ML21277A349
| ML21277A349 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/2021 |
| From: | Leira Cuadrado NRC/NMSS/DMSST/MSLB |
| To: | |
| Leira Cuadrado | |
| References | |
| Download: ML21277A349 (4) | |
Text
October 4, 2021 Public Meeting Summary: July 26, 2021 and August 3, 2021, Public Meeting to Obtain Feedback about the Conduct of NRC Inspections in the NMSS Program Areas During the Public Health Emergency
Background:
The working group conducted two public meetings on July 26, 2021, and August 3, 2021, respectively. During these meetings, a general overview of Phase B of the NMSS COVID-19 Public Health Emergency Oversight Activities Assessment was provided with a focus on objectives and approaches for this effort.
In order to develop recommendations to further enhance current inspection programs during the COVID-19 PHE, future PHEs, or during the standing implementation of the programs, the working group sought the feedback from external stakeholders, to include members of the public, industry representatives, and Agreement States. Six questions were asked to gather feedback on the various methods, adjustments, processes, and inspection techniques used to support inspection activities during the COVID-19 PHE.
Meeting Notices:
- ML21196A534 - July 26, 2021, Meeting to Obtain Feedback about the Conduct of NRC Inspections in the NMSS Program Areas During the Public Health Emergency. Agenda included in the Notice.
- ML21202A113 - August 3, 2021, Meeting to Obtain Feedback about the Conduct of NRC Inspections in NMSS Program Areas During the PHE Handouts:
- ML21203A324 - Phase B Covid Assessment Public Meeting Presentation July 26, 2021
- ML21210A174 - Phase B Covid Assessment Public Meeting Presentation August 3, 2021 Summary: The following is the feedback received from the public meetings:
- 1. What practices and/or processes worked well in the implementation of NMSS oversight/inspection program during the COVID-19 Public Health Emergency that should continue to be used in a future public health emergency or other emergencies that may impact travel?
Representatives From the Nuclear Energy Institute:
Appreciated the opportunity to work closely with the NRC staff and the industry to come up with the means to obtain regulatory relief from requirements that were set. Furthermore, they appreciated the ability to do it remotely so that everyone could remain safe and secure during the pandemic.
Appreciated the process that NRC put into place for efficiently reviewing and approving exemption requests specific to fuel facilities.
During that time, the Division of Fuel Management established guidance and made it available to the public. That guidance was helpful.
NEI also acknowledged the effort by the Division of Fuel Management to routinely reach out to field facilities and solicit input, resulting in an ongoing dialogue with that division.
They hope the NRC will carry on some of these practices in their inspection program from now on.
NEI heard from their clients that NRC inspectors and Headquarters personnel routinely reached out to the sites to ensure that the NRC was making informed decisions about when to travel and how many people to send. This was critical.
When COVID first hit, Region II and Headquarters established a routine call with the operating facilities to get the status of their COVID response posture which of course varied from time to time, and to discuss any emergent needs. Consequently, it helped to learn about the status at the site. It was a real-time information exchange that worked very well.
- 2. What practices and/or processes worked well in the implementation of NMSS oversight/inspection programs during the COVID-19 Public Health Emergency that should continue to be used during the normal implementation of the inspection programs?
Representatives From the Nuclear Energy Institute:
NMSS on occasions, used a hybrid approach where one inspector from the team would be on-site, and one or more inspectors would be at a remote location, either teleworking from home or their work environment. Therefore, there is less exposure to COVID, less exposure to the people on-site, fewer travel costs. When the inspector was on-site, if they had any questions about the licensing basis or some technicality or needed to consult with their home base, they did it immediately with the person that was assisting remotely so it turned out to be efficient for everyone involved. NEI is hoping this approach will continue in the future.
Electronic reading rooms for documents and documents sharing. They want to continue to take advantage of it, since it doesn't involve much paper, time, and energy. It would be more difficult if they were handling classified information, so there must be exceptions to that. But overall, this was a very positive feature.
Representative From the State of Vermont Public Service Department:
The NRC should make an effort to make sure that the general public is aware of the systems that the NRC employ, making sure they understand what the system is there for, and what it can be used for. But more importantly, what it cannot be used for because some members of the public expressed concern about the NRC systems. However, we did not obtain more details on this matter.
- 3. What practices and/or processes used during the implementation of the NMSS inspection program during the COVID-19 Public Health Emergency should not be used in the future implementation of NMSS oversight/inspection programs?
Representative From Union of Concerned Scientists:
When NRC held similar meetings, some inspectors spoke up about issues and concerns they had with remote inspections. Certain aspects of on-site inspection simply cannot be replicated for remote means, including things that cannot be immediately documented Representative From URENCO USA:
They would prefer in case there is an onsite portion and a remote portion, that those portions be done at the same time.
Representative From the State of Vermont Public Service Department:
During the pandemic, we have relied more on remote access (internet access) to conduct business. There are times when remote access is not possible, some of this may be simply that, some of the additional stakeholder organizations, particularly American Indian tribal do not have the electronic access available that would support remote inspection and remote observations. therefore, in case NRC does begin to rely more on remote access, there still needs that require some in-person access.
- 4. What worked well with regard to remote sharing of information (including IT platforms, sharing documentation or records, interviews) to support inspection activities?
Representative From the Nuclear Energy Institute:
The use of electronic reading room, the sharing of documents electronically to reduce the time effort, and the costs associated with photocopying in some cases hundreds or thousands of pages of paper, that is something they hope will continue.
Also, sometimes the exit or entrance interviews were done remotely, and that can be quite effective and productive because they can have the right people available without the need for everyone to be in the same room physically, especially during COVID. Exit and entrance meetings, as well as interviews, can all be done remotely. They think there are many elements of that that are working quite well.
- 5. Do you have any feedback regarding on-site inspection activities during the COVID-19 Public Health Emergency and the additional coordination to support these on-site inspections?
Representative From the State of Vermont Public Service Department:
Very often the NRC inspectors did not know what the local restrictions were. In some instances, they had to track down through the Vermont State Government the local COVID-19 guidance. They would suggest that the NRC makes more efforts to track these types of restrictions for when NRC inspectors are going out on the field.
Representative From the Nuclear Energy Institute:
They have many positive experiences concerning the level of effort that the NRC put in place before even considering coming on site. The NRC was very proactive in reaching out and getting on-site COVID information and adjusting as needed. Then, NRC would make an informed decision about whether to come or not. NRC was making informed
decisions on a real-time basis and consulting with the site to ensure that they were making the best decision for every individual involved. That was very positive
- 6. Any additional feedback related to NRC/NMSS inspection activities during the PHE that you would like to provide to the Working Group, that is not already covered in our previous questions?
Representative From the State of Vermont Public Service Department:
Sometimes the electronic platforms that NRC uses have a different user interface. That is an issue that they have had with ADAMS. They advised us to keep it in mind pertaining all NRCs platforms, particularly in addressing the pandemic in the future, they suggested for us to be aware that what NRC has available internally isn't necessarily what some licensee and what third parties have available too. Make sure that the information is getting to the licensees and third parties.
Representative From the Nuclear Energy Institute:
The agency has been very transparent with regards to the COVID response and approach to the situation. They appreciate the level of communication, coordination, and sensitivity demonstrated during this time.