ML18136A734

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OIG-18-A-13- Audit of Nrc'S Special and Infrequently Performed Inspections Dated May 16, 2018
ML18136A734
Person / Time
Issue date: 05/16/2018
From: Baker B
NRC/OIG/AIGA
To: Mccree V
NRC/EDO
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OIG-18-A-13
Download: ML18136A734 (25)
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Audit of NRCs Special and Infrequently Performed Inspections OIG-18-A-13 May 16, 2018 All publicly available OIG reports (including this report) are accessible through NRCs Web site at http://www.nrc.gov/reading-rm/doc-collections/insp-gen

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OFFICE OF THE INSPECTOR GENERAL May 16, 2018 MEMORANDUM TO: Victor M. McCree Executive Director for Operations FROM: Dr. Brett M. Baker /RA/

Assistant Inspector General for Audits

SUBJECT:

AUDIT OF NRCS SPECIAL AND INFREQUENTLY PERFORMED INSPECTIONS (OIG-18-A-13)

Attached is the Office of the Inspector Generals (OIG) audit report titled Audit of NRCs Special and Infrequently Performed Inspections.

The report presents the results of the subject audit. Following the May 9, 2018, exit conference, agency staff indicated that they had no formal comments for inclusion in this report.

Please provide information on actions taken or planned on each of the recommendations within 30 days of the date of this memorandum. Actions taken or planned are subject to OIG followup as stated in Management Directive 6.1.

We appreciate the cooperation extended to us by members of your staff during the audit. If you have any questions or comments about our report, please contact me at (301) 415-5915 or Paul Rades, Team Leader, at (301) 415-6228.

Attachment:

As stated

Office of the Inspector General U.S. Nuclear Regulatory Commission Defense Nuclear Facilities Safety Board OIG-18-A-13 Results in Brief May 16, 2018 Why We Did This Review Audit of NRCs Special and Infrequently Performed The Nuclear Regulatory Commission Inspections (NRC) may conduct special and infrequent inspections using criteria What We Found in Inspection Manual Chapter (IMC) 2515 Appendix C. These inspections NRC staff are required to review IMC 2515 Appendix C inspection are in addition to baseline procedures on a 4-year periodic basis. However, NRC staff do not inspections conducted at commercial consistently review all IMC 2515 Appendix C inspection procedures nuclear power plants in support of on a periodic basis as required because there is conflicting the Reactor Oversight Process. NRC conducts these special and infrequent guidance and low staff awareness of procedural requirements for inspections in response to safety and conducting these reviews. As a result, outdated IMC 2515 security events at nuclear power Appendix C inspection procedures could reduce the efficiency and plants, and to ensure the safety of effectiveness in the planning and performance of these infrequent, but major plant licensing and maintenance activities. inspections.

NRC conducts IMC 2515 Appendix C Additionally, NRC management is responsible for developing inspections to evaluate emergent application controls to achieve validity, completeness, and technical issues not related to plant licensee performance, fulfill NRCs accuracy of data processed in an information system. However, obligations under domestic NRC staff incorrectly coded inspections under IMC 2515 Appendix interagency memoranda of C in the agencys legacy Reactor Program System. This occurred understanding such as information because application controls in the Reactor Program System, exchanges between NRC and States, Tribes, and local governments, and operational before October 2017, were not sufficient to ensure implement the requirements of Title proper coding of inspections to IMC 2515 Appendix C. Reliable 10 Code of Federal Regulations (10 data is important for effective management and oversight of NRCs CFR) Part 75 for treaties between the inspection activities.

United States and the International Atomic Energy Agency.

What We Recommend The audit objectives were to assess NRCs processes for (1) identifying This report makes six recommendations regarding periodic conditions that warrant special and infrequently performed inspections assessments of IMC 2515 Appendix C inspection procedures and at commercial power reactors under application controls in the Replacement Reactor Program System -

IMC 2515 Appendix C, and (2) Inspections Module.

conducting these inspections in accordance with agency guidance.

