ML21113A063

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Response to OIG Audit of Nrc'S Use of RAIs in Licensing Processes for Snf, Audit Report OIG-21-A-08
ML21113A063
Person / Time
Issue date: 05/07/2021
From: Darrell Roberts
NRC/EDO/DEDMRT
To: Rivera E
NRC/OIG
DHabib NMSS/DFM/STL 301.415.1035
Shared Package
ML21113A140:ML21103A227 List:
References
OIG-21-A-18
Download: ML21113A063 (4)


Text

B. Baker UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 7, 2021 MEMORANDUM TO: Eric Rivera Acting Assistant Inspector General for Audits Office of the Inspector General FROM: Darrell J. Roberts /RA/

Deputy Executive Director for Materials, Waste, Research, State, Tribal, Compliance, Administration and Human Capital Programs Office of the Executive Director for Operations

SUBJECT:

STAFF RESPONSE TO THE OFFICE OF THE INSPECTOR GENERALS AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS USE OF REQUESTS FOR ADDITIONAL INFORMATION IN LICENSING PROCESSES FOR SPENT NUCLEAR FUEL (OIG-21-A-08)

The staff received the Office of the Inspector Generals (OIG) Audit of the NRCs Use of Requests for Additional Information in Licensing Processes for Spent Nuclear Fuel, dated April 9, 2021. This memorandum provides the staffs response to the audit recommendations.

The response includes the planned actions and the target dates for completing the planned actions.

The OIG audit report finds that the NRCs use of requests for additional information in the spent fuel licensing process is effective and efficient. The OIG report made three recommendations regarding requests for additional information in spent nuclear fuel licensing processes to further enhance the program. The OIGs recommendations and staffs responses are provided below.

CONTACT: John B. McKirgan, NMSS/STLB 301-415-5722

E. Rivera 2 Recommendation 1:

Update guidance to document strategies or tools to be used for risk-informing requests for additional information.

Response and Planned Action The NRC staff agrees with the recommendation. The newly developed Division of Fuel Management Instruction on performing an acceptance review includes additional aspects of being risk-informed, such as identifying the significance of each request during the draft request for information stage, clarification calls, and part of division management engagement of any subsequent rounds of requests. The staff has issued guidance for the pilot use of the risk tool and will begin finalizing the guidance. Division management has also issued an expectations memo that reinforces risk-informed decision-making in all licensing processes. Additionally, NRC staff plans to hold early assignment and alignment meetings that use risk insights to help inform the scope, focus, and level of detail of each of the technical review areas involved in a review to support the review of licensing actions.

Target date for completion:

Complete action by first quarter FY2022.

Point of contact:

John B. McKirgan, NMSS/DFM/STLB, 301-415-5722 Recommendation 2:

Conduct training across the division on how to risk-inform relative to the request for additional information process, and conduct refresher training on an as needed, periodic basis.

Response and Planned Action The NRC staff agrees with the recommendation and plans to continue and complete training (including a Popup seminar, Be RiskSMART, in June, and other informal workshops and knowledge management sessions) on the division instruction for requests for additional information, applying the risk tool, and clarify what it means to be risk-informed in the context of the request for additional information process, and applying risk insights to the request for additional information process and other licensing processes.

Target date for completion:

Complete action by first quarter FY2022.

Point of contact:

John B. McKirgan, NMSS/DFM/STLB, 301-415-5722

E. Rivera 3 Recommendation 3:

Create and implement a formalized process to facilitate effective management transitions in the Division of Fuel Management.

Response and Planned Action The NRC staff agrees with the recommendation and plans to develop and implement a turnover checklist to be used when making management changes. The checklist will be included in a division-wide expectations memorandum. In addition, staff will continue to expand the use of Nuclepedia as a knowledge management tool to capture important technical positions and recurrent request for information issues. Review of the branches Nuclepedia inputs will be added to the turnover checklist.

Target date for completion:

Complete action by second quarter FY2022.

Point of contact:

John B. McKirgan, NMSS/DFM/STLB, 301-415-5722

E. Rivera 4

SUBJECT:

STAFF RESPONSE TO THE OFFICE OF THE INSPECTOR GENERALS AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS USE OF REQUESTS FOR ADDITIONAL INFORMATION IN LICENSING PROCESSES FOR SPENT NUCLEAR FUEL (OIG-21-A-08), DATED: May 7, 2021 DISTRIBUTION: OEDO-21-00180 CRegan, NMSS YDiaz-Sanabria, NMSS DHarrison, NMSS DMarcano, NMSS JMarcano, NMSS OSiurano-Perez, NMSS JJolicoeur, OEDO MBlair, OIG GButler, OIG RidsNmssOd Resource RidsOigMailCenter Resource RidsEdoMailCenter Resource ADAMS Accession Number: ML21103A227 Pkg; ML21113A063 Ltr *via e-mail OFFICE NMSS/ DFM/STLB: PM* NMSS DFM/STLB: LA* NMSS/DFM/STLB: BC* NMSS/DFM: D*

NAME DHabib WWheatley JMcKirgan CRegan (acting)

DATE 4/23/2021 4/23/2021 4/23/2021 4/25/2021 OFFICE NMSS: D* OEDO*

NAME JLubinski DRoberts DATE 4/27/2021 05/07/2021 OFFICIAL RECORD COPY