ML20191A059

From kanterella
Jump to navigation Jump to search
Comment Resolution Document SA-106
ML20191A059
Person / Time
Issue date: 01/09/2020
From:
Office of Nuclear Material Safety and Safeguards
To:
Robert Johnson
Shared Package
ML20183A152 List:
References
SA-106
Download: ML20191A059 (3)


Text

Comment Resolution Document Summary of Comments for Interim SA-106, The Management Review Board Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC-20-005, January 9, 2020 Comment No.

Source Location Comment Accepted Remarks 1

NJ IV.C.1 I thought if there were no issues, there would not be an MRB for a periodic meeting. Should we say that here?

Yes You are correct. If there were no issues, then typically there would not be a need for an MRB. We will add

, as appropriate. to the end of the sentence, thereby providing flexibility to be consistent with criteria provided in SA-116, identifying the circumstances when a periodic meeting would be required to have an MRB.

2 NJ IV.G.1 Could specify the Chair-Elect position since it is in our bylaws.

Yes Text modified to specify the Chair-Elect. Also made conforming changes throughout the document.

3 NJ IV.G.2 What criteria? In I. below?

Partial Criteria are provided in V.B.1.b and V.B.2.c, as augmented. Modified Section IV.G.2, to point to criteria provided in V.B.3, and modified Section IV.G.2 to further clarify the criteria.

4.a CO IV.G.3 Section IV.G.3 has a typo, "recommendations".

Yes Corrected.

4.b NJ IV.G.3 Typo: recommendations needs to be spelled correctly Yes Corrected.

5 NJ Last sentence in V.A Does this mean we dont need to have one if everything is good?

No Similar to NJ Q1, the existing language provides the flexibility to not have on if everything is good.

6 NJ Last sentence in V.D.1 What if all the IMPEP team members and MRB members disagree with the Chair?

No The MRB Chair is the statutory NRC decision-maker. The MRB Chair will objectively weigh input from the MRB Members, the IMPEP Team, and the Agreement State Program in order to make a fair and equitable (statutory) regulatory finding.

7 NJ Last sentence in V.D.2 Why isnt probation applicable to NRC programs?

No NRC Program weakness(es) will be addressed immediately, upon identification, by Senior NRC management, rather than waiting for the next IMPEP.

8 CO V.E.1 Page 9: E.1. The Notice Of Appeal template should be included as an appendix.

Partial Going to post all templates to the State Communications Portal.

9 CO V.E.3 E.3. The MRB Chair should be required to provide testimony or feedback from IMPEP team and MRB members (including AS staff) as part of his response. As a result this should be extended to a 30 day response.

Partial The time frame was extended from 14 calendar days to 30 calendar days. The MRB Chairs response to the appeal will include the necessary justification for their conclusions.

10 NJ V.F I dont understand what this means. Who writes letters of support and what is their purpose? Is it only in these 2 instances where Letters of intent are described in SA-SA-116, Periodic Meetings Between IMPEP Reviews. Letters of support

letters of support are required?

Recommended?

may be issued if areas of declining program performance are identified by the RSAO during a periodic meeting. The intent of the letter is to inform higher-level state government officials of the provisions agreed to in the States 274b. Agreement with the NRC and identify the specific items needed to support that agreement. If the MRB Chair directs that a letter of support be issued, staff will draft the letter of support to be signed by the appropriate level of NRC management commensurate to the addressee.

ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT: ML20191A059