ML20244A008
| ML20244A008 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/2020 |
| From: | Joseph Holonich Licensing Processes Branch |
| To: | |
| Holonich J | |
| Shared Package | |
| ML20244A007 | List: |
| References | |
| Download: ML20244A008 (5) | |
Text
Office of Nuclear Reactor Regulation Topical Report Safety Evaluation Topical Report Information Review Information 1 Report Number: EPRI 3002019436 Division/ Branch: DRO 2
Title:
"Remote Source Verification During a Pandemic Project Manager: J. Holonich 3 or Similar State of Emergency: Screening Criteria and Reviewers: A. Armstrong, P.
4 Process Guidance Prescott 5 ADAMS Accession No: ML20205L619 and ML20205L618 6 EPID: L-2020-TOP-0039 7 Docket No.: 99902021 8 Determination of Minimal Revisions 9 Is this the review of very limited scope? Yes X No 10 Does the TR change maintain the original SE conclusions? Yes X No 11 Do the staff methods for establishing the original Yes No 12 X conclusions remain unaffected?
13 If any of the above questions are answered no, a simplified safety evaluation cannot be used.
14 Applicable Review Guidance Used 15 16 17 Standard Review Plan (SRP) for the Review of Safety Analysis Reports for Nuclear Power 18 Plants: LWR Edition (NUREG-0800, Formerly issued as NUREG-75/087), Chapter 17.5, 19 Quality Assurance Program Description - Design Certification, Early Site Permit and New 20 License Applicants Revision 1, Dated 8/2018.
21 22 Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Quality 23 Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Office of Nuclear Reactor Regulation Topical Report Safety Evaluation Topical Report Information Review Information 1 Report Number: EPRI 3002019436 Division/ Branch: DRO 2
Title:
"Remote Source Verification During a Pandemic Project Manager: J. Holonich 3 or Similar State of Emergency: Screening Criteria and Reviewers: A. Armstrong, P.
4 Process Guidance Prescott 5 ADAMS Accession No: ML20205L619 and ML20205L618 6 EPID: L-2020-TOP-0039 7 Docket No.: 99902021 8 Description of Topical Report Content (1000 Word Maximum) 9 10 The Electric Power Research Institutes (EPRIs) submittal of Technical Report (TR) 11 3002019436, Remote Source Verification During a Pandemic or Similar State of 12 Emergency, provides industry guidance for performing remote source verification activities 13 during times of pandemics and states of emergency. The EPRI TR 3002019436 was 14 developed with industry stakeholders, which included NRC staff, to provide the option within a 15 licensees or vendors QA program for remote performance of a source verification when 16 required during exigent conditions. EPRIs report guidance provides guidance for application 17 of video and other real-time communication technologies for the successful performance of 18 remote source verification. Since the capabilities of remote source verification are limited, the 19 techniques included in the report are intended for use only in extreme circumstances such as 20 a global pandemic, when performing on-site source verification may not be possible due to 21 conditions that threaten the health and safety of individuals performing the verification or the 22 work being verified. Successful use of remote source verification involves screening to 23 ensure the activity being conducted by the supplier can be adequately verified, using remote 24 source verification techniques, clearly defined scope and objectives, technology required to 25 remotely witness important aspects of the activity in real time, contingency plans to address 26 the potential for technology failures during the activity, and means for documenting the activity 27 in a format that provides the verifying entity with objective evidence of the activity.
28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Office of Nuclear Reactor Regulation Topical Report Safety Evaluation Topical Report Information Review Information 1 Report Number: EPRI 3002019436 Division/ Branch: DRO 2
Title:
"Remote Source Verification During a Pandemic Project Manager: J. Holonich 3 or Similar State of Emergency: Screening Criteria and Reviewers: A. Armstrong, P.
4 Process Guidance Prescott 5 ADAMS Accession No: ML20205L619 and ML20205L618 6 EPID: L-2020-TOP-0039 7 Docket No.: 99902021 8 Technical Evaluation 9
10 Source verifications are typically performed to verify successful completion of certain 11 fabrication and testing activities related to equipment that are complex, expensive, or 12 designated for use in nuclear safety-related applications. Regulatory requirements and 13 guidance related to the use of source verification to accept a basic component for use, either 14 with or without commercial-grade dedication, are provided in Criterion VII of Appendix B to 15 10 CFR Part 50; NRC Inspection Procedure 43004, Inspection of Commercial-Grade 16 Dedication Programs (Agencywide Documents Access and Management System (ADAMS) 17 Accession No. ML16344A092); and EPRI TR 3002002982, Revision 1 to EPRI NP-5652 and 18 TR-102260, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in 19 Nuclear Safety-Related Applications, dated September 2014 (ADAMS Accession No.
