ML20149L218
| ML20149L218 | |
| Person / Time | |
|---|---|
| Issue date: | 04/17/1997 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Scott Moore NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20149J917 | List: |
| References | |
| NUDOCS 9707310198 | |
| Download: ML20149L218 (18) | |
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UNITED STATES s>* "C%,$**
., 4 NUCLEAR REGULATORY COMMISSION '
3 $ REGloN IV .
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i 611 RYAN PLAZA DRIVE, SUITE 400
+9 +0[ AR LINGTON. TEXAS 760114064 APR l 71997 !
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', MEMORANDUM TCu Scott Moore, Chief (MS: 8F5) !
Programmatic Safety and Procedures Section i
O rati,ons ran h IMNS ,
FROM: In Ross . carano, ir ctor i Division of Nuclear Materials Safety, t
SUBJECT:
COMMENTS ON THE IMPEP NON-COMMON INDICATORS FOR THE SDMP AND THE REGIONAL FUEL CYCLE PROGRAM Donald Cool's memo of March 5,1997, requested comments on the subject non-common performance indicators. Per the request, the enclosed comments are being sent to you. ,
] Attachment 1 contains comments on the Fuel Cycle Program, and Attachment 2 contains comments on the Site Decommissioning Management Plan.
l We appreciate the opportunity to provide these comments.
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Enclosures:
As stated I l
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ATTACHMENT 1 l
RIV COMMENTS REGIONAL FUEL CYCLE PROGRAM
' As a general commeht/we are in agreement with the indicators chosen for evaluation and i
- the evaluation criteria used. The description of the indicators are clear, and the evaluation criteria amply distinguishes between the levels of performance. However, RIV has a serious reservation as described in Comment 1 below and a less significant comment, as provided in 2, below.
- 1. The inspection program for fuel facilities is jointly managed by HQ and the regions. ,
Chemical Safety, MC&A and much of the criticality safety program are now I
- inspected by HQ. Additionally, the master schedule for the inspection program is controlled by HQ, cross inspections between regions and joint inspections with HQ i
have become common, and licensee performance reviews are a joint HQ and regional effort. In effect, the inspection program for the fuel cycle facilities has evolved into a i much more centralized process with close HQ involvement and oversight. As such, ;
the objectives of the fuel cycle non-common performance indicators may need to be !
. re-evaluated. A mere review of a region's performance will only provide limited and
, perhaps misleading conclusions regarding the overall effectiveness of the NRC's fuel i facility inspection program. The past practice of the region having sole inspection responsibility with periodic reviews by HQ becomes somewhat clouded with the I arnalgamation of the inspection prograrn. Region IV requests that this issue be considered and factored into the fuel cycle IMPEP process.
- 2. Several places in the indicators and evaluation criteria imply 1 hat the region should be j maintaining readily retrievable data banks for information to be used in the LPR process. For example, the statement appears under " Status of Fuel Facility inspection Program": "There should be a means for maintaining and readily retrieving regional performance information for each facility (e.g., site issues matrices, incident analysis summaries, enforcement histories) to support . . . LPR," and under
- " Technical Quality of Inspections"
- ". . . the results of inspections should be sommarized and appropriately documented for later references . . . ." The evaluation criteria key results on the existence of such data. Manual Chapter 2604, " Licensee
! Performance Review," does not require specialized data summaries be maintained for the LPR process, and it is inappropriate to impose'such a requirement by the IMPEP process. The creation of special summaries of inspections, incident summaries, and site issues matrices would impose a significant administrative burden on the Region.
All such data is already captured in inspection reports, the IFS System, Preliminary i
Notification files, etc., and it should not be necessary to maintain separate data banks. RIV requests that all such references to this matter be deleted from the document.
f ATTACHMENT 2 i
i RIV COMMENTS I REGIONAL SDMP PROGRAM l We agree in generaf with Parts ll and lll relating to the non-common performance indicators 1
for Site Decommissioning Management Plan. In the case of Region IV, all project management for Region IV SDMP sites rests in Headquarters. Because of this, several of the performance indicators such as Decommissioning Plan reviews, license review work,.
financial assurance, and SDMP milestones are not directly applicable to the Region's activities. The Region's activities on these sites are related mostly to inspections and surveys. Nevertheless, regional staff are responsible for maintaining a close working relationship with the project managers and their management to ensure coordination of regional SDMP related activities. Similarly, the regional inspection staff routinely provide comments and concurrence on review activities undertaken by the project office. These
- coordination activities between the Region and the project offices do not appear to be
- captured by any of the performance indicators.
