ML20155H502

Responds to Re Risk Review Working Group Nuclear Byproduct Matl Survey (SP-98-065,dtd 980723).NRC Presently Awaiting Receipt of Scientech Final Rept to Which Survey Results Will Be Compared

ML20155H502
Person / Time
Issue date:	10/21/1998
From:	Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Aldrich R NEW YORK, STATE OF
References
SP-98-065, SP-98-65, NUDOCS 9811100155
Download: ML20155H502 (8)

Text

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30006 4001 g,,7 October 21, 1998 Ms. Rita Aldrich, Principal Radiophysicist i

' Radiological Health Unit i

Division of Safety and Health New York State Department of Labor State Office Building Campus Building 12, Room 134A Albany, New York 12240

Dear Ms. Aldrich:

. This is in response to your letter of August 24,1998, which referenced the risk review working group's nuclear byproduct material survey (SP-98-065, dated July 23,1998). You asked what information NRC's contractor, Scientech, has provided and how the survey responses augments or confirms that information. Presently, NRC is awaiting receipt of Scientech's final report to which the survey results will be compared.

As way of background, the survey of licensing and inspection personnel was designed to assist the risk review working group in identifying and documenting a technical basis for a risk-informed approach to nuclear byproduct material regulation and in development of plans for a

. graded approach to regulation of such material based on risk information. The survey asked inspection and licensing personnel about typical doses, typical events and frequencies, perceptions of safety, materials and quantities typical to various systems, the existence and value of various barriers to dose, and the value of particular regulatory options. Scientech's report will address most of those same areas. The working group received 41 responses to its survey of licensing and inspection personnel. Data from the responses have been entered into a spread sheet for analysis. The sproarf sheet was modified as data entry progressed in order to accommodate the fullest possible imge of responses (e.g., to expand coding of data to include responses that were not consistent with instructions but that appet red to be useful).

Comments that could not be entered into the spread sheet, but that could affect the data analysis, were noted.

Based on the review to date, respondents appear to have provided information in which they

' had confidence, to admit that they were unfamiliar with some systems and that they could not provide information about them with confidence, and to indicate when they believed that response alternatives were too limited. The review group believes that each individual respondent's answers reflect their own professional opinions based on their experience in licensing and/or inspection (i.e., their exposure to facts). The review group does, however, I

recognize that some questions could not be answered solely on the basis of experience. Such \\}

situations will be kept in mind during analysis of survey responses. The review group understands the limitations of the survey, but believes that there will be useful information that

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reflects the licensing and inspection community's informed opinions, i.e., its corporate knowledge.

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e Rita Aldrich ACT2i1998 The survey is intended as only one of several sources of information used to satisfy the working group's charter. Results will be compared with contractor information about doses, events and frequencies, materials and quantities. Perhaps more importantly, the informed opinions of licensing and inspection personnel about the existence and effectiveness of barriers to dose and the value of particular regulatory options will be compared with contractor developed views on those same subjects.

Shou d you have additional comments or questions, please feel free to contact Dennis Serig at 301-415-7901 or via e-mail at disante cov.

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erely,

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C4 % CO dW Paul H. Lohaus, Deputy Director Office of State Programs l

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i 21 g Rita Aldrich The survey is intended as only one of several sources of information used to satisfy the working group's charter. Results will be compared with contractor information about doses, events and frequencies, materials and quantities. Perhaps more importantly, the informed opinions of licensing and inspection personnel about the existence and effectiveness of barriers to dose and the value of particular regulatory options will be compared with contractor developed views on those same subjects.

Should you have additional comments or questions, please feel free to contact Dennis Serig at 301-415-7901 or via e-mail at djs.@nrc.oov.

Sincerely, OriginalSigned By.'

PAULH.LOHAUS Paul H. Lohaus, Deputy Director Office of State Programs DifLribution:

DlR RF (8S233)

DCD (SP05)

SDroggitis KNSchneider, ASPO

. PDR (YES/)

CPiperiello, NMSS DCool, NMSS JPiccone, NMSS PHolahan, NMSS NYS Labor File

• See previous concurrence.

DOCUMENT NAME: G:\\ ROV \\ALDRICH2. DIS T

• receive a co Mr of this document, Indicate in the box: "C' = Copy without attachment / enclosure "E' = Copy with attachment / enclosure 'N' = No copy OFFICE NMSS:IMNS OSP E

OSP:DD NMSS:IMNS l OSP:D l

l NAME DSerig ROVirgilio:gd PHLohaus FCombs RLBangart DATE 10/20/98*

10/02/98*

10/02/98*

10/21/98*

10/07/98*

OSP FILE CODE: SP-AG-20-3

Rita Aldrich.

The survey is intended as only one of several sources of information used to satisfy the working group's charter. Results will be compared with contract r information about doses, events and frequencies, materials and quantities. Perhaps more im ortantly, the informed opinions of licensing and inspection personnel about the existence nd effectiveness of barriers to dose and the value of particular regulatory options will be coi pared with contractor developed views on those same subjects.

