Nuclear Reactors COVID-19 Activities:
10 CFR Part 20 | 10 CFR Part 26 | 10 CFR 50.48 | 10 CFR 50.55a Codes & Standards | Owner's Activity Reports | 10 CFR Part 55 | 10 CFR Part 73 | Research & Test Reactors | Resident Inspectors | Approved Licensing Requests
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Licensees under 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities" can now use the online submission form identified on this page to request relief, in the form of alternatives, from certain NRC regulatory requirements in 10 CFR 50.55a, "Codes and Standards." The online form is limited to requests to use alternatives submitted under 10 CFR 50.55a(z).
Licensees submitting proprietary information should not use the online form and can submit this information consistent with the requirements of 10 CFR 50.4, "Written Communications."
Under 10 CFR Part 50.55a(z), "Alternatives to Codes and Standards Requirements," alternatives to the requirements of paragraphs 10 CFR 50.55a (b) through (h) or portions thereof must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or
(2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
On June 25, 2020, NRC held a public meeting to introduce the online form titled, "Request for Alternative Under 10 CFR 50.55a(z)(1) and (2)." NRC's presentation slides are available at ADAMS Accession No. ML20177A123.
Under the current emergency clearance through the Office of Management and Budget (OMB) (OMB No. 3150-0244), a licensee has the option to submit a request for an alternative via the online submission form if:
- the request for alternative is due to or is impacted by the COVID-19 public health emergency (PHE), such as social distancing at the site, or
- to provide flexibility in filing, for example, due to teleworking
The request for the permanent clearance through OMB is in process and would allow the online submission form to be used after the termination of the COVID-19 PHE.
On June 24, 2020, the NRC issued an information collection notice (Docket ID: NRC-2020-0145) for the NRC online form, "Request for Alternative under 10 CFR 50.55a(z)(1) and (z)(2)."
Frequently Asked Questions - 10 CFR Part 50.55a
1. Why is NRC creating an online submission form for requests for alternatives under 10 CFR 50.55a(z)?
The NRC is becoming a modern risk-informed regulator and the Web-based relief request (WRR) effort is part of this transformation effort. In addition, this effort is just one piece of a more comprehensive strategy to expand NRC's information technology (IT) capabilities and improve our interactions with internal and external stakeholders.
2. Which NRC licensees are eligible to use the online form?
Licensees under 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," may use this online submission form to request relief, in the form of alternatives, under 10 CFR 50.55a(z).
3. Can the online submission form be used for non-COVID-19 PHE related requests for alternatives under 10 CFR 50.55a(z)? Does the NRC intend to expand the scope of the online submission form to requests for alternatives that are not related to the COVID-19 PHE?
Under the current emergency clearance through OMB (OMB No. 3150-0244), a licensee has the option to submit a request for an alternative via the online submission form if:
- the request for alternative is due to or is impacted by COVID-19 PHE, such as social distancing at the site, or
- to provide flexibility in filing, for example, due to teleworking during the COVID-19 PHE.
The request for permanent clearance through OMB is in process and would allow the online submission form to be used after the termination of the COVID-19 PHE.
The NRC's overall vision is to provide an integrated web-portal system that allows licensees to build individual authenticated profiles, submit licensing actions, check on the status of previously submitted licensing requests, and review billing information.
4. Can licensees submit tables, figures, diagrams, etc. via the online submission form?
Licensees can submit attachments, including tables, figures, diagrams, etc., as part of the online submission form. Licensees will have the option to indicate if they need to submit attachments as part of their request on the form (Question 30). If the licensee selects 'Yes' to Question 30, a follow-up email will be sent to the licensee providing instructions on how to submit the attachments via email. Licensees will need to use their plant-specific Plant Identification Number (PIN), provided to them by their NRC Project Manager, to submit Attachments (NOTE: Keep your assigned PIN private and do not include it in any of your Attachments or document titles). Once the licensee submits the attachments, the attachments will be sent to the NRC Document Processing Center.
NOTE: Licensees who selected 'Yes' to Question 30 regarding attachments, will have 48 hours from the time of online submission to send in attachments. Failure to submit attachments within the 48-hour time period will prompt an automatic rejection of the licensee's online submission. Licensees have the opportunity to re-submit via the online form.
5. What happens if the Attachments do not satisfy the criteria for submission?
As noted in the question above, if a licensee indicates on the form that it will be submitting attachments, a follow-up email will be sent to the licensee providing instructions on how to submit the attachments via email. Attachments must be in PDF format and in compliance with Section 2.1 of Guidance for Electronic Submissions to the NRC, and the total file size should not exceed 10MB. If the attachments exceed 10MB, licensees can submit the attachments via multiple emails.
If the attachments do not satisfy the criteria for submission, then the licensee and cognizant NRC Project Manager will be notified by the NRC Document Processing Center that the submission has been rejected and the email will contain instructions for resubmission of the attachments. If a rejection occurs, the licensee has the option to re-send the corrected attachments via email.
6. Can a licensee submit more than one request for alternative at a time or fleet-wide requests for alternatives using the online submission form?
At this time, the online form only supports plant-specific submissions. The expansion of capabilities to include features like multiple or fleet-wide requests are being evaluated for the future online submission platform.
7. Is there a size limitation on the submission? Is there a file limitation on the attachments?
Several of the online form questions have a size limit of 4000 characters. NRC has created additional "open" questions to help accommodate the size restrictions (e.g., "Question 22. If needed, include additional information for Question 21").
There is a 10 MB size limit for attachments submitted via email. If the attachments exceed 10 MB, licensees can submit the attachments via multiple emails.
8. What happens if the licensee submits a request for alternative via the online submission form and makes an error? How is that corrected?
Licensees will follow the same process for correcting errors in their submittals by submitting a supplement via the Document Control Desk (DCD).
9. Can licensees continue to submit requests for alternatives under 10 CFR 50.55a(z) using the traditional methods, i.e., by mail or by electronic information exchange (EIE)?
Licensees can continue to submit requests for alternatives by mail or through EIE in accordance with the requirements in 10 CFR 50.4. The online submission form is an optional method for submitting requests for alternatives.
10. Are licensees going to submit less information in the request for alternative as a result of this web-based system? Will NRC be looking at less information to make a safety decision?
No. If the licensee chooses to use the web-based system, the level of information that the licensee submits will not change.
This online submission form does not reduce or relax any of the regulatory requirements for the licensee to submit certain information to the NRC.
11. Should the online submission form be used for a short-notice request for alternatives due to an emergent plant condition?
Licensees have the option of using the online submission form for all types of requests for alternatives, including short-notice requests. Licensees also have the option to submit these requests using the traditional methods (mail or EIE).
If verbal authorization is needed for short-notice requests, licensees have the option to submit the request for an alternative via the online submission form.
Page Last Reviewed/Updated Wednesday, October 14, 2020