

staff are attending NRC sponsored training courses, and Georgia is attempting to 
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Enclosure 

place as many staff as possible into the training courses in order to respond to the 

recommendation in this area. Georgia continues to move forward with staff 

qualifications and training. 

2. The review team recommended that Georgia update their inspection procedures and 

enforcement guidance to include the requirements for timely follow up of Increased 

Controls violations. 

Status: Ms. Long stated that the inspection procedures have been updated to 

include the guidance in FSME’s RCPD-07-006 letter and that staff has been trained 

on the revised procedure. 

3. The review team recommended that Georgia develop and implement a process for 

conducting annual accompaniments of all radiation compliance inspectors by a 

supervisor. (Carryover recommendation from the 2004 IMPEP.) 

Status: The Program Supervisor is conducting annual accompaniments of 

inspectors. The accompaniments are documented in an Accompaniments Tracking 

Log. Ms. Long stated that all of her staff had been accompanied during calendar 

year 2010. 

4. The review team recommended that Georgia qualify one additional reviewer in 

Sealed Source and Device (SSD) evaluations to provide backup for the principal 

reviewer. (Carryover recommendation from the 2004 IMPEP.) 

Status: Ms. Long stated that this position remains unfilled at the present time. Due 

to budget constraints within the State, the Program has been unable to fill this vacant 

position. Ms. Long is currently performing the second review for SS&D sheets. In 

the interim, Ms. Long stated that the Program is considering qualifying a second staff 

member to be able to perform the second review for SS&D sheets or asking other 

Agreement States with SS&D programs for help with performing the second review 

on SS&D sheets while the vacancy remains. 

OTHER TOPICS COVERED DURING THE MEETING INCLUDED:

Program Strengths

The Program has recovered from a significant turnover of staff and now has a good mix of staff 

with respect to experienced staff and new hires. The team work and sharing of responsibilities 

amongst the staff are considered Program strengths. There is support for staff training 

throughout the Program management organization. The Program has been responsive to the 

recommendations from the latest IMPEP review. 

Program Weaknesses

Budget constraints are the major Program weakness. Due to a tighter State budget, the 

Program is unable to send staff to the five week health physics course. Also with regards to 

NRC initiatives that the Agreement States are asked to comply with, lack of resources could 

impact how long it takes for the Program to implement these initiatives. 
Page 3 

Enclosure 

Feedback on the NRC’s Program

The Program commented that both the overall relationship and communications with the NRC 

are good. The Program expressed appreciation for the NRC funding of training and added that 

they would like to see the NRC fund the five-week Oak Ridge Health Physics Course. 

Agreement State Program Staffing and Training

The Program staff currently consists of nine individuals, which includes the Program manager. 

There are three staff vacancies, two technical positions and one administrative position. 

Ms. Long stated that Program staff is working together as a team to maintain the Program and 

pick up the workload of the departed staff. 

Support for staff training exists in the Program. Georgia welcomed the NRC’s revised policy on 

funding training for Agreement States. Program staff has attended NRC and other training 

courses, including the NRC’s Security Systems and Principles Course. The Program Manager 

noted that other activities that are not specifically training, such as attendance at meetings, also 

provide valuable opportunities for knowledge sharing. In response to recommendations made 

during the last IMPEP review, the Program has developed core training course requirements for 

program staff. 

Organization

The Georgia Agreement State Program is administered by the Radioactive Materials Program 

which is located in the Air Protection Branch (the Branch). The Branch is a part of the 

Environmental Protection Division of the DNR. Since the most recent IMPEP review, the 

Director of the Environmental Protection Division resigned and the new replacement is F. Allen 

Barnes. 

Program Budget/Funding

The program is adequately funded and is one hundred percent funded by fees. The funds are 

placed into a restricted account that is reserved for the Program. Program management stated 

that licensee fees are not based on a percentage of NRC’s fees. Georgia has not had a fee 

increase since 1992. 

