ML24128A122
| ML24128A122 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/2024 |
| From: | Scott(Ois) Morris NRC/EDO |
| To: | Virkar H NRC/OIG |
| References | |
| OEDO-24-00124 | |
| Download: ML24128A122 (4) | |
Text
Response to the Office of the Inspector Generals Audit of the U.S. Nuclear Regulatory Commissions Safety Inspections of Class II Research and Test Reactors
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the Office of the Inspector Generals (OIGs) recommendations to improv e the NRCs policies, procedures, and program controls for managing safety inspections of Clas s II research and test reactors (RTRs). The staff acknowledges and appreciates OIGs important role and its objectives to enhance agency operations and promote greater economy and efficiency. The staff believes that external and internal assessments offer valuable opportunities to gain insights and enhance the effectiveness and efficiency of the RTR inspection program.
The staff agrees with the OIGs finding that t he NRC performs safety inspections at Class II RTRs in accordance with agency guidance. The OIG determined the NRC could improve by:
- ensuring RTR inspection hours are charged accurately
- ensuring RTR inspectors meet training and qualification requirements
- retaining RTR inspection information centrally
- reviewing and updating RTR inspection guidance periodically
While enhancements to the program will provide va luable improvements, the staff notes that the inspection program is designed with sufficient flexibility to optimize the use of inspection resources and implement inspection commensurate with the safety significance of the RTR. The staff recently assessed the RTR oversight program and independently identified and implemented enhancements following the February 3, 2021, event at the National Institute of Standards and Technology test reactor and following OIGs special inquiry into the NRC oversight of RTRs. The NRC is already addressing many OIG findings from the Class II RTR audit. Additionally, since 2020, the staff has implemented other improvements to the RTR inspection program. These include updating guidance and transitioning the RTR inspection program into the Reactor Program System (RPS). These improvements are designed to address effectiveness and efficiency and to support program performance management.
The NRC staff remains committed to providing effective oversight of the Nations RTRs and to protecting the safety of the public and the env ironment. The NRC staffs review of the OIG audit report highlighted opportunities to further enhance and improve policies, procedures, and program controls for managing the RTR inspection program. The conclusion section of this response lists the NRC staffs planned actions, and the agency intends to implement all actions by June 30, 2025.
Finding: The NRC should ensure RTR inspection hours are charged accurately.
Recommendation 1.1: Update and implement guidance applicable to the NRCs current timekeeping system.
Recommendation 1.2: Establish guidance and training for recording and approving the RTR inspection hours to specific CACs [cost activity codes].
Staff Response:
Enclosure The Office of the Chief Financial Officer (O CFO) will begin updating Management Directive 10.43, Time and Labor Reporting, dated January 23, 2020, to reflect the changes to the new Human Capital Management Cloud System, with an expected completion date of June 30, 2025.
The anomalies associated with inspection hours data that were noted in the OIG report are issues that have occurred during the transition of the inspection program to RPS and have been experienced in similar information technology sy stem transitions. Because the issues were anticipated and accounted for, they did not result in incorrect billing of any RTR licensees and did not impact the tracking of inspection data for future planning and budgeting. The staff has internal controls for fee-billable RTR inspection hours, which are in place to validate and certify billable staff hours and contractor charges. The va lidation process helps the NRC ensure timely and accurate billing for fee-paying licensees and assists with meeting the target error rate of less than 1 percent.
The staff conducted inspector training for labor cost string (i.e., CAC/EPID/Docket) creation within RPS and developed a desk guide to support the transition to RPS. The issues experienced during the transition and observed by OIG have largely been resolved. The staff plans to enhance relevant guidance to further clarify the process for creating, recording, and approving inspection hours where appropriate.
Point of Contact for Recommendation 1.1: Erikka LeGrand, OCFO/DOC/FSOB 301-415-7748
Point of Contact for Recommendation 1.2: Travis Tate, NRR/DANU/UNPO 301-415-3901
Finding: The NRC should ensure RTR inspectors meet training and qualification requirements.
Recommendation 2.1: Update the RTR training guidance to include specific courses and hours for refresher training.