Audit of NRCs Special and Infrequently Performed Inspections TABLE OF CONTENTS ABBREVIATIONS AND ACRONYMS .......................................................... i I. BACKGROUND ................................................................................ 1 II. OBJECTIVE ...................................................................................... 6 III. FINDINGS ................................................................................................... 6 A. NRC Staff Do Not Consistently Review All IMC 2515 Appendix C Inspection Procedures on a Periodic Basis ........ 6 B. Opportunities To Improve Replacement Reactor Program System Data Entry Controls ................................................. 11 IV. CONSOLIDATED LIST OF RECOMMENDATIONS ....................... 15 V. AGENCY COMMENTS ................................................................... 16 APPENDIXES A. OBJECTIVE, SCOPE, AND METHODOLOGY ............................... 17 B. Revision History of IMC 2515 Appendix C Inspection Procedures ..................................................................................... 19 TO REPORT FRAUD, WASTE, OR ABUSE ............................................. 20 COMMENTS AND SUGGESTIONS .......................................................... 20

Audit of NRCs Special and Infrequently Performed Inspections ABBREVIATIONS AND ACRONYMS EOC End-of-Cycle IMC Inspection Manual Chapter NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation OIG Office of the Inspector General 10 CFR Title 10 Code of Federal Regulations i

Audit of NRCs Special and Infrequently Performed Inspections I. BACKGROUND Special and Infrequently Performed Inspections The Nuclear Regulatory Commission (NRC) may conduct special and infrequent inspections using criteria in Inspection Manual Chapter (IMC) 2515 Appendix C. These inspections are in addition to baseline inspections conducted at commercial nuclear power plants in support of the Reactor Oversight Process.1 NRC conducts these special and infrequent inspections in response to safety and security events at nuclear power plants, and to ensure the safety of infrequent, but major plant licensing and maintenance activities.

NRC conducts IMC 2515 Appendix C inspections to evaluate emergent technical issues not related to plant licensee performance, fulfill NRCs obligations under domestic interagency memoranda of understanding such as information exchanges between NRC and States, Tribes, and local governments, and implement the requirements of Title 10 Code of Federal Regulations (10 CFR) Part 75 for treaties between the United States and the International Atomic Energy Agency (see Figure 1).

Regional Administrator authorization is generally required for implementation of IMC 2515 Appendix C inspections.

1 The Reactor Oversight Process is NRCs program to inspect, measure, and assess operating commercial nuclear power plant licensees safety and security, and to predictably respond to declining performance.

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Audit of NRCs Special and Infrequently Performed Inspections Figure 1: IMC 2515 Appendix C Inspection Areas Source: OIG generated from NRC IMC 2515 Appendix C.

Special, Augmented, and Incident Investigation Inspection Process NRC uses the process described in Management Directive 8.3, NRC Incident Investigation Program, in accordance with IMC 0309, Reactive Inspection Decision Basis for Reactors, to determine the appropriate level of response following an unforeseen safety or security event at a plant.

Management Directive 8.3 Process The cognizant Regional Administrator and staff perform an initial review to assess the events safety or security significance to determine the level of response required. After the initial review, staff screen the event through deterministic criteria2 and perform risk analysis, if needed, to determine the decision basis for conducting a special inspection, an augmented inspection, or an incident investigation. Based on the results of the Management Directive 8.3 process, NRC may deploy a Special Inspection Team, an Augmented Inspection Team, or an Incident Investigation Team to gather and analyze information to support NRCs regulatory response.

2 Deterministic criteria consist of a series of yes or no questions to assess the safety or security significance of the event to determine the level of response required.

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Audit of NRCs Special and Infrequently Performed Inspections Special Inspection Team A Special Inspection Team consists of technical experts from the NRC region in which the event took place and is generally not augmented by personnel from headquarters, other regions, or contractors. The Special Inspection Team reports directly to the authorizing Regional Administrator.

Inspection Procedure 93812, Special Inspection, provides implementing procedures for the Special Inspection Team.

Augmented Inspection Team An Augmented Inspection Team consists of technical experts from the region in which the incident took place, augmented by personnel from headquarters, other regions, or contractors as needed. An Augmented Inspection Team response emphasizes fact-finding and determination of probable cause(s), as well as the conditions and circumstances relevant to issues directly related to the event. The Augmented Inspection Team reports directly to the authorizing Regional Administrator. Inspection Procedure 93800, Augmented Inspection Team, provides implementing procedures for the Augmented Inspection Team. As an example, NRC convened an Augmented Inspection Team in response to an industrial accident at Arkansas Nuclear One on March 31, 2013, in which a temporary overhead crane fell onto the turbine deck, causing a loss of offsite power to Unit 1 and an automatic shutdown of Unit 2.

