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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 19, 2021 MEMORANDUM TO:                  Those on the Attached List Signed by Regan, Christ FROM:                            Christopher M. Regan, Acting Director sign ature:cmr          on 11/19/21 Division of Reactor Oversight Office of Nuclear Reactor Regulation
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==SUBJECT:==
APPROVAL OF THE CHARTER FOR FOLLOW-ON REVIEW OF THE LESSONS-LEARNED, BEST PRACTICES, AND CHALLENGES DURING THE COVID-19 PUBLIC HEALTH EMERGENCY This memorandum approves the team charter for the working group tasked with conducting a review of the lessons-learned, best practices, and challenges identified with all relevant stakeholders during the COVID-19 Public Health Emergency (PHE). This will be a follow-on review to the Initial Report on Challenges, Lessons Learned and Best Practices from the 2020 COVID-19 Public Health Emergency - Focus on Regulatory Oversight of Operating Nuclear Reactors (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20308A389). This multi-disciplinary internal team, with representation from all four regions and headquarters staff, will identify lessons learned from performing oversight during the PHE including best practices established with licensees and other stakeholders that could be beneficial for routine use and for future events that limit or prevent access to nuclear plant sites.
While many inspection activities were successfully completed remotely during the PHE, the long-term recommendations provided by the team should account for the value of professional relationships, visible NRC inspector on-site presence, and informal discussions or observations that often result in identifying issues at the site. The teams review should include, but not be limited to, evaluating the three key areas identified during the initial review: 1) information technology (IT) capability and reliability; 2) remote inspection practices; and 3) inspection guidance enhancements.
 
==Enclosure:==
 
Follow-On Review of the Lessons Learned, Best Practices, and Challenges During the COVID-19 Public Health Emergency Charter CONTACTS: Kimyata Morgan-Butler, NRR/DRO (301) 415-0733 Felts, Russ, NRR/DRO (301)415-8529 Thomas Hipschman, NRR/DRO (301) 415-1169
 
MEMORANDUM TO THOSE ON THE ATTACHED LIST DATED:
November 19, 2022
 
==SUBJECT:==
APPROVAL OF THE CHARTER FOR FOLLOW-ON REVIEW OF THE LESSONS-LEARNED, BEST PRACTICES, AND CHALLENGES DURING THE COVID-19 PUBLIC HEALTH EMERGENCY DATED: NOVEMBER 19, 2021 E-Mail Mail Stops Daniel Collins, Division of Operating Reactor RidsRgn1MailCenter Resource Safety, Region I Mark Franke, Division of Reactor Safety,      RidsRgn2MailCenter Resource Region II Mark Miller, Division of Reactor Projects,    RidsRgn2MailCenter Resource Region II Julio Lara, Division of Reactor Projects,    RidsRgn3MailCenter Resource Region III David Curtis, Division of Reactor Safety,    RidsRgn3MailCenter Resource Region III Anthony Vegel, Division of Reactor Projects,  RidsRgn4MailCenter Resource Region IV Ryan Lantz, Division of Reactor Safety,      RidsRgn4MailCenter Resource Region IV Michael Franovich, Division of Risk          RidsNrrDra Resource Assessment, Office of Nuclear Reactor Regulation Sabrina Attack, Division of Physical Security RidsNisr Resource and Cyber Security Policy, Office of Nuclear Security and Incident Response Kathryn Brock, Division of Preparedness and  RidsNmss Resource Response, Office of Nuclear Security and Incident Response Samuel Lee, Division of Security Operations, Office of Nuclear Security and Incident
 
===Response===
Kevin Williams, Division of Materials Safety, Security, State, and Tribal Programs, Office of Nuclear Materials Safety and Safeguards
 
