September 28, 2000

Howard K. Koh, M.D., M.P.H.

Commissioner

Massachusetts Department of Public Health

250 Washington Street, 2nd Floor

Boston, MA 02114

Dear Dr. Koh:

Enclosed is the final report of the follow-up Integrated Materials Performance Evaluation Program

(IMPEP) review of the Massachusetts Sealed Source and Device (SS&D) Evaluation Program. 

The review was conducted by an NRC/Agreement State team during the period June 19-21, 2000. 

The team reviewed in detail the non-common performance indicator of concern identified during

the 1998 IMPEP review, SS&D Evaluation Program. 

The review team found that the SS&D Evaluation Program has improved and has responded to

and resolved the two recommendations from the 1998 IMPEP review for the performance

indicator, SS&D Evaluation Program. Three new recommendations were made, two of which

involved specific comments on SS&D certificates. The team also noted that the SS&D Evaluation

Program should more closely follow the national format in documenting product evaluations in

SS&D registry certificates. 

We appreciate receiving Mr. Hallisey’s August 15, 2000 letter commenting on the draft IMPEP

report. We recognize that much of the information contained in current Massachusetts SS&D

registration certificates was transferred from NRC certificates when the Commonwealth became

an Agreement State. We have revised the report to reflect your comments on Recommendation

#1, but we continue to support the recommendation. NRC staff will discuss with your staff

possible ways to clarify the wording on the certificate mentioned in Recommendation #1. 

Based on the follow-up IMPEP review, the Management Review Board finds that there is no

change to the finding resulting from the January 1998 IMPEP review, that the Massachusetts

radiation protection program is adequate to protect public health and safety and compatible with

NRC’s program.

Section 3 on pages 6 and 7 of the enclosed final report presents the follow-up team’s

recommendations. Based on previous correspondence, discussions during the follow-up review,

and your response to the draft IMPEP report, no response is necessary for Recommendations #2

and #3. We request that you inform us of your plans to address the first recommendation within

30 days of the receipt of this letter. 

Based on the results of the follow-up IMPEP review, the next IMPEP review will be scheduled in

approximately two years.
Howard K. Koh 2 September 28, 2000

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,

/RA/

Carl J. Paperiello

Deputy Executive Director

 for Materials, Research and 

 State and Tribal Programs

Enclosure:

As stated

cc: Nancy Ridley, Assistant Commissioner

Massachusetts Department of Public Health

Robert M. Hallisey, Director

Radiation Control Program

Stephen McGrail

Massachusetts State Liaison Officer

Alice Rogers

Texas Natural Resource Conservation Commission

Organization of Agreement States Liaison to MRB
Howard K. Koh 2 September 28, 2000

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,

/RA/

Carl J. Paperiello

Deputy Executive Director 

 for Materials, Research and 

 State and Tribal Programs

Enclosure:

As stated

cc: Nancy Ridley, Assistant Commissioner

Massachusetts Department of Public Health

Robert M. Hallisey, Director

Radiation Control Program

Stephen McGrail

Massachusetts State Liaison Officer

Alice Rogers

Texas Natural Resource Conservation Commission

Organization of Agreement States Liaison to MRB

bcc: Chairman Meserve

Commissioner Dicus

Commissioner Diaz

Commissioner McGaffigan

Commissioner Merrifield

Distribution:

DIR RF DCD (SP01) PDR (YES/)

SDroggitis Massachusetts File

KSchneider

LRakovan

RBlanton, ASPO

DCool, NMSS

GDeegan, NMSS

STreby, OGC

BPoole, OGC

FCameron, OGC

TCombs, OCA (2)

UBhachu, NMSS

MStephens, FL

DWhite, RI

RBores, RI

DOCUMENT NAME: G:\IMPEP\2000 MA Final Follow-Up IMPEP Report and Letter. wpd

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 STP STP:DD NMSS:D OGC STP:D MRSDED

NAME LBolling:kk FCombs

(By LBolling)

WFKane

(By MVirgilio)

KDCyr

(By SHLewis)

PHLohaus CJPaperiello

DATE 09/12/00 09/12/00 09/26/00 09/25/00 09/27/00 09/28/00

STP-AG-30
INTEGRATED MATERIALS PERFORMANCE EVALUATION 

PROGRAM (IMPEP) FOLLOW-UP REVIEW OF

THE MASSACHUSETTS RADIATION CONTROL PROGRAM

JUNE 19 - 21, 2000

FINAL REPORT

U. S. Nuclear Regulatory Commission
Massachusetts Follow-Up Final Report Page 1

1.0 INTRODUCTION

This report presents the results of the follow-up review of the Massachusetts Department of Public

