ML20120A003
| ML20120A003 | |
| Person / Time | |
|---|---|
| Issue date: | 05/14/2020 |
| From: | John Lubinski, Ho Nieh Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| To: | Bakken C, Moul D, Uhle J Entergy Nuclear, Florida Power & Light Co, Nuclear Energy Institute |
| Poole J | |
| References | |
| Download: ML20120A003 (14) | |
Text
May 14, 2020 Dr. Jennifer L. Uhle Vice President, Generation & Suppliers Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION PLANNED ACTIONS RELATED TO EMERGENCY PREPAREDNESS BIENNIAL EXERCISE REQUIREMENTS FOR ALL LICENSEES DURING THE CORONAVIRUS DISEASE 2019 PUBLIC HEALTH EMERGENCY
Dear Dr. Uhle:
As you know, on January 31, 2020, the U.S. Department of Health and Human Services declared a public health emergency (PHE) for the United States to aid the nations healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 11, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization.
As discussed during a public meeting held on March 20, 2020, with nuclear industry representatives and members of the public, this is an unprecedented time for our country, the U.S. Nuclear Regulatory Commission (NRC), and its regulated entities. In all of our actions, we are committed to following the NRCs Principles of Good Regulation (independence, openness, efficiency, clarity, and reliability) while performing our mission. In keeping with our principles, this letter provides information regarding the NRCs planned actions related to the requirements contained in Title 10 of the Code of Federal Regulations (10 CFR) for full participation biennial exercises during the COVID-19 PHE. This information is applicable to all NRC licensees under Parts 30, 40, 50, 52, 70, and 72 that have a radiological emergency plan.
Under the NRCs regulations in 10 CFR 30.11, 10 CFR 40.14, 10 CFR 50.12(a), 10 CFR 52.7, 10 CFR 70.17, 10 CFR 72.7, the Commission may grant exemptions from its regulations, subject to certain requirements in each of these sections. Exemption requests submitted in response to this letter would need to address the exemption requirements that apply to the applicable part of the NRCs regulations. Consistent with these regulations and as described in this letter, the NRC is prepared to consider on an expedited basis requests for exemptions, upon request from individual licensees, from the biennial emergency plan exercise requirements that are specified in 10 CFR 30.32(i)(3)(xii), 10 CFR 40.31(j)(3)(xii), 10 CFR Part 50, Appendix E.IV.F, 10 CFR 70.22(i)(3)(xii), and 10 CFR 72.32(a)(12)(i) and (ii). These exemptions would, if granted, ensure that licensees engage in activities that do not conflict with practices recommended by the Centers for Disease Control and Prevention to limit the spread of COVID-19.0F1 Biennial exercises, particularly those that integrate onsite and offsite performance, typically require significant resources to schedule, perform, and evaluate (including NRC and the Federal Emergency Management (FEMA) evaluators (if applicable)).
Limitations on the availability of those resources could require an exercise currently scheduled 1 https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html
J. Uhle in calendar year (CY) 2020 to be postponed. The NRC expects a licensee to make a reasonable effort to reschedule the exercise date during CY 2020. But if the licensee cannot coordinate and reschedule the exercise date during CY 2020, then the licensee will need to submit an exemption request to conduct the exercise at some reasonable time in the future (e.g., CY 2021). The NRC notes the guidance in Regulatory Issue Summary (RIS) 2006-003, Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements, dated February 24, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML053390039), provides guidance for Part 50 licensees seeking exemptions in this area. While this RIS is applicable to Part 50 licensees, it may provide useful guidance for Part 30, 40, 52, 70, and 72 licensees. Additionally, a joint NRC and FEMA memorandum to their respective regions provided information in this area via Guidance for Postponement of REP (Radiological Emergency Preparedness) Exercises Due to the COVID-19 Outbreak, dated March 27, 2020 (ADAMS Accession No. ML20085F705).
Requested Information To receive expedited review of an exemption request, a licensee should submit a request that contains the following information:
the licensees last biennial exercise date; the licensees current biennial exercise date; a statement that the licensee has made a reasonable effort to reschedule the exercise during CY 2020, but was unsuccessful; Per RIS 2006-03 and consistent with similar exemptions granted for issues like hurricanes that have impacted exercise scheduling, a statement that the licensee will reschedule the conduct of the biennial exercise within 35 months from the month in which the previously evaluated exercise was conducted in CY 2018; a statement that if an exemption is granted to allow the licensee to conduct the CY 2020 biennial exercise in CY 2021, that future biennial exercises will continue to be held in even years; a statement that the licensee conducted drills, exercises, and other training activities that exercised its emergency response strategies, in coordination with offsite authorities, since the previous biennial exercise; and a statement that the rescheduled biennial exercise has been, or will be, coordinated with the applicable offsite response organizations (if offsite response organization participation is required), the applicable NRC Region, and the applicable FEMA Region.