==SUBJECT:==
APPROVAL OF THE CHARTER FOR FOLLOW-ON REVIEW OF THE LESSONS-LEARNED, BEST PRACTICES, AND CHALLENGES DURING THE COVID-19 PUBLIC HEALTH EMERGENCY DATED: NOVEMBER 19, 2021 DISTRIBUTION:
RidsNrrDro Resource RidsNrrDra Resource RidsNrrOd Resource RidsNisr Resource RidsNmss Resource RidsRgn1MailCenter Resource RidsRgn2MailCenter Resource RidsRgn3MailCenter Resource RidsRgn4MailCenter Resource A. Veil, NRR M. King, NRR A. Kock, NRR D. Lew, RI L. Dudes, RII J. Giessner, RIII S. Morris, RIV J. Lubinski, NMSS M. Gavrilas, NSIR ADAMS Accession No.: ML21322A259                *concurred via e-mail OFFICE      NRR/DRO/IRIB        NRR/DRO          NRR/DRO NAME          THipschman    KMorgan-Butler        CRegan DATE          11/18/2021        11/19/2021        11/19/2021 OFFICIAL RECORD
 
Charter for the Follow-On Review of the Lessons-Learned, Best Practices, and Challenges During the COVID-19 Public Health Emergency November 19, 2021 I.      Purpose The purposes of this charter are to: (1) define a clear problem statement on the need to perform additional efforts to capture lessons learned and best practices on the oversight of power reactors during the COVID-19 public health emergency (PHE); (2) define a scope, objectives and proposed actions to be performed by both involved internal and external stakeholders in support of this effort; (3) outline a process to evaluate lessons learned and best practices for possible revisions/enhancements to the Reactor Oversight Process (ROP) and associated work practices and procedures for future emergencies and non-emergency conditions; (4) outline a process to evaluate the establishment of a Memoranda of Understanding (or similar tool) between licensees and NRC with agreed upon standards and expectations intended to ensure reliable and continued remote access by NRC on licensee plant systems and operational programs through Information Technology (IT) tools and systems. At the conclusion of the effort, the team will issue a memorandum documenting the recommendations related to NRCs lessons-learned, best practices, and challenges during the COVID-19 PHE.
II.      Background The staff completed an initial review of the impacts to the ROP due to the COVID-19 PHE in late calendar year 2020 and documented the results in a report, Initial Report on Challenges, Lessons Learned and Best Practices from the 2020 COVID-19 PHE; Focus on Regulatory Oversight of Operating Nuclear Reactors, dated January 2021 (ADAMS Accession No. ML20308A389). A 17-member NRC team was established to identify lessons-learned and best practices and to make recommendations to improve NRC readiness for future emergencies and non-emergency conditions. These recommendations were focused on three main areas including: 1) information technology (IT) capability and reliability; 2) remote inspection practices; and 3) inspection guidance enhancements.
This initial review was internally focused and although some recommended actions are still open, the agency recognized that as the COVID-19 PHE progressed, a follow-on review would be needed and should include licensees and other stakeholders.
III. Problem Statement The COVID-19 PHE resulted in the need to consider numerous issues (e.g., IT needs, communications, inspection guidance and inspector work practices) for possible future situations where plant site access is limited impacting regulatory oversight of power reactors.
Since the initial COVID-19 PHE lessons learned was conducted 6 months into the COVID-19 PHE, the agency has accumulated over a year of additional experience. As a continually learning organization, it is important for the agency to fully explore the impact of the practices utilized during the COVID-19 PHE on the ROP in order to make informed decisions regarding what long-term improvements can be made to the ROP for both future emergencies and non-emergency conditions. The initial lessons-learned effort was primarily based on the results of an internal staff survey. The follow-on effort should be informed by broader stakeholder interactions with staff, industry, and members of the public and the results of the previous assessments. The value of having NRC inspectors on site to conduct inspections is not in question, but there are potential opportunities for inspection modernization that this effort should fully explore.
Enclosure
 