Health, Radiation Control Program (RCP) conducted June 19-21, 2000. This follow-up review

was directed by the Management Review Board (MRB) based on the results of the January 12-16,

1998 Integrated Materials Performance Evaluation Program (IMPEP) review. The MRB stated

that a limited scope IMPEP follow-up review focusing on the non-common performance indicator,

Sealed Source and Device (SS&D) Evaluation Program, should be conducted two years from the

date of the January 12-16, 1998 review based on the satisfactory with recommendations for

improvement finding for this indicator. The follow-up review also included evaluation of actions

taken by the Commonwealth to address the two recommendations and one suggestion made

during the January 12-16, 1998 IMPEP review involving this indicator.

The follow-up review was conducted by a review team consisting of technical staff members from

the Nuclear Regulatory Commission (NRC) and the State of Florida. Team members are

identified in Appendix A. The follow-up review was conducted in accordance with the “Policy

Statement on Adequacy and Compatibility of Agreement State Programs,” published in the

Federal Register on September 3, 1997 (62 FR 46517), and the November 5, 1999, Revised NRC

Management Directive (MD) 5.6, “Integrated Materials Performance Evaluation Program.”

The Massachusetts Agreement State program is administered by the RCP, located in the

Department of Public Health. Organization charts are included as Appendix B. At the time of the

follow-up review, the Massachusetts program regulated approximately 600 specific licenses,

including all types of major licensees except for uranium mill tailings.

In preparation for the follow-up review, a questionnaire addressing the indicator, SS&D Evaluation

Program and current program status was sent to the RCP on May 10, 2000. The RCP provided a

response to the questionnaire on June 8, 2000. 

The team’s approach for conducting the follow-up review consisted of: (1) an examination of the

RCP’s response to the questionnaire; (2) an in-depth review of the program indicator, 

SS&D Evaluation Program, for the period of January 16, 1998 - June 19, 2000, including a

technical review of selected SS&D program documentation and evaluation of the RCP’s actions in

response to the two recommendations involving this indicator; (3) a discussion of the status of the

RCP’s actions to address the remaining six recommendations in the 1998 report; and (4)

interviews with staff and management to answer questions or clarify issues. The review team

evaluated the information that it gathered against the IMPEP performance criteria for the noncommon performance indicator, SS&D Evaluation Program, for activities conducted during the

period of January 16, 1998 - June 19, 2000. Preliminary results were discussed with the RCP

management on June 21, 2000.

Section 2 below discusses the results of the follow-up review of the RCP program for the 

non-common performance indicator, SS&D Evaluation Program. Section 3 summarizes the review

team's findings and recommendations resulting from the follow-up review. The Commonwealth’s

progress in addressing other recommendations from the 1998 review can be found in Appendix C.
Massachusetts Follow-Up Final Report Page 2

2.0 NON-COMMON PERFORMANCE INDICATOR, SEALED SOURCE AND DEVICE

EVALUATION PROGRAM

During the follow-up review, the team evaluated actions taken by the RCP in response to the two

recommendations noted during the 1998 review, as well as newly completed SS&D registry

certificates. 

Recommendation 7

The review team recommends that the Commonwealth review current policy and

procedures, and update or establish policy and procedures as necessary, including

definition of concurrence reviews consistent with the current MD 5.6. (Section 4.2.1 of the

1998 report).

Current Status

The December 1998 Periodic Meeting summary noted that the RCP had reviewed the current

policy and procedures for its SS&D program with their SS&D staff. The SS&D program had

sufficient staff to perform two independent reviews for sheets consistent with MD 5.6. Each sheet

also receives supervisory review. The Commonwealth indicated that their policy and procedures

for their SS&D program are consistent with MD 5.6. The RCP has recently revised its policy and

procedures for the SS&D program to clarify the policy on first and second reviewer qualifications

and responsibilities, management review, and to reflect recent changes in management structure. 

The revision is consistent with MD 5.6. 

 

Based on the follow-up review, the team considers this recommendation closed.

Recommendation 8

The review team recommends that the Commonwealth establish a signature authority

qualification program for all, including current, SS&D reviewers. (Section 4.2.2 of the 1998

report).

Current Status

The Commonwealth has established a Training Qualification Record for each member of the staff. 

