Integration of Access Authorization and Fitness-for-Duty Rulemaking Efforts

Categorized Under: Energy, Environment



ICF supports the Nuclear Regulatory Commission (NRC) Office of Nuclear Security and Incident Response (NSIR) and Office of Nuclear Reactor Regulation (NRR) in rulemaking activities related to the Fitness-for-Duty (FFD) Rule, which addresses drug and alcohol testing and fatigue monitoring. 

ICF supported development of both the proposed and final rules, which comprehensively revised the requirements to incorporate new technical and security-related criteria, and is currently supporting implementation of the requirements. ICF and our team performed the following activities:

  • Conducted and documented a detailed section-by-section analysis of the changes resulting from the proposed rule
  • Provided data collection support and analysis
  • Conducted and documented detailed regulatory benefit/cost and backfit analyses of the proposed rule
  • Prepared a Paperwork Reduction Act analysis of the reporting and record-keeping requirements in the proposed and final rules
  • Prepared an innovative, risk-informed quantitative analysis of the benefits of the rule’s fatigue management provisions
  • Prepared a detailed summary and analysis of the public comments on the proposed rule
  • Provided expert technical support of drug and alcohol testing and human fatigue
  • Supported the development of guidance documents
  • Provided analysis of the interrelationships among the FFD rule and other security requirements pertaining to nuclear power reactors

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Insight Details

Client: U.S. Nuclear Regulatory Commission (NRC)
Location: US

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