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1 ATTACHMENT 3 t
1 RESOLUTION OF REGIONAL COMMENTS I 1 1 l 1 1
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- Responses to Reaional Comments on IMPEP Non-Common Performance Indicator for Reaional Fuel Cycle insoection Proarams Reaion 1
- 1. On page 7, first full paragraph. Eliminate the word " generally" in the first sentence. ;
Supervisors sho~uld accompany each inspector at least once annually to assess '
performance, provide feedback and maintain the necessary management quality ;
assurance.
Adopted. The word " generally" was removed.
- 2. On page 7, the fourth paragraph. When inspections are conducted by teams, there can only be one team leader... Recommend reword...
Adopted. The paragraph was reworded to indicate more clearly that at least one member of a group on an inspection visit must be a qualified inspector. I
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- 3. On page 11, first full paragraph. Pending escalated enforcement is generally not a good reason to delay communicating inspection findings to a licensee....
y, Adopted. The example of pending escalated enforcement was removed, but there is still provision for delays for legitimate documented reasons.
- 4. On page 17, last paragraph. Eliminate the word "nearly" in the first sentence... ;
4 Adopted. The word "nearly" was removed.
l Reaion 2 We recommend two enhancements"
- 1. Define " appropriate adjustments" to inspections in fuel cycle inspection program.
4 Criteria 1.' The satisfactory rating and satisfactory with reenmmendations rating should allow for changes to IMC 2600 due to emphasis to respond to events and reduction based on Licensee Performance Reviews [ sic).
Adopted. The following text has been added to the performance indicator to specify how the adjustments are made:
"Thessladjustinests'We fedeifallpldstsmined bpTechss6ssolof Hesdqdarters endiegional'manasementidurins:the Lic'ensee
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PerformancA LRevied(LPR) brocessi ofin response to facility events orfconditions. betwesn LPRs/
- 2. There are semi-quantitative descriptive words which appear throughout the document. These words, such as, " frequently," " periodically," " adequately,"
" prompt," etc., could become a basis for misunderstandings. To avoid such misunderstandings, we suggest that an attempt be made to provide definitions or bounds for them.
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Not adopted. Terms such as " frequently," " periodically," " adequately," " prompt,"
etc., currently are used throughout NRC Management Directive (MD) 5.6. The alternative to using these approximate terms is to use quantitative terms such as "95%," "within three weeks," etc. These terms may be more specific, but they imply a process of quantificai ion or measurement that may be even more difficult to justify in terms of effort or sig1ificance. Also, it would be difficult to adopt specific numerical values that would be appropriate for a wide variety of different cases and circumstances. Exceptions could not easily be made to deal with unusual situations, and where numbers were small. The final arbiter of possible confusion in-the use of the evaluation criteria would be the Management Review Board, who would hear the views of both the region and the IMPEP Review Team, interpret the significance of any specific numerical measures considered, and resolve any misunderstandings. q Recion 3 General
- 1. ...Part 11 (page 6) recognizes the difficulties in scheduling and paying for specialized courses for the small number of fuel facilities inspectors who may need unique )
training at any one time. The same sort of consideration should be included in the '
Part 111 Evaluation Criteria for staff training and qualification. j Adopted. The evaluation criteria in Part lil have been amended to reflect such training difficulties. !
- 2. Both part il and Part 111 should, in addressing response to incidents ... make references to regional capabilities to respond in coniunction with NMSS. These are ;
mutual responsibilities; the region should be judged on holding up its end.
Adopted. Appropriate lar.guage has been placed in Parts ll and lll to reflect the fact that the region acts in conjunction with Headquarters to respond to incidents.
