ML23122A164
| ML23122A164 | |
| Person / Time | |
|---|---|
| Issue date: | 05/26/2023 |
| From: | Andrea Veil Office of Nuclear Reactor Regulation |
| To: | Virkar H NRC/OIG/AIGA |
| References | |
| OEDO-22-00428, OIG-22-A-06 | |
| Download: ML23122A164 (1) | |
Text
May 26, 2023 MEMORANDUM TO: Hruta Virkar Assistant Inspector General for Audits Office of the Inspector General King, Michael signing on behalf of Veil, Andrea on 05/26/23 FROM: Andrea D. Veil, Director Office of Nuclear Reactor Regulation
SUBJECT:
STATUS OF RECOMMENDATIONS: 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)
This memorandum provides the U.S. Nuclear Regulatory Commission (NRC) staffs updates for the open recommendations from the Office of the Inspector Generals (OIGs) report OIG-22-A-06, Audit of the Nuclear Regulatory Commissions Oversight of Counterfeit, Fraudulent, and Suspect Items at Nuclear Power Reactors, dated February 9, 2022. The staff continues to implement actions cited in OIGs audit and remains responsive to OIGs recommendations. The staffs initial response to OIG, dated April 11, 2022, described the planned actions for each recommendation listed below. OIG provided its analysis and status of recommendations on April 26, 2022. The staff updated the status for each recommendation in a letter dated September 20, 2022. OIG provided its analysis and status of recommendations on October 26, 2022. OIG considers recommendations 1, 3, and 5 as closed. Recommendations 2, 4, 6, 7 and 8 remain open and resolved.
Enclosure:
Correspondence Reference for OIG-22-A-06 CONTACT: Frankie Vega, NRR/DRO (301) 415-1617
H. Virkar 2 Recommendation 1:
Develop processes and guidance to collect, process, and disseminate CFSI [counterfeit, fraudulent, and suspect item] information.
Status:
Closed Recommendation 2:
Communicate those processes across the agency, or at least to the divisions affected by CFSI.
NRC Staff Update:
The NRC developed an outreach and communications plan (Agencywide Documents Access and Management System Accession No. ML22297A267) to enhance communications on CFSI.
The CFSI Steering Committee has reviewed the outreach and communications plan, which has been shared with NRC program and regional offices affected by CFSI. The January 2023 inspector newsletter contained an article to raise awareness of the outreach and communications plan.
Target Completion Date: Completed. The NRC staff issued the outreach and communications plan in November 2022.
Point of
Contact:
Deanna Zhang, NRR/DRO 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.
Status:
Closed Recommendation 4:
Clearly define CFSI.
NRC Staff Update:
The response to recommendation 6 references the documents and inspection guidance that have been or will be updated. The NRC staff will continue to work with the program offices to update these documents.
Target Completion Date: October 2023.
Point of
Contact:
Deanna Zhang, NRR/DRO
H. Virkar 3 Recommendation 5:
Include a CFSI category in the Allegations Management System (AMS).
Status:
Closed Recommendation 6:
Develop inspection guidance with examples pertaining to identifying CFSI in inspection procedures.
NRC Staff Update:
The NRC staff has updated inspection guidance across business lines (e.g., operating reactor baseline inspections, spent fuel storage and transportation inspections, vendor inspections, new reactor construction inspections) to include appropriate CFSI guidance, including the agencys formal definition of CFSI. Specifically, the staff has updated the following inspection manual chapter (IMC) and inspection procedures (IPs):
IMC 2507, Vendor Inspections (ML23037A834)
IP 43002, Routine Inspections of Nuclear Vendors (ML22340A482)
IP 43004, Inspection of Commercial-Grade Dedication Programs (ML22340A481)
IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance (ML22340A480)
IP 36100.001, Inspection of 10 CFR 50.55(e) Programs for Reporting Defects and Noncompliance During Construction (ML23025A396)
The NRC will update the following IPs by September 2023:
IP 60852, ISFSI Component Fabrication by Outside Fabricators IP 60853, On-Site Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation IP 86001, Design, Fabrication, Testing, and Maintenance of Transportation Packagings The NRC will update the following regulatory guides (RGs) by October 2023:
RG 1.164, Dedication of Commercial-Grade Items for Use in Nuclear Power Plants RG 1.234, Evaluating Deviations and Reporting Defects and Noncompliance Under 10 CFR Part 21
H. Virkar 4 The NRC staff continues to engage external stakeholders (e.g., Electric Power Research Institute (EPRI), International Atomic Energy Agency) in seeking insights to inform updates to the NRCs guidance on CFSI, as needed.
