ML20111A015

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Memorandum-COVID19 Resident Inspection Coverage
ML20111A015
Person / Time
Issue date: 04/17/2020
From: Andrea Kock
Office of Nuclear Material Safety and Safeguards
To: Laura Dudes, John Lubinski
Office of Nuclear Material Safety and Safeguards, NRC/RGN-II
Tiktinsky D
References
Download: ML20111A015 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 17, 2020 MEMORANDUM TO: John W. Lubinski, Director Office of Nuclear Material Safety and Safeguards Laura A. Dudes, Regional Administrator, RII FROM: Andrea L. Kock, Director Andrea L. Digitally signed by Andrea L. Kock Division of Fuel Management Kock Date: 2020.04.17 17:36:07

-04'00' Office of Nuclear Material Safety and Safeguards

SUBJECT:

IMPLEMENTATION OF RESIDENT INSPECTOR COVERAGE AT CATEGORY I FUEL FACILITIES DURING COVID-19 This memorandum provides guidance on resident office coverage at Category I fuel facilities during maximum teleworking for COVID-19. The purpose of this guidance is to protect the health of inspectors and site personnel, while maintaining oversight that supports reasonable assurance of adequate protection of public health and safety. The end date of this guidance is until further notice. The Division of Fuel Management (DFM) and the Division of Fuel Facility Inspection (DFFI) in RII will continue to assess this guidance and update it as needed.

The Region II Office is encouraged to use the attached table. Emphasis should be placed on maximizing the use of reduced on-site time to assess the licensees activities. Particular attention should be paid to the changing circumstances and how those affect the margin to safety. The Region II Office will have the flexibility to increase or decrease facility coverage based on the following considerations:

  • The specific health and safety circumstances of individual inspectors and their families, and availability of other inspectors as appropriate.
  • Facility risk configuration (e.g., items relied on for safety (IROFS), outage activities, planned maintenance activities, alternative staffing mechanisms).
  • Ability to maintain awareness of facility safety and safeguards performance (facility conditions and Corrective Action Program entries) and planned activities, e.g., outage work and maintenance activities, from the resident inspectors remote work locations, including the quality of connectivity and information availability.
  • The need to access classified information not available remotely.

CONTACT: Alayna N. Pearson, NMSS/DFM 301-415-3174

A. Kock, et al

  • The local COVID-19 conditions around the facility and the community where the inspectors reside, including directions from local authorities.

When elevated risk of COVID-19 infections are present in the local community or at a fuel facility, inspectors should contact regional management to determine the best practices to consider for remote and onsite activities, informed by licensee practices and requests, and coordinated with NRC COVID-19 guidance. Regional management should increase engagement with facility management as inspector coverage decreases.

Following the COVID-19 public health emergency, DFM and DFFI will assess impacts to the oversight program for fuel facilities and determine the need for a full or modified program. In the meantime, regional managers should work with inspectors to conduct the core program as appropriate, given the flexibilities and guidance in this memorandum.

Enclosure:

As stated cc: C. Regan

ML20106F226 OFFICE DFM/IOB RII/DFFI DFM NAME APearson LSuggs ALKock DATE 04/16/2020 04/16/2020 04/16/2020 DFFI Resident Office Site Coverage and Baseline Inspection During Maximum Teleworking for COVID-19 In support of Federal Government-wide efforts to maximize teleworking, this guidance is for Division of Fuel Facility Inspection (DFFI) Resident Inspector staff to support social distancing efforts, while maintaining site coverage using telework. NRC will continuously assess this guidance and update it accordingly as the situation develops. Effective immediately until further notice:

1) Resident inspectors are to establish remote access to the maximum extent made possible.
2) All resident inspector staff are to telework and practice social distancing techniques as described in the table.
3) Regional management shall determine the need for and authorize any onsite inspection activities if warranted, considering the guidance in the table.

Work Status Plant Status Event Response Baseline Inspections Consistent with IMC 2600 Practice social distancing when on Use remote means to the Inspections will be (ROI 0702) provisions site and follow site specific maximum extent possible to evaluated for ability to regarding site coverage, requirements for COVID-19. assess reportable events complete objectives each site should at a (such as, Appendix A to Part remotely or for deferral.

minimum be visited by a Remotely access licensee 70, 70.50, 70.52, safeguards resident once every six information using available report, etc.) and determine NMSS and the regions days, barring event technology. Focus on independent need for on-site response. will assess impacts to response requirements. review of important plant the baseline inspection Nominally, SRIs will visit parameters and status of COVID-19 Regional management program for all sites 1-2 times per week unless actions being taken by the licensee. (branch chief) will authorize after the COVID-19 determined otherwise by any on-site response for National Emergency Region II management. Acknowledging the limited nature risk-significant events such subsides.

of access permitted because of the as Emergency Response classified material controls, all Organization (ERO) available technology includes: activation and/or declared

  • Phones and email, including emergencies.

licensee bridge lines that may be set up for scheduled If onsite presence is briefings. authorized, respond to the site per IP 88135.02 and IP 88075.

Practice social distancing when on site and follow site specific requirements for COVID 19.

Enclosure