20 ML18199A161), which was endorsed by NRC Regulatory Guide 1.164, Dedication of 21 Commercial-Grade Items for Use in Nuclear Power Plants, Revision 0, dated June 2017 22 (ADAMS Accession No. ML17041A206), and defines source verification. In all cases, both 23 the regulatory requirements and guidance refer to source verifications being performed at 24 the contractor or subcontractor source, by direct observation, or at the location of material 25 procurement or manufacture, respectively.
26 27 Given technological advances since the requirements of Appendix B were first promogulgated, 28 EPRI TR 3002019436 guidance proposed alternatives in lieu of the regulatory requirements 29 of Criterion VII for performing source verifications. The proposed alternative provides 30 guidance for the application of video and other real-time communication technologies for the 31 successful performance of remote source verification. The use of this method of verification 32 is only applicable when a pandemic or similar state of emergency has been declared 33 restricting access or travel to and/or from those locations affected by the declaration.
34 35 EPRI TR 3002019436 was prepared to provide licensees and vendors with guidance 36 for using remote communication and video capabilities to perform remote source 37 verification in extreme circumstances where it is not possible to perform onsite source 38 verification due to conditions that threaten the health and safety of individuals 39 performing the verification. The NRC staff reviewed EPRI TR 3002019436 and 40 determined from its review, that implementing adequate quality controls prior to 41 witnessing the remote source verification should address the limitations identified in 42 EPRI TR 3002019436.
43 44 EPRI TR 3002019436 provides a screening of the specific source verification to be 45 performed to determine if remote source verification is appropriate for the activities Office of Nuclear Reactor Regulation Topical Report Safety Evaluation Topical Report Information Review Information 1 Report Number: EPRI 3002019436 Division/ Branch: DRO 2
Title:
"Remote Source Verification During a Pandemic Project Manager: J. Holonich 3 or Similar State of Emergency: Screening Criteria and Reviewers: A. Armstrong, P.
4 Process Guidance Prescott 5 ADAMS Accession No: ML20205L619 and ML20205L618 6 EPID: L-2020-TOP-0039 7 Docket No.: 99902021 8 being verified prior to conducting the activity remotely. The EPRI TR 3002019436 9 required screening employs the following six attributes with associated guidance 10 provided:
11 12 1. Is it possible to do onsite verification surveillance?
13 2. Is the activity an assessment?
14 3. Can the activity be adequately verified surveilled remotely?
15 4. Can progress and results be captured and communicated in real-time?
16 5. Can a maintainable record be created for objective evidence? and 17 6. Does the original requestor initiating entity concur with the use of remote 18 verification surveillance?
19 20 Based on the implementation of adequate quality controls and adherence to the 21 guidance of EPRI TR 3002019436, the NRC staff concluded that remote source 22 verification will be an effective alternative for source verification activities during 23 exigent conditions. Although remote source verification cannot, and should not, be 24 fully replace the ability to observe and verify activities at the source, the use of modern 25 communication technologies does permit a remote source verification plan to be 26 developed and implemented that will continue to satisfy the relevant criteria of 27 Appendix B to 10 CFR Part 50. Therefore, EPRI TR 3002019436 guidance provides 28 an equivalent, and acceptable level of quality control during exigent conditions.
29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Office of Nuclear Reactor Regulation Topical Report Safety Evaluation Topical Report Information Review Information 1 Report Number: EPRI 3002019436 Division/ Branch: DRO 2
Title:
"Remote Source Verification During a Pandemic Project Manager: J. Holonich 3 or Similar State of Emergency: Screening Criteria and Reviewers: A. Armstrong, P.
4 Process Guidance Prescott 5 ADAMS Accession No: ML20205L619 and ML20205L618 6 EPID: L-2020-TOP-0039 7 Docket No.: 99902021 8 Conclusions 9
10 Although remote source verification is not intended to replace the ability to observe 11 and verify activities at the source, the NRC staff finds that available technologies can 12 be effectively applied to sufficiently and successfully verify certain activities in extreme 13 circumstances as discussed in EPRI TR 3002019436. The NRC staff has reviewed 14 EPRI TR 3002019436 and determined that appropriate implementation of the 15 guidance and quality controls, will continue to meet the requirements of Criterion VII of 16 Appendix B to 10 CFR Part 50, and therefore, is an acceptable form of meeting the 17 regulatory requirements for source verifications during pandemics or similar states of 18 emergency 19 20 21 22 23 24 25 26 Conditions and Plant-Specific Action Items 27 28 N/A 29 30 31 32 33 34 35 36 ADAMS Accession Nos: Package: ML ; Email: ML ; SE: ML20239A847 37 38 Approval Printed Name Signature Date 39 40 Technical Branch Chief Kerri Kavanagh 41 42 43 Projects Branch Chief Dennis Morey 44 45 1