ML21295A302
| ML21295A302 | |
| Person / Time | |
|---|---|
| Issue date: | 11/02/2021 |
| From: | Andrea Veil NRC/NRR/DRO |
| To: | Laura Dudes, Mirela Gavrilas, Jack Giessner, David Lew, Scott(Ois) Morris Office of Nuclear Security and Incident Response, NRC Region 1, NRC/RGN-II, NRC/RGN-III, NRC Region 4 |
| Thomas Hipschman NRR/DRO/IRIB 415-1169 | |
| References | |
| Download: ML21295A302 (6) | |
Text
MEMORANDUM TO:
Mirella Gavrilas, 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 FROM:
Andrea Veil, Director Office of Nuclear Reactor Regulation
SUBJECT:
IMPLEMENTATION OF INSPECTION PROGRAMS FOLLOWING RE-ENTRY FROM THE PUBLIC HEALTH EMERGENCY FOR THE REACTOR SAFETY PROGRAM This purpose of this memorandum is to supplement the guidance in MC 2515 Light-Water Reactor Inspection Program Operations Phase, and IMC 2515 Appendix E, Inspection Program Modifications During Pandemics, Epidemics or Other Widespread Illnesses and Diseases to aid in the performance of the Reactor Oversight Process (ROP) inspection activities as COVID-19 conditions and restrictions change across the country. This memorandum also supersedes 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), the May 28, 2020 memorandum, Inspection Guidance During Transition From Covid-19 Mandatory Telework (ML20141L766) and the February 1, 2021 memorandum, Calendar Year 2021 Inspection Guidance During Covid-19 Telework Restrictions,, (ML21027A274) issued by the Office of Nuclear Reactor Regulations (NRR) Division of Reactor Oversight (DRO).
CONTACT: Kimyata Morgan-Butler, NRR/DRO (301) 415-0733 Thomas Hipschman, NRR/DRO (301) 415-1169 November 2, 2021 King, Michael signing on behalf of Veil, Andrea on 11/02/21
M. Gavrilas, et al Effective November 7, 2021, inspection programs should continue to be implemented in accordance with the inspection manual and procedures, as well as the additional guidance provided in this memo. During COVID-19 some activities were reduced in frequency and support functions curtailed. The inspection program retained the required activities to ensure the facilities operated safely. Although the Public Health Emergency continues, based on current conditions in country, the facilities and the workspaces are in a safe condition to support full implementation.
Although most inspection and oversight (regional and resident) activities should be conducted on-site, any such site-specific conditions that could impact the health and safety of the inspectors will continue to be addressed by the cognizant regional office in coordination with the program office. Regional inspections may continue to use the flexibilities, as appropriate, leveraged during the COVID-19 Public Health Emergency (PHE) such as completing inspections objectives and sample requirements using alternative methods (remotely) or as hybrid inspections (with concurrent and/or onsite follow-up remote activities). This guidance is intended to balance the importance of protecting the health and safety of our staff with the need to conduct effective oversight that supports NRCs critical safety mission.
The following considerations should be viewed as guiding principles for regional decision-making when planning on-site activities:
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 or are traveling to, including directions from local authorities.
In conjunction with the principles above, the intent is to perform inspection activities onsite and to complete the nominal baseline inspection samples for the current and future inspection cycles. This also includes returning to normal onsite presence by resident inspectors and conducting region-based inspections onsite to the extent that is safely possible. Inspectors and regional management should refer to IMC 2515, Appendix E, Inspection Program Modifications During Pandemics, Epidemics, or Other Widespread Illnesses or Diseases, the August 17, 2021 memorandum Resident Inspector Telework Guidance (Post Re-Entry) (ML21229A139),
and this memorandum for guidance associated with performance of oversight activities.
M. Gavrilas, et al The enclosure provides additional detailed guidance for specific ROP program elements in addition to IMC 2515, and IMC 2515 Appendix E. NRR is mindful that because of the ongoing and changing pandemic, ROP completion and some performance metrics may not be met for Calendar Year 2021. Regional office managers should consider the risks to our inspectors health and safety and that of licensees employees when making decisions about inspection completion. The regions should use the normal processes described in IMC 2515 to document ROP and program metric completion.
NRR will continue to assess this guidance and update it as needed. NRR has coordinated with NMSS on issuing parallel guidance for their licensees.
Enclosure:
CY 2021 ROP Completion Guidance
- Via e-mail OFFICE NRR/DRO NRR/DRO/DD NRR/DRO NRR/D NAME THipschman*
KMorgan-Butler(A)*
CRegan*
AVeil* (MKing for)
DATE 10/26/2021 10/26/2021 10/29/2021 11/2/2021
ADDITIONAL CY 2021 ROP COMPLETION GUIDANCE Enclosure ROP Program Implementation Guidance Comments Vendor Inspection Program A revised FY2022 inspection schedule has been planned to use the IQVB COVID-19 inspection selection strategy.
Combination of virtual and onsite inspections/audits will be conducted.
Goal of conducting 20 inspections, audits, and observations per FY will be met in FY2022.
Reactive Inspections (Metric E-2)
Reference (IMC 0307 App A, page 8)
No effect on implementation.
Reactive inspections can be performed. Evaluate on a case-by-case basis.
Completion of Supplemental Inspections (Metric E-1)
Reference (IMC 0307 App A, page 8)
Evaluate on a case-by-case basis.
Supplemental inspections can be performed. Evaluate on a case-by-case basis.
Deep backshift inspections hours Reference (IMC 2515, page 16)
No effect on implementation.
IMC 2515 requirement is 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per site, per year per year?
ROP Performance Indicators Reference (IMC 0608)
ERO participation PI possibly affected. FAQ 20-02 approved to address impacts.
Revisit FAQ to ensure existing extension date (12/31/2021) remains sufficient.
Inspector Objectivity Reviews by Supervisors (Metric I-4). Reference (IMC 0307, App A, page 3)
Perform as reasonably achievable.
Review progress but do not hold regions accountable for metric in CY2021.
Senior Management on Site Visits Reference (IMC 0102, pages 7-8)
Perform as reasonably achievable.
Prioritize visits based on oversight needs.
Permanent Site Staffing (Metric I-6)
Reference (IMC 0307, App A, page 4)
No expected effect on implementation.
Each site should be evaluated on a case-by-case basis.
Public Engagement Annual Assessment Meetings (Metric O-3)
Reference (IMC 0307, App A, page 6)
No effect on implementation.
Regions can perform virtual public meetings or other public engagement activities per IMC 0305.
SDP detailed risk evaluations requiring site visits and associated delays - 255-day SDP Reference (IMC 0307, App A, page 9)
No effect on implementation.
If exceeded explain in CY2021 Self-Assessment.
ADR/Reg Conferences/PEC delays No effect on implementation.
All activities can be performed virtually as needed Initial Inspector Qualification Reference (IMC 1245, page 5)
No effect on implementation.
Inspector supervisors manage qualification program as needed Inspector Requalification (Metric I-5)
Reference (IMC 0307, App A, page 3)
No effect on implementation.
IMC 1245 has a one-time deviation for the COVID-19 PHE.
Resident Inspector Objectivity Visits to Other Sites (Metric I-3)
Reference (IMC 0307, App A, page 2)
SRI/RIs can still perform if reasonably achievable.
Review progress but do not hold regions accountable for metric in CY2021.
2021 ROP self-assessment Reference (IMC 0307)
No effect on implementation.
None.
Operator Licensing Reference (NUREG 1021)
Conducting Initial Operator License Examinations during COVID-19 guidance has been given to the Regions None