ML22137A292
| ML22137A292 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/2022 |
| From: | Yiu Law NRC/NRR/DRO/IQVB |
| To: | |
| Diaz-Castillo, Y | |
| References | |
| Download: ML22137A292 (11) | |
Text
May 2022 Nuclear Regulatory Commission (NRC)
Conducting Vendor Inspections During a Pandemic - Lessons Learned Yiu Law NRR/DRO/IQVB
Agenda
- Background and Overview
- How the NRC Adapted and Made Decisions
- Weekly COVID Assessment
- Lessons Learned
- 2020 and 2021 Inspections Performed
- Questions or Comments 2
Background and Overview
- The Quality Assurance and Vendor Inspection Branch (IQVB) conducts approximately 20 vendor inspections/audits/observations per fiscal year.
- Vendor inspections include both routine inspections (IP43002) and reactive inspections (IP43003).
- Prior to 2020, all vendor inspections were performed at the vendors facilities.
Inspection Procedure (IP) 43002 Routine Inspections of Nuclear Vendors IP 43003 Reactive Inspections of Nuclear Vendors 3
Background and Overview
- Due to the stay-at-home mandates, the ability for NRC inspectors to travel was directly impacted.
- To adapt, IQVB developed strategies to perform both on-site and remote (or hybrid) vendor inspections to meet the agencys goal.
4
How the NRC Adapted and Made Decisions
- Developed a strategy for determining how to conduct vendor inspections.
- How severe is the COVID condition at a vendors location?
- Covid questionnaire to ask vendor
- Is remote or hybrid inspection an option? Is it a good option?
- Some areas can be inspected remotely more effectively than others such as corrective actions, internal audits, 10 CFR Part 21, etc.
- Areas like M&TE may not be a good option for remote inspection
- Management Discretion M&TE - Measuring & Test Equipment 5
Weekly COVID Assessment 6
https://covid.cdc.gov/covid-data-tracker/#county-view Summerville, SC (Dorchester County)
Update 4/4: 2.33%
Update 4/11: 3.03%
Update 4/18: 2.5%
Update 5/2: 8%
Update 5/9: 12.56%
Update 4/4: Low Update 4/11: Low Update 4/18: Low Update 5/2: Low Update 5/9: Low Wilmington, NC (New Hanover County)
Update 4/4: 2.48%
Update 4/11: 5.27%
Update 4/18: 8.29%
Update 5/2: 13.67%
Update 5/9: 15.98%
Update 4/4: Low Update 4/11: Low Update 4/18: Low Update 5/2: Low Update 5/9: Low Jacksonville, FL (Duval County)
Update 4/4: 2.24%
Update 4/11: 3.19%
Update 4/18: 3.43%
Update 5/2: 7.07%
Update 5/9: 8.59%
Update 4/4: Low Update 4/11: Low Update 4/18: Low Update 5/2: Low Update 5/9: Low North Bethesda, MD (Montgomery County)
Update 4/4: 1.45%
Update 4/11: 2.09%
Update 4/18: 3.37%
Update 5/2: 4.4%
Update 5/9: 5.54%
Update 4/4: Low Update 4/11: Low Update 4/18: Low Update 5/2: Low Update 5/9: Low
Weekly COVID Assessment 7
https://usafacts.org/visualizations/coronavirus-covid-19-spread-map/
0 1000 2000 3000 4000 5000 6000 10/01/2021 10/07/2021 10/13/2021 10/19/2021 10/25/2021 10/31/2021 11/06/2021 11/12/2021 11/18/2021 11/24/2021 11/30/2021 12/06/2021 12/12/2021 12/18/2021 12/24/2021 12/30/2021 01/05/2022 01/11/2022 01/17/2022 01/23/2022 01/29/2022 02/04/2022 02/10/2022 02/16/2022 02/22/2022 02/28/2022 03/06/2022 03/12/2022 03/18/2022 03/24/2022 03/30/2022 04/05/2022 04/11/2022 04/17/2022 04/23/2022 04/29/2022 05/05/2022 FL - Duval County MD - Montgomery County NC - New Hanover County SC - Dorchester County
Lessons Learned
- Engage vendors early to coordinate inspection logistics. Chances are that some or most of a vendors staff is still working at home in some capacity.
- Use of electronic file sharing systems such as Microsoft Box to gather high level documents such as QA manuals and implementing procedures.
- Establish virtual communication tools such as Microsoft Teams, WebEx or Zoom with vendors to ensure entrance, exit and daily debrief meetings are conducted effectively.
QA - Quality Assurance 8
Lessons Learned
- NRC inspectors may or may not be able to sign forms related to COVID at a vendors facility.
Early engagement and communication is key.
- Be flexible. A vendor may not have all their staff available on site. The NRC inspector availability can change as well.
- Even at vendor locations with low COVID rates, the NRC inspectors still practice safety protocols such as social distancing, mask wearing etc.
9
2020 and 2021 Inspections Performed 10 On-Site 12 Remote 2
FY 2020 Inspections On-Site 7
Remote 3
FY 2021 Inspections Not counting other activities such as observation of Nuclear Procurement Issues Corporation (NUPIC) audits Data from Vendor Newsletters (https://www.nrc.gov/reactors/new-reactors/oversight/quality-assurance/vendor-insp/vendor-newsletters.html)
Questions or Comments?
11