The record documents the basic, specialized and advanced training which is required of each staff

member. Management sign-offs are required for each course or alternative training area,

including on-the-job training. Management then assigns work based on an assessment of the

staff’s documented training and experience. 

Based on the follow-up review, the team considers this recommendation closed.

2.1 Technical Quality of Product Evaluations Program

The team reviewed SS&D actions, deficiency correspondence, and checklists for nine SS&D

cases, staffing and training, and responses to incidents and allegations. SS&D certificates were
Massachusetts Follow-Up Final Report Page 3

reviewed for accuracy, appropriateness of authorizations, tie-down statements, and overall

technical quality. Casework was evaluated for timeliness, adherence to good radiation safety

practices, acceptable engineering practices, references to appropriate regulations, documentation

of safety evaluation reports, manufacturing Quality Assurance/Quality Control (QA/QC),

supporting documents, peer or supervisory review as indicated, and proper signature authority. 

The files were checked for retention of necessary documents and other supporting data.

The review team noted that the SS&D evaluation program receives good management support

and oversight. The inspection tracking system has been expanded to include all open dockets

(licensing, SS&D and inspections). The Program Supervisor obtains and reviews a system printout each week and otherwise as needed. A meeting is then held with the licensing and inspection

section supervisors to track the progress of all pending cases. Written feedback on completed

cases is provided by the section supervisors to the Program Supervisor each week. Cases and

personnel can then be re-assigned as needed. 

Nine SS&D case files were selected for review including work performed by all reviewers. The

cross-section sampling included all of the Commonwealth’s major SS&D manufacturer/distributors

as defined by the Commonwealth, including the following types: gas chromatography, industrial

radiography, medical high dose-rate (HDR) afterloader, and well logging. SS&D actions included

new certificates, renewals, amendments, and terminations. SS&D actions during the review

period included issuance of three new certificates and four amendments, two conversions and one

inactivation totaling ten SS&D actions. A list of the SS&D files reviewed with case specific

comments can be found in Appendix D.

The review team concludes that the SS&D evaluation program has shown improvement since the

1998 IMPEP review, however, additional areas for improvement in the technical quality of product

evaluations were identified. The RCP staff has gained experience in this area due to the case

work transferred from the NRC upon the effective date of their Agreement. The RCP has also

been presented with an unusual challenge in absorbing 214 SS&D registry certificates from the

State of Illinois. Each of these certificates will require an assessment for inactivation or

amendment for continued use in the SS&D registry. 

Based on review of the nine selected SS&D casework files, the review team found that the SS&D

files were maintained in an orderly manner and correspondence was filed chronologically. 

Management involvement in the program is at the appropriate level. 

The review team noted that one certificate MA-0628-D-137-S, contains conditions of use which

could be misinterpreted as either granting a generic exemption, or implying that no exemption is

required. The circumstances in this case were unique, so there was no available guidance or

precedent for Massachusetts to follow. NRC staff will discuss with Massachusetts possible ways

to clarify the wording on the certificate. The review team recommends that the RCP coordinate

with NRC staff possible ways to revise SS&D registry certificate MA-0628-D-137-S, to make clear

that a generic exemption has not been granted, and that a specific exemption is needed to use the

device under special conditions.
Massachusetts Follow-Up Final Report Page 4

Based on discussion with the RCP staff and review of the case files, the review team noted that

radiographic source changer model 650, identified in SS&D registry certificate MA-0628-D-127-S

dated February 9, 2000, does not currently meet the performance requirements for radiographic

operations detailed in 10 CFR 34.20. This device is not equipped with a positive lock mechanism

which will secure the source. Also the registry certificate lists both devices that meet 10 CFR

34.20 and devices that do not meet 10 CFR 34.20, which creates uncertainty for the SS&D

registry certificate user as to which limiting conditions pertain to a given model. A statement in the

Safety Analysis Summary, that the model 650 source changer is acceptable for licensing, is

inconsistent with current policy concerning the 650 model changer. The review team recommends

that the RCP reevaluate the radiographic source changers in SS&D registry certificate MA-0628-

D-127-S dated February 9, 2000, especially model 650, which does not meet the performance

requirements for radiographic operations detailed in 10 CFR 34.20. The SS&D registry certificate

should be revised by RCP to reflect this reevaluation and those limitations necessary for the use

of these devices. The SS&D registry certificate should reflect these modifications in the section

on Limitations and/or Other Considerations of Use. A separate registration certificate should be

issued for the devices which meet the 10 CFR 34.20 requirements.