Target Completion Date: October 2023 Point of
Contact:
Deanna Zhang, NRR/DRO Recommendation 7:
Develop CFSI training for inspectors.
NRC Staff Update:
The NRC staff had previously stated it would revise IMC 1245, Appendix A, Basic-Level Training and Qualification Journal, to include an individual study activity (ISA) on the topic of CFSI. However, after further evaluation, the NRC staff has instead revised several ISAs in IMC 1245, Appendix B, General Proficiency-Level Training and Qualification Journal (ML23037A835), to include relevant CFSI information. The staff is currently working on updating IMC 1246, Appendix B2, Training Requirements and Qualification Journal for Spent Fuel Storage and Transportation Inspector, and IMC 1246, Appendix B3, Training Requirements and Qualification Journal for Independent Spent Fuel Storage Installation Inspector, and plans to issue these documents by November 2023.
The NRC staff has held preliminary discussions with EPRI to have EPRIs CFSI training made more readily accessible to inspectors. These discussions will continue in the upcoming months.
Target Completion Date: November 2023 Point of
Contact:
Deanna Zhang, NRR/DRO Recommendation 8:
Develop a knowledge management and succession plan for CFSI.
NRC Staff Update:
The Office of Nuclear Regulator Regulation, Division of Reactor Oversight, Generic Communications and Operating Experience Branch, has assigned new members to the CFSI Technical Review Group. These new members will receive training on CFSI awareness and the CFSI Technical Review Group processes. The NRC staff has updated the Nuclepedia page on CFSI (https://nuclepedia.usalearning.gov/index.php/Counterfeit,_Fraudulent,_and_Suspect_Items) to incorporate additional information. The NRC staff will continue to ensure the identification, capture, retention, transfer, use, and reuse of relevant critical knowledge associated with CFSI.
Target Completion Date: Completed Point of
Contact:
Deanna Zhang, NRR/DRO
H. Virkar 5
SUBJECT:
STATUS OF RECOMMENDATIONS FROM 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) DATE: May 26, 2023 DISTRIBUTION: OEDO-22-00428 Non Public DZhang, NRR KKavanagh, NRR RFelts, NRR RLagios, NSIR CSafford, NMSS CRios-Collazo, OI DPelton, OE PHabighorst, OIP RidsNrrOd Resource RidsNrrMailCenter Resource RidsOedoMailCenter Resource ADAMS ACCESSION NO.: ML23122A164 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB QTE*
NAME FVega DZhang KKavanagh JDougherty DATE 5/3/2023 5/3/2023 5/3/2023 5/9/2023 OFFICE NRR/DRO NMSS/DFM NSIR OI NAME RFelts CSafford RLagios CRios-Collazo DATE 5/11/2023 5/11/2023 5/16/2023 5/16/2023 OFFICE OGC/LHE/SE OE NRR NAME PMoulding DPelton AVeil (MKing for)
DATE 5/16/2023 5/17/2023 5/26/2023 OFFICIAL RECORD COPY
Correspondence Reference OIG-22-A-06, Audit of the Nuclear Regulatory Commissions Oversight of Counterfeit, Fraudulent, and Suspect Items at Nuclear Power Reactors OIG-22-A-06, Audit of the Nuclear Regulatory Commissions Oversight of Counterfeit, Fraudulent, and Suspect Items at Nuclear Power Reactors, February 9, 2022 (Agencywide Documents Access and Management System Accession No. ML22040A058).
Memorandum from Darrell J. Roberts to Eric Rivera, 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),
April 11, 2022 (ML22077A775).
Memorandum from Eric Rivera to Daniel H. Dorman, Status of Recommendations: Office of the Inspector Generals Audit of the USNRCs Oversight of Counterfeit, Fraudulent, and Suspect Items at Nuclear Power Reactors (OIG-22-A-06), April 26, 2022 (ML22116A020).
Memorandum from Andrea D. Veil to Eric Rivera, 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), September 20, 2022 (ML22237A227).
Memorandum from Hruta Virkar to Daniel H. Dorman, Status of Recommendations: Office of the Inspector Generals Audit of the USNRCs Oversight of Counterfeit, Fraudulent, and Suspect Items at Nuclear Power Reactors (OIG-22-A-06), October 6, 2022 (ML22280A058).
Enclosure