OIG-22-A-06, Status of Recommendations: Audit of the U.S. Nuclear Regulatory Commissions Oversight of Counterfeit, Fraudulent, and Suspect Items at Nuclear Power Reactors Dated October 6, 2022
| ML22280A058 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/2022 |
| From: | Virkar H NRC/OIG/AIGA |
| To: | Dan Dorman NRC/EDO |
| Cianci S | |
| References | |
| OIG-22-A-06 | |
| Download: ML22280A058 (10) | |
Text
NRC Headquarters l 11555 Rockville Pike l Rockville, Maryland 20852 l 301.415.5930 www.nrcoig.oversight.gov MEMORANDUM DATE:
October 6, 2022 TO:
Daniel H. Dorman Executive Director for Operations FROM:
Hruta Virkar, CPA /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 SEPTEMBER 20, 2022 Attached is the Office of the Inspector Generals (OIG) analysis and status of recommendations as discussed in the agencys response dated September 20, 2022.
Based on this response, recommendations 1, 3, and 5 are now closed.
Recommendations 2, 4, 6, 7, and 8 remain open and resolved. Please provide an updated status of the open, resolved recommendations by May 31, 2023.
If you have any questions or concerns, please call me at (301) 415-1982 or Paul Rades, Team Leader, at (301) 415-6228.
Attachment:
As stated cc:
M. Bailey, OEDO E. Stahl, OEDO J. Jolicoeur, OEDO RidsEdoMailCenter Resource OIG Liaison Resource EDO_ACS Distribution
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 2
Recommendation 1:
Develop processes and guidance to collect, process, and disseminate Counterfeit, Fraudulent, and Suspect Items (CFSI) information.
Agency Response Dated September 20, 2022:
The U.S. Nuclear Regulatory Commission (NRC) staff revised the Counterfeit, Fraudulent, and Suspect Items (CFSI) Technical Review Group (TRG) Desktop Guide (Agencywide Documents Access and Management System Accession No. ML22257A124) to include a more detailed and systematic process for collecting and disseminating CFSI information. This desktop guide has been reviewed by the CFSI Steering Committee and has been shared with NRC program and regional offices affected by CFSI.
Target Completion Date: Completed. The NRC staff issued the TRG Desktop Guide in September 2022.
Point of
Contact:
Deanna Zhang, NRR/DRO.
OIG Analysis:
The OIG reviewed the revised CFSI TRG Desktop Guide for collecting, processing, and disseminating CFSI information, and verified that it meets the intent of this recommendation.
This recommendation is now closed.
Status:
Closed.
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 3
Recommendation 2:
Communicate those processes across the agency, or at least to the divisions affected by CFSI.
Agency Response Dated September 20, 2022:
The NRC revised 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. This desktop guide has been reviewed by the CFSI Steering Committee and has been shared with NRC program and regional offices affected by CFSI. 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 Complete Date: November 2022.
Point of
Contact:
Deanna Zhang, NRR/DRO.
OIG Analysis:
The proposed actions meet the intent of this recommendation. The OIG reviewed the communication process in the revised CFSI TRG Desktop Guide. The OIG will close this recommendation upon reviewing the agency outreach and communications plan. Therefore, this recommendation remains open and resolved.
Status:
Open: Resolved.
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 4
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.
Agency Response Dated September 20, 2022:
The NRC staff developed, and the NRC CFSI Steering Committee has approved, an agencywide CFSI oversight charter (ML22235A791) detailing objectives, overall approach, and strategy in order to enhance the agencys ability to mitigate the risk associated with CFSI. The charter includes the roles and responsibilities necessary to accomplish NRC activities associated with CFSI at an agencywide level. The charter incorporates a definition of CFSI to ensure consistency when addressing related agency oversight activities and is consistent with the long-term actions planned in response to Recommendation 4. This definition has been reviewed for alignment with the definitions for CFSI contained in industry guidance and international standards. The charter has been shared with NRC program and regional office affected by CFSI.
Target Completion Date: Completed. The CFSI Steering Committee approved the agencywide CFSI charter in September 2022.
