ML20287A432
| ML20287A432 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 10/15/2020 |
| From: | Nuclear Energy Institute |
| To: | Geoffrey Miller Plant Licensing Branch II |
| Miller G | |
| References | |
| Download: ML20287A432 (8) | |
Text
Input on Actions to Address COVID-19 Exemptions October 15, 2020
Introductions and Opening Statement
©2020 Nuclear Energy Institute 3 10 CFR Part 20 Respiratory Radiological Protection - only one request that came from a Research Test Reactor. No requests from any LWR licensees. No anticipated need for extension or requests for 2021.
10 CFR 55 Operators License - only one request for extension from a Research Test Reactor. No need for general exemption extension or applications anticipated for 2021 at this time.
10 CFR 50.55a Owners Activity Report - some requests anticipated for 2021 Spring outages.
Exemptions with Limited Further Needs
©2020 Nuclear Energy Institute 4 CY 2020: Requests submitted for relief/alternatives for Fall 2020 outages on as-needed bases CY 2021: Anticipate similar requests for Spring 2021 outages if no appreciable improvement in health risk 10 CFR 50.55a Codes and Standards
©2020 Nuclear Energy Institute 5 CY: 2020 and 2021: Extensions primarily for outages anticipated through 2020 and into 2021 for Spring outages.
A specific item for NRC consideration is reduction of maintenance worker days off from 6 to 4 to align with existing outage allowance.
Clarity around the extent to which the WHR exemption can be used pre-outage, for example a standard one week of pre-outage work could be performed using the alternate WHR provisions. More than a week could be allowed if justified by the licensee.
10 CFR Part 26 Work Hour Requirements
©2020 Nuclear Energy Institute 6 CY 2020 and 2021: Potential exemptions needed for fire drills and extensions for annual training dependent on vendor availability CY 2021: Live fire training already extended through December 2021 10 CFR Part 50.48 Fire Brigade Requirements
©2020 Nuclear Energy Institute 7 For CY 2020, exemptions granted to licensees for elements of Part 73 Examples: Annual Exercise, Range Activity/Weapon Qualifications Licensees will not be required to make up 2020 Annual Exercises For CY 2021, RG 5.75, Training and Qualifications, will be utilized to develop flexibility for what licensees can do to meet the Annual Exercise requirement without violating site-specific pandemic plan(s)/restriction(s)
Other exemptions for Part 73 requirements will be handled as-needed Agreed upon flexibility/options for 2021, we anticipate full compliance Any options outside of RG 5.75 would require NRC approval 10 CFR Part 73 Physical Protection
Questions and Discussion