The review team discussed with RCP staff NRC Information Notice 95-58 issued on December 18,

1995 whereby NRC informed its licensees that all radiographic exposure devices and associated

equipment in use after January 1, 1996, needed to comply with the requirements specified in 10

CFR 34.20. All requests for exemptions to the 10 CFR 34.20 requirements have been submitted

for NRC’s evaluation by the specific user of the devices and not the manufacturers. The review

team also discussed with RCP staff that the RCP should consider conducting periodic QA/QC

inspections of its licensed SS&D manufacturers to enhance the technical quality of product

evaluations.

Additional case specific comments are attached to this report as Appendix D. These comments

center around numerous non-safety related variances from the format for documenting SS&D

evaluations as described in NUREG-1556, Volume 3, “Application for Sealed Source and Device

Evaluation and Registration.” The Commonwealth indicated that where possible and practical the

guidance in NUREG-1556, Volume 3, was utilized to compile the SS&D registration certificates. 

The RCP updated and re-issued their procedure for processing registration applications on June

6, 2000. This procedure was reviewed and no comments were developed as a result of the

review.

The review team recommends that in the interest of national consistency, and where practical, the

RCP closely follow the format for documenting product evaluations in SS&D registry certificates as

detailed in NUREG-1556, Volume 3. 

The review team recommends that Massachusetts’ performance with respect to the sub-indicator,

Technical Quality of Product Evaluation Program, be found satisfactory with recommendations for

improvement.
Massachusetts Follow-Up Final Report Page 5

2.2 Technical Staffing and Training

During the review period, the RCP was reorganized. The Acting Program Supervisor was

promoted to Program Supervisor and one of the three reviewers was promoted to Supervisor of

the SS&D/Licensing Section. The SS&D/Licensing Section currently has two reviewers who

divide their time between licensing and SS&D reviews. During the review period the RCP hired

an SS&D reviewer with an extensive industrial licensing and product evaluation background. The

RCP also lost an experienced SS&D/License reviewer who resigned in May 2000. The RCP hired

a replacement who began work on July 3, 2000. The RCP management indicated that staffing

levels for the SS&D evaluation program are adequate at present, but can easily be adjusted to

cope with any increases in the number of SS&D applications.

The review team examined the training and experience folders for the staff and management

involved in the SS&D evaluation program. The educational qualifications for the current staff were

evaluated in 1998 and found to be acceptable. Based on recommendations from the 1998 IMPEP

review, the RCP established a Training Qualification Record to document basic, specialized and

advanced training obtained by the staff. Each staff member must document his or her training,

whether formal, alternative or on-the-job. This record is reviewed and initialed by management so

that staff may receive credit for the training. The RCP is to be commended for its exceptional

documentation of on-the-job training. The review team noted that the record for a new employee

clearly indicated a listing of assignments, license numbers, program code, licensee type, dates

and the names of the RCP mentors. In addition to the listing, a brief narrative was attached to the

record which explained the specific activity performed for each case, i.e., licensing, inspection,

SS&D review, etc. The RCP, as a matter of policy, cross trains its staff. Individuals with unique

education and experience are consulted and contribute to SS&D reviews.

The review team discussed with RCP changing the sequence of courses taken to enhance the

skills of the SS&D reviewers. The review team believes that moving the following courses from

the advanced training category to the required basic training category will accomplish this

enhancement: Safety Aspects of Industrial Radiography Course, Teletherapy/Brachytherapy

Course and the Root Causes/Incident Investigation Workshop. This should also help newly hired

SS&D reviewers to obtain fully qualified status in a shorter period of time. 

The review team recommends that Massachusetts’ performance with respect to the sub-indicator,

Technical Staffing and Training, be found satisfactory. 

2.3 Evaluation of Defects and Incidents Regarding Sealed Sources and Devices

During the review period, the Commonwealth reported six incidents involving equipment failure or

malfunction. The review team examined each file and noted that the RCP staff promptly and

appropriately responded to these incidents and no overexposures or medical misadministrations

were reported. The incident reports submitted to the Nuclear Materials Event Database

corresponded to those contained in the RCP’s incident log. As needed, the RCP staff conducts

on-site investigations of licensed SS&D manufacturers with special attention to QA/QC programs. 

The SS&D incident files were orderly and incidents were filed chronologically. The review team

noted that, in one case, a licensed SS&D manufacturer is approximately 60-days overdue in

providing a final report to the RCP on a leaking radiography source from overseas. The review
Massachusetts Follow-Up Final Report Page 6

team noted that during the review period, there were no allegations related to the SS&D

evaluation program.

