ML20238B878
| ML20238B878 | |
| Person / Time | |
|---|---|
| Issue date: | 08/27/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| Shared Package | |
| ML20225A036 | List: |
| References | |
| Download: ML20238B878 (22) | |
Text
RETROSPECTIVE REVIEW OF ADMINISTRATIVE REQUIREMENTS Public Meeting August 27, 2020
OPENING REMARKS
RULEMAKING PROCESS 3
Clarify NEIs comments1 on the Retrospective Review of Administrative Requirements Not requesting new inputs or comments Why Are We Here?
1 NEIs comments on the NRCs Retrospective Review of Administrative Requirements [85 FR 6103; Docket ID NRC-2017-0214], dated May 6, 2020 (ADAMS Accession No. ML20128J340).
RULEMAKING PROCESS 4
NRC published Federal Register notice in February 2020 (85 FR 6103) with a 90-day public comment period.
- Requested input from the public on outdated or duplicative administrative requirements
Background
Held public meetings to discuss the NRCs request Received a combined total of 145 items for consideration
RULEMAKING PROCESS 5
Table 3: Annual Reporting on Work Hours, Page 6 - Please clarify if NEIs request is limited to reporting requirements in Part 26, Subpart I - Managing Fatigue (i.e.,
work hours), OR is the request broader, given the references to requirements only applicable to the reporting of FFD program information on drug and alcohol testing (Paul Harris/NRC)
Discussion/Clarification
RULEMAKING PROCESS 6
Table 3: Annual Reporting on Work Hours, Page 6 - If the request also applies to the drug and alcohol testing information in annual FFD program performance reports submitted to the NRC under 26.417(b)(2) and 26.717(e), please clarify the basis to justify the elimination of these reports (Paul Harris/NRC)
Discussion/Clarification
RULEMAKING PROCESS 7
Table 4: Prompt Notifications on Work Hours, Page 8 - Please clarify whether NEIs request is limited to reporting requirements in Part 26, Subpart I -
Managing Fatigue (i.e., work hours), OR is the request broader, given the references to requirements only applicable to the reporting of FFD program information on drug and alcohol testing. If NEIs request is specific to Fatigue reporting requirements, please provide specific reference (Paul Harris/NRC)
Discussion/Clarification
RULEMAKING PROCESS 8
Table 4: Prompt Notifications on Work Hours, Page 8 - If the request is specific to the 24-hour notifications to the NRC headquarters operation center on the following significant FFD policy violations and programmatic failures, please clarify the basis to justify the request to eliminate the reports and instead rely on the onsite resident inspector to review plant condition reports (Paul Harris/NRC)
Discussion/Clarification
RULEMAKING PROCESS 9
Table 4: Prompt Notifications on Work Hours, Page 8 - Please describe the information evaluated to justify the statement We have not found an example of the NRC taking immediate action, such as commencing a reactive inspection, based on the 24-hour notifications prescribed in Part 26 (Paul Harris/NRC)
Discussion/Clarification
RULEMAKING PROCESS 10 Table 6: Duplication of Requirements in Part 50, Emergency Plan, and Reporting Rules, Page 13 - Clarify how licensees would ensure the records of event review will be retained for three years after issuing the LER (Caroline Tilton/NRC)
Discussion/Clarification
RULEMAKING PROCESS 11 Table 6: Duplication of Requirements in Part 50, Emergency Plan, and Reporting Rules, Page 13 - Clarify which regulatory requirement is duplicative of 10 CFR 50.36a(a)(2) (Caroline Tilton/NRC)
Discussion/Clarification
RULEMAKING PROCESS 12 Table 7: Reporting of Items Available in CAP or Site Records, Page 15 - Clarify what is meant by the comment to revise 10 CFR 55.46(d)(3) to maintain records as opposed to submitting a report. 10 CFR 55.46(d)(3) only requires that the records be made available to the NRC for review.
(Theresa Buchanan/NRC)
Discussion/Clarification
RULEMAKING PROCESS 13 Table 7: Reporting of Items Available in CAP or Site Records, Page 15 - Clarify how licensees would ensure the same level of quality and accuracy in the information requested if the requirement is changed from submit a report to maintain as a record (Caroline Tilton/NRC)
Discussion/Clarification
RULEMAKING PROCESS 14 Table 8: Reporting of Effluent Data versus Retain in Records, Page 20 - Clarify how licensees would ensure the same level of quality and accuracy in the information requested if the requirement is changed from submit a report to maintain as a record (Caroline Tilton/NRC)
Discussion/Clarification
RULEMAKING PROCESS 15 Table 9: Treatment of Current Licensing Basis Information, Page 22 - Clarify the term no substantial decrease in effectiveness in the recommendations for proposed changes (Andrea Keim/NRC)
Discussion/Clarification
RULEMAKING PROCESS 16 Table 13: Reporting on Operator Licenses, Page 31 - Clarify requested changes to both 10 CFR 50.74 and 10 CFR 55.25, as applicable, as relates to the facility licensee submitting reports on any permanent disqualifying medical conditions for individual licensed operators (Theresa Buchanan/NRC)
Discussion/Clarification
RULEMAKING PROCESS 17 Table 13: Reporting on Operator Licenses, Page 31 - Clarify the request to revise 10 CFR 55.25 such that the individual licensed operator is no longer required to report the disqualifying medical condition directly to the NRC (Theresa Buchanan/NRC)
Discussion/Clarification
RULEMAKING PROCESS 18 Table 17: Letters Approving Proprietary Withholdings, Page 39 - Clarify what NEI meant by the term official record in the rationale for the proposed change.
NRC confirmation letters are put into ADAMS and sent to licensees but are not considered "official records" for licensee records management purposes (Christina England/NRC)
Discussion/Clarification
RULEMAKING PROCESS 19 Please contact:
- Andrew Carrera, 301-415-1078, Andrew.Carrera@nrc.gov
- Pamela Noto, 301-415-6795, Pamela.Noto@nrc.gov; or
- Nebiyu Tiruneh, 301-415-2080, Nebiyu.Tiruneh@nrc.gov.
Have Questions?
RULEMAKING PROCESS 20 There are several ways you can provide your feedback on this meeting:
- Scan QR code for NRC Public Meeting Feedback Form (meeting ID# 20200995); or
- Go to the Public Meeting Schedule and click on the Meeting Feedback link.
How Did We Do?
CLOSING REMARKS
RULEMAKING PROCESS 22 NEI - Nuclear Energy Institute NRC - Nuclear Regulatory Commission ADAMS - Agencywide Documents Access and Management System Acronym/Abbreviation CAP - Corrective Action Process CFR - Code of Federal Regulations LER - Licensee Event Report FFD - Fitness For Duty