ML18075A079: Difference between revisions

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{{#Wiki_filter:MOU Between DoD and NRCRichard ChangNMSS/DUWP/MDB Overview*Purpose*Background
{{#Wiki_filter:MOU Between DoD and NRC Richard Chang NMSS/DUWP/MDB
*RIS (2016-06) and MOU
 
*Implementation of MOU with DoD
Overview
*RIS and MOU benefits
* Purpose
*Potential Agreement State involvement  
* Background
*DoD service providers
* RIS (2016-06) and MOU
*Three NRC regulatory processes
* Implementation of MOU with DoD
*Conclusions Purpose*Give background on NRC's jurisdiction over radium*Discuss NRC's involvement with military remediation
* RIS and MOU benefits
*Provide an update on the Memorandum of Understanding (MOU) and Regulatory Issue Summary (RIS)
* Potential Agreement State involvement
*Explain NRC's role under the MOU  
* DoD service providers
*Discuss the potential role for Agreement States (AS)
* Three NRC regulatory processes
Background on NRC's Jurisdiction over Radium
* Conclusions
*Energy Policy Act of 2005 (EPAct) expanded the Atomic Energy Act's (AEA) definition of byproduct material to include discrete sources of radium
 
-226*NRC regulations implemented provisions of the EPActin 2007 and defined the term "discrete source"
Purpose
*A discrete source is "a radionuclide that has been processed so that its concentration within a material has been purposely increased for use for commercial, medical, or research activities" and any contamination from that source.
* Give background on NRCs jurisdiction over radium
Background on NRC's Jurisdiction over Radium
* Discuss NRCs involvement with military remediation
*NRC has jurisdiction over discrete sources of radium-226 used by the military in medical or research activities or in a manner similar to a commercial activity.
* Provide an update on the Memorandum of Understanding (MOU) and Regulatory Issue Summary (RIS)
*NRC does nothave jurisdiction over radium-226 used by the military in military operations (e.g., combat or training)
* Explain NRCs role under the MOU
Background on NRC's Jurisdiction over Radium
* Discuss the potential role for Agreement States (AS)
*In 2007 the Commission directed the NRC staff to interact with DoD regarding military uses of radium
 
*Uncertainty over precise meaning and scope of NRC's jurisdiction of military radium  
Background on NRCs Jurisdiction over Radium
*MOU developed as a way for NRC and DoD to work together; avoid dual regulation; and avoid jurisdiction disagreements  
* Energy Policy Act of 2005 (EPAct) expanded the Atomic Energy Acts (AEA) definition of byproduct material to include discrete sources of radium-226
*NRC developed a RIS (2016
* NRC regulations implemented provisions of the EPAct in 2007 and defined the term discrete source
-06) and MOU RIS (2016-06)*Published May 9, 2016
* A discrete source is a radionuclide that has been processed so that its concentration within a material has been purposely increased for use for commercial, medical, or research activities and any contamination from that source.
*Clarifies NRC's jurisdiction for military radium
 
-radium or items and equipment containing radium not used in or intended for use in military operations
Background on NRCs Jurisdiction over Radium
-Confirmed contamination  
* NRC has jurisdiction over discrete sources of radium-226 used by the military in medical or research activities or in a manner similar to a commercial activity.
*Regulatory approaches  
* NRC does not have jurisdiction over radium-226 used by the military in military operations (e.g., combat or training)
-MOU for confirmed contamination (radium and other unlicensed AEA material)
 
-Licensing for items and equipment
Background on NRCs Jurisdiction over Radium
*NRC responses to public comments on the draft RIS MOU*Signed April 28, 2016
* In 2007 the Commission directed the NRC staff to interact with DoD regarding military uses of radium
*Purpose-Minimize dual regulation while ensuring protection
* Uncertainty over precise meaning and scope of NRCs jurisdiction of military radium
-Documents roles, responsibilities
* MOU developed as a way for NRC and DoD to work together; avoid dual regulation; and avoid jurisdiction disagreements
,and relationship between NRC and DoD
* NRC developed a RIS (2016-06) and MOU
*Scope-Sites with DoD response actions under CERCLA/DERP to address confirmed releases of unlicensed radioactive material subject to AEA  
 
-Buildings being remediated, but not licensed
RIS (2016-06)
-Active installations, BRAC properties, and FUDS MOU*Content of MOU
* Published May 9, 2016
-Communication/contacts
* Clarifies NRCs jurisdiction for military radium
-Annual site inventory
  - radium or items and equipment containing radium not used in or intended for use in military operations
-Coordination and planning
  - Confirmed contamination
-Access to information and sites
* Regulatory approaches
-NRC involvement (stay informed or monitor)
  - MOU for confirmed contamination (radium and other unlicensed AEA material)
-NRC dose criteria
  - Licensing for items and equipment
-NRC technical assistance  
* NRC responses to public comments on the draft RIS
-Records-Service provider licenses
 
