ML20114E015

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Slides for April 23, 2020, Public Meeting to Discuss Potential Regulatory Relief for Part 30 & 34 Licensees
ML20114E015
Person / Time
Issue date: 04/23/2020
From:
Office of Nuclear Material Safety and Safeguards
To:
Rakovan L
References
Download: ML20114E015 (25)
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Please stand by The Meeting on Regulatory Relief for NRC Part 30 & 34 Licensees will begin shortly Please ensure you have called into the bridge line, its the only audio for todays meeting:

Bridge Line: 888-965-9717 Pass Code: 8276943

Regulatory Relief Pathways for NRC Part 30 & 34 Licensees During the COVID-19 Public Health Emergency April 23, 2020 Division of Materials Safety, Security, State, and Tribal Programs, Office of Nuclear Material Safety and Safeguards Division of Nuclear Materials Safety NRC Region I

Welcome, Purpose & Agenda Mike Layton, Director Division of Materials Safety, Security, State, and Tribal Programs 3

Purpose of Todays Meeting

  • Discuss available regulatory relief pathways for 10 CFR Part 30 & 34 licensees during the COVID-19 public health emergency
  • Discuss the process by which to submit requests for regulatory relief
  • Hear from licensees on the types of regulatory relief they expect they might need 4

Agenda 5

Time Topic Speaker 1:00 p.m.

Introduction Mike Layton, Director Division of Materials Safety, Security, State, and Tribal Programs 1:05 p.m.

Meeting Logistics Lance Rakovan, Facilitator 1:10 p.m.

Regulatory Relief Pathways David Alley, Chief Materials Safety and Tribal Liaison Branch 1:20 p.m.

General Overview of Exemption Requests Randy Ragland, Senior Health Physicist Division of Nuclear Materials Safety, NRC Region I 1:30 p.m.

Comments from Participants 2:25 p.m.

Meeting Recap and Adjourn David Alley

Meeting Logistics

  • Meeting audio is through the bridge line only (Bridge Line: 888-965-9717 Pass Code: 8276943 )
  • Participants are in listen-only mode until the public comment portion of the meeting

April 7 licensee letter (ML20094G166), and temporary exemptions tables (ML20108E943 &

ML20108E944)

  • During the public comment portion of meeting, comment by phone or by submitting a message via WebEx Chat 6

Regulatory Relief Pathways David Alley, Chief Materials Safety and Tribal Liaison Branch 7

Materials Licensee Letter - April 7, 2020

  • This letter outlines the regulatory options for materials licensees to seek regulatory relief that may be necessary during the COVID-19 public health emergency.

Exemptions to regulations and amendments for license conditions and tie downs

Potential for NRC to issue enforcement discretion

Emergency regulatory relief

Accessible at ADAMS Accession No. ML20094G166 8

Temporary Exemption

  • Exemptions are expected to be temporary.
  • The expiration date of the exemption and/or any extension of deadlines to comply with regulatory requirements will be specified.
  • Should additional time beyond the exemption be needed, the NRC would consider an exemption based on a subsequent request that updates all the information in the initial request.

9

NRC Preparation for Anticipated Relief Requests

  • Developed guidelines for regional reviewers to quickly process anticipated requests
  • Unanticipated requests will be evaluated but may take more time to process 10

Points of Contact for Regulatory Relief

Agreement State Licensees

  • See the Organization of Agreement States (OAS) Web site for links to Agreement State COVID-19 responses:

12 https://www.agreementstates.org/covid response.html

Exemption Request Overview Randy Ragland, Senior Health Physicist Division of Nuclear Materials Safety, NRC Region I 13

What to Include in COVID-19 Exemption Request Request to seek regulatory relief that may be necessary during the COVID-19 public health emergency Describe which areas and activities are shut down or have limited access and which are fully operational Describe required activities that cannot be met during the shut-down:

Regulations License conditions License commitments Compensatory measures to ensure that licensed material is being stored and used safely Expected length of time that you will be shut down or have access restrictions in place 14

NRC Experience With Exemption Requests Licensees requested relief from daily, weekly, monthly, quarterly, semi-annual, and annual commitments for the Radiation Safety Program:

Area Surveys Source inventories Source leak tests Instrument calibration Dosimetry exchanges Routine door lock checks Environmental air sampling Research protocol renewals Vendor Activities (e.g., source exchange, PMs) 15

NRC Experience With Exemption Requests -

Continued

April 17, 2020: NRC Issued Exemption Template to Staff for 10 CFR Parts 30 & 34

  • Physical inventory
  • Leak testing
  • Dosimetry exchanges
  • Refresher training
  • Radiation safety committee
  • Annual program reviews 17

April 17, 2020: NRC Issued Exemption Template to Staff for 10 CFR Parts 30 & 34 10 CFR Part 34 34.25(b)(1): Instrument calibration (6 month) 34.27(c)(1): Leak testing (6 month) 34.27(e): DU leak testing (12 month) 34.29(a): Inventory (quarterly) 34.43(d): Refresher training (12 month) 34.43(3)(1): Performance assessment (6 month) 18

March 31, 2020 Exemption for ASNT Recertifications 10 CFR 34, Appendix A, Section II.5:

Provide a certification period of not less than 3 years nor more than 5 years; Relief provided for certifications due to expire March 31 - September 30, 2020; ASNT may grant two extensions up to 90 days each, as needed during the COVID-19 emergency (ML20090C666) 19

NRC Experience With Exemption Requests

  • Some delays occurred due to a lack of specific information
  • Regulation
  • License condition
  • License or docket number
  • Full scope of relief needed
  • Some requests did not need relief, but it was later determined that they did not need certain relief 20

NRC Experience With Exemption Requests Some requests did not need relief Dosimetry change-outs for programs with the maximum dose <10% of occupational dose limits (i.e., <500 mrem)

Most applications allow for a prospective evaluation rather than requiring the use of dosimetry Leak testing for sealed sources in storage Bioassays frequencies which are not tied down by the application or license condition Survey instrument calibrations for survey instruments that are not in-use 21

Emergency Relief Requests If necessary, licensees may request immediate exemptions via e-mail or phone Oral requests must be followed up within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a written requests Directors of the regional Divisions of Nuclear Materials Safety can provide oral authorization of the requested exemptions if immediate relief is needed and they deem appropriate In urgent, off-hours cases, call the Headquarters Emergency Operations Center at 301-816-5100 22

Participant Comments To make a comment over the phone, press

  • then 1 and follow the prompts You can also submit shorter comments or questions by sending a WebEx chat message to All Panelists 23

Questions for Licensees

  • What hardships related to NRC regulations are you experiencing or expect to experience in the next 3 months due to the COVID-19 emergency?
  • Are there any specific NRC regulations which you do not think you will be able to meet?
  • How long do you believe exemptions might be necessary?
  • To inform our approach regarding inspections:

Are licensees able to support routine in-person inspections? What conditions would be necessary?

24

In Closing

  • For questions:
  • Send meeting format feedback to Lance.Rakovan@nrc.gov 25
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