ML20258A063

Comment Resolution Document SA-104

ML20258A063
Person / Time
Issue date:	01/07/2020
From:	Office of Nuclear Material Safety and Safeguards
To:
KATHY MODES/NMSS/MSST
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ML20183A152	List: ML20183A205 ML20184A178 ML20184A179 ML20184A180 ML20189A007 ML20191A059 ML20204A816 ML20224A143 ML20258A063 ML20274A160
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Download: ML20258A063 (2)

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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 Source Location Comment Accepted Remarks No.

1 New V. A. 3 Editorial Comments: Should procedures No This procedure applies to the UR Jersey apply say procedures do not apply? and LLRW programs. The UR and LLRW procedure points back to UR and LLRW program both have their No this procedure for the general own SA procedures too. Should 3 and 4 evaluation of licensing actions be combined in one paragraph to include (e.g., thorough, complete, etc.)

all 3 of the non-common indicators?

This procedure does not apply to the evaluation of the licensing actions for SSDR.

2 New V.B.2.h Legally binding conditions or license Yes Language was added. Yes, Jersey conditions Should this be requirements license conditions are legally such as license conditions? Arent license binding.

conditions legally binding?

3 New General Is this text to ensure that they (license No Action Submitting license conditions, Jersey conditions) have been sent to the NRC for other than those that point back to a compatibility review required or a a Programs regulation or are suggestion? I dont think this is a standard license conditions (e.g., in requirement for all license conditions. NUREG-1556, Vol. 20), are required to be submitted to the NRC for review.

4 New V.C.1 Editorial Comment Replace NRC or Yes Jersey Agreement State radiation control program for Program

5 New V.D.14 Provide clarification for: Implementation of No Action During IMPEP reviews we will Jersey licensing initiatives. In particular, the evaluate and mention in the report reviewer should identify these initiatives for if a Program has other licensing initiatives, such as, a general a performance-based review (i.e.,

licensing program or other radiography certification, general licensing licensing programs.

programs, etc.).

6 Iowa V.F.3 In Section V, Lettered Paragraph F, Yes SA-104 was updated to reflect Numbered Paragraph 3 states, "Section more general language for the II.A.3 of NMSS procedure SA-100 contains development of recommendations in SA-100. Most of the appendices criteria regarding the development of were removed from the SA recommendations by the IMPEP team." I procedures, including the appendix question that statement as Appendix D of on development of SA-100 is titled "Criteria and Examples of recommendations, and are Recommendations" and I don't see a available in the state Section II.A.3 in SA-100 anywhere? communication portal website at https://scp.nrc.gov/impeptools.html.

ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT: ML20258A063