ML20191A059

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: ML20183A205 ML20184A178 ML20184A179 ML20184A180 ML20189A007 ML20191A059 ML20204A816 ML20224A143 ML20258A063 ML20274A160
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 Source Location Comment Accepted Remarks No.

1 NJ IV.C.1 I thought if there were no issues, there would Yes You are correct. If there were no not be an MRB for a periodic meeting. Should issues, then typically there would not we say that here? 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 Yes Text modified to specify the Chair-is in our bylaws. 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, Yes Corrected.

"recommendations".

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

correctly 5 NJ Last Does this mean we dont need to have one if No Similar to NJ Q1, the existing sentence everything is good? language provides the flexibility to in V.A not have on if everything is good.

6 NJ Last What if all the IMPEP team members and No The MRB Chair is the statutory NRC sentence MRB members disagree with the Chair? decision-maker. The MRB Chair will in V.D.1 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 Why isnt probation applicable to NRC No NRC Program weakness(es) will be sentence programs? addressed immediately, upon in V.D.2 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 Partial Going to post all templates to the should be included as an appendix. State Communications Portal.

9 CO V.E.3 E.3. The MRB Chair should be required to Partial The time frame was extended from provide testimony or feedback from IMPEP 14 calendar days to 30 calendar team and MRB members (including AS staff) days. The MRB Chairs response to as part of his response. As a result this should the appeal will include the necessary be extended to a 30 day response. justification for their conclusions.

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

letters of support are required? may be issued if areas of declining Recommended? 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