Incident Investigation Team An Incident Investigation Team consists of technical experts who, to the extent possible, do not have, and have not had previous significant involvement with licensing and inspection activities at the affected facility.

A senior manager leads the Incident Investigation Team to perform this single NRC investigation of a significant event. There have been no incident investigations performed over the past 10 years, from 2008 through 2017.

Other Infrequent Inspections Process NRC reviews licensees performance over a 12-month period as part of the process described in IMC 0305, Operating Reactor Assessment 3

Audit of NRCs Special and Infrequently Performed Inspections Program, to plan other infrequent IMC 2515 Appendix C inspections.

Each regional office conducts an end-of-cycle (EOC) review of each plant using performance indicators, inspection results, and enforcement actions compiled over the assessment period to plan other IMC 2515 Appendix C inspection activities for the next 18 to 24 months following the end of the assessment period.

In preparation for the EOC assessment review meetings,3 regional offices develop an EOC package, which in accordance with IMC 0305 consists of a meeting agenda to identify topic areas of discussion during the meeting, a plant issues matrix, plant performance summaries, and a proposed inspection plan for each plant. These documents are electronically submitted prior to the EOC meeting to facilitate meeting discussions.

Regional division directors and/or branch chiefs present the results of the annual review to the Regional Administrator. This results in issuance of an annual assessment letter to the licensee within 9 weeks after the end of the EOC assessment period.

NRCs Inspection Oversight Roles and Responsibilities NRCs Office of Nuclear Reactor Regulation (NRR) is responsible for the overall management, support, and oversight of IMC 2515 Appendix C inspections, including the language used in IMC 2515 Appendix C inspection procedures. The Division of Inspection and Regional Support within NRR makes revisions to the reactor inspection program and oversees regional implementation. Inspectors are responsible for performing IMC 2515 Appendix C inspections, while Regional Managers oversee these and are responsible for ensuring IMC 2515 Appendix C inspections are completed.

Inspections Performed Under IMC 2515 Appendix C During the period from January 2008 through October 2017, the agency performed 1,004 inspections under IMC 2515 Appendix C.4 See Figure 2 for a chart showing a summary of the types of inspections performed under IMC 2515 Appendix C.

3 The EOC assessment review meeting is held annually in each region, and is chaired by the Regional Administrator.

4 The 273 incorrectly coded inspections in the agencys Reactor Program System did not correlate to any of the 35 inspection procedures listed under IMC 2515 Appendix C. NRC used the Reactor Program System for planning, scheduling, reporting, and analyzing nuclear power plant inspections. NRC subsequently replaced this data system with the Replacement Reactor Program System - Inspections Module in October 2017.

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Audit of NRCs Special and Infrequently Performed Inspections Figure 2: Inspections Performed Under IMC 2515 Appendix C 2008-2017 273 Incorrectly Coded 624 Infrequently Performed Inspections Inspections 27% 62%

10 Augmented Inspections 1%

97 Special Inspections 10%

Source: OIG analysis of IMC 2515 Appendix C inspection data from NRCs legacy Reactor Program System.

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Audit of NRCs Special and Infrequently Performed Inspections II. OBJECTIVE The audit objectives were to assess NRCs processes for (1) identifying conditions that warrant special and infrequently performed inspections at commercial power reactors under IMC 2515 Appendix C, and (2) conducting these inspections in accordance with agency guidance. See Appendix A for information on the audit scope and methodology.

III. FINDINGS NRC has adequate processes for determining when and where to conduct IMC 2515 Appendix C inspections at commercial power reactors and for conducting these inspections in accordance with agency guidance.

However, NRC could benefit from periodic assessments of IMC 2515 Appendix C inspection procedures and testing of application controls in the Replacement Reactor Program System - Inspections Module.

A. NRC Staff Do Not Consistently Review All IMC 2515 Appendix C Inspection Procedures on a Periodic Basis NRC staff are required to review IMC 2515 Appendix C inspection procedures on a 4-year periodic basis. However, NRC staff do not consistently review all IMC 2515 Appendix C inspection procedures on a periodic basis as required because there is conflicting guidance and low staff awareness of procedural requirements for conducting these reviews.