How to Submit Requests Licensees should make every effort to submit timely exemption requests. Licensees should continue to follow 10 CFR 30.6, Communications, 10 CFR 40.5, Communications, 10 CFR 50.4, Written communications, 10 CFR 52.3, Written communications, 10 CFR 70.5, Communications, or 10 CFR 72.4, Communications, as appropriate. To ensure timely
J. Uhle receipt and review of these exemption requests, licensees should also send an email with the request to their facilitys NRC project manager, in addition to submitting the application as provided in NRC regulations.
Review Process The NRC will consider these requests on a case-by-case basis and, if the requirements for an exemption are met, will provide a written decision. Based upon its review, the NRC staff may condition any exemption approval, as appropriate. If sufficient time is not available for the NRC to provide a prior written decision for the exemption, then the NRC may provide a verbal decision that will be followed promptly with a letter documenting the approval or denial of the request.
Duration of Exemptions Exemptions that are approved under this process would be in effect until the performance of the rescheduled biennial exercise per the specific direction of the NRCs approval of the exemption.
Licensees must come back into compliance with the regulations or receive approval for an additional exemption period from the NRC before the end of each exemption period.
Alternative Approaches This letter does not preclude requests for exemptions that take a different approach or present different rationales. The NRC will review such requests on a case-by-case basis.
If you have any further questions about the contents of this letter, please contact your facilitys NRC project manager.
Paperwork Reduction Act Statement This letter contains guidance for implementing the voluntary information collections related to requesting exemptions from requirements contained in 10 CFR Parts 30, 40, 50, 52, 70, and 72 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et. seq.). These information collections were approved by the Office of Management and Budget under control numbers 3150-0017, -0020, -0011, -0151, -0009, and -0132, respectively. Estimated burden per response to comply with this voluntary information collection request is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Send comments regarding these information collections to the Information Services Branch (T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, Office of Management and Budget, Washington, DC 20503.
J. Uhle Public Protection Notification The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid Office of Management and Budget control number.
Sincerely, Sincerely, Ho K. Nieh, Director John W. Lubinski, Director Office of Nuclear Reactor Regulation Office of Nuclear Material Safety and Safeguards Ho K.
Nieh Digitally signed by Ho K. Nieh Date: 2020.05.14 12:09:24 -04'00' Robert Lewis Digitally signed by Robert Lewis Date: 2020.05.14 10:55:16 -04'00'
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION PLANNED ACTIONS RELATED TO EMERGENCY PREPAREDNESS BIENNIAL REQUIREMENTS FOR ALL LICENSEES DURING THE CORONAVIRUS DISEASE 2019 PUBLIC HEALTH EMERGENCY MAY 14, 2020 Identical letters sent to:
Dr. Jennifer L. Uhle Vice President, Generation & Suppliers Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 Mr. Chris Bakken Executive Vice President Nuclear Operations & Chief Nuclear Officer Entergy Nuclear 1340 Echelon Parkway Jackson, MS 39213 Mr. Don Moul Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: NT3/JW 15430 Endeavor Drive Jupiter, FL 33478
- via email OFFICE NSIR/DPR/POB/BC*
NSIR/DRP/RLB/BC*
NRR/DORL/LPL1/BC*
NSIR/DPR/D*
NAME BKahler JAnderson JDanna KBrock DATE 04/30/2020 05/01/2020 05/04/2020 05/04/2020 OFFICE NMSS/DFM/D*
NMSS/DUWP/D*
NRR/DORL/D*
OGC - NLO*
NAME AKock Holahan CErlanger TCampbell DATE 05/04/2020 05/01/2020 05/04/2020 05/06/2020 OFFICE NMSS/D*
NRR/D*
NAME JLubinski (RLewis for)
HNieh DATE 05/14/2020 05/14/2020
May 14, 2020 Mr. Chris Bakken Executive Vice President Nuclear Operations & Chief Nuclear Officer Entergy Nuclear 1340 Echelon Parkway Jackson, MS 39213
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION PLANNED ACTIONS RELATED TO EMERGENCY PREPAREDNESS BIENNIAL REQUIREMENTS FOR ALL LICENSEES DURING THE CORONAVIRUS DISEASE 2019 PUBLIC HEALTH EMERGENCY
Dear Mr. Bakken:
As you know, on January 31, 2020, the U.S. Department of Health and Human Services declared a public health emergency (PHE) for the United States to aid the nations healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 11, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization.
