ML18025B093
| ML18025B093 | |
| Person / Time | |
|---|---|
| Issue date: | 06/02/2023 |
| From: | Lizette Roldan-Otero NRC/NMSS/DMSTR/ASPB |
| To: | |
| Roldan-Otero L | |
| Shared Package | |
| ML17152A398 | List: |
| References | |
| Download: ML18025B093 (2) | |
Text
Comment #
Office Date of Comment Section Comment Concur?
(Y/N)
Author Response 1
OAS 9/20/2017 V.C.iii For special technical assistance requests (TARs), it is suggested that the Agreement State should also include evidence that it pursued alternative means of addressing the issue on its own, including attempting to obtain assistance from other agencies within the State or Commonwealth, other Agreement States, or independent organizations, such as the Organization of Agreement States, the Conference of Radiation Control Program Directors, or procuring contractors or consultants. This level of research may take an extended period of time. For example, procuring a contractor would require the creation of a scope of work, a request for proposal, and other procurement procedures that could take over a year to complete for some states. Perhaps an additional assessment on the timeliness requirement of the TAR could allow the NRC to pursue the request on a case by case basis without evidence that a consultant was considered.
Yes The NRC will consider TARs on a case by case basis without evidence that a consultant was considered provided the Agreement State pursue other means such as assistance from other agencies within the State or other Agreement States. The pursue of alternative means does not have to encompass all of the examples mentioned in the text.
Comment Request Letter RCPD-17-011 dated August 21, 2017 Resolution of Comments: SA-1001, "Technical Assistance to Agreement States" 1 of 2 ML18025B093
Comment #
Office Date of Comment Section Comment Concur?
(Y/N)
Author Response 2
OAS 9/20/2017 Section V.C.iv. The first sentence states that an Agreement State may request the use of an NRC medical consultant to evaluate a medical event in their State at no additional cost. The next sentence states that the Agreement State should also include evidence that it pursued alternative means of addressing the issue on its own, including attempting to obtain assistance from other agencies within the State or Commonwealth, other Agreement States, or independent organizations, such as the Organization of Agreement States, the Conference of Radiation Control Program Directors, or procuring contractors or consultants, and that the State or Commonwealth does not have the funds to reimburse the NRC for use of the consultant. These two sentences are contradictory. Agreement States agree that medical event assistance should be free of charge. How does an Agreement State demonstrate that no funds are available without initiating the burdensome procurement process?
How does an Agreement State demonstrate that it reached out to all other Agreement States? Or would the requirement be to reach out to just a few, or just the OAS? And since OAS members are CRCPD members, would that be sufficient? Again, timeliness should be a consideration by the NRC for approving a TAR.
No The NRC does not have the statutory authority to fund Agreement State programs. A reasonable attempt to pursue alternate means of addressing medical event assistance includes evaluating whether the State: (1) has available medical staff in other State agencies to address the issue, (2) can procure the assistance of medical staff outside its agency to address the issue using State funds; and (3) has evaluated the availability of medical staff from other agencies (e.g., OAS, CRCPD, or another Agreement State). It would not be expected that all 37 Agreement States would have to be contacted in a reasonable attempt effort; however, only contacting a small Agreement State program with either minimal available resources or medical event expertise would not be considered a reasonable attempt.
The NRC service will be free of charge for those Agreement States that demonstrate the need and that the State made a reasonable effort to resolve the issue without NRC assistance.
3 OAS 9/20/2017 The OAS appreciates that the word "should" is used in SA-1001 and hopes that the NRC considers this when reviewing TARs.
Yes The NRC will consider the word "should" when reviewing TARs.
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