ML20184A180

Comment Resolution Document SA-107

ML20184A180
Person / Time
Issue date:	12/09/2019
From:	Office of Nuclear Material Safety and Safeguards
To:
Beardsley F
Shared Package
ML20183A152	List: ML20183A205 ML20184A178 ML20184A179 ML20184A180 ML20189A007 ML20191A059 ML20204A816 ML20224A143 ML20258A063 ML20274A160
References
SA-107
Download: ML20184A180 (3)

Text

Comment Resolution Document Summary of Comments for Interim SA-200, Compatibility Categories and Health and Safety Identification for NRC Regulations and Other Program Elements Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC-19-078, December 9, 2019 Comment Source Location Comment Accepted Remarks No.

1 CO Various It is quite difficult to piece together the actual list of Program YES The Program Elements table elements and their compatibility. Especially when it comes to previously listed as Appendix A can guidance documents and other non-regulatory program now be found on the website. It elements. The procedure suggests that they are listed in a table was revised to contain both in appendix A but that has been deleted. It does however regulatory and non-regulation indicate that A current section-by-section summary of the program elements, to indicate the compatibility and health and safety categories of regulations in adequacy/compatibility category Title 10 of the CFR can be found on the NMSS websites and give examples.

Regulation Toolbox1 but there is no reference to non-regulatory program elements. A list of AGREEMENT STATE PROGRAM Also another table listing regulation ELEMENTS 2015- PRESENT is found in the toolbox at: and non-regulation program https://scp.nrc.gov/regulationtoolbox/Program_Elements_table.pdf elements that the Agreement states may need to implement However, these have an implementation date for AS for some depending on the compatibility items but none for others and does not indicate Compatibility category has been added to the category. Some of these have implementation due dates for same site. This table lists those those items that are compatibility D as described within the documents issued to the documents themselves. This is a mess. It is difficult at best to Agreement State, their decipher the expectations of the NRC in regard to these. compatibility category and date of implementation, if applicable.

Even though certain items within the documents are a D compatibility; the overall procedure may be a C compatibility.

2 CO General While we understand that the revision and authoring of these Yes Efforts have been taken to address procedures is a multi-organization process involving many these differences.

individuals, when looking at the collection there seems to be a multitude of different voices and writing styles and as a result it lacks uniformity.

3 CO General Specifically, it appears that many of the appendices address Yes Please note that most of the common items and it would be appropriate to use common titles appendices in the interim for the appendices and to keep them in a common order if procedures (i.e., the Examples of possible. Less than Satisfactory Findings of Program Performance from the common and non-common IMPEP performance indicators; the casework summary sheets, and inspector accompaniment summary sheets, will be posted on the IMPEP toolbox at:

https://scp.nrc.gov/impeptools.html) have been removed and will be placed on the SCP Web site to allow for dynamic revisions.

4 CO General Additionally, during the drafting process the idea of consistency YES Procedure revised accordingly.

within these procedures regarding the phrase "Agreement State or NRC..." vs. "NRC or Agreement State..." was discussed. This should be made uniform throughout the procedures.

5 NJ General: Applies Follow-up should be hyphenated. Yes Procedure revised accordingly.

to all Interim SA procedures ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT: ML20184A179