Attached to this report, as Appendix E, are summaries of the six incidents involving equipment

failure or malfunction.

The review team recommends that Massachusetts’ performance with respect to the sub-indicator,

Evaluation of Defects and Incidents Regarding Sealed Sources and Devices, be found

satisfactory.

3.0 SUMMARY

The follow-up review team found Massachusetts’ performance in responding to and resolving the

two recommendations involving the non-common performance indicator, Sealed Source and

Device Evaluation Program, to be acceptable.

As noted in Section 2 above, the follow-up review team found Massachusetts’ performance to be

satisfactory with recommendations for improvement for the sub-indicator, Technical Quality of the

Product Evaluation Program. The review team found Massachusetts’ performance to be

satisfactory for the sub-indicators, Technical Staffing and Training and Evaluation of Defects and

Incidents Regarding Sealed Sources and Devices. Overall, the review team recommends that

Massachusetts’ performance with respect to the indicator, SS&D Evaluation Program, continue to

be found satisfactory with recommendations for improvement. 

Accordingly, since there is no change to the findings resulting from the January 1998 IMPEP

review, the review team recommended and the Management Review Board agreed to continue to

find the Massachusetts’ program to be adequate to protect public health and safety and

compatible with NRC’s program.

Below is a summary list of recommendations, as mentioned in earlier sections of this report, for

evaluation and implementation, as appropriate, by the Commonwealth.

1. The review team recommends that the RCP coordinate with NRC staff possible ways to

revise SS&D registry certificate MA-0628-D-137-S, to make clear that a generic exemption

has not been granted, and that a specific exemption is needed to use the device under

special conditions. (Section 2.1) 

2. The review team recommends that the RCP reevaluate the radiographic source changers

in SS&D registry certificate MA-0628-D-127-S dated February 9, 2000, especially model

650, which does not meet the performance requirements for radiographic operations

detailed in 10 CFR 34.20. The SS&D registry certificate should be revised by RCP to

reflect this reevaluation and those limitations necessary for the use of these devices. The

SS&D registry certificate should reflect these modifications in the section on Limitations

and/or Other Considerations of Use. A separate registration certificate should be issued

for devices which meet the 10 CFR 34.20 requirements. (Section 2.1)
Massachusetts Follow-Up Final Report Page 7

3. The review team recommends that in the interest of national consistency, and where

practical, the RCP closely follow the format for documenting product evaluations in SS&D

registry certificates as detailed in NUREG-1556, Volume 3. (Section 2.1)
LIST OF APPENDICES AND ATTACHMENTS

Appendix A SS&D IMPEP Review Team Members

Appendix B Massachusetts Radiation Control Program Organization Charts

Appendix C Status of Recommendations from the Previous Review 

Appendix D SS&D Casework Reviews

Appendix E Incident Casework Reviews

Attachment 1 Massachusetts Comments on the Draft Follow-up IMPEP Report

dated August 15, 2000
APPENDIX A 

SS&D IMPEP REVIEW TEAM MEMBERS

Name Area of Responsibility

Lloyd Bolling, STP Team Leader

Technical Staffing and Training

Ujagar Bhachu, NMSS Technical Quality of Product Evaluation

Program

Michael Stephens, Florida Evaluation of Defects and Incidents

Regarding Sealed Sources and Devices

Duncan White, Region I Periodic Meeting 
APPENDIX B

COMMONWEALTH OF MASSACHUSETTS

ORGANIZATION CHARTS

(ML003736028)

NAMES AND POSITIONS OF CURRENT

SEALED SOURCE AND DEVICE EVALUATION PROGRAM

(Effective 6/21/00)

Dr. Salifu Dakubu, Supervisor

Radioactive Materials Program

Environmental Engineer V

I

I

I

Kenath Traegde, Supervisor

Licensing and SS&D Section 

Environmental Engineer IV

I

I

_____________________________________________________

Agostino Savastano Robert Walker Vacant (7/3/2000) 

 Env. Engineer III Env. Engineer III Env. Engineer III 
Massachusetts Follow-Up Final Report Page C.2

Status of Recommendations from 

the Previous Report

Recommendation 3

The review team recommends that program managers conduct annual field

accompaniments of each inspector to assess performance. (Section 3.2)

Response from December 1998 Periodic Meeting Summary

The Program Director and the Program Supervisor have performed 10 accompaniments in

1998. The remaining inspector will be accompanied within the next two weeks.

Current Status

The Program Supervisor indicated that inspection accompaniments are now performed by the

Materials Inspection Section Supervisor. According to RCP management, the program is meeting

their goal of at least an annual accompaniment for each inspector.