Should you have additional comments or questions, please feel free to contact Dennis Serig at 301-415-7901 or via e-mail at dis @nrc.aov.

f Sincerely, Paul H., haus, Deputy Director Office of tate Programs Distribution:

DIR RF (8S233)

DCD (SP06)

SDroggitis PDR (YES/)

KNSchneider, ASPO CP periello, NMSS DCool, NMSS JPiccone, NMSS PHolihan, NMSS NYS Labor File

• See previous concurrence.

DOCUMENT NAME: G:\\ ROV \\ALDRICH2. DIS j

To r.e.iv.. co >r or this encum.nt. indie.t. in th. box: c. copu.itnoue attachmenvenciosur. e.edwitpfattachment/.nclosur. N. No co>y OFFICE NMSS:IMNS E

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• Rita Aldrich The survey is intended as only one of several sources of nformation used to satisfy the working group's charter. Results will be compared with contract information about doses, events and frequencies, materials and quantities. Perhaps more i ortantly, the informed opinions of licensing and inspection personnel about the existence nd effectiveness of barriers to dose and the value of particular regulatory options will be co pared with contractor developed views on those same subjects.

Should you have additional comments or questions, ease feel free to contact Dennis Serig at 301 415-7901 or via e-mail at dis @nre.aov.

Sincer.y, Paul. Lohaus, Deputy Director Offic of State Programs 4

Distribution:

DIR RF (8S233)

DCD (Sf06)

SDroggitis PDR (Y S/)

KNSchneider, ASPO CPaperiello, NMSS DCool, NMSS JPiccone, NMSS PHoldian, NMSS NYS Labor File

• See previous concurrence.

DOCUMENT NAME: G:\\ ROV \\ALDRICH2. DIS

. T? receive a ce py of thle document, Indicate in the box: 'C's Cep r thout attachment / enclosure *E' = Copy with attachment / enclosure

'N' = No cow OFFICE NMSS:IMNS l E OSP E / OSP:DD l NMSS:IMNS OSP:D l

p NAME DSerig Dt' ROVirgilio:gd

. HLohaus FCombs RLBangart DATE 10he/98 10/02/98*

10/02/98*

10/ /98 10/07/98*

OSP FILE CODE: SP-AG-20-3

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ita Aldrich 'Thes ey is intended as only one of several sources of information used to satisfy the working group's 1arter. Results will be compared with contractor information about doses, events and frequence, materials and quantities. Perhaps more importantly, the informed opinions of licensing a inspection personnel about the existence and effectiveness of barriers to dose and j

- the value of rticular regulatory options will be compared with contractor developed views on those same s ects.

Should you have ditional comments or questions, please feel free to contact Dennis Serig at -

301-415-7901 or vi e-mail at disanrc.aov.

l Sincerely, i

Paul H. Lohaus, Deputy Director Office of State Programs Distribution:

DIR RF (8S233)

DCD (SP06)

SDroggitis PDR (YES/)

KNSchneider, ASPO DCool, NMSS FCombs, NMSS JPiccone, NMSS PHolihan, NMSS DSerig, NMSS l

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' August 24,1998 Mr. Paul Lohaus--

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Washington, D.C. 20555

Dear Mr. Lohaus:

i I have completed the survey referred to in your letter SP-98-065 and returned it to Dennis

" Serig. However, this survey instrument was seriously flawed and I do not see how the responses

- received could be used as indicated in your letter to capture the " corporate knowledge" of regulatory personnel.

It a_. lear;wliiit pie _ce._f'tWdata gathersid'th_rougliihi. _._._ill b_e tre,.._d_as fa_ctiTal,a.

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WCD LS P U d) y STATE OF NEW YORK DEPARTMENT OF LABOR DIVISION OF SAFETY AND HEALTH OD i

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August 24,1998 Mr. Paul Lohaus Deputy Director Office of State Programs United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Lohaus:

I have completed the survey referred to in your letter SP-98-065 and retumed it to Dennis Serig. However, this survey instrument was seriously flawed and I do not see how the responses received could be used as indicated in your letter to capture the " corporate knowledge" of regulatory personnel.

It is unclear what pieces of the data gathered through this survey will be treated as factual and what will be treated as opinion. Since participants were instructed not to review files or other sources, and not to consult with other staff, it would appear that all of the responses should be regarded as anecdotal. It is also apparent that responses should not be regarded as the professional opinions of the respondents, since they are responses to carefully framed questions with a limited choice of answers.

I would be very interested in knowing how the survey responses will be used to " augment and confirm information provided by Scientech." What information has Scientech provided.,and how will responses to this survey augment or confirm them?

Sincerely, y3 Rita Aldrich N

Principal Radiophysicist RA:jmp i

Telephone: 518-457-1202 FAX: 518-485-7406 d-A -Y a s m_. 2, ~ v q 2

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