-Funding-Dispute resolution Implementation of MOUwith DoD*DoD annual site inventory completed
MOU
*Two types of NRC involvement  
* Signed April 28, 2016
-"Stay informed"
* Purpose
-EPA has regulatory oversight (NPL sites)-"Monitoring"
  - Minimize dual regulation while ensuring protection
-EPA does not have regulatory oversight (non-NPL site)
  - Documents roles, responsibilities, and relationship between NRC and DoD
Benefits Resulting fromthe RIS and MOU
* Scope
*Clarifies jurisdictional boundaries  
  - Sites with DoD response actions under CERCLA/DERP to address confirmed releases of unlicensed radioactive material subject to AEA
*Avoids dual regulation  
  - Buildings being remediated, but not licensed
*Clarifies the regulatory approach for remediation  
  - Active installations, BRAC properties, and FUDS
*Provides independent federal oversight to ensure protection of public health and safety Potential Agreement State Involvement
 
*Keep each other informed  
MOU
*Service provider license coordination
* Content of MOU
-Jurisdictional questions
  - Communication/contacts
-Coordination of activities at sites with dual jurisdiction DoD Service Providers
  - Annual site inventory
*DoD service providers involved with remediation must have an NRC or AS license (e.g., reciprocity)
  - Coordination and planning
*NRC guidance on determining jurisdiction (FSME 039, "Clarification on the Determination of Regulatory Jurisdiction of Nonfederal Entities Conducting Cleanup Activities on Federal Property in Agreement States.")*Under the MOU  
  - Access to information and sites
-DoD verifies that its service providers use NRC guidance to determine appropriate license
  - NRC involvement (stay informed or monitor)
-DoD will provide appropriate land jurisdiction to service providers
  - NRC dose criteria
*NRC plans to coordinate its service provider inspections with its future MOU activities Three NRC Regulatory Processes*Three different processes and requirements  
  - NRC technical assistance
-Licensed sites: Follow NRC decommissioning requirements and MML license requirements
  - Records
-NRC/DoD MOU sites: involvement at unlicensed sites; CERCLA/DERP requirements and MOU provisions
  - Service provider licenses
-Licensed service providers: DoD contractors conducting remediation at both licensed and MOU sites; NRC and/or Agreement State license requirements Conclusions
  - Funding
*MOU implementation has started
  - Dispute resolution
*AS and NRC will need to coordinate service
 
-provider activities
Implementation of MOU with DoD
*NRC's goal is to work with the Army towards successful MOU implementation without being disruptive to existing plans.}}
* DoD annual site inventory completed
* Two types of NRC involvement
  - Stay informed - EPA has regulatory oversight (NPL sites)
  - Monitoring - EPA does not have regulatory oversight (non-NPL site)
 
Benefits Resulting from the RIS and MOU
* Clarifies jurisdictional boundaries
* Avoids dual regulation
* Clarifies the regulatory approach for remediation
* Provides independent federal oversight to ensure protection of public health and safety
 
Potential Agreement State Involvement
* Keep each other informed
* Service provider license coordination
  - Jurisdictional questions
  - Coordination of activities at sites with dual jurisdiction
 
DoD Service Providers
* DoD service providers involved with remediation must have an NRC or AS license (e.g., reciprocity)
* NRC guidance on determining jurisdiction (FSME   039, Clarification on the Determination of Regulatory Jurisdiction of Nonfederal Entities Conducting Cleanup Activities on Federal Property in Agreement States.)
* Under the MOU
  - DoD verifies that its service providers use NRC guidance to determine appropriate license
  - DoD will provide appropriate land jurisdiction to service providers
* NRC plans to coordinate its service provider inspections with its future MOU activities
 
Three NRC Regulatory Processes
* Three different processes and requirements
    - Licensed sites: Follow NRC decommissioning requirements and MML license requirements
    - NRC/DoD MOU sites: involvement at unlicensed sites; CERCLA/DERP requirements and MOU provisions
    - Licensed service providers: DoD contractors conducting remediation at both licensed and MOU sites; NRC and/or Agreement State license requirements
 
Conclusions
* MOU implementation has started
* AS and NRC will need to coordinate service-provider activities
* NRCs goal is to work with the Army towards successful MOU implementation without being disruptive to existing plans.}}

