ML20121A277

Draft Presentation Slides - May 5, 2020 Public Meeting on Source Security (10 CFR Part 37) Regulatory Relief for NRC Licensees

ML20121A277
Person / Time
Issue date:	04/30/2020
From:	Kim Lukes NRC/NMSS/DMSST
To:
LUKES K/NMSS
References
Download: ML20121A277 (20)

Text

Please stand by, the Meeting on Source Security Regulatory Relief for NRC Licensees will begin shortly.

Please ensure you have called into the bridge line, its the only audio for todays meeting:

Bridge Line: 877-891-6976 Pass Code: 4061382

Source Security Regulatory Relief Pathways for NRC Licensees During the COVID-19 Public Health Emergency May 5, 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

Purpose of Todays Meeting

• Discuss available regulatory relief pathways for licensees implementing 10 CFR Part 37 for physical protection of Category 1 and Category 2 radioactive materials 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 3

Agenda Time Topic Speaker Mike Layton, Director, 1:00 p.m. Introduction Division of Materials Safety, Security, State, and Tribal Programs 1:05 p.m. Meeting Logistics Sarah Lopas, Facilitator George Smith, Chief, 1:10 p.m. Regulatory Relief Pathways Source Management and Protection Branch Randy Ragland, Senior Health Physicist, General Overview of 1:20 p.m. Division of Nuclear Materials Safety, Exemption Requests NRC Region I 1:30 p.m. Comments from Industry and Public 2:25 p.m. Meeting Recap and Adjourn George Smith 4

Meeting Logistics

• Meeting audio is through the bridge line only (Bridge Line: 877-891-6976, Pass Code: 4061382)

• Participants are in listen-only mode until the public comment portion of the meeting

• Meeting materials include slides (ML20121A277), April 7 licensee letter (ML20094G166), and Part 37 licensee exemption letter (ML20121A222)

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

• Please do not give any specific information about your facility or discuss classified, safeguards, or security-related information during the question and answer session 5

Regulatory Relief Pathways George Smith, Chief Source Management Protection Branch 6

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 7

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.

8

NRC Preparation for Anticipated Relief Requests

• Developed draft letter to allow NRC regions to quickly process anticipated exemption requests

• Continually reviewing information received from 10 CFR Part 37 licensees regarding the impact of the COVID-19 emergency to prepare for anticipated requests

• Requests not yet considered will be evaluated but may take more time to process 9

Points of Contact for Regulatory Relief

• Region I James Trapp, Director James.Trapp@nrc.gov

• Region III David Pelton, Director David.Pelton@nrc.gov

• Region IV Mary Muessle, Director Mary.Muessle@nrc.gov

• DANU John Monninger, Director John.Monninger@nrc.gov

• DFM Andrea Kock, Director Andrea.Kock@nrc.gov

• DUWP Patricia Holahan, Director Patricia.Holahan@nrc.gov 10

Agreement State Licensees

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

https://www.agreementstates.org/covid response.html 11

Exemption Request Overview Randy Ragland, Senior Health Physicist Division of Nuclear Materials Safety, NRC Region I 12

Many Licensees May Not Require Relief

• Physical security measures are already in-place

• Requirement due dates may not occur during access restrictions

• Some requirements can possibly be accomplished remotely

• Training

• LLEA Coordination

• Annual review of access authorization program

• Annual review of physical security program 13

What IF You Need Relief?

• NRC Headquarters developed a draft exemption letter:

• 37.23(b)(2): Recertification of reviewing official

• 37.25(c): Reinvestigation

• 37.43(c)(3): Refresher training

• 37.51(a): Maintenance and testing

• To submit requests for temporary exemptions, see the nuclear materials relief request form at https://www.nrc.gov/about-nrc/covid-19/materials/med-indust-academic.html 14

What to Include in COVID-19 Exemption Request

• Request 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 or 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 15

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

• In urgent, off-hours cases, call the Headquarters Emergency Operations Center at 301-816-5100 16

Industry and Public 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 17

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?

18

Contacts

• For questions:

• Region I: James Trapp,

• DANU Director John Monninger, Director James.Trapp@nrc.gov John.Monninger@nrc.gov

• Region III: David Pelton,

• DFM Director Andrea Kock, Director David.Pelton@nrc.gov Andrea.Kock@nrc.gov

• Region IV: Mary Muessle,

• DUWP Director Patricia Holahan, Director Mary.Muessle@nrc.gov Patricia.Holahan@nrc.gov

• Send meeting format feedback to Sarah.Lopas@nrc.gov 19

In Closing Address to submit certification for reviewing official:

Director, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 ATTN: Source Management and Protection Branch Mail Stop to submit fingerprints to the NRC:

U.S. Nuclear Regulatory Commission Director, Division of Physical and Cyber Security Policy Attn: Criminal History Program/Mail Stop - T-08B20 11545 Rockville Pike Rockville, MD 20852 20