Editorial
- 1. Typo, Adopted
- 2. Typo, Adopted
- 3. Page 9, suggest " appropriately updated" vs. " frequently updated" Adopted
- 4. Page 10, first full sentence: replace with "There are few differences inspections scheduled and completed and what is currently intended for each of the facilities."
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Adopted. The subject sentence was replaced by, "There are few differences
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- 5. Typo, Adopted l
- Reaion 4 i
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- 1. The inspection program for fuel cycle facilities is jointly managed by HQ and the
- regions... In effect, the inspection program for the fuel cycle facilities has evolved into a much more centralized process with close HQ involvement and oversight. As
, such, the objectives of the fuel cycle non-common performance indicators may need to be re-evaluated. A mere review of a region's performance will only provide limited and perhaps misleading conclusions regarding the overall effectiveness of the NRC's fuel facility inspection program... Region IV requests that this issue be j considered and factored into the fuel cycle IMPEP process.
4 Partially adopted. FCOB only partially agrees with the statement that a review of the region's performance will only provide limited and perhaps misleading
. conclusions regarding the overall effectiveness of the NRC's fuel facility inspection program. The regional IMPEP review is not intended to draw conclusions about the overall program, just the particular contribution made by the subject region. The ;
7 wording of the general statement in Part 11 of the indicator has been modified to !
! better reflect this, i ;
i "... the presence of these (satisfactorily implemented) siements I l in a regional fuel cycle inspection program should provide assurance to senior NRC management, and to the public, that the isgional program is effective."
The purpose of IMPEP originally was to use common performance indicators to I evaluate both the regional NRC materials programs and those of the Agreement States on a comparable basis. The non-common indicators were added to evaluate the performance of the remaining aspects of the regional programs under NMSS oversight that were not in common with Agreement State programs. It is true that a self-assessm'ent program by NMSS to review the Headquarters portion of the fuel facility inspection program may shed more light on the performance of the fuel cycle inspection program overall, but such a program is beyond the scope of IMPEP. The current non-common performance indicator for the fuel cycle inspection program attempts to focus on only the region's performance as part of an integrated program across all regions and Headquarters. The entire Appendix on the non-common performance indicator for regional fuel cycle inspection programs has been reviewed
- to ensure that it is only regional performance that is at issue in an IMPEP review, so that no region will be held responsible for actions or decisions affecting the region's fuel cycle inspection program not its own.
- 2. Several places in the indicators and evaluation criteria imply that the region should be maintaining readily retrievable data banks for information to be used in the LPR process.... Manual Chapter 2604, Licensee Performance Review," does not require
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specialized data summaries be maintained for the LPR process. The creation of L
special summaries of inspections, incident summaries, and site issues matrices would impose a significant administrative burden on the Region. All such data is already captured in inspection reports, the IFS system, Preliminary Notification files, etc., and it should not be necessary to maintain separate data banks. RIV requests that all such references to this matter be deleted from the document.
Partially adopted. The content of the non-common performance indicator for regional fuel cycle inspection programs should not be construed as requirements.
The indicator describes the essential elements of an effective fuel cycle inspection program on a generic ba:,!s. Region IV is, in particular, a special case in that it has only one fully operational fuel cycle facility, and one fuel facility inspector.
Therefore, the task of organizing raw data to develop summary information regarding fuel facility licensee performance, at the time an LPR is conducted, would be less onerous in Region IV than it would be in Regions 11 and Ill. In general, raw data, such as inspection reports, Preliminary Notification and Morning Report files, the IFS system, etc., do not capture the expert judgement that could be assembled in summaries of regional performance information, such as site issues matrices, that are in fact maintained in other regions, and considered to be a good practice, though not specifically required in IMC 2600 or 2604. Such summaries help to collect the informed opinions of several different inspectors who may visit a particular facility at different times over a two year period between LPRs. At the time an LPR is to be conducted, these inspectors may be unavailable, and the task of constructing a summary review of the licensee's performance based on raw data alone could be onerous and result in an untimely LPR.