As a result, outdated IMC 2515 Appendix C inspection procedures could reduce the efficiency and effectiveness in the planning and performance of these inspections.

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Audit of NRCs Special and Infrequently Performed Inspections What Is Required NRC Should Review IMC 2515 Appendix C Inspection Procedures on a 4-year Periodic Basis NRCs Inspection Manual Chapter 0307, Reactor Oversight Process Self-Assessment Program, and NRRs office instruction, NRR Procedures for Processing Inspection Manual Documents, require periodic review of inspection procedures. Specifically, Inspection Manual Chapter 0307 states that each inspection procedure will be reviewed at least once every 4 years.

Additionally, the Government Accountability Offices Standards for Internal Control in the Federal Government 5 (Green Book) states management is responsible for providing procedures that support efficient operations, reliable reporting and communication, and reasonable assurance that agency requirements are met.

What We Found NRC Staff Do Not Consistently Review All IMC 2515 Appendix C Inspection Procedures as Required Contrary to agency guidance, NRC staff do not consistently review all IMC 2515 Appendix C inspection procedures on a 4-year periodic basis.

Rather, staff rely on the Inspection Program Feedback Process6 to review these inspection procedures and revise them as needed. To gain a better understanding of how often IMC 2515 Appendix C inspection procedures are reviewed, OIG analyzed the revision history of all 35 inspection procedures listed under IMC 2515 Appendix C. Based on this analysis, OIG found 5

GAO-14-704G, September 2014.

6 The feedback process is used by NRC staff to identify and resolve problems, concerns, or difficulties encountered in implementing NRCs inspection programs. The feedback form is the formal mechanism used for initiating a change to an inspection program document.

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Audit of NRCs Special and Infrequently Performed Inspections 21 inspection procedures have not been reviewed within the required 4-year period.

13 inspection procedures have been reviewed within the required 4-year period.

1 inspection procedure (60715) was created in October 2015, and will require review by October 2019.

Additionally, 5 of these 35 inspection procedures date back to the Systematic Assessment of Licensee Performance, which was superseded by the Reactor Oversight Process in April 2000.

See Table 1 for a list of IMC 2515 Appendix C inspection procedures and periods since last review.

Table 1: IMC 2515 Appendix C Inspection Procedures and Periods Since Last Review Periods Since Last Review Inspection Procedure 0-4 Years 4-8 Years 8-12 Years 12-16 Years 16-20 Years 20-24 Years 24-28 Years 28-32 Years 36100 37060 40001 40100 41500 43004 50001 50003 52003 60705 60710 60715*

60845 60854.1 60855.1 60856.1 71003 71004 71007 71013 71150 81311 85420 92050 92702 92709 92711 92712 92722 92723 93001 93002 93100 93800 93812 Total 13 7 7 1 1 4 0 1

Source: OIG analysis of IMC 2515 Appendix C inspection procedures revision history.

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Audit of NRCs Special and Infrequently Performed Inspections Additionally, see Appendix B of this report for a revision history of all 35 inspection procedures listed under IMC 2515 Appendix C.

Why This Occurred Conflicting Guidance and Low NRC Staff Awareness Regarding the Requirement for Periodic Reviews NRC staff do not periodically review IMC 2515 Appendix C inspection procedures because NRC has conflicting guidance regarding the frequency of inspection procedure reviews, and there is low staff awareness of procedural requirements for these reviews.

Conflicting Guidance NRC has conflicting guidance regarding how often IMC 2515 Appendix C inspection procedure reviews are to be done. For example, IMC 0307 states each inspection procedure will be reviewed at least once every 4 years. However, NRRs office instruction states reviews are to be done every 5 years.

Low Staff Awareness of Procedural Requirements NRC staff and supervisors responsible for reviewing IMC 2515 Appendix C inspection procedures are generally not aware of the requirements in IMC 0307, and NRRs office instruction to periodically review IMC 2515 Appendix C inspection procedures.

OIG interviewed four NRC staff and two supervisors who are responsible for updating IMC 2515 Appendix C inspection procedures. These NRC staff and supervisors were generally not aware of the requirements in IMC 0307 and the NRRs office instruction. Rather, they referenced IMC 0040, Preparing, Revising, and Issuing Documents for the NRC Inspection Manual, as guidance to review IMC 2515 Appendix C inspection procedures. However, IMC 0040 does not directly address frequency of inspection procedure reviews. Instead, it focuses on developing clear, accurate, and effective IMC documents.

