ML19345D211

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Confirms Discussion Re Review of Ny City Radiation Control Program.Recommends Procedures Be Modified to Include Provision for Followup & Recording of Results of All Previous Violations
ML19345D211
Person / Time
Issue date: 11/20/1980
From: Lubenau J
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Solon L
NEW YORK, NY
Shared Package
ML19345D206 List:
References
NUDOCS 8012120243
Download: ML19345D211 (1)


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NOV go,gg0 Leonard Solon, Ph.D., Director Bureau for Radiation Control New York City Department of Health 377 Broadway New York, New York 10013

Dear Dr. Solon:

This is to confirm my discussion with you following the completion of the review of the New York City radiation control program.

I am pleased to report that, in our opinion, the New York City radiation control program is adequate to protect the public health and safety and compatible with the program of the Nuclear Regulatory Commission. You and ycur staff made commendable progress in responding to our comments and recommendations following the initial program review meeting in i

i June, 1980.

We have two additional comments to offer.

First, the staff has prepared revised procedures for documenting inspections. We recommended that the procedures be modified to include a provision for follow-up and recording of results of follow-up of all, previous citations for violations.

Secondly, we recomend the City discard the practice of announcing inspec-tions. Unannounced inspections are more likely to enable inspectors to observe operations and review licensed radiation control programs as they are actually implemented by licensees. In this regard, we recomend flexibility be provided to staff in scheduling inspections tc avoid licensees being able to predict inspections, i.e. at established, rigid intervals.

The staff should also be permitted to conduct additional reinspections before the next scheduled inspection when the supervisor determines a reinspection is merited. Reinspections may be merited by previously identified violations, or for other cause.

I would appreciate your response to these comments. Please accept my thanks for the courtesy and cooperation extended to me by Messrs. Letsinger, Krindler and Borri.

Sincerely, kff A

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Joel 0. Lubenau, Acting Assistant Director

'"for State Agreements Program Office of State Programs 8012120 M 3

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