ML20150A146
| ML20150A146 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/2020 |
| From: | Clay Johnson NRC/OCFO |
| To: | Tannenbaum M Electric Power Research Institute |
| smh | |
| References | |
| Download: ML20150A146 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 8, 2020 Mr. Marc H. Tannenbaum Senior Technical Executive Electric Power Research Institute 1300 West W.T. Harris Boulevard Charlotte, NC 28262-8550
Dear Mr. Tannenbaum:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated April 30, 2020 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML20143A062), requesting a fee exemption under Section 170.11(a)(1)(ii) of Title 10 of the Code of Federal Regulations (10 CFR) for NRC review of the Electric Power Research Institute (EPRI) Technical Report, Remote Source Verification During a Pandemic or Similar State of Emergency: Screening Criteria and Process Guidance (EPRI 3002019436).
The NRC has established regulations for the granting of fee exemptions under 10 CFR 170.11, Exemptions, which may be applied for in accordance with 10 CFR 170.5, Communications.1 The NRC staff has reviewed your request based on the following regulations, 10 CFR 170.11(a)(1)(ii) and 10 CFR 170.11(a)(13):
10 CFR 170.11(a) No application fees, license fees, renewal fees, inspection fees, or special project fees shall be required for: (1) A special project that is a request/report submitted to the NRC... (ii) When the NRC, at the time the request/report is submitted, plans to use the information in response to an NRC request from the Office Director level or above to resolve an identified safety, safeguards, or environmental issue, or to assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins).
10 CFR 170.11(a)(13) All fee exemption requests must be submitted in writing to the Chief Financial Officer in accordance with § 170.5, and the Chief Financial Officer will grant or deny such requests in writing.
Your letter stated that NRC review and endorsement and subsequent industry implementation of [EPRIs] Technical Report Remote Source Verification During a Pandemic or Similar State of Emergency: Screening Criteria and Process Guidance will result in generic regulatory improvements, optimized allocation of resources on issues during the period of pandemic constraints and most importantly the protection of the health and safety of nuclear industry workers and the general public.
1 10 CFR 170.5 provides that All communications concerning the regulations in this part should be addressed to the NRCs Chief Financial Officer, either by mail to the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; by hand delivery to the NRCs offices at 11555 Rockville Pike, Rockville, Maryland; or, where practicable, by electronic submission, for example, via Electronic Information Exchange, or CD-ROM.
The EPRI technical report provides guidance with respect to a licensees or vendors quality assurance program for remote performance when a source verification is required. Typically, a source verification is used to verify successful completion of certain fabrication and testing activities related to equipment that is complex, expensive, or designated for use in nuclear safety-related applications. The EPRI technical report specifically addresses being limited to remote source verification activities. It does not address other quality assurance activities such as vendor audits or surveys used to qualify a vendors quality assurance program. It provides guidance for the application of video and other real-time communication technologies for the successful performance of remote source verification. The EPRI technical report notes that the techniques included in the report are intended for use only in extreme circumstances, such as when a pandemic or similar state of emergency has been declared restricting access or travel to and/or from those locations affected by the declaration.
The inability to perform quality assurance activities such as audits, commercial grade surveys, and source verifications at suppliers facilities is impacting plant maintenance operations. The worldwide pandemic caused by the Coronavirus Disease (COVID-19) has impacted the ability for licensees and vendors to perform the required verification activities at vendor locations. The declaration of various stay-at-home orders as a result of the COVID-19 public health emergency prevents licensees and vendors from traveling to complete an on-site source verification.
Although remote source verification is not intended to replace the ability to observe and verify activities at the source, there may be appropriate circumstances where available technologies could be effectively applied to sufficiently and successfully verify certain activities in extreme circumstances. If approved by the NRC, remote source verification may result in an effective alternative for a range of source verification activities. The EPRI technical report provides guidance for controls that will be in place prior to witnessing the surveillance and a screening process to determine if remote source verification is appropriate for the activities being verified prior to conducting the activity remotely.
Therefore, the NRC staffs review of EPRI Technical Report 3002019436 meets the criteria under 10 CFR 170.11(a)(1)(ii) because it may serve as an effective means to address the ability to perform remote source verification that is not addressed by NRC regulations or existing guidance. Thus, the NRC staff concludes that the review of the EPRI technical report, if found acceptable for use, would assist the NRC in generic regulatory improvements or efforts; therefore, the fee exemption request is approved.
If you have any technical questions regarding this matter, please contact Mr. Paul Prescott at 301-415-3026. Please contact Mr. William Blaney, of my staff, at 301-415-5092 for any fee-related questions.
Sincerely, Cherish K. Johnson Chief Financial Officer Cherish K.
Johnson Digitally signed by Cherish K. Johnson Date: 2020.07.08 07:56:25
-04'00'
SUBJECT:
LETTER TO MARC TANNENBAUM RESPONSE TO FEE WAIVER EPRI TECHNICAL REPORT 3002019436 PAPER DATED: July 8, 2020 DISTRIBUTION:
K.Riner, OCFO RidsNmssOd Resource H. Jones,NRR P. Prescott, NRR J. Holonich, NRR K. Kavanagh, NRR D.Morey, NRR A. Armstrong, NRR ADAMS: Yes No Initials: WB SUNSI Review: WB Publicly Available Non-Publicly Available Sensitive Non-Sensitive ADAMS Accession No: ML20150A115 (package); ML20143A062 (incoming);
ML20150A146 (letter) *via e-mail OFFICE OCFO/DOB/LFPT OCFO/DOB/LFPT NRR OGC NAME WBlaney JJacobs*
HNieh* M.Gavrilas for MAlbert*
DATE 06/01/20 06/01/20 06/05/20 06/25/20 OFFICE OCFO/DOC/LAFBB OCFO/DOC/LAFBB OCFO/DOB/LFPT OCFO/DOB NAME JGibbs-Nicholson*
MBlair*
ACRossi*
RCAllwein*
DATE 06/30/20 06/29/20 07/01/20 07/01/2020 OFFICE OCFO/DOB DCFO CFO NAME JEShay*
BFicks CKJohnson DATE 07/07/20 07/07/20 07/08/20 OFFICIAL RECORD ONLY