ML20210R537
| ML20210R537 | |
| Person / Time | |
|---|---|
| Issue date: | 07/19/1999 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| Shared Package | |
| ML20210R532 | List: |
| References | |
| NUDOCS 9908170136 | |
| Download: ML20210R537 (2) | |
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1 July 19,1999' l
l MEMORANDUM TO: Paul H. Lohaus, Director l Office of State Programs FROM: Carl J. Paperiello, Director s I Office of Nuclear Material Safety ,
and Safeguards
SUBJECT:
FOLLOW-UP INTEGRATED MATERIALS PERFORMANCE EVALUATION PROGRAM REVIEW OF THE NEW YORK CITY DEPARTMENT OF HEALT ' RADIATION CONTROL PROGRAM (NYCH) l l 1 am responding to the draft letter sent to me on July 9,1999, for my review and concurrence.
As a member of the Management Review Board, I concu ' with the draft letter, and support its central findings. However, I offer the following points for our consideration:
A. Substantive Comments:
1, Page 2: Why is the third paragraph necessary? IMPEP suggestions are not recommendations. They do not rpquire a Region, an Agreement State, or i
in this case, a City, to respond. } hey need not be implemented to assure satisfactory program performance. Therefore, it appears inappropriate for NRC to include this paragraph.
- 2. Page 3: The current status paragraph in ludes the following statement:
"The team found that NYCH ha completed 170 inspections in 1998." {
Earlier, in the third paragraph o'n page 1, there is a reference to the combined New York programs l first reading, I misinterpreted ese facts, andth[ regulating assumed 1,400 that only about specific l 1/8 of the licenses had been ir7spected in 1998. If this were true, it would have been nearly impossible to complete the inspections in accordance with the frequencies in Inspedtion Manual Chapter 2800. To clarify this point, the report should include the number of specific licenses regulated by the NYCH. If the figure ofl170 inspections is correct, I would estimate that NYCH regulates about 500-550 licenses.
CONTACT: George Deegan, NMSS/IMNS (301)415-7834 9900170136 990729 PDR STPRQ ESON g
Neal L. Cohen, M.D. .
I appreciate the courtesy and cooperation extended to the IMPEP team during the follow-up review and your support of the radiation control program. I look forward to our agencies continuing to work cooperatively in the future.
Sincerely,
) '
Frank J.@firaglia, 0 6 Deputy Executive Director for Regulatory Programs
Enclosure:
As stated 7
cc: Gene Miskin, Director Bureau of Radiological Health, NYCH John P. Spath, Director Radioactive Waste Policy and Nuclear Coordination, NYSERDA Rita Aldrich, Principal Radiophysicist Radiological Health Unit, NYDL Karim Rimawi, Ph.D., Director Bureau of Environmental Radiation Protection, NYSH
)
Paul J. Merges. Ph.D., Director Bureau of Radiation and Hazardous Site Management i