ML22032A009

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OIG-21-A-08-Status of Recommendations: Audit of the U.S. Nuclear Regulatory Commission'S Use of Requests for Additional Information in Licensing Processes for Spent Nuclear Fuel Dated February 1st, 2022
ML22032A009
Person / Time
Issue date: 02/01/2022
From: Rivera E
NRC/OIG/AIGA
To: Dan Dorman
NRC/EDO
References
OIG-21-A-08
Download: ML22032A009 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OFFICE OF THE INSPECTOR GENERAL February 1, 2022 MEMORANDUM TO: Daniel H. Dorman Executive Director for Operations FROM: Eric Rivera /RA/

Acting Assistant Inspector General for Audits Office of the Inspector General

SUBJECT:

STATUS OF RECOMMENDATIONS: 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)

REFERENCE:

DIRECTOR OF THE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGAURDS, MEMORANDUM DATED JANUARY 25, 2022 Attached is the Office of the Inspector Generals (OIG) analysis and status of recommendations as discussed in the agencys response dated January 25, 2022.

Based on this response, recommendations one, two, and three are now closed. All recommendations associated with this audit are now closed, and no further action is needed.

If you have questions or concerns, please call me at (301) 415-5915 or Mike Blair, Team Leader, at (301) 415-8399.

Attachment:

As stated cc: J. Jolicoeur, OEDO S. Miotla, OEDO RidsEdoMailCenter Resource OIG Liaison Resource EDO_ACS Distribution

Audit Report AUDIT OF THE NRCS USE OF REQUESTS FOR ADDITIONAL INFORMATION IN LICENSING PROCESSES FOR SPENT NUCLEAR FUEL (OIG-21-A-08)

Status of Recommendations Recommendation 1: Update guidance to document strategies or tools to be used for risk-informing requests for additional information.

Agency Response Dated January 25, 2022: On May 7, 2021, the staff agreed with the recommendation and identified aspects of being risk-informed that appear in the newly developed Division of Fuel Management (DFM)

Instruction on performing an acceptance review (ADAMS Accession No. ML21113A063). In January 2020, Division management issued an expectations memo reinforcing risk-informed decision-making in all licensing processes (ADAMS Accession No. ML20010D837). In December 2021, the staff subsequently issued two division instructions involving requests for additional information and risk-informing the review process.

In accordance with the new division instructions, U.S.

Nuclear Regulatory Commission (NRC) staff should conduct early assignment and alignment meetings using risk insights to help inform the scope, focus, and level of detail of each technical area involved in the review of licensing and certification actions. Based on the experience from the staffs pilot of the risk tool on two storage system amendment requests (ADAMS Accession No. ML20318A268), the staff is preparing an assessment and observations report which includes recommendations for refinements and improvements to the tool.

With the completion of the division instructions, which institutionalized consideration of risk insights in early assignment/alignment meetings, deployment of the risk tool, and issuance of the expectations memo, DFM has completed its actions for this recommendation.

Point of contact: Yoira Diaz-Sanabria, NMSS/DFM, 301-415-8064 OIG Analysis: OIG reviewed the three division instructions and the expectations memo, as mentioned in the agencys response, and confirmed that these guidance documents

Audit Report AUDIT OF THE NRCS USE OF REQUESTS FOR ADDITIONAL INFORMATION IN LICENSING PROCESSES FOR SPENT NUCLEAR FUEL (OIG-21-A-08)

Status of Recommendations Recommendation 1 (cont.):

OIG Analysis (continued):

contain strategies or tools for risk-informing requests for additional information. This recommendation is closed.

Status: Closed.

Audit Report AUDIT OF THE NRCS USE OF REQUESTS FOR ADDITIONAL INFORMATION IN LICENSING PROCESSES FOR SPENT NUCLEAR FUEL (OIG-21-A-08)

Status of Recommendations 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.

Agency Response Dated January 25, 2022: On May 7, 2021, the staff agreed with the recommendation and proposed to continue and complete training related to risk informing the licensing processes for spent fuel storage and transportation. In 2020 and 2021, the staff participated in 6 pop-up seminars for Be RiskSMART. Additionally, this training has been established as a course in NRCs Talent Management System (Be riskSMART: A Tool for Everyone). Also, in December 2021, DFM conducted training for staff on the two division instructions discussed above that address risk informing the review process. This training provided guidance on making risk-informed decisions during the licensing and certification processes for spent fuel storage requested actions, which includes the request for additional information process. With the completion of this training, DFM has completed its actions for this recommendation.

OIG Analysis: OIG reviewed training resources related to the request for additional information process, including the Be RiskSMART SharePoint site, and the resources and pop-up seminars posted on the site, as well as the training presentations on the division instructions, which address risk-informing. OIG concluded that these training resources adequately address risk-informing relative to the request for additional information process. This recommendation is closed.

Status: Closed.

Audit Report AUDIT OF THE NRCS USE OF REQUESTS FOR ADDITIONAL INFORMATION IN LICENSING PROCESSES FOR SPENT NUCLEAR FUEL (OIG-21-A-08)

Status of Recommendations Recommendation 3: Create and implement a formalized process to facilitate effective management transitions in the Division of Fuel Management.

Agency Response Dated January 25, 2022: On May 7, 2021, the staff agreed with the recommendation and proposed to develop and implement a turnover checklist to be used when making management changes. On December 17, 2021, the staff finalized the checklist and included it in a division-wide expectations memorandum, both available on the Divisions internal SharePoint site. In addition, as proposed in the staff response, DFM staff expanded the use of Nuclepedia as a knowledge management tool. Since the OIG audit, DFM staff participated in the NMSS Office-wide Nuclepedia Create-a-thon. Some of the input received during the event was incorporated in the management turnover checklist. The division started implementing this checklist when it was issued, and it will be part of the responsibilities of a new supervisor. With the completion of these activities, DFM has completed its actions for this recommendation.

OIG Analysis: OIG reviewed the expectations memorandum and the DFM supervisor transition checklist. OIG believes these documents will help DFM facilitate effective management transitions. This recommendation is closed.

Status: Closed.