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Audit of NRCs Special and Infrequently Performed Inspections Why This Is Important Outdated IMC 2515 Appendix C Inspection Procedures Could Reduce Efficiency and Effectiveness in the Planning and Performance of Infrequently Performed Inspections NRC inspectors conducting IMC 2515 Appendix C inspections rely on IMC 2515 Appendix C inspection procedures to plan and perform these inspections. Therefore, outdated inspection procedures could reduce efficiency and effectiveness in the planning and performance of IMC 2515 Appendix C inspections. For example, inspectors could spend unnecessary time looking for other guidance to supplement outdated IMC 2515 Appendix C inspection procedures. Additionally, if IMC 2515 Appendix C inspection procedures are not periodically updated with current and complete guidance, the relevance and thoroughness of inspection tasks could be affected.

Recommendations OIG recommends that the Executive Director for Operations

1. Update IMC 2515 Appendix C and applicable NRR guidance to reflect the requirement to ensure consistent and periodic reviews of IMC 2515 Appendix C inspection procedures.
2. Implement means for scheduling and tracking periodic reviews of IMC 2515 Appendix C inspection procedures.
3. Review the inspection procedures listed in IMC 2515 Appendix C to determine if they are still warranted.

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Audit of NRCs Special and Infrequently Performed Inspections B. Opportunities To Improve Replacement Reactor Program System Data Entry Controls NRC management is responsible for developing application controls to achieve validity, completeness, and accuracy of data processed in an information system. However, NRC staff incorrectly coded inspections under IMC 2515 Appendix C in the agencys legacy Reactor Program System. This occurred because application controls in the Reactor Program System, operational before October 2017, were not sufficient to ensure proper coding of inspections to IMC 2515 Appendix C. This is of concern as NRC management needs reliable inspection data for effective management and oversight.

What Is Required NRC Should Strengthen Application Controls to Ensure the Validity, Completeness, and Accuracy of Data Processed in the Agencys Replacement Reactor Program System The Government Accountability Offices Application controls are those Standards for Internal Control in the controls that are incorporated Federal Government (Green Book) directly into computer applications stipulates that management is to achieve validity, completeness, responsible for developing application accuracy, and confidentiality of controls to achieve validity, transactions and data during completeness, and accuracy of data application processing.

processed in an information system. Application controls include, among other things, controls over input, processing, output, and data management system controls.

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Audit of NRCs Special and Infrequently Performed Inspections What We Found NRC Staff Incorrectly Coded Inspections under IMC 2515 Appendix C NRC staff incorrectly coded inspections under IMC 2515 Appendix C in the agencys legacy Reactor Program System. OIG reviewed 1,004 inspections performed under IMC 2515 Appendix C in the agencys legacy Reactor Program System from January 2008 through October 2017, and found 273 were incorrectly coded. The 273 incorrectly coded inspections did not correlate to any of the 35 inspection procedures listed under IMC 2515 Appendix C. These inspections should have been recorded in the legacy Reactor Program System using codes for inspection procedures that are not part of IMC 2515 Appendix C.

See Figure 3 for a graphical representation of the total number of IMC 2515 Appendix C and incorrectly coded inspections between January 2008 and October 2017.

Figure 3: IMC 2515 Appendix C and Incorrectly Coded Inspections Source: OIG analysis of IMC 2515 Appendix C inspection data from NRCs legacy Reactor Program System.

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Audit of NRCs Special and Infrequently Performed Inspections Why This Occurred Insufficient Application Controls in Reactor Program System to Ensure Proper Inspection Coding NRC staff incorrectly coded inspections under IMC 2515 Appendix C in the agencys legacy Reactor Program System because application controls in the Reactor Program System were not sufficient to ensure proper inspection coding.7 Although there were insufficient application controls in the agencys Reactor Program System to ensure proper inspection coding, the agency reportedly addressed this problem when it replaced the Reactor Program System with the Replacement Reactor Program System - Inspections Module in October 2017. However, the agency could not provide sufficient evidence during this audit that controls had been implemented to ensure proper IMC 2515 Appendix C inspection coding.

