ML20224A143

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Comment Resolution Document SA-103
ML20224A143
Person / Time
Issue date: 12/18/2019
From:
Office of Nuclear Material Safety and Safeguards
To:
Joe O'Hara
Shared Package
ML20183A152 List:
References
Download: ML20224A143 (2)


Text

Comment Resolution Document External comments Summary of Comments for Interim SA-103, Reviewing the Non-Common Performance Indicator, Technical Staffing and Training Sent to the Agreement States, NRC NMSS, NRC Regions I, III, and IV for Comment in STC-19-079, December 18, 2019 Comment No.

Source Location Comment Accepted Remarks 1

JGoodman; NJ V.C.4.a.

The Agreement State program?

Does NRC care about the number of x-ray inspectors or nuclear power plant emergency response positions? Ms. Goodmans comment refers to the term Radiation Control Program No The term Radiation Control Program is used to be in alignment with The Agreement State Program Policy Statement.

No change made.

2 JGoodman; NJ V.C.4.b.

Same. Comment refers to the term Radiation Control Program No The term Radiation Control Program is used to be in alignment with The Agreement State Program Policy Statement.

No change made.

3 JGoodman; NJ V.D.

This might be appropriate because management may have authority over all radiation programs.

N/A Comment Noted.

4 JGoodman; NJ Appendix A Just program to be consistent with SA102? Comment refers to the term Radiation Control Program No The term Radiation Control Program is used to be in alignment with The Agreement State Program Policy Statement.

No change made.

5 PPeterson; CO 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, Yes Efforts have been taken to address these differences.

when looking at the collection there seems to be a multitude of different voices and writing styles and as a result it lacks uniformity.

6 PPeterson; CO 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.

7 PPeterson; CO 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 Comment Incorporated. Agreement State comes first. Procedure revised accordingly ADAMS ACCESSION NUMBERS PACKAGE: ML20183A152 COMMENT RESOLUTION DOCUMENT:

ML20224A143