As discussed during a public meeting held on March 20, 2020, with nuclear industry representatives and members of the public, this is an unprecedented time for our country, the U.S. Nuclear Regulatory Commission (NRC), and its regulated entities. In all of our actions, we are committed to following the NRCs Principles of Good Regulation (independence, openness, efficiency, clarity, and reliability) while performing our mission. In keeping with our principles, this letter provides information regarding the NRCs planned actions related to the requirements contained in Title 10 of the Code of Federal Regulations (10 CFR) for full participation biennial exercises during the COVID-19 PHE. This information is applicable to all NRC licensees under Parts 30, 40, 50, 52, 70, and 72 that have a radiological emergency plan.
Under the NRCs regulations in 10 CFR 30.11, 10 CFR 40.14, 10 CFR 50.12(a), 10 CFR 52.7, 10 CFR 70.17, 10 CFR 72.7, the Commission may grant exemptions from its regulations, subject to certain requirements in each of these sections. Exemption requests submitted in response to this letter would need to address the exemption requirements that apply to the applicable part of the NRCs regulations. Consistent with these regulations and as described in this letter, the NRC is prepared to consider on an expedited basis requests for exemptions, upon request from individual licensees, from the biennial emergency plan exercise requirements that are specified in 10 CFR 30.32(i)(3)(xii), 10 CFR 40.31(j)(3)(xii), 10 CFR Part 50, Appendix E.IV.F, 10 CFR 70.22(i)(3)(xii), and 10 CFR 72.32(a)(12)(i) and (ii). These exemptions would, if granted, ensure that licensees engage in activities that do not conflict with practices recommended by the Centers for Disease Control and Prevention to limit the spread of COVID-19.1F1 Biennial exercises, particularly those that integrate onsite and offsite performance, typically require significant resources to schedule, perform, and evaluate (including NRC and the Federal Emergency Management (FEMA) evaluators (if applicable)).
1 https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html
C. Bakken Limitations on the availability of those resources could require an exercise currently scheduled in calendar year (CY) 2020 to be postponed. The NRC expects a licensee to make a reasonable effort to reschedule the exercise date during CY 2020. But if the licensee cannot coordinate and reschedule the exercise date during CY 2020, then the licensee will need to submit an exemption request to conduct the exercise at some reasonable time in the future (e.g., CY 2021). The NRC notes the guidance in Regulatory Issue Summary (RIS) 2006-003, Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements, dated February 24, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML053390039), provides guidance for Part 50 licensees seeking exemptions in this area. While this RIS is applicable to Part 50 licensees, it may provide useful guidance for Part 30, 40, 52, 70, and 72 licensees. Additionally, a joint NRC and FEMA memorandum to their respective regions provided information in this area via Guidance for Postponement of REP (Radiological Emergency Preparedness) Exercises Due to the COVID-19 Outbreak, dated March 27, 2020 (ADAMS Accession No. ML20085F705).
Requested Information To receive expedited review of an exemption request, a licensee should submit a request that contains the following information:
the licensees last biennial exercise date; the licensees current biennial exercise date; a statement that the licensee has made a reasonable effort to reschedule the exercise during CY 2020, but was unsuccessful; Per RIS 2006-03 and consistent with similar exemptions granted for issues like hurricanes that have impacted exercise scheduling, a statement that the licensee will reschedule the conduct of the biennial exercise within 35 months from the month in which the previously evaluated exercise was conducted in CY 2018; a statement that if an exemption is granted to allow the licensee to conduct the CY 2020 biennial exercise in CY 2021, that future biennial exercises will continue to be held in even years; a statement that the licensee conducted drills, exercises, and other training activities that exercised its emergency response strategies, in coordination with offsite authorities, since the previous biennial exercise; and a statement that the rescheduled biennial exercise has been, or will be, coordinated with the applicable offsite response organizations (if offsite response organization participation is required), the applicable NRC Region, and the applicable FEMA Region.
How to Submit Requests Licensees should make every effort to submit timely exemption requests. Licensees should continue to follow 10 CFR 30.6, Communications, 10 CFR 40.5, Communications, 10 CFR 50.4, Written communications, 10 CFR 52.3, Written communications, 10 CFR 70.5, Communications, or 10 CFR 72.4, Communications, as appropriate. To ensure timely
C. Bakken receipt and review of these exemption requests, licensees should also send an email with the request to their facilitys NRC project manager, in addition to submitting the application as provided in NRC regulations.