Why This Is Important NRC Needs Reliable Inspection Data for Effective Management and Oversight NRC management needs quality information to monitor inspection activities and ensure that the agency is effectively carrying out its safety mission. A lack of effective application controls in the Replacement Reactor Program System could lead to data reliability problems that limit management and oversight of commercial nuclear power reactor inspections. Additionally, agency staff and managers need reliable inspection data so they can accurately report agency activities to key stakeholders such as the Commission, Congress, and State officials.

7 Even though NRC staff incorrectly coded their work in the Reactor Program System as IMC 2515 Appendix C inspections, OIG did not identify fee billing issues because licensees are charged a standardized hourly labor rate for inspections in accordance with 10 CFR Part 170.20.

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Audit of NRCs Special and Infrequently Performed Inspections Recommendations OIG recommends that the Executive Director for Operations

4. Strengthen application controls in the Replacement Reactor Program System - Inspections Module to ensure NRC staff are correctly coding inspections under IMC 2515 Appendix C.
5. Periodically test application controls in the Replacement Reactor Program System - Inspections Module to ensure NRC staff are correctly coding inspections under IMC 2515 Appendix C.
6. Train NRC staff how to properly code IMC 2515 Appendix C inspections in the Replacement Reactor Program System -

Inspections Module.

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Audit of NRCs Special and Infrequently Performed Inspections IV. CONSOLIDATED LIST OF RECOMMENDATIONS OIG recommends that the Executive Director for Operations

1. Update IMC 2515 Appendix C and applicable NRR guidance to reflect the requirement to ensure consistent and periodic reviews of IMC 2515 Appendix C inspection procedures.
2. Implement means for scheduling and tracking periodic reviews of IMC 2515 Appendix C inspection procedures.
3. Review the inspection procedures listed in IMC 2515 Appendix C to determine if they are still warranted.
4. Strengthen application controls in the Replacement Reactor Program System - Inspections Module to ensure NRC staff are correctly coding inspections under IMC 2515 Appendix C.
5. Periodically test application controls in the Replacement Reactor Program System - Inspections Module to ensure NRC staff are correctly coding inspections under IMC 2515 Appendix C.
6. Train NRC staff how to properly code IMC 2515 Appendix C inspections in the Replacement Reactor Program System - Inspections Module.

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Audit of NRCs Special and Infrequently Performed Inspections V. AGENCY COMMENTS An exit conference was held with the agency on May 9, 2018. Agency management provided comments prior to this meeting, after reviewing a discussion draft. Agency management stated their general agreement with the report findings and recommendations.

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Audit of NRCs Special and Infrequently Performed Inspections Appendix A OBJECTIVE, SCOPE, AND METHODOLOGY Objective The audit objectives were to assess NRCs processes for (1) identifying conditions that warrant special and infrequently performed inspections at commercial power reactors under IMC 2515 Appendix C, and (2) conducting these inspections in accordance with agency guidance.

Scope The audit focused on identifying NRCs conditions that warrant special and infrequently performed inspections for commercial power reactors. We conducted this performance audit from September 2017 through January 2018 at NRC headquarters in Rockville, Maryland and identified inspections performed under IMC 2515 Appendix C from January 2008 to October 2017. Internal controls related to the audit objective were reviewed and analyzed.

Methodology To accomplish the audit objectives, OIG reviewed relevant criteria for this audit including:

Government Accountability Office, Standards for Internal Control in the Federal Government NRCs Principles of Good Regulation Additionally, OIG reviewed and analyzed the following guidance documents Inspection Manual Chapter 0040, Preparing, Revising, and Issuing Documents for the NRC Inspection Manual Inspection Manual Chapter 0305, Operating Reactor Assessment Program 17

Audit of NRCs Special and Infrequently Performed Inspections Inspection Manual Chapter 0307, Reactor Oversight Process Self-Assessment Program Inspection Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors Inspection Manual Chapter 2515, Appendix C, Special and Infrequently Performed Inspections Office of Nuclear Reactor Regulation, Office Instruction 102 (OVRST-102), Revision 2 Management Directive 8.3, NRC Incident Investigation Program To understand how NRC staff and managers identify safety inspections to be performed at commercial nuclear power plants, OIG interviewed NRC staff and management from NRR and all regional offices. OIG also identified the number of special and infrequently performed inspections from calendar years January 2008 through October 2017. In analyzing these inspections, OIG discovered inadequate application controls in the agencys legacy Reactor Program System.

