ML23313A144

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Status of Recommendations- Office of the Inspector General'S Audit of the U.S. Nuclear Regulatory Commission'S Oversight of Counterfeit, Fraudulent, and Suspect Items at Nuclear Power Reactors (OIG 22-A-06)
ML23313A144
Person / Time
Issue date: 12/15/2023
From: Andrea Veil
Office of Nuclear Reactor Regulation
To: Virkar H
NRC/OIG/AIGA
References
Download: ML23313A144 (5)


Text

December 15, 2023 MEMORANDUM TO: Hruta Virkar Assistant Inspector General for Audits Office of the Inspector General King, Michael signing on behalf FROM: Andrea D. Veil, Director of Veil, Andrea on 12/15/23 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 gives the U.S. Nuclear Regulatory Commission (NRC) staffs updates on progress on 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 the recommendations on April 26, 2022. The staff updated the status for each recommendation in letters dated September 20, 2022, and May 26, 2023. OIG again provided its analysis and status of recommendations on October 26, 2022, and June 8, 2023. OIG considers recommendations 1, 2, 3, 5, and 8 as closed. Recommendations 4, 6, and 7 remain open and resolved. In this update, the staff provides an update to the remaining actions yet to be completed for recommendations 4 and 6, and the completion of the actions associated with recommendation 7.

CONTACT: Frankie Vega, NRR/DRO (301) 415-1617

H. Virkar 2 Recommendation 4:

Clearly define CFSI.

NRC Staff Update:

The NRC will include the definition of CFSI in its updated inspection procedures and guidance, as identified in the response to recommendation 6, which 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 the remaining documents.

Target Completion Date: April 2024 Point of

Contact:

Deanna Zhang, NRR/DRO Recommendation 6:

Develop inspection guidance with examples pertaining to identifying CFSI in inspection procedures.

NRC Staff Update:

The NRC staff has updated the following inspection procedures to incorporate appropriate CFSI guidance, including the agencys formal definition of CFSI:

  • IP 60852, ISFSI Component Fabrication by Outside Fabricators, dated August 17, 2023 (Agencywide Documents Access and Management System Accession No. ML23216A051)
  • IP 60853, Onsite Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation, dated August 17, 2023 (ML23216A052)
  • IP 86001, Design, Fabrication, Testing, and Maintenance of Transportation Packagings, dated August 17, 2023 (ML23216A053)

The staff continues working with other program offices to update the following regulatory guides (RGs):

  • RG 1.164, Revision 0, Dedication of Commercial-Grade Items for Use in Nuclear Power Plants, issued June 2017 (ML17041A206)
  • RG 1.234, Revision 0, Evaluating Deviations and Reporting Defects and Noncompliance Under 10 CFR Part 21, issued April 2018 (Ml17338A072)

The NRC has issued updates to these two RGs for public comment, and the agency anticipates resolving any comments received by the end of December 2023. Accounting for the Office of Management and Budgets review of the two RGs, the staff plans to issue these RGs by March 2024.

H. Virkar 3 Following the update of these two RGs, the NRC will issue an administrative change to Regulatory Issue Summary (RIS) 2015-08, Oversight of Counterfeit, Fraudulent, and Suspect Items in the Nuclear Industry, dated June 24, 2015 (ML15008A191), to reference the definition of CFSI in these two RGs. The staff anticipates completing this administrative change to RIS 2015-08 by April 2024.

Target Completion Date: April 2024 Point of

Contact:

Deanna Zhang, NRR/DRO Recommendation 7:

Develop CFSI training for inspectors.

NRC Staff Update:

The staff has updated Inspection Manual Chapter (IMC) 1246, Appendix B2, Training Requirements and Qualification Journal for Storage and Transportation Inspector, dated October 2, 2023 (ML23249A185), and IMC 1246, Appendix B3, Training Requirements and Qualification Journal for Independent Spent Fuel Storage Installation Inspector (ML23326A085), to include an individual study activity on the topic of CFSI.

The Electric Power Research Institute (EPRI) CFSI training is readily available to NRC inspectors with EPRIs online course, Counterfeit, Fraudulent, and Suspect Items, Version 2.0.

Target Completion Date: Completed. The NRC staff has issued the remaining IMCs to include an individual study activity on the topic of CFSI and has made EPRIs CFSI training more accessible to inspectors.

Point of

Contact:

Deanna Zhang, NRR/DRO

Enclosure:

Correspondence Reference for OIG 22 A 06

H. Virkar 4

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: December 15, 2023 DISTRIBUTION: OEDO-23-00213 Non Public DZhang, NRR KKavanagh, NRR RFelts, NRR PMcKenna, NRR RLagios, NSIR LHowell, NMSS OLopez-Santiago CRios-Collazo, OI DPelton, OE PHabighorst, OIP RidsNrrOd Resource RidsNrrMailCenter Resource RidsOedoMailCenter Resource ADAMS ACCESSION NO.: ML23313A144 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB QTE*

NAME FVega DZhang KKavanagh JDougherty DATE 11/15/2023 11/16/2023 11/16/2023 11/21/2023 OFFICE NRR/DRO NMSS/DFM NSIR OI NAME RFelts LHowell RLagios CRios-Collazo DATE 12/4/2023 12/8/2023 12/6/2023 12/7/2023 OFFICE OGC/LHE/SE OE NRR NAME PMoulding DPelton AVeil (MKing for)

DATE 12/1/2023 12/4/2023 12/15/2023 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).

Memorandum from Andrea D. Veil to Hruta Virkar, 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), May 26, 2023 (ML23122A164).

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), June 8, 2023 (ML23163A237).

Enclosure