ML20287A290

NRC Slides for October 15, 2020 Public Meeting- Licensing Issues to Address the COVID-19 Public Health Emergency Going Forward

ML20287A290
Person / Time
Issue date:	10/15/2020
From:	Ed Miller NRC/NRR/DORL/LPL2-1
To:
Miller E
References
Download: ML20287A290 (17)

Text

Public Meeting Licensing Issues to address the COVID-19 Public Health Emergency going forward October 15, 2020

NRC Approach

• Coordination of activities across agency

• Tracking cumulative and potentially synergistic effects of regulatory actions

• Each action considered on a case-and situation-specific basis

- Preserve safety

- Evaluate undue hardship/public interest

• Continued stakeholder engagement 2

Topical Areas Regulatory guidance for exemptions/relief issued

• Part 26 - Work hours

• Part 50.55a - Owners Activity Reports

• Part 55 - Operator requalification program and medical exams

• Part 20 - Respirator fit tests and medical evaluations

• Fire Protection Plan Requirements

• Emergency Plan Biennial Exercise

• Part 73 - Security training and qualification 3

4

Overall Guidance Applicable to all requests

• Working on a letter to address various topical areas

• Submit via normal process (i.e., Mail, EIE, online form, if available)

- Keep assigned PM informed

• Specifically address impacts of COVID-19 that necessitate licensing action

- Original requests were during a more homogenous environment of restrictions

- Varying levels of restrictions and their impacts need to be addressed

- Individual licensee situation and hardship needs to be addressed 5

Part 26 - Work Hours Applications

• Several applications by industry

• Anticipate applications going forward Letter - ML20087P237 Addendum - ML20098B333 Requests

• Need to address why unable to comply with work hour controls and how exemption will mitigate the impact of COVID-19 on safety/security

• Sequential usage:

- Exemption periods separated by less than 14 days of compliance with Part 26 work hour controls

- Need to address contributing and mitigating factors for cumulative fatigue 6

50.55a - Owners Activity Report Applications

• Some Applications by industry

• Anticipate Applications going forward Letter - ML20098D975 Requests

• Licensee will need to address inability of technology or other solutions such as remote collaboration to meet requirements 7

Part 55 - Requalification and Medical Exams Applications

• Some applications by industry

• Anticipate applications going forward Letter - ML20104C071 Requests

• Original letter may be of use in developing exemption request

• Should include date for when compliance will be achieved

• For requalification should provide dates of last requalification exams and scheduled end date of current cycle

• For medical exemption provide when make-up exam will be conducted 8

Part 20 - Respirator Fit Tests and Medical Evaluations Applications

• Low applications by industry

• Do not anticipate applications going forward Letter - ML20099G757 Requests

• Original letter may be of use in developing exemption request 9

Fire Protection Applications

• Low application by industry

• Do not anticipate applications going forward Letter - ML20122A022 Requests

• Existing letter cover going into 2021 for live fire training

• Original letter may be of use in developing exemption request in other areas

• Licensees may consider whether community volunteer firefighting activities could be credited towards compliance 10

Emergency Preparedness Exercise Applications

• Significant applications by licensees

• Anticipate applications going forward Letter - ML20120A003 Addendum - ML20223A152 Requests

• Existing letters cover 2020

• Staff considering need for letter addressing 2021 11

Part 73 - Security Training and Qualification Non Force-on-Force Applications

• Some applications by industry

• Do not anticipate applications going forward Letter - ML20105A483 Requests

• Original letter may be of use in developing exemption request

• See additional slides 12

Part 73 - Security Training and Qualification Force-on-Force Applications

• Significant applications by industry

• Anticipate applications going forward Requests

• NRC plans to issue letter in October to provide additional clarification for 2020 exercises

• Staff considering need for letter addressing 2021

• See additional slides 13

Fuel Facilities and Spent Fuel Storage Usage

• Small number of requests from these licensees

- Seven requests for Fuel Cycle Facilities

- Five requests for ISFSIs

• Topics

- Training and Requalification

- Emergency Preparedness Drills Letter - ML20094G166 Subsequent Requests

• Currently, very limited indications of requests for extensions or new requests.

• Early notification and pre-application communications are strongly encouraged.

14

Decommissioning and Uranium Recovery Usage

• Small number of requests from these licensees

- Three requests Decommissioning Reactor Facilities

- Four requests for Uranium Recovery Facilities

• Topics

- Training and Training Exercises

- Ground Water Monitoring

- Radiation Safety Technician Qualifications Subsequent Requests

• Currently, licensees are reviewing their need to request for extensions or new requests.

• Early notification and pre-application communications are strongly encouraged 15

Stakeholder Perspectives 16

Questions 17