ML18102B139

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OEDO-17-00687 Memorandum to Dr. Brett M. Baker from Fred Brown Status of Recommendations and Staff Response to the Office of the Inspector General'S Audit of the U.S. Nrc'S Vendor Inspection Program (OIG-10-A-20)
ML18102B139
Person / Time
Issue date: 05/15/2018
From: Frederick Brown
Office of New Reactors
To: Baker B
NRC/OIG/AIGA
Sakadales A, NRO/DCIP
Shared Package
ML17305A860 List:
References
OEDO-17-00687, OIG-10-A-20
Download: ML18102B139 (7)


Text

May 15, 2018 MEMORANDUM TO: Dr. Brett M. Baker Assistant Inspector General for Audits FROM: Frederick D. Brown, Director /RA/ VOrdaz for Office of New Reactors

SUBJECT:

STATUS OF RECOMMENDATIONS AND STAFF RESPONSE TO THE OFFICE OF THE INSPECTOR GENERALS AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS VENDOR INSPECTION PROGRAM (OIG-10-A-20)

This memorandum provides the U.S. Nuclear Regulatory Commission (NRC) staffs updates for the remaining open recommendations from the Office of the Inspector Generals (OIGs) audit OIG-10-A-20, Audit of NRCs Vendor Inspection Program, dated September 28, 2010. The staff continues to implement actions in response to OIGs audit and remains responsive to OIGs recommendations.

Recommendation 1:

Develop an NRO Vendor Inspection Program planning document that:

a. Articulates a clear purpose for the Vendor Inspection Program.
b. Establishes metrics to evaluate the success of the Vendor Inspection Program.

Status: Closed.

Recommendation 2:

Develop and document a methodology to identify vendors that supply safety-related parts and services to the nuclear industry with Appendix B quality assurance programs.

Status: Closed.

Recommendation 3:

Develop and document a risk-informed methodology to select vendors for inspection.

Status: Closed.

CONTACT: Antoinette Sakadales, NRO/DCIP 301-415-6441

B. Baker 2 Recommendation 4:

Develop and use a vendor outreach/communications plan.

Status: Closed.

Recommendation 5:

Align NRC guidance and regulations to clarify acceptance methods for commercial-grade dedication.

Status: Closed.

Recommendation 6:

Issue regulatory guidance to clarify sampling expectations for commercial-grade dedication.

Status: Closed.

Recommendation 7:

OIG Analysis dated November 7, 2017:

Issue regulatory guidance describing a process that NRC considers acceptable for compliance with Part 21.

Status: Resolved.

NRC Staff Update:

Actions taken and planned:

In April of 2018, the staff issued Regulatory Guide (RG) 1.234, Rev. 0, Evaluating Deviations and Reporting Defects and Noncompliance under 10 CFR Part 21, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17338A072). RG 1.234 was previously issued as Draft Guide (DG)-1291 dated July 2017 (ADAMS Accession No. ML16165A298). Regarding the development of DG-1291, in February 2016, the Nuclear Energy Institute (NEI) submitted NEI 14-09, Revision 1, Guidelines for Implementation of 10 CFR Part 21 Reporting of Defects and Noncompliance (ADAMS Accession No. ML16054A825), to the NRC for review and approval. The staff has completed its review of NEI 14-09 and RG 1.234, Rev. 0, with three clarifications (i.e., reporting requirements, training, and Part 21 applicability to design certification applicants) and endorses its use as an acceptable means of demonstrating compliance with the NRCs regulations. Therefore, NEI 09, Revision 1 provides adequate guidance to implement the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, and will supersede NUREG-0302, Revision 1, Remarks Presented (Questions/Answers Discussed) at Public Regional Meetings to Discuss Regulations (10 CFR Part 21) for Reporting of Defects and Noncompliance: July 12-26, 1977, issued October 1977. This approach is consistent with SECY-11-0032, Consideration of the Cumulative Effects of Regulation in the Rulemaking Process, dated March 2, 2011 (ADAMS Accession No. ML110190027), and SECY-11-0135,

B. Baker 3 Staff Plans to Develop the Regulatory Basis for Clarifying the Requirements in Title 10 of the Code of Federal Regulations Part 21, Reporting of Defects and Noncompliance, dated September 29, 2011 (ADAMS Accession No. ML112430138).

Target Completion Date: The staff issued the final RG 1.234 (previously DG-1291) in April 2018.