Throughout the audit, auditors considered the possibility of fraud, waste, or abuse in the program.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

The audit was conducted by Paul Rades, Team Leader; Avinash Jaigobind, Audit Manager; John Thorp, Senior Technical Advisor; Jimmy Wong, Senior Management Analyst; Deyanara Gonzalez Lainez, Auditor; and Chanel Stridiron, Auditor.

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Audit of NRCs Special and Infrequently Performed Inspections Appendix B Revision History of IMC 2515 Appendix C Inspection Procedures Inspection Procedure Number Inspection Procedure Title Date Last Updated 36100 10 CFR Part 21 Inspections at Nuclear Power Reactors 02/13/2012 10 CFR 50.69 Risk-Informed Categorization and Treatment of 37060 Structures, Systems, and Components Inspection 09/14/2011 40001 Resolution of Employee Concerns 06/03/1997

  • 40100 Independent Safety Culture Assessment Follow-up 04/09/2015 41500 Training and Qualification Effectiveness 06/13/1995
  • 43004 Inspection of Commercial-Grade Dedication Programs 01/27/2017
  • 50003 Pressurizer Replacement Inspection 09/12/2017 52003 Digital Instrumentation & Control Modification Inspection 10/31/2008 60705 Preparation for Refueling 07/27/1995 60710 Refueling Activities 07/27/1995
    • 60715 Reserved for: Spent Fuel Safety at Operating Reactors 10/30/2015 60845 Operation of Intra-Unit Fuel Transfer Canister and Cask System 04/26/2012 60854.1 Preoperational Testing of ISFSIs at Operating Plants 09/05/2006 60855.1 Operation of an ISFSI at Operating Plants 09/05/2006 60856.1 Review of 10 CFR 72.212(b) Evaluations at Operating Plants 02/02/2004
  • 71003 Post-Approval Site Inspection For License Renewal (or 71013) 07/08/2016
  • 71004 Power Uprate 05/15/2017 71007 Reactor Vessel Head Replacement Inspection 06/04/2007
  • 71013 Site Inspections at Plants with Timely Renewal Applications 09/25/2013 71150 Discrepant or Unreported Performance Indicator Data 01/04/2007 Physical Security Requirements for Independent Spent Fuel
  • 81311 Storage Installations 08/25/2017 Inspection of IAEA Safeguards For Inspectors at Power 85420 Reactors 06/22/1988 92050 Review of Quality Assurance For Extended Construction Delay 04/04/2000 Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters ,

Confirmatory Orders, and Alternative Dispute Resolution 92702 Confirmatory Orders 01/10/2008

  • 92709 Licensee Strike Contingency Plans 03/14/2014 Continued Implementation of Strike Plans During an Extended
  • 92711 Strike 03/14/2014
  • 92712 Resumption of Normal Operations After a Strike 03/14/2014 Follow up Inspection for Any Severity Level I or II Traditional Enforcement Violation or for Two or More Severity Level III 92722 Traditional Enforcement Violations in a 12 Month Period 08/11/2009 Follow up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12 92723 Month Period 08/11/2009
  • 93001 OSHA Interface Activities 08/10/2016 93002 Managing Fatigue 11/09/2009
  • 93100 Safety Conscious Working Environment Issue Follow-up 04/09/2015 93800 Augmented Inspection Team 03/23/2009 93812 Special Inspection 11/15/2011
  • Inspection procedures were reviewed within in the past 4 years in response to the Inspection Program Feedback Process.

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Audit of NRCs Special and Infrequently Performed Inspections TO REPORT FRAUD, WASTE, OR ABUSE Please

Contact:

Email: Online Form Telephone: 1-800-233-3497 TTY/TDD: 7-1-1, or 1-800-201-7165 Address: U.S. Nuclear Regulatory Commission Office of the Inspector General Hotline Program Mail Stop O5-E13 11555 Rockville Pike Rockville, MD 20852 COMMENTS AND SUGGESTIONS If you wish to provide comments on this report, please email OIG using this link.

In addition, if you have suggestions for future OIG audits, please provide them using this link.

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