United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Protocol for Accompaniment on NRC Inspections

HPPOS-108 PDR-9111210256

Title: Protocol for Accompaniment on NRC Inspections

See the memorandum from R. K. Hoefling to F. Brenneman

dated November 2, 1982. It provides a list of approved

terms and conditions under which individuals are allowed to

accompany NRC inspectors as observers on inspections of

nuclear power plants.

The State of Pennsylvania expressed an interest in having

personnel of their Department of Environmental Resources

accompany NRC regional-based or resident inspectors as

observers on inspections of nuclear plants located within

that state.

A protocol was developed for signature for the Commonwealth

of Pennsylvania that allowed persons employed by the

Department of Environmental Resources to accompany NRC

staff on inspections, under the following conditions:

1. Specific approval for each accompaniment will be

obtained from NRC Region I Office prior to accompanying an

NRC inspection.

2. Accompaniment is limited to no more than two

individuals on any single inspection.

3. Individuals accompanying NRC inspectors shall not,

in any manner, interfere with the orderly conduct of the

inspection. NRC inspectors are authorized to refuse to

permit continued accompaniment by an individual whose

conduct interferes with a fair and orderly inspection or

whose conduct does not follow the terms and conditions

included within this Protocol. The reports of information

obtained by State participants under this Protocol should

be subject to supervisory review as are all findings of NRC

Inspectors.

4. NRC inspectors will not normally object to the

presence of individuals accompanying them during

inspections or discussions with the licensee regarding

inspection matters covered by the accompaniment. The NRC

reserves the right to exclude such individuals on a

case-by-case basis from any portion of an inspection or a

discussion if the presence of such individuals has the

potential for impeding the inspector's ability to carry out

his/her inspection.

5. Notwithstanding the other provisions of this

Protocol, individuals accompanying NRC inspectors will not

normally be provided access to proprietary information or

information concerning the physical security plan for a

facility. Exceptions to this provision will be considered

on a case-by-case basis and may require execution of

appropriate non-disclosure agreements.

6. Individuals accompanying NRC inspectors pursuant to

this Protocol do so at their own risk. The Nuclear

Regulatory Commission will accept no responsibility for

injuries and exposures to harmful substances which may

occur to such individuals during the inspection and will

assume no liability for any incidents associated with the

accompaniment. Individuals accompanying NRC inspectors

agree to waive all claims of liability against the

Commission.

7. The NRC will not make arrangements for the persons

accompanying the NRC inspector to gain access to the

licensee's facility, but will inform the licensee that the

NRC has no objection to the specific individuals

accompanying the NRC inspectors. Arrangements to gain

access to the licensee's facilities are the responsibility

of the accompanying individual, subject to not disclosing

the date of the inspection.

Regulatory references: None

Subject codes: 12.18, 12.19

Applicability: Reactors

Page Last Reviewed/Updated Thursday, March 29, 2012