Review Process The NRC will consider these requests on a case-by-case basis and, if the requirements for an exemption are met, will provide a written decision. Based upon its review, the NRC staff may condition any exemption approval, as appropriate. If sufficient time is not available for the NRC to provide a prior written decision for the exemption, then the NRC may provide a verbal decision that will be followed promptly with a letter documenting the approval or denial of the request.
Duration of Exemptions Exemptions that are approved under this process would be in effect until the performance of the rescheduled biennial exercise per the specific direction of the NRCs approval of the exemption.
Licensees must come back into compliance with the regulations or receive approval for an additional exemption period from the NRC before the end of each exemption period.
Alternative Approaches This letter does not preclude requests for exemptions that take a different approach or present different rationales. The NRC will review such requests on a case-by-case basis.
If you have any further questions about the contents of this letter, please contact your facilitys NRC project manager.
Paperwork Reduction Act Statement This letter contains guidance for implementing the voluntary information collections related to requesting exemptions from requirements contained in 10 CFR Parts 30, 40, 50, 52, 70, and 72 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et. seq.). These information collections were approved by the Office of Management and Budget under control numbers 3150-0017, -0020, -0011, -0151, -0009, and -0132, respectively. Estimated burden per response to comply with this voluntary information collection request is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Send comments regarding these information collections to the Information Services Branch (T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, Office of Management and Budget, Washington, DC 20503.
C. Bakken Public Protection Notification The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid Office of Management and Budget control number.
Sincerely, Sincerely, Ho K. Nieh, Director John W. Lubinski, Director Office of Nuclear Reactor Regulation Office of Nuclear Material Safety and Safeguards Ho K.
Nieh Digitally signed by Ho K. Nieh Date: 2020.05.14 12:09:54 -04'00' Robert Lewis Digitally signed by Robert Lewis Date: 2020.05.14 10:56:01 -04'00'
May 14, 2020 Mr. Don Moul Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: NT3/JW 15430 Endeavor Drive Jupiter, FL 33478
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION PLANNED ACTIONS RELATED TO EMERGENCY PREPAREDNESS BIENNIAL REQUIREMENTS FOR ALL LICENSEES DURING THE CORONAVIRUS DISEASE 2019 PUBLIC HEALTH EMERGENCY
Dear Mr. Moul:
As you know, on January 31, 2020, the U.S. Department of Health and Human Services declared a public health emergency (PHE) for the United States to aid the nations healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 11, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization.
As discussed during a public meeting held on March 20, 2020, with nuclear industry representatives and members of the public, this is an unprecedented time for our country, the U.S. Nuclear Regulatory Commission (NRC), and its regulated entities. In all of our actions, we are committed to following the NRCs Principles of Good Regulation (independence, openness, efficiency, clarity, and reliability) while performing our mission. In keeping with our principles, this letter provides information regarding the NRCs planned actions related to the requirements contained in Title 10 of the Code of Federal Regulations (10 CFR) for full participation biennial exercises during the COVID-19 PHE. This information is applicable to all NRC licensees under Parts 30, 40, 50, 52, 70, and 72 that have a radiological emergency plan.
Under the NRCs regulations in 10 CFR 30.11, 10 CFR 40.14, 10 CFR 50.12(a), 10 CFR 52.7, 10 CFR 70.17, 10 CFR 72.7, the Commission may grant exemptions from its regulations, subject to certain requirements in each of these sections. Exemption requests submitted in response to this letter would need to address the exemption requirements that apply to the applicable part of the NRCs regulations. Consistent with these regulations and as described in this letter, the NRC is prepared to consider on an expedited basis requests for exemptions, upon request from individual licensees, from the biennial emergency plan exercise requirements that are specified in 10 CFR 30.32(i)(3)(xii), 10 CFR 40.31(j)(3)(xii), 10 CFR Part 50, Appendix E.IV.F, 10 CFR 70.22(i)(3)(xii), and 10 CFR 72.32(a)(12)(i) and (ii). These exemptions would, if granted, ensure that licensees engage in activities that do not conflict with practices recommended by the Centers for Disease Control and Prevention to limit the spread of COVID-19.2F1 Biennial exercises, particularly those that integrate onsite and offsite 1 https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html
D. Moul performance, typically require significant resources to schedule, perform, and evaluate (including NRC and the Federal Emergency Management (FEMA) evaluators (if applicable)).
