ML20141L766

Inspection Guidance During Transition from COVID-19 Mandatory Telework

ML20141L766
Person / Time
Issue date:	05/28/2020
From:	Ho Nieh Office of Nuclear Reactor Regulation
To:	Laura Dudes, Jack Giessner, Brian Holian, David Lew, Scott(Ois) Morris Office of Nuclear Security and Incident Response, NRC Region 1, NRC/RGN-II, NRC/RGN-III, NRC Region 4
McKenna P
References
Download: ML20141L766 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 28, 2020 MEMORANDUM TO: Brian Holian, Director, Office of Nuclear Security and Incident Response David C. Lew, Regional Administrator, RI Laura A. Dudes, Regional Administrator, RII Jack Giessner, Regional Administrator, RIII Scott A. Morris, Regional Administrator, RIV Digitally signed by Ho K.

FROM: Ho K. Nieh, Director Ho K. Nieh Nieh Date: 2020.05.28 Office of Nuclear Reactor Regulation 19:00:31 -04'00'

SUBJECT:

INSPECTION GUIDANCE DURING TRANSITION FROM COVID-19 MANDATORY TELEWORK This purpose of this memorandum is to provide guidance for the regional offices to increase the level of Reactor Oversight Process (ROP) inspection activities as COVID-19 restrictions begin to ease across the country. This memorandum supplements the April 6, 2020, memorandum, Updated Implementation of Resident Inspector Site Coverage During COVID-19 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20097E538) issued by the Office of Nuclear Reactor Regulations (NRR) Division of Reactor Oversight (DRO).

This guidance is intended to balance the importance of protecting the health and safety of our inspectors and site personnel along with the need to conduct effective oversight that supports NRCs critical safety mission. The considerations listed in the April 6 memorandum still apply and should be viewed as guiding principles for regional decisions to resume the NRCs on-site inspection by residents and regional inspectors. For your convenience, the considerations for determining whether to increase or decrease on-site inspection have been updated and provided here in this memo:

• Specific health and safety circumstances of individual inspectors and their families, and availability of other inspectors as appropriate;

• Plant risk configuration, including but not limited to, the availability of safety-related systems, outage activities, planned or emergent maintenance activities;

• The availability, connectivity and usefulness of remote technologies for inspectors to provide effective oversight of safety and security activities, including plant information (e.g., meetings, corrective action program, or other data);

• On-site COVID-19 conditions and trends; and

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

CONTACT: Philip J. McKenna, NRR/DRO 301-415-0037

This memorandum establishes the goal for the calendar year (CY) 2020 ROP to be completed with at least the minimum inspection samples for the baseline inspection program for each site.

The enclosure provides detailed guidance for specific ROP program elements in CY 2020.

Notwithstanding this stated goal, NRR is mindful that because of this unprecedented public health emergency, ROP completion and some performance metrics may not be met for CY 2020. The regions should consider the risks to our inspectors health and safety - and that of our licensees employees - when making decisions about inspection completion. The regions should use the normal processes described in Inspection Manual Chapter (IMC) 2515 to document ROP and program metric completion.

The regions, NRR, and the Office of Nuclear Security and Incident Response (NSIR) are encouraged to begin scheduling and implementing team and individual inspections. For team inspections, the dates should be planned and coordinated with the licensee.

Lastly, the regions are encouraged to leverage telework technology where such technologies can be shown to effectively accomplish the objectives of the NRCs inspection procedures and/or effectively minimize the further spread of COVID-19 during administrative aspects of the ROP (e.g., preparation and documentation, entrance and exit meetings, etc.).

NRR will continue to assess this guidance and update it as needed.

Enclosure:

CY 2020 ROP Completion Guidance

ML20141L766 Via e-mail NRR-106 OFFICE DRO/IRSB/BC* DRO/DD (A)* DRO/D* NRR/D*

NAME PMcKenna THipschman CMiller HNieh DATE 5/21/2020 5/28/2020 5/28/2020 5/28/2020 CY2020 ROP COMPLETION GUIDANCE May 28, 2020 ROP Program Implementation Guidance Comments Baseline Sample Completion (Metric I-1) Inspect to at least minimum Evaluate results of sample Reference (IMC 0307, App A, page 1): samples. (Nominal samples completion periodically. (See Note are acceptable if time 1) permits and adequate samples are available)

Team Inspections on a 3 Year and 2 Year Determine if portions of or Review periodically to gather data Cycle entire procedure can be if inspection cycle can be met completed remotely. when inspection is rescheduled.