Point of

Contact:

Antoinette Sakadales, NRO/DCIP/QVIB-2 301-415-6441 Recommendation 8:

Clearly indicate via the NRC public Web site how and when Part 21 has changed.

Status: Closed.

Recommendation 9:

Develop guidance that clarifies the requirements for vendors on how to approve accredited commercial-grade calibration laboratories for safety-related applications.

Status: Closed.

Recommendation 10:

Develop and implement a formal agencywide strategy and plan to monitor and evaluate counterfeit, fraudulent, and suspect items.

Status: Closed.

Enclosure:

Correspondence History OIG-10-A-20, Audit of NRCs Vendor Inspection Program

ML17305A860 *via e-mail NRO-002 OFFICE NRO/DCIP/QVIB-2* NRO/DCIP/QVIB-2* NRO/DCIP/QVIB-2* QTE PPrescott JDougherty*

NAME ASakadales KKavanagh (KKavanagh for)

DATE 4/20/2018 4/12/2018 4/12/2018 4/13/2108 OFC NRO/DCIP OGC/NLO NRO TMcGinty NAME JMartin FBrown (VOrdaz for)

(PKrohn for)

DATE 4/25/2018 5/4/2018 05/15/2018 Correspondence History OIG-10-A-20, Audit of NRCs Vendor Inspection Program Audit Report: Audit of NRCs Vendor Inspection Program (OIG-10-A-20), September 28, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102730627).

Memorandum to the Assistant Inspector General for Audits: Staff Response to the Office of the Inspector Generals Audit of the Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), October 30, 2010 (ADAMS Accession No. ML102950601).

Memorandum to the Executive Director for Operations (EDO): Status of Recommendations:

Audit of the Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20),

January 11, 2011 (ADAMS Accession No. ML110130015).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), May 26, 2011 (ADAMS Accession No. ML111290142).

Memorandum to the EDO: Status of Recommendations: Audit of the Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), July 27, 2011 (ADAMS Accession No. ML11209C350).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), January 6, 2012 (ADAMS Accession No. ML13555A069.

Memorandum to the EDO: Status of Recommendations: Audit of the Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), March 9, 2012 (ADAMS Accession No. ML120690007).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), August 3, 2012 (ADAMS Accession No. ML12207A607).

Memorandum to the EDO: Status of Recommendations: NRCs Vendor Inspection Program (OIG 10-A-20), September 13, 2012 (ADAMS Accession No. ML12257A180).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), February 4, 2013 (ADAMS Accession No. ML13028A364).

Memorandum to the EDO: Status of Recommendations: NRCs Vendor Inspection Program (OIG-10-A-20), March 26, 2013 (ADAMS Accession No. ML13085A004).

Enclosure

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), July 31, 2013 (ADAMS Accession No. ML13199A511).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG 10-A-20), October 17, 2013 (ADAMS Accession No. ML13290A366).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), February 3, 2014 (ADAMS Accession No. ML14029A069).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG 10-A-20), March 12, 2014 (ADAMS Accession No. ML14071A050).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), August 6, 2014 (ADAMS Accession No. ML14190B319).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG-10-A-20), September 18, 2014 (ADAMS Accession No. ML14261A414).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), January 14, 2015 (ADAMS Accession No. ML14345A672).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG 10-A-20), March 10, 2015 (ADAMS Accession No. ML15069A073).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), July 6, 2015 (ADAMS Accession No. ML15154B636).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG-10-A-20), August 13, 2015 (ADAMS Accession No. ML15225A090).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), January 7, 2016 (ADAMS Accession No. ML15320A498).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG-10-A-20), March 7, 2016 (ADAMS Accession No. ML16067A008).

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Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), August 19, 2016, (ADAMS Accession No. ML16194A294).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG-10-A-20), September 16, 2016, (ADAMS Accession No. ML16260A057).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), April 7, 2017 (ADAMS Accession No. ML17059D058).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG-10-A-20), May 2, 2017, (ADAMS Accession No. ML17122A217).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20),October 10, 2017 (ADAMS Accession No. ML17215A873).

Memorandum to the EDO: Status of Recommendations: Audit of NRCs Vendor Inspection Program (OIG-10-A-20), November 1, 2017 (ADAMS Accession No. ML17305A724).

Memorandum to the Assistant Inspector General for Audits: Status of Recommendations and Staff Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Vendor Inspection Program (OIG-10-A-20), May 15, 2018 (ADAMS Accession No. ML18105B139).

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