ML20196L518
| 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 Source Location Comment Accepted Remarks No.
1 Colorado General: While we understand that the revision and Yes Efforts have been taken to address Applies to authoring of these procedures is a multi- these differences.
all Interim organization process involving many SA individuals, when looking at the collection there procedures seems to be a multitude of different voices and writing styles and as a result it lacks uniformity.
2 Colorado General: Specifically, it appears that many of the Yes Please note that most of the Applies to appendices address common items and it appendices in the interim all Interim would be appropriate to use common titles for procedures (i.e., the Examples of SA the appendices and to keep them in a common Less than Satisfactory Findings of procedures order if possible. 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: Additionally, during the drafting process the Yes Change made.
Applies to idea of consistency within these procedures all Interim regarding the phrase "Agreement State or SA NRC..." vs. "NRC or Agreement State..." was procedures discussed. This should be made uniform throughout the procedures.
4 NJ General: Follow-up should be hyphenated. Yes Change made.
Applies to all Interim SA procedures 5 NJ SA-105 This doesnt make sense. An incident applies Yes The sentence was deleted and to an event that caused conditions described in replaced with two sentences from Section I.a 10 CFR? There are many conditions SA-300 Reporting Material described in the CFR. Specifically, what Events.
conditions?
6 NJ SA-105 By using the word request, does that mean an Yes The IMPEP Team Leader and the Agreement State can say no? Having IMPEP Program management can Section members present may distract from the negotiate if an IMPEP team IV.A.3 programs response and actually cause member can observe an ongoing missteps in the response. Agreement states incident.
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.
7 NJ SA-105 If the Agreement state program managers Yes The Working group noted that this agree. This refers to this bullet: bullet does not belong in the Section preparation section and has been V.B.3 Conduct staff discussions, as removed.
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.
8 NJ SA-105 If agreed to by the Agreement State managers, Yes The bullet was re-written:
observe the receipt, disposition, and/or Section inspection of a new incident, should one occur Observe the performance-based V.D.3.p during the on-site review 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 Sometimes a State just uses phone Yes We changed the example to conversations or meetings to determine if a include interviews with inspectors.
Appendix response is necessary. No documentation Now the example reads:
A #2 for does not mean that the response was not SBNI coordinated or systematic. 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