Reschedule portions (See Note 6) requiring onsite activities or reschedule entire inspection to be to be completed on-site within the cycle.

Emergency Preparedness Inspections Rescheduled to be If graded exercises are Biennial Graded Exercise & Program completed within the cycle. rescheduled to the next calendar Inspections year, the biennial program inspection should be pulled into this calendar year to ensure inspection oversight is provided in CY2020.

Force-on-Force Inspections Efforts being made to Performing FOF inspections in a reschedule and complete graded approach: re-initiating within the cycle. However, modified A week activities in July continued COVID restrictions and tentatively planning B week may necessitate further activities to resume in August.

delays. Assessing site-specific conditions for licensees 6-8 weeks prior to planned inspections to make decisions.

Security Baseline Inspection Program: Rescheduled to be Staff is coordinating with regions completed within the cycle. to prioritize inspections when on-site travel restrictions are lifted.

Priority should be given to FoF and annual samples. For biennial and triennial IPs review periodically to gather data if inspection cycle can be met when inspections are rescheduled.

Temporary Instructions Extend due date as required. None Cyber Security Full Implementation Rescheduled to be All inspections previously Inspections completed within the cycle. scheduled to occur through June are being rescheduled to later in CY2020 or early CY 2021.

Radiation Safety Inspections Rescheduled to be On-site portion of inspections will Reference (IPs 71124.01 thru 08): completed within the cycle. be deferred until site access is (See Note 3) restored.

Vogtle 3&4 TBD ITAAC inspections in the transition plan.

Enclosure

Vendor Inspection Program A revised FY2020 inspection Goal of conducting 20 schedule has been planned. inspections per FY could be in jeopardy.

Reactive Inspections (Metric E-2) No effect on implementation. Reactive inspections can be Reference (IMC 0307 App A, page 8) performed. Evaluate on a case by case basis.

Completion of Supplemental Inspections Evaluate on a case by case With current status of the (Metric E-1) basis. Action Matrix, very few Reference (IMC 0307 App A, page 8) supplemental inspections planned.

Deep backshift inspections hours No effect on implementation. IMC 2515 requirement is 50 Reference (IMC 2515, page 16) hours per site.

ROP Performance Indicators ERO participation PI possibly Revisit FAQ to ensure existing Reference (IMC 0608) affected. FAQ 20-02 approved extension date (12/31/2020) to address impacts. remains sufficient.

Inspector Objectivity Reviews by Perform as reasonably Review progress but do not Supervisors (Metric I-4). Reference (IMC achievable. hold regions accountable for 0307, App A, page 3) metric in CY2020.

Senior Management on Site Visits Perform as reasonably Prioritize visits based on Reference (IMC 0102, pages 7-8) achievable. oversight needs.

ROP Annual Audit at Region IV No effect on implementation. Perform entire audit remotely if Reference (IMC 0307, App C draft) in-person audit cannot reasonably be scheduled.

Permanent Site Staffing (Metric I-6) No expected effect on Each site should be evaluated Reference (IMC 0307, App A, page 4) implementation. on a case by case basis.

Public Engagement Annual Assessment No effect on implementation. Regions can perform virtual Meetings (Metric O-3) public meetings or other public Reference (IMC 0307, App A, page 6) engagement activities per IMC 0305.

SDP detailed risk evaluations requiring site No effect on implementation. If exceeded explain in 2020 visits and associated delays - 255-day SDP Self-Assessment.

Reference (IMC 0307, App A, page 9)

ADR/Reg Conferences/PEC delays No effect on implementation. All activities could be performed virtually.

Initial Inspector Qualification No effect on implementation. Inspector supervisors are Reference (IMC 1245, page 5) already managing their qualification programs.

Inspector Requalification (Metric I-5) No effect on implementation. IMC 1245 already covers the Reference (IMC 0307, App A, page 3) deviation process.

