CSN information on compliance with established nuclear safety and radiation protection requirements during the COVID-19 pandemic
The Spanish Nuclear Safety Council (CSN) informs on how it considers that Royal Decree 463/2020, declaring the state of alarm for the management of the health crisis caused by COVID-19, should be applied in relation to nuclear safety, radiation protection and physical protection.
In the first place, it is reported that it is beyond the capacities of the CSN to generically exempt from compliance with the requirements established in laws, regulations approved by Royal Decree, ministerial orders or authorizations issued by the Government, either national or regional.
However, in cases where the CSN considers that a non-compliance is justifiable due to the situation created by the pandemic (and it has been merely formal or without appreciable impact on nuclear or radiological safety), CSN will generally refrain from imposing or proposing coercive actions of any kind.
For illustrative purposes and by no means being an exhaustive list, the following cases may be mentioned: delays in the submission of periodic reports required in authorizations or regulations, the delivery of mandatory training courses, the payment of certain fees, the collection or analysis of certain environmental samples or the monthly substitution of personal dosimeters.
Secondly, all the requirements established by the CSN, such as instructions of all kinds, or authorizations and licenses granted by the CSN itself, remain in effect and the evaluation of submitted applications continues. However, it is considered justified by the actions derived from the pandemic the suspension in the fulfillment of those obligations under these instructions, authorizations and licenses which are merely formal or without appreciable impact on nuclear or radiological safety, as well as these obligations that, having a minor impact, might conflict with health procedures with a more direct impact as implemented by the health authorities.
Also by way of example and without constituting a complete list, it may be mentioned the renewal of operating licenses and associated administrative procedures, medical examinations and payment of fees, renewal or use of radiological passbooks and obligations associated with their validity, as well as education and training activities, use of wrist and ring dosimeters placed on the apron or on the glasses in interventional radiology -which may collide with the health protocols of not introducing into the room any object that can become a vector for the spread of the virus-, application requests’ deadlines, implementation deadlines established in transitional provisions of instructions, responses to requests for additional information in relation to the ongoing evaluation of applications or response times in relation to warnings under the sanctioning regulatory process.
Finally, the regulatory body kindly requests that, during this situation, documents should be sent to the CSN only by digital means through the electronic office. If this channel could not be used due to any problem, please send the documentation by email or any other electronic means. Sending paper documents should be avoided as much as possible since it can be a vector for the virus to spread.
*Check here the glossary of technical terms*