Inspection and Licensing Programs

The Program’s inspection frequencies are at least as frequent as NRC’s. At the time of the 

periodic meeting three Priority 1 inspections, four Priority 2 inspections, and eight Priority 3 

inspections were overdue by more than twenty five percent of the assigned inspection interval. 

About 11 other inspections were past due at the time of the meeting. The Program monitors 

and tracks inspection scheduling. Management is aware of the backlog and the importance of 

inspection program schedules. Ms. Long attributed this backlog is due in large part to the 

technical position vacancy. Additional options to help complete the overdue inspections in the 

absence of the technical position vacancy; such as reprioritizing the inspections based on 

priority code; were discussed with Program Management.
Page 4 

The Program currently has approximately 520 licensees. Georgia licensees are subject to a five 

year license renewal term. As of the periodic meeting the Program has 17 licensing actions that 

have been in house for more than one year. The Program receives about 400 licensing actions 

per year. 

Regulations and Legislative Changes

There have not been any legislative changes or proposals that have affected the Program. 

Georgia has three overdue regulations due for adoption. 

The following regulations are currently overdue: 

• “Exemptions from Licensing, General Licenses, and Distribution of Byproduct Material: 

Licensing and Reporting Requirements,” 10 CFR Parts 30, 31, 32, and 150 amendment 

(72 FR 58473), that was due for implementation on December 17, 2010. 

 (RATS ID 2007-2) 

• “Requirements for Expanded Definition of Byproduct Material,” 10 CFR Parts 20, 30, 31, 

32, 33, 35, 61, and 150 amendment (72 FR 55864), that was due for implementation on 

November 30, 2010. (RATS ID 2007-3) 

• “Occupational Dose Records, Labeling Containers, and Total Effective Dose Equivalent,” 

10 CFR Parts 19 and 20 amendment (72 FR 68043), that was due for implementation on 

February 15, 2011. (RATS ID 2008-1) 

Georgia plans to have final regulations adopted and in place before the next IMPEP review 

which is tentatively scheduled for FY 2012. 

Event Reporting

The Program communicates reportable incidents to the NRC Operations Center and Region I 

when appropriate in a prompt manner. Since the last IMPEP review in September 2008, twelve 

events were reported to the NRC. It was noted during this Periodic meeting that a few of the 

events had either not been closed out by the State or the reports were either not completed by 

the State or had additional information requests from Idaho National Laboratory. The Program 

agreed to follow-up on these issues as appropriate. 

Response to Incidents and Allegations

The Program continues to be sensitive to notifications of incidents and allegations. Incidents 

are quickly reviewed for their effect on public health and safety. Staff is dispatched to perform 

onsite investigations when necessary. The Program is aware of the need to maintain an 

effective response to incidents and allegations. 

Sealed Source and Device (SS&D) Evaluation Program

Since the 2008 IMPEP review the Program has received 12 SS&D actions. Five of the 12 

SS&D actions have been completed as of the date of this periodic meeting and one SS&D 

action was rescinded. It was noted that a few of the 12 SS&D actions were received in the
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Enclosure 

second half of calendar year 2009 and still had not been completed by the Program. Ms. Long 

stated that the Program would work on completing these actions and also work on eliminating 

the current backlog. 

Large, Complicated, or Unusual authorizations for use of Radioactive Material

The Program received an interesting request from one of their major medical licensees, who is 

looking become a broadscope medical licensee by including their sister hospitals as satellite 

locations. The Program is in the early stages of evaluating this request and is planning to meet 

with the applicant licensee in the coming future to discuss the logistics of this request. 

Commonwealth’s Mechanisms to Evaluate Performance

Ms. Long stated that the Branch conducts self assessments by tracking program statistics and 

completing supervisor accompaniments of inspectors. 

CONCLUSIONS: 

Georgia has been responsive to the recommendations that were made during the 2008 IMPEP 

review. Staffing vacancies continue to impact the Program. The effort to reduce the inspection 

backlog continues. 

NRC staff recommends that the next IMPEP review should be conducted as scheduled in 

FY 2013 (tentatively October 2012).