ML22077A775
| ML22077A775 | |
| Person / Time | |
|---|---|
| Issue date: | 04/11/2022 |
| From: | Andrea Veil Office of Nuclear Reactor Regulation |
| To: | Rivera E NRC/OIG/AIGA |
| Zhang D | |
| References | |
| OIG-22-A-06 | |
| Download: ML22077A775 (6) | |
Text
April 11, 2022 MEMORANDUM TO:
Eric Rivera Acting Assistant Inspector General for Audits FROM:
Darrell J. Roberts Deputy Executive Director for Reactor and Preparedness 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 OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
The staff has received the Office of the Inspector Generals (OIGs) report for Audit OIG-22-A-06, Audit of Nuclear Regulatory Commissions Oversight of Counterfeit, Fraudulent, and Suspect Items at Nuclear Power Reactors, dated February 9, 2022. This memorandum provides the staffs responses to the eight OIG recommendations, including the staffs planned actions to enhance the U.S. Nuclear Regulatory Commissions oversight process for counterfeit, fraudulent, and suspect items and target dates for completion. The staff selected target dates for completion to not impact current oversight and outreach activities, recognizing that planned actions are primarily enhancements to the agencys oversight of nuclear power reactor programs.
Enclosure:
Staff Response to Recommendations from OIG-22-A-06 CONTACT: Deanna Zhang, NRR/DRO (301) 415-1946 Signed by Roberts, Darrell on 04/08/22
ML22077A775 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO NRR NAME DZhang KKavanagh RFelts AVeil (MKing for)
DATE 3/18/2022 3/22/2022 3/23/2022 4/4/2022 OFFICE NSIR/DPCP NMSS/DFM OI OGC/LHE/SE NAME JBeardsley CRegan JPrichard PMoulding DATE 3/28/2022 3/28/2022 3/28/2022 3/29/2022 OFFICE OE OIP/ECNB OEDO NAME TMartinezNavedo PHabighorst DRoberts DATE 3/28/2022 3/28/2022 4/08/2022
Enclosure Staff Response to Recommendations from OIG-22-A-06 Recommendation 1:
Develop processes and guidance to collect, process, and disseminate CFSI information.
Response
The staff agrees with the recommendation.
Planned actions: The U.S. Nuclear Regulatory Commission (NRC) staff will enhance the existing processes and guidance to include a more detailed and systematic process to collect, process, and disseminate counterfeit, fraudulent, and suspect items (CFSI) information.
Specifically, as noted in the audit report, the NRC CFSI Technical Review Group (TRG) has a desktop guide describing the general process to be followed when assessing potential CFSI concerns. The NRC staff plans to revise the TRG Desktop Guide to include a more detailed and systematic process for collecting and disseminating CFSI information. This desktop guide will be shared with NRC program and regional offices affected by CFSI.
Target date for completion: September 2022 Point of Contact (POC): Deanna Zhang, CFSI TRG Lead Recommendation 2:
Communicate those processes across the agency, or at least to the divisions affected by CFSI.
Response
The staff agrees with the recommendation.
Planned actions: The NRC staff will revise the CFSI TRG Desktop Guide to include a process for communicating with liaisons in the NRC program and regional offices affected by CFSI, including processes for sharing the desktop guide with internal stakeholders. The NRC staff will also coordinate with NRC program and regional offices to develop an outreach and communications plan to enhance communications on this subject.
Target date for completion: October 2022 POC: Deanna Zhang, CFSI TRG Lead Recommendation 3:
Develop a coherent agencywide approach for CFSI, identifying the agencys primary objective regarding mitigation of CFSI into agency-regulated equipment, components, systems, and structures.
Response
The staff agrees with the recommendation.
Planned actions: The NRC staff, as directed by the NRC CFSI steering committee, will coordinate with NRC program and regional offices to develop an agencywide CFSI oversight charter detailing objectives, overall approach, and strategy in order to enhance the agencys ability to mitigate the risk associated with CFSI. The charter will clearly state the roles and responsibilities necessary to accomplish NRC activities associated with CFSI at an agencywide level. The charter will incorporate a CFSI definition to ensure consistency when addressing related agency oversight activities and will be consistent with the long-term actions planned in response to Recommendation 4. This definition will be reviewed for alignment with definitions for CFSI contained in industry guidance and international standards.
Target date for completion: August 2022 POC: Deanna Zhang, CFSI TRG Lead Recommendation 4:
Clearly define CFSI.
Response
The staff agrees with this recommendation.
Planned actions: The NRC staff will incorporate the definition for CFSI from the charter developed in response to Recommendation 3 into guidance documents, including the CFSI TRG desktop guide, inspection guidance (e.g., inspection procedures for commercial-grade dedication for vendors and reactor facilities), and other relevant documents.
Target date for completion: April 2023 POC: Deanna Zhang, CFSI TRG Lead Recommendation 5:
Include a CFSI category in the AMS.
Response
The staff agrees with this recommendation.
The staff will include a CFSI category in the AMS.
Target date for completion: December 30, 2022 POC: Lisamarie Jarriel, AAA Recommendation 6:
Develop inspection guidance with examples pertaining to identifying CFSI in inspection procedures.
Response
The staff agrees with the recommendation.
Planned actions: The NRC staff plans to evaluate current inspection guidance across business lines (e.g., operating reactor baseline inspections, spent fuel storage and transportation, vendor inspections, new reactor construction inspections) to include appropriate CFSI guidance in inspection procedures. Potential revisions to inspection procedures may include appendices with examples of key attributes for identifying potential CFSI to facilitate inspection activities.
The NRC staff also plans to engage external stakeholders (e.g., Electric Power Research Institute (EPRI), International Atomic Energy Agency) and seek insights and experience to inform any updates to NRCs guidance on CFSI, as needed.
Target date for completion: April 2023 POC: Deanna Zhang, CFSI TRG Lead Recommendation 7:
Develop CFSI training for inspectors.
Response
The staff agrees with the recommendation.
Planned actions: The NRC staff plans to develop an individual study activity (ISA) on the topic of CFSI to include in inspection manuals that support different inspection programs (e.g.,
operating reactor baseline inspections, spent fuel storage and transportation, vendor inspections, new reactor construction inspections). The NRC staff provided CFSI awareness training to disseminate CFSI related information to inspection staff in March of 2022; future awareness training will be offered on an as-needed basis. The NRC staff also plans to engage EPRI to have EPRIs CFSI training more readily accessible to inspectors.
Target date for completion: March 2023 for ISA development; Awareness training activities will be offered an as-needed basis.
POC: Deanna Zhang, CFSI TRG Lead Recommendation 8:
Develop a knowledge management and succession plan for CFSI.
Response
The staff agrees with the recommendation.
Planned actions: The NRC staff plans to incorporate CFSI knowledge management plans into the NRCs Knowledge Management Program and workforce planning activities to ensure the identification, capture, retention, transfer, use, and reuse of relevant critical knowledge associated with CFSI.
Target date for completion: November 2022 POC: Deanna Zhang, CFSI TRG Lead