The performance indicator subelement for " Status of Fuel Cycle inspection Program" has been modified to clarify that specialized summary information files (e.g., site issue matrices, etc.) are not required, but that they may be practical alternatives in some situations. Since the IMPEP review is focused on regional performance, Region IV would not be penalized if it were demonstrated through good performance that the LPR for its lone facility could be conducted satisfactorily without its having had to maintain specialized summary information files on licensee performance.
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DWM RESPONSES TO COMENTS ON THE DRAFT i
IMPEP.NON-COMON PERFORMANCE INDICATORS FOR THE SDMP i
p REGION I COMENTS I Region I did not comment on the SDMP non-comon performance indicators t -REGION II COMMENT:
f "There-are semi-quantitative descriptive words which appear throughout the document. These words, such as, " frequently," " periodically," " adequately,"
" prompt," etc. could become a basis for misunderstandings. To avoid-such
- misunderstandings we suggest that an attempt be made to provide definitions or
- bounds for them." !
! DWM RESPONSE: Initially, DWM agreed with the Region's coments. However,
, discussions with NMSS indicated that it was more appropriate to provide the i staff with the flexibility to evaluate the SDMP consistantly with other IMPEP i Common and Non-common indicators. Therefore, we have revised the evaluation
- criteria for the SDMP program to be consistant with other IMPEP program i elements.
- REGION III COMENTS
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" Accountability for SDMP project management functions is assigned to-the Division of Waste Management; Part 11 should limit its focus [to] those 1
-responsibilities assigned to the Region."
DWM RESPONSE: As stated in NRC Inspection Manual Chapter 2605 (Decomissioning Procedures for Fuel Cycle and Materials Licensees) "The responsibility for implementing the decomissioning proaram at nuclear facilities resides with the NRC regional office in which the facility is located, or NMSS, as appropriate. The lead office has the responsibility for coordir.ating the implementation of the decommissioning program at the facility within NRC. In general, the regional office will assume lead responsibility for most licensed sites undergoing decommissioning. NMSS will provide overall program and policy direction for the regional offices for decomissioning facilities. NMSS will also provide oversight guidance and site-specific support to the regions for all decomissioning facilities to ensure that licensees are conducting the decomissioning in a consistent manner. NMSS mn (emphasis added). assume oversight responsibility for sites listed on the SDMP, or others, after consultation with the regional office." For those SDMP sitos where the Regional office has lead responsibility for coordinating the management of the decommissioning project within NRC, the performance of the Regional SDMP program will be evaluated using the Performance Indicators in Part'II. For SDMP sites where DWM has lead responsibility for the
' decommissioning project, only those functions assigned to the Region (e.g.,
inspections) will be evaluated using the Performance Indicators in Part II.
REGION III EDITORIAL COMMENTS:
DWM staff agrees with the Region's suggested revisions.
REGION IV COMMENT:
"We agree in general with Parts II and III relating to the non-common performance indicators for [the] Site Decommissioning Management Plan. In the case of Region IV, all project management for Region IV SDMP sites rests in Headquarters. Because of this, several of the performance indicators such as Decommissioning Plan reviews, license review work, financial assurance, and SDMP milestones are not directly applicable to the Region's activities. The Region's activities on these sites are related mostly to inspections and surveys. Nevertheless, regional staff are responsible for maintaining a close working relationship with the project managers and their management to ensure coordination of regional SDMP related activities. Similarly, the regional inspection staff routinely provide comments and concurrence on review activities undertaken by the project office. These coordination activities between the Region and the project offices do not appear to be captured by any of the performance indicators."
DWM RESPONSE: DWM believes that coordination of decommissioning of SDMP sites with Regional staff is critical to ensuring that sites are decommissioned safely and in accordance with applicable NRC regulations and the approved decommissioning plan. The Regional staff routinely provide Prcject Managers with invaluable information throughout the decommissioning process, through reviews of proposed decommissioning actions, responding to emergencies, inspections and surveys.