Resident Inspector Objectivity Visits to SRI/RIs can still perform if Review progress but do not Other Sites (Metric I-3) reasonably achievable. hold regions accountable for Reference (IMC 0307, App A, page 2) metric in CY2020.

2020 ROP self-assessment No effect on implementation. None.

Reference (IMC 0307)

Operator Licensing Various effects on Conducting Initial Operator Reference (NUREG 1021) implementation. (See Note 2) License Examinations during COVID-19 guidance has been given to the Regions. (See Note 7)

Notes on Potential Problem Areas in completing the CY2020 ROP:

1. IP 71111.20, REFUELING AND OTHER OUTAGE ACTIVITIES has 18 high level requirements to complete the IP. Some high-level requirements are very specific (i.e. If containment is opened, conduct a walkdown of containment just before closure).

IMC 2515 states that the inspector is to perform the inspection requirements most appropriate to the activity being inspected in order to declare an activity (sample) as being satisfactorily completed. Inspectors that do not complete a high-level requirement when it is available to be completed will need to document the IP as partially completed.

For IP 71111.20, there is no means to go back and complete the missed requirement.

2. IP 71111.11B, LICENSED OPERATOR REQUALIFICATION PROGRAM is performed by the DRS operating license examiners. Sites perform simulator requalification examinations every year, and the requalification inspection is performed on a two-year cycle. Regional inspections of simulator exams at some sites are currently in their second year and DRS inspectors may not be able to travel to the site to inspect this portion of 71111.11B (i.e. Observe the administration of simulator scenarios and JPMs during the conduct of an annual requalification operating test required by 10 CFR 55.59(a)(2).). Sites usually perform these over a six-week period to hit every operating crew. Regions may not be able to inspect this part of 71111.11B at some sites. This would also make this IP partially complete with no means to go back and complete it during the 2-year inspection cycle.

3. IP71124.01, RADIOLOGICAL HAZARD ASSESSMENT AND EXPOSURE CONTROLS, is performed by regional inspectors annually. The IP states: Inspections should be performed during a refueling outage (RFO) or when radiologically significant work is being performed. When appropriately risk-informed samples are not available for inspection follow completion guidance of IMC 0306 section 06.08.f.3 (Note: Not highlighted in the procedure). The problem is for sites that have completed refueling outages this year and this sample was not completed on site. DRA is evaluating if the IP can be completed when the regional RP inspectors eventually go back on site this year (even though the RFO has been completed).

4. IPs 71114.01, EXERCISE EVALUATION, and 71114.07, HOSTILE ACTION EVENT could be a challenge for regional EP inspectors to complete if too many EP exercises are postponed. IP 71114.06, DRILL EVALUATION, can be completed by the resident inspector when licensees resume EP drills. NSIR will closely coordinate these evaluations for the remainder of the year.

Other Notes:

5. IMC 0306, PLANNING, SCHEDULING, TRACKING, AND REPORTING OF THE REACTOR OVERSIGHT PROCESS (ROP), section 06.08 gives guidance on Inspection Procedure Completion Status. This guidance discusses guidance for marking samples as Complete, Complete - by Reference, Complete - minimum sample not available, Complete - opportunity to apply full procedure not available, and Complete - in previous year(s).

6. For inspections conducted on a 2, 3, or other year cycle, it is anticipated that for the inspections being scheduled during the earlier parts of the cycle, the inspection will likely be able to be accomplished on time, given licensee and NRC staff availability. If the inspection to be scheduled is in the latter part of the cycle, availability of licensee staff to be able to support inspections and other onsite activities (INPO and other utility onsite visit activities, Operator Licensing Exams, etc.) and availability of NRC inspection resources may challenge the ability to complete the inspection on time. In those cases, the considerations in the cover memo to this attachment should be used to determine the priority for scheduling the inspection.

7. Conducting Initial Operator License Examinations during COVID-19 guidance has been provided to the regions to support continuance of Operator Licensing (OL) exams, which play a mission critical part in ensuring that sufficient licensed operators are available to support safe operations. A copy of the guidance memo is available to NRC staff on the NRR/DRO/IRIB Pandemic Inspection Guidance and Resources SharePoint site.