ML20238B878

August 27, 2020 Rroar Public Meeting Slides

ML20238B878
Person / Time
Issue date:	08/27/2020
From:	Office of Nuclear Material Safety and Safeguards
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ML20225A036	List: ML20225A047 ML20238B878 ML20264E691
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Download: ML20238B878 (22)

Text

RETROSPECTIVE REVIEW OF ADMINISTRATIVE REQUIREMENTS Public Meeting August 27, 2020

OPENING REMARKS

Why Are We Here?

Clarify NEIs comments1 on the Retrospective Review of Administrative Requirements RULEMAKING PROCESS Not requesting new inputs or comments 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).

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Background

NRC published Federal Register notice in February 2020 (85 FR 6103) with a 90-day public comment period.

RULEMAKING

• Requested input from the public on outdated or duplicative PROCESS administrative requirements Held public meetings to discuss the NRCs request Received a combined total of 145 items for consideration 4

Discussion/Clarification Table 3: Annual Reporting on Work Hours, Page 6 - Please clarify if NEIs request is RULEMAKING limited to reporting requirements in Part 26, Subpart I - Managing Fatigue (i.e.,

PROCESS 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) 5

Discussion/Clarification Table 3: Annual Reporting on Work Hours, Page 6 - If the request also applies to the RULEMAKING drug and alcohol testing information in annual FFD program performance reports PROCESS 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) 6

Discussion/Clarification Table 4: Prompt Notifications on Work Hours, Page 8 - Please clarify whether NEIs request is limited to reporting RULEMAKING requirements in Part 26, Subpart I -

PROCESS 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) 7

Discussion/Clarification Table 4: Prompt Notifications on Work Hours, Page 8 - If the request is specific RULEMAKING to the 24-hour notifications to the NRC PROCESS 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) 8

Discussion/Clarification Table 4: Prompt Notifications on Work Hours, Page 8 - Please describe the RULEMAKING information evaluated to justify the PROCESS 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) 9

Discussion/Clarification Table 6: Duplication of Requirements in Part 50, Emergency Plan, and Reporting RULEMAKING Rules, Page 13 - Clarify how licensees would ensure the records of event review PROCESS will be retained for three years after issuing the LER (Caroline Tilton/NRC) 10

Discussion/Clarification Table 6: Duplication of Requirements in Part 50, Emergency Plan, and Reporting RULEMAKING Rules, Page 13 - Clarify which regulatory requirement is duplicative of 10 CFR PROCESS 50.36a(a)(2) (Caroline Tilton/NRC) 11

Discussion/Clarification Table 7: Reporting of Items Available in CAP or Site Records, Page 15 - Clarify RULEMAKING what is meant by the comment to revise 10 CFR 55.46(d)(3) to maintain records as PROCESS 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) 12

Discussion/Clarification Table 7: Reporting of Items Available in CAP or Site Records, Page 15 - Clarify RULEMAKING how licensees would ensure the same level of quality and accuracy in the PROCESS information requested if the requirement is changed from submit a report to maintain as a record (Caroline Tilton/NRC) 13

Discussion/Clarification Table 8: Reporting of Effluent Data versus Retain in Records, Page 20 - Clarify how RULEMAKING licensees would ensure the same level of quality and accuracy in the information PROCESS requested if the requirement is changed from submit a report to maintain as a record (Caroline Tilton/NRC) 14

Discussion/Clarification Table 9: Treatment of Current Licensing Basis Information, Page 22 - Clarify the RULEMAKING term no substantial decrease in effectiveness in the recommendations for PROCESS proposed changes (Andrea Keim/NRC) 15

Discussion/Clarification Table 13: Reporting on Operator Licenses, Page 31 - Clarify requested changes to RULEMAKING both 10 CFR 50.74 and 10 CFR 55.25, as applicable, as relates to the facility licensee PROCESS submitting reports on any permanent disqualifying medical conditions for individual licensed operators (Theresa Buchanan/NRC) 16

Discussion/Clarification Table 13: Reporting on Operator Licenses, Page 31 - Clarify the request RULEMAKING to revise 10 CFR 55.25 such that the individual licensed operator is no longer PROCESS required to report the disqualifying medical condition directly to the NRC (Theresa Buchanan/NRC) 17

Discussion/Clarification Table 17: Letters Approving Proprietary Withholdings, Page 39 - Clarify what NEI RULEMAKING meant by the term official record in the rationale for the proposed change.

PROCESS 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) 18

Have Questions?

Please contact:

- Andrew Carrera, 301-415-1078, Andrew.Carrera@nrc.gov RULEMAKING PROCESS

- Pamela Noto, 301-415-6795, Pamela.Noto@nrc.gov; or

- Nebiyu Tiruneh, 301-415-2080, Nebiyu.Tiruneh@nrc.gov.

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How Did We Do?

There are several ways you can provide your feedback on this meeting:

RULEMAKING - Scan QR code for NRC Public Meeting Feedback Form (meeting PROCESS ID# 20200995); or

- Go to the Public Meeting Schedule and click on the Meeting Feedback link.

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CLOSING REMARKS

Acronym/Abbreviation ADAMS - Agencywide Documents Access and Management System CAP - Corrective Action Process CFR - Code of Federal Regulations RULEMAKING PROCESS FFD - Fitness For Duty LER - Licensee Event Report NEI - Nuclear Energy Institute NRC - Nuclear Regulatory Commission 22