NRC Inspection Manual Chapter 2605," Decommissioning Procedures for Fuel Cycle and Materials Liccnsees" recognizes that coordination between HQ and Regional staff ic vitil to the successful completion of the decommissioning project and the Performance Indicators specifically cite adherence with requirements in Manual chapter 2605 in evaluating SDMP programs. The Manual Chapter places the responsibility for ensuring that all aspects of the decommissioning project are appropriately coordinated, both within and without NRC, on the' License Reviewer / Project Manager for the project. As such, DWM believes that it is appropriate te evaluate this as part of the evaluation of the lead office for the decommissioning project.
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j ATTACHMENT 4
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COMMENTS AND RESPONSES TO THE
, NON-COMMON PERFORMANCE INDICATORS
! LOW-LEVEL RADIOACTIVE WASTE
- DISPOSAL PROGRAM
- SEALED SOURCE AND DEVICE j DISPOSAL PROGRAM J
- URANIUM RECOVERY PROGRAM
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SUMMARY
OF COMMENTS ON NON-COMMON PERFORMANCE INDICATORS Low-level Radioactive Waste (LLRW) Discosal Proaram Sent to the Agreement States for Comment: June 3,1996 (SP-96-059)
Comments Received:~ ~ lilinois, 7/30/96 Texas (TNRCC),8/9/96 Kentucky, 6/6/96 I
Response to/ Resolution of Comments: !
l KENTUCKY SUPPORTED LLRW NON-COMMON PERFORMANCE INDICATOR - NO COMMENTS l
RESPONSE TO ILLINOIS' COMMENTS ON IMPEP LLRW NON-COMMON PERFORMANCE j INDICATOR - '
Comment: ,
1 The only area that could be problematic is the second area, technical sta1fing and training. l The training requirements are very unique and subject to a wide variety of interpretations.
In NUREG-1274, the NRC estimated that twenty-two technical disciplines were required for the review of a low-level radioactive waste disposal facility license application. Many of these disciplines will be satisfied by the regulatory agency by using contractual staff and/or personnel from other regulatory agencies. A strict enforcement of provisions contained in the draft document such as "The staff should be afforded opportunities for training that are consistent with the needs of the low-level waste program, such as attendance at counterpart meetings, university programs and national conventions" (page 2 of the draft document in the section entitled Technical Staffing and Training) could be subject to a wide degree of interpretation by the review team. Whether or not a contract geologist, for example, is afforded the opportunity to participate in a national convention would probably have little to do with the effective licensing review of an application. It appears that a reasonable interpretation of the staffing and training provisions prevailed l during the North Carolina IMPEP review, but the potential for problems in this area exists as written in the draft document.
Response
The IMPEP review process is to be performance based and not prescriptive, therefore, we agree whether a contact geologist is afforded the opportunity to participate in a national convention may have little to do with effective licensing review. The NRC/OAS training working group's results will also be factored into this area with respect to training.
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Comment:
The only other area of note in the draft document concerns editorial problems in Part Ill, Evaluation Criteria. For example, "is" should be changed to "are" in the last sentence on l page 1. in the paragraph beginning with " Pre-licensing interaction." Another example can l be found on page 2, fourth bullet, the words " low-level" should be deleted. There are several other obvious, er,rors that should be corrected before finalizing the document.
Response
The changes have been made in the revised document.
RESPONSE TO TEXAS' (TNRCC) COMMENTS ON IMPEP LLRW NON-COMMON PERFORMANCE INDICATOR Comment 1:
Part II: In item 1 (status of LLW disposal inspection), there is a statement that siting and construction phase are essential to ensure the facility is being sited and constructed in accordance with regulatory requirements and good safety practices. Clarification of the meaning of " siting inspection" is needed. Is this referring to whether facilities are actually being constructed at the specific locations applied for and in accordance with specifications authorized in the license? Or, is this referring to the evaluation of the suitability of the proposed site during the license application phase? If the latter is intended, then this should more appropriately be made part of item 3 relating to licensing actions.
Response
The revised document has been revised to clarify that pre-licensing inspections during siting and construction phases are essential.
Comment 2:
Part II: In item'3 (technical quality of licensing actions), second paragraph, the last sentence regarding examination of ongoing requests may require clarification. Is the intent that licensing actions that are in progress will on!v be reviewed if there are some particular health and safety implications and not otherwise?
