ML23163A237
| ML23163A237 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/2023 |
| From: | Virkar H NRC/OIG/AIGA, OIG Watch |
| To: | Dan Dorman, Scott(Ois) Morris NRC/EDO, NRC/EDO/DEDR |
| References | |
| OIG-22-A-06 | |
| Download: ML23163A237 (1) | |
Text
MEMORANDUM DATE: June 8, 2023 TO: Daniel H. Dorman Executive Director for Operations Scott A. Morris Deputy Executive Director for Reactor and Preparedness Programs Office of the Executive Director for Operations FROM: Hruta Virkar /RA/
Assistant Inspector General for Audits
SUBJECT:
STATUS OF RECOMMENDATIONS: AUDIT OF THE U.S.
NUCLEAR REGULATORY COMMISSIONS OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
REFERENCE:
DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION, MEMORANDUM DATED MAY 26, 2023 Attached is the Office of the Inspector Generals (OIG) analysis and status of recommendations as discussed in the agencys response dated May 26, 2023. Based on this response, recommendations 2 and 8 are now closed. Recommendations 1, 3, and 5 were previously closed. Recommendations 4, 6, and 7 remain open and resolved.
Please provide an updated status of the open, resolved recommendations by December 31, 2023.
If you have any questions or concerns, please call me at 301.415.1982 or Avinash Jaigobind, Team Leader, at 301. 415.5402.
Attachment:
As stated cc: M. Bailey, OEDO J. Jolicoeur, OEDO RidsEdoMailCenter Resource OIG Liaison Resource EDO_ACS Distribution NRC Headquarters l 11555 Rockville Pike l Rockville, Maryland 20852 l 301.415.5930 www.nrcoig.oversight.gov
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS Status of Recommendations (OIG-22-A-06)
Recommendation 2: Communicate those processes across the agency, or at least to the divisions affected by CFSI.
Agency Response Dated May 26, 2023: The NRC developed an outreach and communication plan 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 communication plan.
Target Complete Date: Completed. The NRC staff issued the outreach and communications plan in November 2022.
Point of
Contact:
OIG Analysis: The OIG reviewed the NRCs outreach and communications plan to enhance communication about CFSI. Additionally, the OIG read the January 2023 inspector newsletter article and determined that it raises awareness of CFSI and describes the process of collecting, evaluating, and disseminating CFSI information. The recommendation is now closed.
Status: Closed.
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Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS Status of Recommendations (OIG-22-A-06)
Recommendation 4: Clearly define CFSI.
Agency Response Dated May 26, 2023: 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 office to update these documents.
Target Complete Date: October 2023.
Point of
Contact:
OIG Analysis: The proposed actions meet the intent of this recommendation. The OIG will close this recommendation when the CFSI definition is incorporated into other guidance documents (e.g., inspection procedures, regulatory guides, etc.), as identified in the agencys response to recommendation 6. This recommendation remains open and resolved.
Status: Open: Resolved.
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Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS Status of Recommendations (OIG-22-A-06)
Recommendation 6: Develop inspection guidance with examples pertaining to identifying CFSI in inspection procedures.
Agency Response Dated May 26, 2023: 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
- IP 43002, Routine Inspections of Nuclear Vendors
- IP 43004, Inspection of Commercial-Grade Dedication Programs
- IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance
- IP 36100.01, Inspection of 10 CFR 50.55(e) Programs for Reporting Defects and Noncompliance During Construction The NRC will update the following IPs by September 2023:
- IP 60852, ISFI 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 4
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS Status of Recommendations (OIG-22-A-06)
Recommendation 6 (continued):
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:
OIG Analysis: The OIG reviewed and verified the incorporation of CFSI inspection guidance in the following IMC and IPs: IMC 2507; IP 43002; IP 43004; IP 36100; and, IP 36100.001. The other proposed actions meet the intent of this recommendation. The OIG will close this recommendation upon reviewing CFSI inspection guidance and regulatory guides identified in the staffs status update. This recommendation remains open and resolved.
Status: Open: Resolved.
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Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS Status of Recommendations (OIG-22-A-06)
Recommendation 7: Develop CFSI training for inspectors.
Agency Response Dated May 26, 2023: 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, 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:
OIG Analysis: The proposed actions meet the intent of this recommendation. The OIG will close this recommendation upon reviewing the revisions to IMC 1245 Appendix B, IMC 1246 Appendix B2, and IMC 1246 Appendix B3 to include an individual study activity on the topic of CFSI, as well as EPRIs CFSI training made available to NRC staff. This recommendation remains open and resolved.
Status: Open: Resolved.
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Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS Status of Recommendations (OIG-22-A-06)
Recommendation 8: Develop a knowledge management and succession plan for CFSI.
Agency Response Dated May 26, 2023: The office of Nuclear Reactor Regulation, Division of Reactor Oversight, Generic Communications and Operating Experience Branch, has assigned new members to the CFSI Technical Review Group. These members will receive training on CFSI awareness and the CFSI Technical Review Group processes. The NRC staff has updated the Nuclepedia page on CFSI 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:
OIG Analysis: The OIG reviewed the updates to the NRCs Nuclepedia page on CFSI. Additionally, the OIG verified new members were added to the CFSI Technical Review Group, to ensure relevant critical knowledge associated with CFSI is captured.
This recommendation is now closed.
Status: Closed.
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