ML20108E943

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Enclosure 2 - Table of Evaluated Regulatory/License Condition Exemptions for Part 30
ML20108E943
Person / Time
Issue date: 04/17/2020
From:
Office of Nuclear Material Safety and Safeguards
To:
David Alley
Shared Package
ML20108E940 List:
References
Download: ML20108E943 (3)


Text

Material Licensee Generic Exemptions During the Emergency Caused by the COVID-19 Pandemic 1

04/13/2020 Regulation Description of Exemption Safety Basis (Open)

Safety Basis (Closed)

Exemption Language 10 CFR 30.34 Terms and conditions of licenses 10 CFR 30.34 The requirement in License Condition

[number] to perform a physical inventory every 6 months; This exemption is relatively short compared to the required 6-month interval. Therefore, the exemption does not constitue a significant increase in risk to public health and safety.

This exemption is relatively short compared to the required 6-month interval. Additionally, the extension of inventory time does not constitute a significant increase in risk to public health and safety, because the licensee suspended operations and is not using these instruments.

From the date of issuance of this letter for a period of 90 days, the licensee is exempt from the requirement in license condition [number] to perform a physical inventory of licensed material every 6 months.

Inventories shall be completed within 30 days following the expiration of this exemption.

10 CFR 30.34 The requirement in License Condition

[number] to perform leak testing every 6 months or at the frequency specified in the SSD; Note: The leak testing requirements specified in the SSD range from 6 months to 3 years.

This exemption is relatively short compared to the required leak testing interval. Therefore, the exemption does not constitue a significant increase in risk to public health and safety.

This exemption is relatively short compared to the required leak testing interval. Additionally, the extension of the leak test time does not constitute a significant increase in risk to public health and safety, because the licensee suspended operations and is not using these sources.

From the date of issuance of this letter for a period of 90 days, the licensee is temporarily exempt from the requirement in license condition

[number] to perform leak tests every 6 months. The licensee shall perform the required leak tests within 30 days of the expiration of this exemption.

10 CFR 30.34 The requirement in License Condition

[number] to perform surveys Note: for companies who are still operating, make This exemption is relatively short compared to the required survey interval. Therefore, the exemption does not constitue a significant increase in risk to public health and safety This exemption is relatively short compared to the required survey interval. Additionally, the extension of survey time does not constitute a significant increase in risk to public health and safety, because the licensee suspended From the date of this letter for a period of 90 days, the licesnee is temporarily exempt from the survey time interval required by license condition [number].

The licensee shall perform the required surveys within 7 days

Material Licensee Generic Exemptions During the Emergency Caused by the COVID-19 Pandemic 2

sure that this exemption is needed operations and is not using these instruments.

of the expiration of this exemption.

10 CFR 30.34 The requirement in License Condition

[number] to exchange dosimetry This exemption is relatively short compared to the required dosimetry exchange interval.

Therefore, the exemption does not constitue a significant increase in risk to public health and safety.

This exemption is relatively short compared to the required dosimetry exchange interval.

Additionally, the extension of dosimetry exchange time does not constitute a significant increase in risk to public health and safety, because the licensee suspended operations and is not using equipment that would lead to accumulated dose.

From the date of this letter for a period of 90 days, the licensee is temporarily exempt from the dosimetry exchange requirement in license condition

[number]. The licensee shall shall make the required dosimitery exchanges within 7 days of the expiration of this exemption.

10 CFR 30.34 The requirement in License Condition

[number] to provide radiation safety refresher training at intervals not to exceed 12 months This exemption is relatively short compared to the required refresher training interval. The NRC notes that the licensee must continue to provide initial radiation safety training to each radiation worker. Therefore, the exemption does not constitue a significant increase in risk to public health and safety.

This exemption is relatively short compared to the required refresher training interval.

Additionally, the extension of time between training does not constitute a significant increase in risk to public health and safety, because the licensee suspended operations and is not acting under the authority of its license.

From the date of issuance of this letter until for a period of 90 days, the licensee is temporarily exempted from the refresher training frequency requirement in license condition

[number]. The licensee shall provide the required refresher training within 90 days of the expiration of this exemption.

10 CFR 30.34 The requirement in License Condition

[number] to perform instrument calibration This exemption is relatively short compared to the required calibration interval. Therefore, the exemption does not constitue a significant increase in risk to public health and safety.

This exemption is relatively short compared to the required calibration interval. Additionally, the extension of time between instrument calibrations does not constitute a significant increase in risk to public health and safety, because the licensee suspended operations and is not using the instruments for which calibration is required.

From the date of this letter for a period of 90 days, the licensee is temporarily exempt from the calibration time interval requirement in license condition

[number]. The licensee shall perform the required calibration within 7 days of the expiration of this exemption.

Material Licensee Generic Exemptions During the Emergency Caused by the COVID-19 Pandemic 3

10 CFR 30.34 The requirement in License Condition

[number] to hold Radiation Safety Committee meetings at intervals not to exceed [X]

months; Note: this exemption should only be used for licensees that have suspended licensed activities.

[Do not issue this exemption for companies that are still acting under the authority of their licenses]

The extension of time between Radiation Safety Committee meetings does not constitute a significant increase in risk to public health and safety, because the licensee suspended operations and is not acting under the authority of its license.

From the date of issuance of this letter for a period of 90 days, the licensee is temporarily exempted from the requirement in license condition

[number] to perform Radiation Safety Committee meetings at intervals not to exceed [X]

months. The licensee shall hold the required meeting within 30 days of the expiration of this exemption.

10 CFR 30.34 The requirement in License Condition

[number] to complete an annual program review at intervals not to exceed 12 months; This exemption is relatively short compared to the required annual program review interval.

Therefore, the exemption does not constitue a significant increase in risk to public health and safety.

This exemption is relatively short compared to the required annual program review interval.

Additionally, the extension of time between annual program reviews does not constitute a significant increase in risk to public health and safety, because the licensee suspended operations and is not acting under the authority of its license.

From the date of issuance of this letter for a period of 90 days, the licensee is temporarily exempted from the requirement in license condition

[number] to perform an annual program review at intervals not to exceed 12 months. The licensee shall perform the annual program review within 90 days of the expiration of this exemption.