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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 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
*NRC responses to public comments on the draft RIS MOU*Signed April 28, 2016
 
*Purpose-Minimize dual regulation while ensuring protection
RIS (2016-06)
-Documents roles, responsibilities
* Published May 9, 2016
,and relationship between NRC and DoD
* Clarifies NRCs jurisdiction for military radium
*Scope-Sites with DoD response actions under CERCLA/DERP to address confirmed releases of unlicensed radioactive material subject to AEA  
- radium or items and equipment containing radium not used in or intended for use in military operations
-Buildings being remediated, but not licensed
- Confirmed contamination
-Active installations, BRAC properties, and FUDS MOU*Content of MOU
* Regulatory approaches  
-Communication/contacts
- MOU for confirmed contamination (radium and other unlicensed AEA material)
-Annual site inventory
- Licensing for items and equipment
-Coordination and planning
* NRC responses to public comments on the draft RIS
-Access to information and sites
 
-NRC involvement (stay informed or monitor)
MOU
-NRC dose criteria
* Signed April 28, 2016
-NRC technical assistance  
* Purpose
-Records-Service provider licenses
- Minimize dual regulation while ensuring protection
-Funding-Dispute resolution Implementation of MOUwith DoD*DoD annual site inventory completed
- Documents roles, responsibilities, and relationship between NRC and DoD
*Two types of NRC involvement  
* Scope
-"Stay informed"
- Sites with DoD response actions under CERCLA/DERP to address confirmed releases of unlicensed radioactive material subject to AEA  
-EPA has regulatory oversight (NPL sites)-"Monitoring"
- Buildings being remediated, but not licensed
-EPA does not have regulatory oversight (non-NPL site)
- Active installations, BRAC properties, and FUDS
Benefits Resulting fromthe RIS and MOU
 
*Clarifies jurisdictional boundaries  
MOU
*Avoids dual regulation  
* Content of MOU
*Clarifies the regulatory approach for remediation  
- Communication/contacts
*Provides independent federal oversight to ensure protection of public health and safety Potential Agreement State Involvement
- Annual site inventory
*Keep each other informed  
- Coordination and planning
*Service provider license coordination
- Access to information and sites
-Jurisdictional questions
- NRC involvement (stay informed or monitor)
-Coordination of activities at sites with dual jurisdiction DoD Service Providers
- NRC dose criteria
*DoD service providers involved with remediation must have an NRC or AS license (e.g., reciprocity)
- NRC technical assistance  
*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  
- Records
-DoD verifies that its service providers use NRC guidance to determine appropriate license
- Service provider licenses
-DoD will provide appropriate land jurisdiction to service providers
- Funding
*NRC plans to coordinate its service provider inspections with its future MOU activities Three NRC Regulatory Processes*Three different processes and requirements  
- Dispute resolution
-Licensed sites: Follow NRC decommissioning requirements and MML license requirements
 
-NRC/DoD MOU sites: involvement at unlicensed sites; CERCLA/DERP requirements and MOU provisions
Implementation of MOU with DoD
-Licensed service providers: DoD contractors conducting remediation at both licensed and MOU sites; NRC and/or Agreement State license requirements Conclusions
* DoD annual site inventory completed
*MOU implementation has started
* Two types of NRC involvement  
*AS and NRC will need to coordinate service
- Stay informed - EPA has regulatory oversight (NPL sites)
-provider activities
- Monitoring - EPA does not have regulatory oversight (non-NPL site)
*NRC's goal is to work with the Army towards successful MOU implementation without being disruptive to existing plans.}}
 
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.}}

Latest revision as of 06:28, 6 January 2025

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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