Recommendation 2.2: Track post-qualification and refresher training.
Recommendation 2.3: Periodically review the RTR training program to ensure consistency, effectiveness, and relevance.
Staff Response
All staff members who perform RTR inspections are qualified and have completed post-qualification and refresher training. The staff agrees with OIGs observations for improving qualification tracking and clarifying training requirements. The staff plans to enhance RTR inspector training by including instructions on recording and tracking required training, in accordance with Office of Nuclear Reactor Regulation Office Instruction ADM-504, Revision 4, Qualification Program, dated April 10, 2023, and Inspection Manual Chapter (IMC) 1245, Qualification Program for Reactor Inspecto rs, effective May 15, 2023. The enhancements will include the tracking of post-qualification and refresher training requirements as specified in IMC 1245, Appendix D1, Maintaining Qualifications , effective November 6, 2023. Additionally,
as a result of the NRCs response to the recent OIG special inquiry on RTR oversight (Agencywide Documents Access and Managem ent Systems (ADAMS) Accession No. ML23272A039), many enhancements to the trai ning program are underway. The staff will periodically revise the RTR training program to reflect new training needs of the RTR staff as determined by changes to policy or procedures, or both. The NRC staff plans to update the RTR inspector training and implement the tracking of post-qualification and refresher training by December 31, 2024.
Point of Contact for Recommendations 2.1, 2.2, and 2.3: Travis Tate, NRR/DANU/UNPO 301-415-3901
Finding: The NRC should centrally retain RTR inspection program information.
Recommendation 3.1: Establish a plan and milestones to fully implement the use of the RPS to support oversight of the RTR inspection program.
Staff Response
RTR inspection data are documented and are available in ADAMS and other sources. To further improve inspection data management and retrieval, the NRC is already making efforts to ensure inspection information is centrally retained in RPS. Current improvements include creating a report template for the RPS report generator tool, expanding the use of RPS from scheduling inspections to inspection data management, tracking inspection findings and follow-up items, and creating program performance reports. The staff will update the plans and schedule to complete the transition of the RTR inspection program into RPS to improve the efficiency of program implementation and management of the program data in one central location by December 31, 2024.
Point of Contact for Recommendation 3.1: Travis Tate, NRR/DANU/UNPO 301-415-3901
Finding: The NRC should periodically review and update RTR inspection guidance
Recommendation 4.1: Periodically review and update the RTR inspection guidance in accordance with IMC 0040
Staff Response
The staffs actions to address this finding are reflected in its response to the OIG special inquiry into the NRC oversight of RTRs (ADAMS Accession No. ML24030A502). The staff will incorporate guidance enhancements in IMC 2545, Research and Test Reactor Inspection Program, effective June 1, 2020, for performing the periodic review of IMCs and inspection procedures for RTRs. The NRC staff plans to implement the above action by December 31, 2024.
Point of Contact for Recommendation 4.1: Travis Tate, NRR/DANU/UNPO 301-415-3901
Staff Conclusion
The NRC staff appreciates OIGs insights for improving the policies, procedures, and controls for managing safety inspections of Class II RTRs. The staff recently assessed the RTR oversight program and independently identified and implemented enhancements; it is already addressing many OIG findings from the Class II RTR audit. Additionally, since 2020, the staff has implemented other improvements to the RTR inspection program. The improvements include updating guidance and transitioning the RTR inspection program management into RPS. These improvements are designed to address effectiveness and efficiency and to support program performance management. The NRC staff is taking the following additional actions to enhance the RTR inspection program in response to the OIG audit report:
- by December 31, 2024:
Enhance relevant guidance to further clarify the process for creating, recording and approving inspection hours in RPS.
Enhance the RTR inspector training program to ensure the recording and tracking of required training, including the tracking of post-qualification and refresher training.
Periodically revise the RTR training program to reflect new training needs of the RTR staff.
Update the plans and schedule to complete the transition of the RTR inspection program into RPS.
Enhance guidance for performing a periodic review of inspection guidance for RTRs.
- by June 30, 2025:
Complete OCFO updates to Management Directive 10.43 to reflect the changes to the new Human Capital Management Cloud System.