United States Nuclear Regulatory Commission - Protecting People and the Environment

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Security & Emergency Preparedness COVID-19 Activities: Power Reactor Training & Qualification for Personnel Performing Security Duties | Emergency Preparedness

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10 CFR Part 73, Appendix B, Section VI Nuclear Power Reactor Training and Qualification Plan for Personnel Performing Security Program Duties

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Highlights

  • The regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Appendix B, Section VI require individuals "assigned to perform duties and responsibilities required for the implementation of the Commission-approved security plans, licensee response strategy, and implementing procedures" to meet minimum training and qualification requirements.

  • The initial issuance of EGM 20-002 included an attachment allowing NRC inspectors to consider enforcement discretion for certain Appendix B requirements for security training and requalification. These include: 10 CFR Part 73, Appendix B, Section VI, Subpart B, "Employment Suitability and Qualification," Subpart C, "Duty Training," Subpart D, "Duty Qualification and Requalification," Subpart E, "Weapons Training," Subpart F, "Weapons Qualification and Requalification Program," and Subpart G, "Weapons, Personal Equipment and Maintenance."

  • The EGM is applicable to operating power reactors, power reactors undergoing decommissioning, and independent spent fuel storage installations issued a general license under 10 CFR Part 50.

  • On April 20, the NRC issued a letter outlining specific conditions that licensees should include in exemption requests in order to receive an expedited review process.  If approved, the conditions of the exemption will maintain reasonable assurance of safety and security during a defined, limited period.

  • The NRC is prepared to use its existing authority in granting, upon request from individual licensees, exemptions from the requirements specified in 10 CFR Part 73, Appendix B, Section VI, Subparts B, C, D, E, F, and/or G, if the conditions in the April 20 letter are met and licensees provide an acceptable basis for the request and description of measures it will take to ensure continued proficiency of security staff.

  • Any granted exemptions will ensure security training and qualification programs appropriately maintain licensee flexibility in using personnel resources to most effectively manage the impacts of the COVID-19 PHE on maintaining the safe operation of operating nuclear power reactors, reactors undergoing decommissioning, and independent spent fuel storage installations issued a general license under 10 CFR Part 50.

Related Communication

  • On April 15, 2020 the NRC issued Attachment 1 to EGM 20-002 to provide guidance to NRC inspection staff for the disposition of apparent violations of U.S. Nuclear Regulatory Commission (NRC) requirements for security training and requalification during the COVID-19 public health emergency (PHE).

  • On April 20, 2020 the NRC issued a letter to outline the process by which the NRC is prepared to grant temporary exemptions from the requirements specified in 10 CFR Part 73, Appendix B, Section VI, Subparts B, C, D, E, F, and/or G.

Frequently Asked Questions - 10 CFR Part 73, Appendix B, Section VI

How will NRC oversee licensee's implementation of this guidance?

  • The baseline security inspection program has a variety of inspection procedures that are used to review the training and qualification requirements for licensee security staff.

  • The NRC continues to monitor licensee programs during the PHE via inspection activities and will continue to provide oversight and obtain insights related to the licensee's abilities to maintain protection of public health and safety.

  • NRC inspectors will have access to licensee site-specific documents related to the exemption. In addition, NRC inspectors are available to periodically review any issues concerning the security staff, and the NRC retains the right to rescind any exemptions and/or use enforcement should circumstances warrant.

How does NRC justify providing enforcement discretion or granting exemptions to these requirements?

  • The NRC has determined that enforcement discretion is reasonable during the PHE because of the rigorous nature of nuclear security personnel training programs, which consist of regularly scheduled training activities to include weapons training, contingency response drills and exercises, and demonstrated acceptable performance of day-to-day job activities (e.g., detection and assessment, patrols, searches, and defensive operations).

  • The discretion is specific to security personnel who have previously demonstrated proficiency and are currently qualified and is not applicable for initial qualification of security personnel. Note: The EGM includes applicability for the 40 hour on-the-job requirement for individuals who have been previously qualified.

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Page Last Reviewed/Updated Wednesday, May 27, 2020