This recommendation should be verified at the next IMPEP review.

Recommendation 4

The review team recommends that, due to current program demands and the projected

increase in workload, program management closely monitor the filling of the RCP

vacancies. (Section 3.3)

Response from December 1998 Periodic Meeting Summary

Since the IMPEP review, the total staffing for the materials program has increased from

seven to 10 individuals. The Program Director stated that RCP has approval to hire four

more individuals in 1999 and is currently pursuing quality candidates for these positions.

Current Status

The review team noted that the RCP has filled vacant positions in the program with quality

candidates with a combination of individuals from other government agencies, private industry,

and local universities to meet their program demands, particularly in the area of SS&D. The

program had one vacancy, but a candidate for this position was selected and began work on July

3, 2000. 

This recommendation should be closed at the next IMPEP review.
Massachusetts Follow-Up Final Report Page C.3

Status of Recommendations from 

the Previous Report

Recommendation 5

The review team recommends that the Commonwealth manage the training program to

ensure that staff receive required training courses to fulfill RCP qualification requirements

for inspectors and license reviewers. (Section 3.3)

Response from December 1998 Periodic Meeting Summary

RCP maintains a training qualification record for its staff that includes basic, specialized

and advanced training areas or courses for inspectors, license reviews and sealed source

and device (SS&D) reviewers. The Commonwealth also contracted a radiography course

held in November 1998 through one of its licensees (Amersham).

Current Status

The review team examined the training records for new employees and noted that the RCP

maintains excellent records of each individual’s training received, inspection performed or

accompanied, or licensing actions reviewed. 

This recommendation should be closed at the next IMPEP review.

Recommendation 6

The review team recommends that the RCP provide written periodic feedback on the

disposition of allegations to allegers in accordance with Commonwealth procedures. 

(Section 3.5)

Response from December 1998 Periodic Meeting Summary

RCP has received four allegations this year, two of which were anonymous. Known

allegers were provided periodic written feedback regarding the actions taken by RCP to

resolve their concerns.

Current Status

The review team discussed the RCP’s allegation program with their allegation coordinator and

reviewed a select number of files. Written periodic feedback on the disposition of the allegations

back to the allegers was noted in all files reviewed by the team. Since the December 1998

Periodic Meeting, the NRC referred five allegations to the RCP for their action. All referred

allegations were investigated and all but one has been closed. The remaining open allegation

involved an extensive investigation and enforcement action by the RCP and is currently

undergoing final management review for closure. 

This recommendation should be closed at the next IMPEP review.
APPENDIX C

STATUS OF RECOMMENDATIONS FROM THE PREVIOUS REVIEW

Recommendation 1

The review team recommends that initial inspections of licensees be performed within six

months of the licensee’s receipt of licensed material, within six months after

commencement of licensed activities, or within one year of license issuance, whichever

comes first, consistent with IMC 2800. (Section 3.1) 

Response from December 1998 Periodic Meeting Summary

Since the last review, RCP has issued approximately 30 new licenses with nearly all

licensees inspected within six months. Within six months of license issue, RCP staff calls

the licensee to determine if licensed activities have commenced and an inspection is

conducted.

Current Status

RCP indicated that they continue to perform initial inspections of licensees within six months of the

receipt of licensed material, within six months after commencement of licensed activities, or within

one year of license issuance, whichever comes first. Initial inspections are announced.

This recommendation should be verified at the next IMPEP review.

Recommendation 2

The review team recommends that the Commonwealth increase the number of reciprocity

inspections to better evaluate the health and safety implications of out-of-state companies

working in Massachusetts. (Section 3.1)

Response from December 1998 Periodic Meeting Summary

The RCP has performed approximately 15 to 20 reciprocity inspections this year. To

facilitate the performance of reciprocity inspections, an individual on the materials staff is

assigned on a weekly basis to review incoming reciprocity requests for possible

inspections.

Current Status

The RCP uses NRC’s reciprocity inspection goals outlined in Inspection Manual Chapter 1220.

The Program Supervisor indicated that the number of reciprocity inspections RCP performs

exceeds these goals.

This recommendation should be verified at the next IMPEP review. 
ATTACHMENT 1

MASSACHUSETTS COMMENTS ON DRAFT FOLLOW-UP

IMPEP REPORT DATED AUGUST 15, 2000

(ML003745309)