ML20214T591
| ML20214T591 | |
| Person / Time | |
|---|---|
| Issue date: | 03/27/1986 |
| From: | Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Hildenbrand P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-10 1789, NUDOCS 8609300348 | |
| Download: ML20214T591 (3) | |
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DISTRIBUTION W1 s/f. (4017 WMGT r/f NMSS r/f REBroning
/86/03/25/EA-REV MBell J0 Bunting PSJustus MWeber & r/f NOTE T0:
Paul Hildenbrand, Project Manager PDR Basalt Waste Isolation Project, WMRP Ncoleman Division of Waste Management FROM:
Michael F. Weber, WMGT Division of Waste Management
SUBJECT:
COMMENTS ON FINAL EA. STANDARD REVIEW PLAN As you requested in the weekly BWIP team meeting on March 26, 1986, enclosed please find my comments on the Standard Review Plan (SRP) for Final Environmental Assessments (NWPA) for candidate HLW repository sites. Several of my comments suggest revisions to the SRP, which should contribute to the final EA review process.
Please contact me if you would like to discuss my comments.
Michael F. Weber Geotechnical Branch Division of Waste Management
Enclosure:
Comments on the EA SRP cc: MFliegel, WMGT PJustus,.WMGT WM Record File WM Project
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1 COMMENTS ON " STANDARD REVIEW PLAN FOR FINAL ENVIRONMENTAL ASSESSMENTS" 1.
The Standard Review Plan (SRP) is ambiguous in its discussion of the scope of the review of DOE's Final Environmental Assessments.
' Individual descriptions of the review scope conflict with one another.
In addition, the SRP refers to an undefined adjective -
" level-of-effort".
The SRP should be revised to state clearly the scope and objectives of the FEA review.
Sections 3 -and 4 of the SRP describe the objectives and scope of the FEA review, respectively. These objectives include (pp. 4 and 5):
To document major concerns with DOE's responses to NRC's major comments and certain detailed comments.
- .To document major concerns with new data and information resulting from revisions / additions to the DEAs by DOE.
- To document major concerns with changes to findings and supporting material in the FEAs.
- To document major concerns with technical evaluations in Chapter 7.
To document inconsistencies between DOE's evaluation methodology in Chapter 7 and the siting guidelines.
Consistent with these ccmprehensive objectives, it appears that the only concerns outside the scope of this review are those that were inadvertently omitted from NRC's review of the DEAs.
On page 5, however, the SRP states that the review should not be a comprehensive and detailed review to identify every concern and to document these concerns as major and detailed comments.
This guidance may be interpreted to mean that NRC staff should concentrate on DOE's responses to major comments and avoid a detailed review of the rest of the FEA.
Certainly the SRP does not direct the NRC staff to ignore major concerns that may be identified for the first time in the FEA review.
But at what level should the reviewer truncate the detailed review?
It appears that detailed review of information in addition to DOE's responses to major NRC comments is necessary to fulfill the objectives stated above.
The SRP should be revised to clarify the scope of the review and to ensure consistency between'the stated objectives and scope of the review.
Consistent with the discussion aLove, the SRP characterizes the FEA review as a " level-of-effort" review.
The plan does not, however, define what a
" level-of-effort" review is' or how it impacts the scope of the review.
The SRP should be revised to clarify appropriate levels of detail for the review.
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The SRP repetitively uses the adjective " major" to qualify concerns and
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comments that will be documented in the FEA review.
The plan does not, i
however, define " major" in the context of the FEA review or provide examples i
of the types of concerns that should be considered " major."
The SRP should be revised to provide reviewers with a bash (e.g., set of criteria) to determine whether concerns are major using exper' ace gained in the DEA review.
3.
The SRP states that suggested resolutions will not be included in NRC's l
major comments on the FEAs.
The plan should be revised to justify this L
omission.
4.
According to the SRP, Branch Chiefs will only become involved in the FEA review process in Step 3 after comments have been merged into a complete package. Consistent with the recommendations of the Section Leaders Committee, authors of the SRP should consider involving Branch Chiefs earlier in the process to aid in development of commenting strategies. Such involvement could be accomplished, for example, in Step 2 at the verbal concurrence milestone along with Section Leader and Project Manager review.
5.
The SRP should be revised to identify members and individual responsibilities of the Production and Editorial Team (cf. p. 13).
6.
The Quality Assurance section of the SRP is ambiguous in that it does not provide detailed QA requirements for the staff to follow in performing the FEA review.
For example, is staff required to retain draft and marked-up copies of comments that are generated between quality reviews?
Is the resolution process documented in some fashion other than by maintaining copies of revised products? Is staff required to document responses to non-editorial comments of the draft comments?
What are the necessary professional qualifications for individual technical reviewers of the FEA and peer reviewers of comments (e.g., Decision Support System Review Personnel)?
The SRP should be revised to provide NRC staff with specific guidance on QA requirements for the FEA review.
7.
The SRP states that specific FEA review guidance (listed on page 19) will be provided to reviewers well in advance of the review.
This guidance has not been provided to the reviewers as of 3/26/86.
Those portions of the guidance vital' to preparation of comments (e.g., example ccmments, writing guidance, production guidance) 'should be provided to reviewers as soon as practicable.
8.
(Editorial Comment)
Page 12 of the SRP incorrectly references Figure 2 rather than Figure 3 to describe the elements of the FEA review organization.
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