Response
It is the intent to examine the State's performance in licensing. Normally, those licensing actions that are not health and safety matters, would not necessarily be reviewed.
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4 Comment 3:
Part lil. Under Satisf actorv section, third paragraph, there is a statement " Reviews of i amendments and renewal applications demonstrate thorough analysis of a licensee's '
inspection and enforcement history." This statement should be modified by adding the words "if applicable" at the end. With respect to license amendments, there may be instances of routine amendments for which analysis of a licensee's inspection or enforcement history is not relevant and will not be done. A state regulatory program
- should not be put in the position of having to do unnecessary analysis of inspection and enforcement history when it is not applicable to an amendment, in order to fulfill NRC's evaluation criteria.
Response
This change has been made in the revised document. ;
Comment 4:
Part 111. Under Satisf actorv section, fourth paragraph, there is a statement " Supervisors accompany nearly allinspectors on an annual basis." Clarification of this is needed. For example, does the accompaniment have to be on a low-level waste disposal license inspection? If so, and an inspection is required only annually by the NRC Inspection Manual Chapter 2800, then in effect, the supervisor would have to accomoany on each low-level disposal facility inspection. Texas statutes require a resident inspector at the proposed Texas LLW disposal facility, and periodic accompaniment by the supervisor would be possible. In general, however, we suggest that annual accompaniment of an inspector on inspections of any other types of licenses should be satisf actory to fulfill the evaluation criteria for the LLW program.
Response
For the resident inspector, an annual accompaniment would be expected. For other inspectors, an annual accompaniment en other complex types of licenses would be satisfactory. Note, an inspector qualified for medical inspections may not be an acceptable inspector for a low-level waste disposal facility, where an inspector with uranium recovery qualifications would be.
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4 Sealed Source and Device Evaluation Proaram Sent to the Agreement States for Comment: January 5,1996 (SP-96-002)
Comments Received: Illinois, 2/27/96 Washington, 2/7/96 Response to/ Resolution'of Comments:
I RESPONSE TO ILLINOIS' COMMENTS ON IMPEP SS&D NON-COMMON PERFORMANCE INDICATOR Comment A:
, Regarding item 1 of your letter, the second paragraph of the letter to which this is attached 4
addresses our concerns regarding the non-common performance indicators for SS&D
- programs. The Department believes that these additional indicators are unnecessary. A
. listing of standards, SRP's and guidance documents that must be used to evaluate SS&D
- programs against, would be much more useful tools for evaluating performance.
Response: (Letter sent to Illinois on July 2,1996)
- j. The draft non-common performance indicator - Sealed Source and Device Evaluation Program defines the criteria for evaluating the performance of Agreement State programs in j this area. It is directed at helping ensure consistency in the scope and findings of IMPEP team reviews. The IMPEP review teams will use current standards, SRPs and guidance documents as tools in evaluating the performance of a State program in this area, but the
- primary focus will be on program performance. We recognize the potential for redundancy
. in some areas such as training and qualifications of staff and we will take that comment l~ along with other comments received and our experience in conducting these reviews into l consideration when preparing final IMPEP procedures. At that time, we will also determine
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the need to revise the IMPEP indicators to clarify all requirements and to eliminate any duplication.
Comment B: ,
in item 2 of your letter, you have addressed Part 21 concerns to a degree. However, you ,
still have not indicated whether or not the states will be held to some portion or all of Part )
21 during these program reviews. Your indicators imply that we will. Department staff was given the same impression at the September workshop.
Response
Per Office of State Programs Procedure B.7 (Revision 1), " Compatibility Categories and Health and Safety identification for NRC Regulations and Other Program Elements:"
The provisions in Part 21 derive from statutory authority in the Energy Reorganization Act, not the AEA, that does not apply 4
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to Agreement States. Therefore, this Part cannot be addressed under either compatibility or adequacy. While it may be argued that there are health and safety reasons to require States to adopt the provisions of Part 21, States may not have the statutory authority to do so.
Comment C: ,
Regarding item of your letter, the Department believes that states generating NARM cheets need to be included in your audit and SRP's. We understand that this material is not under your- jurisdiction, but if these certificates are to serve any useful purpose they must be held to the same standard as other SS&D sheets.
