ML20069A021
| ML20069A021 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 03/05/2020 |
| From: | Wearne J Nuclear Energy Institute |
| To: | Office of Nuclear Material Safety and Safeguards |
| Carrera A | |
| Shared Package | |
| ML20036C409 | List: |
| References | |
| Download: ML20069A021 (7) | |
Text
©2020 Nuclear Energy Institute Retrospective Review of NRCs Administrative Requirements March 5, 2020 Justin Wearne
©2020 Nuclear Energy Institute 2 Development of industry input Industry priority - 50.72 PRM Recommendations Overview
©2020 Nuclear Energy Institute 3 Industry Review ~ 300 items One Two Three Four Five Six NRC 7 NEI Category
§ 11.16 Immediately by telephone; with prompt written confirmation
§ 19.13(a),(b)
Annually J
§ 19.13(c)
Within 30 days of request or determination of exposure, whichever is later J
A
§ 19.13(d)
Concurrent with submittal of report to the NRC J
C
§ 19.13(e)
Upon request of employee or employee designee (30 days thereafter)
J A
©2020 Nuclear Energy Institute 4 Sub categories created under each NRC criterion.
Criterion 1, Not Used - 6 subcategories Criterion 2, Alternative - 12 subcategories Criterion 3, Less Frequent - 4 subcategories Criterion 4, Burden - 4 subcategories Subcategories were consolidated into ~ ten items. NEI will address these in responding to the FRN questions Criterion 6 - Other criteria we wanted to flag for NRC. One example is candidates for direct final rules.
Criterion 7 - Items that NEI took for action. Examples include effluent reporting templates.
Results
©2020 Nuclear Energy Institute 5 Petition for rulemaking submitted August 2, 2018 Requested NRC amend 10 CFR 50.72 to eliminate non-emergency reporting requirements These reports are outdated and add burden without benefit to public health and safety, in our view Docketed by NRC as PRM-50-116 and published for public comment in November 2018 (83 FR 58509)
Public comment period closed on February 4, 2019 following the receipt of 16 public comments No visible progress since that time Industry Priority - 50.72 PRM
©2020 Nuclear Energy Institute 6 Residents receive pre-notification prior to 50.72 reporting.
Criterion 1, Not Used - Trends and OE built on 50.73 reports. Pre-Calls cover communication to region. Reactive inspections can be performed without 50.72 reports.
Criterion 2, Alternative - Pre-calls cover communications. LER provides more details.
Criterion 3, Less Frequent - LER satisfies agencys needs.
Criterion 4, Burden - Two engineers / Two operators / Two Licensing over eight hours. Large distraction at time of discovery.
Industry Priority - 50.72 PRM (cont)
©2020 Nuclear Energy Institute 7 We appreciate the opportunity to provide our input We urge the NRC to act on our 50.72 petition (PRM-50-116) expeditiously We urge the NRC to act promptly on the next phase of the RROAR Recommendations