2 IV.      Objectives This multi-disciplinary team, with representation from all four regions and headquarters staff, will identify additional lessons learned and best practices established with licensees and other stakeholders during the COVID-19 PHE that could be beneficial for routine use and for future events that limit or prevent access to nuclear power plant sites. The team should develop a shared understanding of what practices worked, and how they were effective and successful in achieving reasonable assurance of safe plant operations. In particular, the group will evaluate, using objective data where reasonably possible, the short and longer implications of the practices used conducting inspections during the COVID-19 PHE (effectiveness and efficiency) and its impact on the Agencys ability to provide reasonable assurance of adequate protection for nuclear safety.
V.      Proposed Actions Establish a team comprised of members from NRRs Divisions of Reactor Oversight and Risk Assessment, the Office of Nuclear Security and Incident Response, and the four regional offices. In addition, the team will also include a working group member from the Office of Nuclear Materials Safety and Safeguards (NMSS). This working group member will serve as a liaison to the NMSS COVID-19 PHE Phase B working group to allow for sharing of key information and lessons-learned between the ongoing COVID-19 PHE efforts in the reactor and materials programs. The working group should interact with industry representatives and other stakeholders during a series of public meetings. Working group members reviewing reactor safety and security practices shall have regional inspection and resident inspector experience during the COVID-19 PHE. Regional members will be expected to brief regional management and staff throughout the review and provide regional feedback to the group for consideration throughout the course of the effort. Additionally, team members will participate in public meetings.
The Director, Division of Reactor Oversight (DRO) will assign an Executive sponsor for these follow-on lessons learned review who will provide oversight, guidance, and assistance with change management and resolving differing views, as requested by the review team. The Executive sponsor will also ensure that NRC management is kept abreast of the working groups progress, challenges, and recommendations to help ensure a successful outcome.
Considering the experience gained by inspectors in completing the baseline inspection program during the COVID-19 PHE, and to ensure more consistent implementation of inspection activities at operating nuclear power plants, the working group will evaluate lessons learned and best practices developed from the inspection experiences of our licenses and interactions with other stakeholders. The team will also evaluate the practices licensees used during the COVID-19 PHE to provide information and data regarding plant status, meetings and corrective actions.
This will assist in helping the team determine whether those practices should be utilized in the future or enhanced with site-specific memorandums. The team will also make recommendations for potential revisions and enhancements to the ROP and/or supporting guidance, procedures, and interactions with stakeholders.
VI.      Scope
 
3 The overall review shall encompass a larger set of lessons learned as COVID-19 has continued and capture the appropriate data to help us better understand the COVID-19 PHE impacts on NRCs oversight program. It should include the following items:
* Engagement with internal and external stakeholders (NEI, Entergy, NextEra, UCS, international organizations (IAEA, NEA, etc.). The charter defines the problem statement, scope and objectives, roles and responsibilities and intended outcomes regarding what we have learned from performing oversight of power reactors during the COVID-19 PHE. External engagement is essential to consider a broader and more diverse set of lessons learned.
* Evaluation of what long-term improvements should be made to the ROP.
* Assessment of the various improvements of licensees sharing important safety information remotely with the NRC, an evaluation of the benefits of continuing this information sharing and the risks of losing this level of improved information sharing.
Develop, if warranted, a standard set of expectations to be considered when revising already established NRC-Licensee Information Memoranda of Understanding, such as what is used for the resident offices.
* Evaluation of the three key areas identified during the initial review: 1) information technology (IT) capability and reliability, 2) remote inspection practices, and 3) inspection guidance enhancements.
* Evaluation of the use of hybrid inspections (partially remote, partially on-site) for routine and emergent use.
* Evaluation of OIG Audit Report 21-A-13, Audit of the NRCs Pandemic Oversight of Nuclear Power Plants and provide options to address the recommendation.
In addition, the following questions may be considered during the course of the review:
o  As a result of the COVID-19 PHE, how did the agency and licensees adopt new or innovative technology (e.g., increased remote oversight, improved access to licensee information, use of cameras, etc.)?
o  How well was the health and safety of inspectors and licensee staff, such as control room operators, considered and protected during the planning of inspections as well as when performing onsite inspection activities? What criteria was used to assess whether the inspection could be deferred, modified, or canceled?
o  What is the long-term impact of the COVID-19 PHE on licensees (e.g., long term impact of reduced staffing on site, deferred maintenance, impact of not undertaking emergency and security training, etc.)?
o  What impact would the continued use of the practices established during the COVID-19 PHE have on the long-term effectiveness and efficiency of the ROP?
o  How was the training and qualification of the inspection staff affected by the COVID-19 PHE?
 