Response
4 We will continue to include NARM cert'ificates in the SS&D database, however, due to the fact that our authority is limited to Atomic Energy Act material and because of resource
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Comment D:
l Regarding item 8 of your letter, you have indicated that inspections of SS&D activities i evaluated in other states would be difficult, However, they could be performed by the
" contracting" state in much the same way that NRC will have to perform inspections in <
states relinquishing SS&D evaluation authority. I j
! Response:
We have no objection to States contracting among themselves in this area provided that the manufacturers'/ distributors' commitments are enforceable by the licensing State. You should note that in States where SS&D authority has been relinquished, the manufacturers /
distributors are directly subject to NRC regulations if they want their products listed in the registry.
RESPONSE TO WASHINGTON'S COMMENTS ON IMPEP SS&D NON-COMMON PERFORMANCE INDICATOR j
Comment 1:
page 1- the first paragraph clearly and appropriately notes that the performance indicators contained herein are to be used to evaluate both Agreement States and the NRC !
Headquarters SS&D programs. However, from this point forward the document only refers to the Agreement States. This should be corrected by specifically mentioning the Headquarters program throughout whenever the Agreement States program is referenced.
(Alternatively, a general reference to "SS&D programs" could be substituted for
" Agreement State programs" in the following references).
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a) page 1, third paragraph, 5th line: "In order to evaluate the performance of Agreement State and NRC Headquarters programs, three areas ..."
t 4 b) page 2, top,4th line: "...as completed by each of the reviewers in the State or NRC Headquarters."
l c) page 3, top, line.1: " States and NRC Headquarters will be evaluated..."
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}" The first paragraph was incorrect and should not have indicated that the NRC Headquarters program would be evaluated against these indicators as a non-common performance
- indicator. At this time, NRC committed to a review of the Headquarters program, but not
. necessarily a review through IMPEP.
4 Comment 2:
- Page 3 -- about the middle of the page this sentence appears
- " Applicable guidance
- documents are followed, unless approval to use alternate procedures is obtained." The i
question is "obtained from whom?" This should be clearly specified.
Response
f Approval to use alternate procedures should be coordinated with management. This
- change has been made in the revised document.
Comment 3:
Page 4 - " Category N" -- this appears out of context. Can you teli me what it is? If it is not applicable, why mention it? I
Response
Category N is included for certain performance indicators where there exist adequate justification for withholding a rating.
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o Uranium Recoverv Proaram Sent to the Agreement States for Comment: October 7,1996, (SP-96-109)
Sent to Regions for Comment: February 4,1997 Comments Received:_ Colorado (11/20/96)
Region IV (2/27/97)
Response to/ Resolution of Comments:
RESPONSE TO COLORADO'S COMMENTS ON iMPEP URANIUM RECOVERY PROGRAM Comment:
i Our only comment is with regard to the need for " maintaining and retrieving statistical data on the status of the inspection program," found on page one of the document, under the section " Status of Uranium Recovery inspection Program." It is unclear what measures need to be tracked. Is it frequency of inspection, number of violations or some other parameter? It is also unclear as to what statistic will be used (e.g. Student's t, or F or some other statistic)? The use of this statistical database needs to be explained and clarified.
Response
This is language consistent with the common indicators which refers to the number of overdue inspections.
RESPONSE TO REGION IV'S COMMENTS ON IMPEP URANIUM RECOVERY PROGRAM Comment:
This is in response to NMSS's memo dated February 4,1997, regarding non-common performance indicators (Part II) and evaluation criteria (Part Ill) for UR. (There was no Part I with the memo.) The only comment we have relates to Part 11, Page 1, Area 1, which states, in part, that the frequency of inspections for production facilities as specified in MC's 2600 and 2801 is yearly. Actually, the NORMAL interval specified is twice per year, and as you know, that has been our practice in Region IV. No other comments.
Response
Part 11 has been revised to clarify that the frequency for these types of facilities is specified in NRC Inspection Manual, Chapters 2600 and 2801, and the reference to a yearly internal has been deleted.
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