ML23086C029
| ML23086C029 | |
| Person / Time | |
|---|---|
| Issue date: | 07/06/2023 |
| From: | Russell Felts NRC/NRR/DRO/IRIB |
| To: | Mark King Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23086C030 | List: |
| References | |
| Download: ML23086C029 (4) | |
Text
MEMORANDUM TO: Mike King, Deputy Director Office of Nuclear Reactor Regulation FROM: Russell Felts, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation THRU: Patrick Finney, Acting Branch Chief Reactor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
DISPOSITION OF RECOMMENDATIONS FROM THE FOLLOW-ON REVIEW OF LESSONS LEARNED, BEST PRACTICES, AND CHALLENGES DURING THE COVID-19 PUBLIC HEALTH EMERGENCY The purpose of this memorandum is to communicate the path forward for recommendations in the Follow-On Review of Lessons-Learned, Best Practices, and Challenges During the Covid-19 Public Health Emergency (PHE) report (ML22172A159). The Division of Reactor Oversight (DRO), in consultation with the regional offices, aligned on a plan for disposition of each of the report recommendations.
This plan reflects the broad agreement internally and externally that on-site and in-person inspection remains the most effective and preferred inspection method for most NRC inspection activities, while also seeking to leverage experience gained utilizing existing program flexibilities, communications technology, and innovative hybrid inspection approaches to provide ongoing benefits to agency effectiveness and efficiency.
A new working group consisting of at least one representative from each regional office, the Office of Nuclear Regulation (NRR), the Office of Nuclear Security and Incident Response (NSIR), and the Office of Nuclear Material Safety and Safeguards (NMSS) will be established (Charter ML23086C054) to implement the following four recommendations from the report:
Revise IMC 2515, Appendix E to include direction for program offices to identify consistent criteria, resources, evaluation methodology, and inspection prioritization for future events (Recommendation 1 from the report).
Establish a standard definition of on-site, remote, and hybrid inspection that will be added to IMC 2515 (Recommendation 2).
CONTACT: Manuel Crespo, NRR/DRO 301-415-0298July 6, 2023 Signed by Felts, Russell on 07/06/23 Signed by Finney, Patrick on 07/06/23
M. King
Incorporate high level guidance, controls, and risk mitigation strategies that outline the use and limitations of hybrid inspection practices in IMC 2515 and 2901, such that inspections are efficient and effective (Recommendation 3).
Revise IMC 2515 and 2901 to include guidance on when hybrid/virtual meetings (i.e.,
entrances and exits) may be beneficial for effectiveness and efficiency (Recommendation 4).
Below is the proposed timeline for the working group:
Date Milestone Notes Each Region, NRR, NSIR, and June 2023 Staff and Charter Working Group NMSS will provide at least one representative Modifications will include:
Definition of On-site, remote and hybrid.
Propose Modifications to IMC 2515, Allowance for use of hybrid August 2023 IMC 2515 Appendix E, and inspection practices and IMC 2901 strategies Establishment of methodology for inspection prioritization
September/October Complete review and approval of 2023 IMC 2515, IMC 2515 Appendix E, and IMC 2901 October 2023 Brief Commissioners Assistants As needed November 2023 Implementation date for new revisions of IMCs
In addition, DRO, in consultation with the regional offices, intends to pursue the following recommendations outside of the working group, each of which was of low priority:
Ensure each Region/Site has updated their Information Technology (IT) Memorandums of Understanding (MOUs) with licensees by the end of 2023, if needed.
By November 2023, submit a project proposal, as part of the NRCs Future Focused Research program, to explore implementation or development of standard information sharing solutions with industry.
By January 2024, revised IMC 0620 to include a voluntary list of standards and expectations for licensee information sharing with NRC inspectors.
By June 2023, issue an NRC Announcement that reiterates and clarifies the NRCs policy restrictions on the use of personal devices to access a licensees network.
The staff recommended that the TTC continue their routine monitoring of virtual training options.
In response, the TTC returned training courses back to in-person except for the technology series initial course (304), which will remain virtual. DRO will continue to engage with OCHCO/HRTD on their evaluation of the effectiveness and efficiency of virtual training courses compared to in-person training courses.
Finally, the staff decided that no action be taken on the following recommendation, as it was determined to be an ineffective use of inspector resources:
M. King
Encourage resident inspectors to prioritize problem, identification, and resolution (PI&R) semiannual trend samples with appropriate input from regional inspectors in the near-term to assess for trends attributable to the PHE.
M. King
SUBJECT:
PLAN AND TIMELINE FOR IMPLEMENTING RECOMMENDATIONS FROM THE FOLLOW-ON REVIEW OF LESSONS-LEARNED, BEST PRACTICES, AND CHALLENGES DURING THE COVID-19 PUBLIC HEALTH EMERGENCY DATE: July 6, 2023
DISTRIBUTION:
RidsNrrDro RidsNrrOd Resource RidsNsir Resource RidsNmss Resource RidsRgn1MailCenter Resource RidsRgn2MailCenter Resource RidsRgn3MailCenter Resource RidsRgn4MailCenter Resource A. Veil, NRR M. King, NRR A. Kock, NRR R. Lorson, RI L. Dudes, RII J. Giessner, RIII R. Lewis, RIV J. Lubinski, NMSS M. Gavrilas, NSIR
ADAMS Accession No. ML23086C029 NRR-106 OFFICE NRR/DRO/IRIB NRR/DRO/IRIB NRR/DRO NRR/DRO NAME M. Crespo THipschman TMartinezNavedo RFelts DATE 3/27/2023 6/21/2023 6/26/2023 6/26/2023 OFFICE Region 1 Region 2 Region 3 Region 4 NAME R.Lorson L. Dudes J. Giessner R. Lewis DATE 7/6/2023 7/6/2023 6/30/2023 7/6/2023 OFFICE NMSS NSIR NRR/DRO/IRIB NAME J. Lubinski M.Gavrilas PFinney DATE 7/5/2023 7/6/2023 7/6/2023 OFFICAL RECORD COPY