4 Once the review is complete and recommendations are developed, the review team will present the results and recommendations to NRR, NSIR, NMSS, DRO and regional management, and to external stakeholders during public meetings. Following the presentation(s), the review team will issue a memorandum documenting the results of the review and any recommendations.
Any proposed enhancements will reflect the value the NRC places on having NRC inspectors on site to conduct inspections.
Upon issuance of the memorandum, the working group will be disbanded.
VI.      Methods To be developed by team leader working with team members and the Executive sponsor.
VII.      Projected Timeline Activity                Month                      Participants NRR/DRO, NRR/DRA, Regional Internal alignment on September          Directors, NMSS, NRR OD and DOD, draft charter Regional Administrators Provide opportunity for external alignment on        October            NRR/DRO draft charter Identify working group October/November NRR/DRO, Executive Sponsor members Issue charter and November            NRR/DRO commence review Initial leadership briefing with NRR OD and                                  Executive Sponsor and Working Group December Regional Administrators                          Co-Leads (RAs)
Communicate with baseline IP leads, regional staff, RIs, and    Monthly            Working Group members DRO staff as necessary to complete the review Public meetings to September to May    Executive Sponsor, Working Group engage with industry and 2022                members, NRR/DRO management other stakeholders Bi-Monthly Progress reviews with        (November 2021,    DRO management, Executive Sponsor, NRR OD and RAs              February 2022,      Working Group members April 2022)
Commission Assistants As Needed          TBD briefing Complete review and develop                      April 2022          Working Group recommendations Present results and          May 2022            Working Group recommendations to NRR, NSIR, NMSS, DRO, regional management, industry,
 
5 and other stakeholders address feedback Document conclusions and recommendations in memo to DRO Director.                                Executive Sponsor, Working Group, DRO August 2022 Upon issuance of the                                Director memo, the working group will be disbanded.
VIII. Team Membership
* Executive Sponsor - Mark Franke, RII
* Co-Team Leaders - Gene Guthrie, RII; Jeff Bream, DRO
* NRR/DRO - Tom Hipschman (Advisor); Project Coordinator (Eric Duncan, DRO; Valerie Gray, NRAN, DRO)
* NRR/DRA - Lundy Pressley
* Region I - Justin Hawkins; Don Jackson
* Region II - Matt Endress
* Region III - Paul LaFlamme
* Region IV - Greg Kolcum, Shiattin Makor
* NSIR - Jared Justice (Physical Security); Don Johnson (Emergency Preparedness);
Mario Fernandez (Cyber Security)
* NMSS - Leira Cuadrado (Liaison to Materials Phase B Effort)
Consult with appropriate IP leads, regional and resident inspectors, and industry representatives. It is estimated that the staffs level of effort will be approximately 5-7 hours per week.
IX.      Meetings Team meetings will be scheduled bi-weekly during the review period. Public meetings will be held in accordance with agency guidance meetings. Meeting schedules will be adjusted as necessary.
X.      Time Reporting All activities will be documented in HRMS using CAC A11018 or other office specific CACs for ROP program development (DPR - A11015; DPCP/DSO - A11020).}}

Revision as of 16:14, 16 January 2022

Charter for the Follow-On Review of the Challenges, Lessons Learned, and Best Practices During the COVID-19 Public Health Emergency
ML21322A259
Person / Time
Issue date: 11/19/2021
From: Christopher Regan
NRC/NRR/DRO/IRIB
To: Sabrina Atack, Kathryn Brock, Dan Collins, David Curtis, Mark Franke, Mike Franovich, Ryan Lantz, Julio Lara, Samson Lee, Mark Miller, Anton Vegel, Kevin Williams
Office of Nuclear Material Safety and Safeguards, NRC/NRR/DRO, Office of Nuclear Security and Incident Response, NRC Region 1, NRC/RGN-II, NRC/RGN-III, NRC/RGN-V
Eric Duncan, NRR/DRO/IRIB, 630-829-9620
References
Download: ML21322A259 (8)
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