On April 3, Russian Government issued two decrees establishing special licensing and oversight procedures for pandemic period. The documents were issued pursuant to the Federal law 98-FZ to facilitate response to pandemic. Earlier we published the detailed information on this Federal law.
The Government Decree N 438 establishes special procedures for planning and conducting oversight in 2020. The procedures apply to oversight of nuclear security as well.
The procedure defines that nuclear sites handling nuclear material and operating nuclear facilities remain subject to scheduled oversight inspections. The procedure also defines exhaustive list of grounds for conducting unscheduled inspections, including inspections of nuclear sites.
Although a list of grounds for conducting unscheduled inspection substantially differ from the list defined in regular oversight procedures, grounds applicable to nuclear security inspections mostly remain the same, e.g.:
- The inspections assigned by the President or the Government
- The inspection aimed at verifying elimination of recently detected violation of regulatory requirements to restore recently suspended license
- The inspection conducted after an organization applies for a license to verify compliance with licensing criteria. In case of nuclear license, such criteria include nuclear security
The inspections, scheduled and unscheduled, have to be conducted remotely, e.g. by using audio or video. The procedure defines several exceptions that allow conducting on-site inspection, e.g. authorization from the Government or President. We assume that Rostechnadzor will develop new approaches and procedures for remote inspections, as before such inspections were not a part of nuclear oversight, including oversight of nuclear security.
The Government Decree N 440 defines specifics of licensing in 2020. The decree does not apply to nuclear licensing. Thus, Rostechnadzor uses regular licensing procedures, taking into account provisions of Government decree N 438 related to licensing inspections mentioned above. We assume that the Government may later define specific procedures for nuclear licensing. We do not expect substantial relaxation of licensing procedures or criteria.