Revision as of 15:56, 21 October 2019

MOU Between Dod and NRC - Meeting Slides
ML18075A079
Person / Time
Issue date: 03/16/2018
From: Richard Chang
Division of Decommissioning, Uranium Recovery and Waste Programs
To:
RChang DUWP
Shared Package
ML18075A077 List:
References
Download: ML18075A079 (20)
v • d • e


Text

MOU Between DoD and NRC Richard Chang NMSS/DUWP/MDB

Overview

  • Purpose
  • Background
  • Implementation of MOU with DoD
  • Potential Agreement State involvement
  • DoD service providers
  • Three NRC regulatory processes
  • Conclusions

Purpose

  • Give background on NRCs jurisdiction over radium
  • Discuss NRCs involvement with military remediation
  • Provide an update on the Memorandum of Understanding (MOU) and Regulatory Issue Summary (RIS)
  • Explain NRCs role under the MOU
  • Discuss the potential role for Agreement States (AS)

Background on NRCs Jurisdiction over Radium

  • Energy Policy Act of 2005 (EPAct) expanded the Atomic Energy Acts (AEA) definition of byproduct material to include discrete sources of radium-226
  • NRC regulations implemented provisions of the EPAct in 2007 and defined the term discrete source
  • A discrete source is a radionuclide that has been processed so that its concentration within a material has been purposely increased for use for commercial, medical, or research activities and any contamination from that source.

Background on NRCs Jurisdiction over Radium

  • NRC has jurisdiction over discrete sources of radium-226 used by the military in medical or research activities or in a manner similar to a commercial activity.
  • NRC does not have jurisdiction over radium-226 used by the military in military operations (e.g., combat or training)

Background on NRCs Jurisdiction over Radium

  • In 2007 the Commission directed the NRC staff to interact with DoD regarding military uses of radium
  • Uncertainty over precise meaning and scope of NRCs jurisdiction of military radium
  • MOU developed as a way for NRC and DoD to work together; avoid dual regulation; and avoid jurisdiction disagreements
  • NRC developed a RIS (2016-06) and MOU

RIS (2016-06)

  • Published May 9, 2016
  • Clarifies NRCs jurisdiction for military radium

- radium or items and equipment containing radium not used in or intended for use in military operations

- Confirmed contamination

  • Regulatory approaches

- MOU for confirmed contamination (radium and other unlicensed AEA material)

- Licensing for items and equipment

  • NRC responses to public comments on the draft RIS

MOU

  • Signed April 28, 2016
  • Purpose

- Minimize dual regulation while ensuring protection

- Documents roles, responsibilities, and relationship between NRC and DoD

  • Scope

- Sites with DoD response actions under CERCLA/DERP to address confirmed releases of unlicensed radioactive material subject to AEA

- Buildings being remediated, but not licensed

- Active installations, BRAC properties, and FUDS

MOU

- Communication/contacts

- Annual site inventory

- Coordination and planning

- Access to information and sites

- NRC involvement (stay informed or monitor)

- NRC dose criteria

- NRC technical assistance

- Records

- Service provider licenses

- Funding

- Dispute resolution

Implementation of MOU with DoD

  • DoD annual site inventory completed
  • Two types of NRC involvement

- Stay informed - EPA has regulatory oversight (NPL sites)

- Monitoring - EPA does not have regulatory oversight (non-NPL site)

Benefits Resulting from the RIS and MOU

  • Clarifies jurisdictional boundaries
  • Avoids dual regulation
  • Clarifies the regulatory approach for remediation
  • Provides independent federal oversight to ensure protection of public health and safety

Potential Agreement State Involvement

  • Keep each other informed
  • Service provider license coordination

- Jurisdictional questions

- Coordination of activities at sites with dual jurisdiction

DoD Service Providers

  • DoD service providers involved with remediation must have an NRC or AS license (e.g., reciprocity)
  • NRC guidance on determining jurisdiction (FSME 039, Clarification on the Determination of Regulatory Jurisdiction of Nonfederal Entities Conducting Cleanup Activities on Federal Property in Agreement States.)

- DoD verifies that its service providers use NRC guidance to determine appropriate license

- DoD will provide appropriate land jurisdiction to service providers

  • NRC plans to coordinate its service provider inspections with its future MOU activities

Three NRC Regulatory Processes

  • Three different processes and requirements

- Licensed sites: Follow NRC decommissioning requirements and MML license requirements

- NRC/DoD MOU sites: involvement at unlicensed sites; CERCLA/DERP requirements and MOU provisions

- Licensed service providers: DoD contractors conducting remediation at both licensed and MOU sites; NRC and/or Agreement State license requirements

Conclusions

  • MOU implementation has started
  • AS and NRC will need to coordinate service-provider activities
  • NRCs goal is to work with the Army towards successful MOU implementation without being disruptive to existing plans.
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