STC-20-005, Comment Resolution Document SA-105
| ML20196L518 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| Kahy Modes | |
| Shared Package | |
| ML20183a152 | List: |
| References | |
| SA-105, STC-20-005 | |
| Download: ML20196L518 (3) | |
Text
Comment Resolution Document Summary of Comments for Interim SA-105, Reviewing the Common Performance Indicator, Technical Quality of Incident and Allegation Activities Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC-20-005, January 9, 2020 Comment No.
Source Location Comment Accepted Remarks 1
Colorado General:
Applies to all Interim SA procedures While we understand that the revision and authoring of these 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.
Yes Efforts have been taken to address these differences.
2 Colorado General:
Applies to all Interim SA procedures Specifically, it appears that many of the appendices address common items and it would be appropriate to use common titles for the appendices and to keep them in a common order if possible.
Yes Please note that most of the appendices in the interim procedures (i.e., the Examples of Less than Satisfactory Findings of Program Performance from the 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.
3 Colorado General:
Applies to all Interim SA procedures Additionally, during the drafting process the idea of consistency within these procedures regarding the phrase "Agreement State or NRC..." vs. "NRC or Agreement State..." was discussed. This should be made uniform throughout the procedures.
Yes Change made.
4 NJ General:
Applies to all Interim SA procedures Follow-up should be hyphenated.
Yes Change made.
5 NJ SA-105 Section I.a This doesnt make sense. An incident applies to an event that caused conditions described in 10 CFR? There are many conditions described in the CFR. Specifically, what conditions?
Yes The sentence was deleted and replaced with two sentences from SA-300 Reporting Material Events.
6 NJ SA-105 Section IV.A.3 By using the word request, does that mean an Agreement State can say no? Having IMPEP members present may distract from the programs response and actually cause missteps in the response. Agreement states should be allowed to respond without distractions. In fact, the incident may be large enough to ask the IMPEP team to reschedule if all staff are involved. A state should not feel like they are being graded while they are responding to an actual event. That would be like FEMA grading a real NPP accident while it is occurring.
Yes The IMPEP Team Leader and the Program management can negotiate if an IMPEP team member can observe an ongoing incident.
7 NJ SA-105 Section V.B.3 If the Agreement state program managers agree. This refers to this bullet:
Conduct staff discussions, as necessary; review internal written procedures; review incident and allegation files; accompany a staff member into the field, if appropriate; and maintain a reference summary of all casework reviewed and any personnel interviewed during the on-site review.
Yes The Working group noted that this bullet does not belong in the preparation section and has been removed.
8 NJ SA-105 Section V.D.3.p If agreed to by the Agreement State managers, observe the receipt, disposition, and/or inspection of a new incident, should one occur during the on-site review Yes The bullet was re-written:
Observe the performance-based actions (e.g., receipt, disposition, and inspection) of a new incident, should one occur during the on-site review (if approved by Program management 9
NJ SA-105 Appendix A #2 for SBNI Sometimes a State just uses phone conversations or meetings to determine if a response is necessary. No documentation does not mean that the response was not coordinated or systematic.
Yes We changed the example to include interviews with inspectors.
Now the example reads:
The review teams evaluation of selected incident case files and interviews with inspectors found that the Programs responses to reported incidents were not well coordinated, not consistent, and in some cases, not thorough.
ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT: ML20196L518