ML20204A816
| ML20204A816 | |
| Person / Time | |
|---|---|
| Issue date: | 12/18/2019 |
| From: | Ohara J NRC/NMSS/DMSST/ASPB |
| To: | |
| O'HARA J | |
| Shared Package | |
| ML20183A152 | List: |
| References | |
| SA-101 | |
| Download: ML20204A816 (3) | |
Text
Comment Resolution Document external comments Summary of Comments for Interim SA-101, Reviewing the Non-Common Performance Indicator, Status of Materials Inspection Program Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC-19-079, December 18, 2019 Comment Source Location Comment Accepted Remarks No.
1 J. III Background In order to determine this Yes Yes, it is true. However, its not Goodman; information, the capability for background information (nor is it NJ maintaining and retrieving particularly useful sentence, in statistical data on the status of an retrospect). Another commenter inspection program must exist. made a similar point and I believe I Why was this [sentence] deleted, have satisfied your point(s) in isnt this true? section V.B.2 a. & b. Procedure revised accordingly.
2 J. V. B. 3. e. Highlighted the words a Yes The reviewer would use the Goodman; reasonable attempt I dont frequencies in IMC 2800 . If the AS NJ Page 5 of 9 understand what would prevent a Program uses different definitions, reviewer from using the they will be noted in the IMPEP frequencies in MC2800. report. Appendix B Question 5 provides additional guidance.
Procedure revised accordingly.
3 J. General If the reviewer is just using a No Agreed. However, the reviewer Goodman; subset of inspection reports issued would not be using a subset of NJ during the review period and it is of inspection reports to make this concern, e.g. 60% are over the determination. The reviewer would Programs time period, then the have to use all the inspection Program should be given a chance reports issued during the review to produce all inspection report period to make an objective statistics for the review period. The judgement regarding overall selected reports may have not performance. Appendix B Q7 been representative of the addresses this question. No Programs overall performance. change made as a result of this comment.
4 J. Appendix A What if they still do not have N/A For licensees which do not Goodman; 1.d. material after 18 months? possess licensed material or have NJ not engaged in principal activities, they would be inspected in accordance with IMC 2800 section 05.02 Initial Inspection section b.
page 14. No change made as a result of this comment.
5 J. Appendix A 2 Inspections are always compared Yes Comment Incorporated. Procedure Goodman; to NRC Priorities in IMC 2800 revised accordingly.
NJ rather than the Programs internal inspection frequencies 6 P.Peterson; General While we understand that the Yes Efforts have been taken to address CO revision and authoring of these these differences.
procedures is a multi-organization process involving many 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.
7 P.Peterson; General Specifically, it appears that many of Yes Please note that most of the CO the appendices address common appendices in the interim items and it would be appropriate procedures (i.e., the Examples of to use common titles for the Less than Satisfactory Findings of appendices and to keep them in a Program Performance from the common order if possible. 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.
8 P.Peterson; General Additionally, during the drafting Yes Comment Incorporated. Agreement CO process the idea of consistency State comes first. Procedure within these procedures regarding revised accordingly.
the phrase "Agreement State or NRC..." vs. "NRC or Agreement State..." was discussed. This should be made uniform throughout the procedures.
ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT: ML20204A816