ML22140A342
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| ML22140A342 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/2022 |
| From: | Jared Justice Office of Nuclear Security and Incident Response |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML22140A342 (8) | |
Text
Security Inspections During Periods of Site Inaccessibility
Prudent Regulatory Oversight in a Challenging Environment
- The COVID19 public health emergency created a need to adapt across all cornerstones, including Security, to maintain effective oversight.
- Baseline security inspections posed unique challenges that required inspector agility, forward thinking, and cooperation.
Challenges
- Performancebased activities
- Information sensitivity
- Forceonforce inspections
- Some remote inspection techniques not suitable for security inspections
- Inspector presence on site
Adapting to a Hybrid Inspection Environment
- What can be done remotely and what requires some level of inspector presence on site?
- Example: Verify that the licensee implementing procedures for vehicle search describe areas of the vehicle to be searched vs. Verify that the licensee conducts vehicle searchesin accordance with regulations
- What items are more prudent to complete on site?
- Example: Verify that the licensees reviewing official reviews and evaluates all of the background information required by 10 CFR 73.56 in making Access Authorization decisions
Adapting to a Hybrid Inspection Environment
- Can fewer inspectors be used for onsite visits to limit personnel exposure?
- Can frequencies for completing inspection procedures be leveraged to safely complete onsite inspection procedure requirements at a later date?
ForceonForce Inspections
- Particularly unique due to the number of NRC staff and licensee personnel involved
- Adapted the program to support two different inspection formats depending on COVID19 conditions
- Permitted flexibilities in licenseeconducted drills and exercises to encourage requalification and validation of protective strategy effectiveness
Lessons Learned
- Inspector presence and inperson interactions are vital to the longterm health of the security baseline inspection program.
- Clear and deliberate communication is important in a hybrid environment.
- Some remote techniques did not provide the most efficient method for sample completion.
Questions?
- For further questions, contact Jared Justice at jared.justice@nrc.gov