Limitations on the availability of those resources could require an exercise currently scheduled in calendar year (CY) 2020 to be postponed. The NRC expects a licensee to make a reasonable effort to reschedule the exercise date during CY 2020. But if the licensee cannot coordinate and reschedule the exercise date during CY 2020, then the licensee will need to submit an exemption request to conduct the exercise at some reasonable time in the future (e.g., CY 2021). The NRC notes the guidance in Regulatory Issue Summary (RIS) 2006-003, Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements, dated February 24, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML053390039), provides guidance for Part 50 licensees seeking exemptions in this area. While this RIS is applicable to Part 50 licensees, it may provide useful guidance for Part 30, 40, 52, 70, and 72 licensees. Additionally, a joint NRC and FEMA memorandum to their respective regions provided information in this area via Guidance for Postponement of REP (Radiological Emergency Preparedness) Exercises Due to the COVID-19 Outbreak, dated March 27, 2020 (ADAMS Accession No. ML20085F705).
Requested Information To receive expedited review of an exemption request, a licensee should submit a request that contains the following information:
the licensees last biennial exercise date; the licensees current biennial exercise date; a statement that the licensee has made a reasonable effort to reschedule the exercise during CY 2020, but was unsuccessful; Per RIS 2006-03 and consistent with similar exemptions granted for issues like hurricanes that have impacted exercise scheduling, a statement that the licensee will reschedule the conduct of the biennial exercise within 35 months from the month in which the previously evaluated exercise was conducted in CY 2018; a statement that if an exemption is granted to allow the licensee to conduct the CY 2020 biennial exercise in CY 2021, that future biennial exercises will continue to be held in even years; a statement that the licensee conducted drills, exercises, and other training activities that exercised its emergency response strategies, in coordination with offsite authorities, since the previous biennial exercise; and a statement that the rescheduled biennial exercise has been, or will be, coordinated with the applicable offsite response organizations (if offsite response organization participation is required), the applicable NRC Region, and the applicable FEMA Region.
How to Submit Requests Licensees should make every effort to submit timely exemption requests. Licensees should continue to follow 10 CFR 30.6, Communications, 10 CFR 40.5, Communications, 10 CFR 50.4, Written communications, 10 CFR 52.3, Written communications, 10 CFR 70.5,
D. Moul Communications, or 10 CFR 72.4, Communications, as appropriate. To ensure timely receipt and review of these exemption requests, licensees should also send an email with the request to their facilitys NRC project manager, in addition to submitting the application as provided in NRC regulations.
Review Process The NRC will consider these requests on a case-by-case basis and, if the requirements for an exemption are met, will provide a written decision. Based upon its review, the NRC staff may condition any exemption approval, as appropriate. If sufficient time is not available for the NRC to provide a prior written decision for the exemption, then the NRC may provide a verbal decision that will be followed promptly with a letter documenting the approval or denial of the request.
Duration of Exemptions Exemptions that are approved under this process would be in effect until the performance of the rescheduled biennial exercise per the specific direction of the NRCs approval of the exemption.
Licensees must come back into compliance with the regulations or receive approval for an additional exemption period from the NRC before the end of each exemption period.
Alternative Approaches This letter does not preclude requests for exemptions that take a different approach or present different rationales. The NRC will review such requests on a case-by-case basis.
If you have any further questions about the contents of this letter, please contact your facilitys NRC project manager.
Paperwork Reduction Act Statement This letter contains guidance for implementing the voluntary information collections related to requesting exemptions from requirements contained in 10 CFR Parts 30, 40, 50, 52, 70, and 72 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et. seq.). These information collections were approved by the Office of Management and Budget under control numbers 3150-0017, -0020, -0011, -0151, -0009, and -0132, respectively. Estimated burden per response to comply with this voluntary information collection request is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Send comments regarding these information collections to the Information Services Branch (T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, Office of Management and Budget, Washington, DC 20503.
D. Moul Public Protection Notification The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid Office of Management and Budget control number.
Sincerely, Sincerely, Ho K. Nieh, Director John W. Lubinski, Director Office of Nuclear Reactor Regulation Office of Nuclear Material Safety and Safeguards Ho K.
Nieh Digitally signed by Ho K. Nieh Date: 2020.05.14 12:10:18 -04'00' Robert Lewis Digitally signed by Robert Lewis Date: 2020.05.14 10:56:20 -04'00'