ML20258A063
| ML20258A063 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| KATHY MODES/NMSS/MSST | |
| Shared Package | |
| ML20183A152 | List: |
| References | |
| Download: ML20258A063 (2) | |
Text
Comment Resolution Document Summary of Comments for Interim SA-104, Reviewing the Common Performance Indicator Technical Quality of Licensing Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC letter 20-004, date January 7, 2020 Comment No.
Source Location Comment Accepted Remarks 1
New Jersey V. A. 3 Editorial Comments: Should procedures apply say procedures do not apply?
UR and LLRW program both have their own SA procedures too. Should 3 and 4 be combined in one paragraph to include all 3 of the non-common indicators?
No No This procedure applies to the UR and LLRW programs. The UR and LLRW procedure points back to this procedure for the general evaluation of licensing actions (e.g., thorough, complete, etc.)
This procedure does not apply to the evaluation of the licensing actions for SSDR.
2 New Jersey V.B.2.h Legally binding conditions or license conditions Should this be requirements such as license conditions? Arent license conditions legally binding?
Yes Language was added. Yes, license conditions are legally binding.
3 New Jersey General Is this text to ensure that they (license conditions) have been sent to the NRC for a compatibility review required or a suggestion? I dont think this is a requirement for all license conditions.
No Action Submitting license conditions, other than those that point back to a Programs regulation or are standard license conditions (e.g., in NUREG-1556, Vol. 20), are required to be submitted to the NRC for review.
4 New Jersey V.C.1 Editorial Comment Replace NRC or Agreement State radiation control program for Program Yes
5 New Jersey V.D.14 Provide clarification for: Implementation of licensing initiatives. In particular, the reviewer should identify these initiatives for a performance-based review (i.e.,
radiography certification, general licensing programs, etc.).
No Action During IMPEP reviews we will evaluate and mention in the report if a Program has other licensing initiatives, such as, a general licensing program or other licensing programs.
6 Iowa V.F.3 In Section V, Lettered Paragraph F, Numbered Paragraph 3 states, "Section II.A.3 of NMSS procedure SA-100 contains criteria regarding the development of recommendations by the IMPEP team." I question that statement as Appendix D of SA-100 is titled "Criteria and Examples of Recommendations" and I don't see a Section II.A.3 in SA-100 anywhere?
Yes SA-104 was updated to reflect more general language for the development of recommendations in SA-100. Most of the appendices were removed from the SA procedures, including the appendix on development of recommendations, and are available in the state communication portal website at https://scp.nrc.gov/impeptools.html.
ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT: ML20258A063