Point of
Contact:
Deanna Zhang, NRR/DRO OIG Analysis:
The OIG reviewed the agencywide CFSI oversight charter, which includes a definition of CFSI; objective; roles and responsibilities associated with CFSI at an agencywide level; and overall approach and strategies to mitigate risk. Based on this review, the OIG determined that the agencywide CFSI oversight charter meets the intent of this recommendation. This recommendation is now closed.
Status:
Closed.
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 5
Recommendation 4:
Clearly define CFSI.
Agency Response Dated September 20, 2022:
The NRC staff has incorporated the definition for CFSI into the agencywide CFSI charter, referenced in response to Recommendation 3. Also, this CFSI definition has been incorporated into the CFSI TRG Desktop Guide referenced in response to Recommendation 1. The NRC staff has reviewed guidance documents, inspection guidance (e.g., inspection procedures for commercial-grade dedication for vendors and reactor facilities), and other relevant documents to determine whether the updated CFSI definition must be incorporated into such documents. Inspection procedures that will be updated are referenced as part of the response to Recommendation 6. Based on the administrative processes to revise certain guidance documents (e.g., regulatory guides) to include the CFSI definition, the NRC staff determined that the target completion date needs to be extended. The NRC staff will continue working with the NRC program offices to have these documents updated.
Target Complete Date: October 2023.
Point of
Contact:
Deanna Zhang, NRR/DRO.
OIG Analysis:
The OIG reviewed the CFSI definition in the CFSI charter and CFSI TRG Desktop Guide. The OIG will close this recommendation when the CFSI definition is incorporated into other guidance documents (e.g., inspection procedures, regulatory guides, etc.). This recommendation remains open and resolved.
Status:
Open: Resolved.
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 6
Recommendation 5:
Include a CFSI category in the Allegations Management System (AMS).
Agency Response Dated September 20, 2022:
The staff added a new CFSI category to the Discipline field in the AMS and instructed allegations staff of its use. The staff also added a link on the NRC Allegation Program SharePoint site to the CFSI Investigations Nuclepedia page.
Target Completion Date: Completed. A CFSI category was added in AMS on July 1, 2022.
Point of
Contact:
Lisamarie Jarriel, AAA.
OIG Analysis:
The OIG verified the addition of a new CFSI category to the Discipline field in the AMS, as well as a link from the NRC Allegation Program SharePoint site to the CFSI Investigations Nuclepedia page. This recommendation is now closed.
Status:
Closed.
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 7
Recommendation 6:
Develop inspection guidance with examples pertaining to identifying CFSI in inspection procedures.
Agency Response Dated September 20, 2022:
The NRC staff has completed its evaluation of inspection guidance across business lines (e.g., operating reactor baseline inspections, spent fuel storage and transportation, vendor inspections, new reactor construction inspections) to identify the inspection procedures that need modification to include appropriate CFSI guidance, including the agencys formal definition of CFSI. Through this evaluation, the NRC staff identified the following inspection procedures (IPs) and an inspection manual chapter (IMC) for revision:
- 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 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 staff incorporated CFSI guidance in the new Reactor Oversight Process baseline inspection procedure IP 71111.21N.03, Commercial Grade Dedication, dated June 28, 2022.
The NRC staff is currently engaging external stakeholders (e.g., Electric Power Research Institute (EPRI), International Atomic Energy Agency) to seek insights to inform any updates to the NRCs guidance on CFSI, as needed.
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 8
Target Completion Date: April 2023.
Point of
Contact:
Deanna Zhang, NRR/DRO.
OIG Analysis:
The OIG reviewed and verified the incorporation of CFSI inspection guidance in IP 71111.21N.3. The other proposed actions meet the intent of this recommendation. The OIG will close this recommendation upon reviewing CFSI inspection guidance in the revisions to IMC 2507 and inspection procedures identified in the staffs status update.
This recommendation remains open and resolved.
Status:
Open: Resolved.
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 9
Recommendation 7:
Develop CFSI training for inspectors.
Agency Response Dated September 20, 2022:
The NRC staff has identified the relevant inspection manual chapters for the inspector qualification activities of different inspection programs that need to be revised to include an individual study activity on the topic of CFSI. Specifically, the staff identified IMC 1245, Appendix A, Basic-Level Training and Qualification Journal; 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. The NRC staff provided CFSI awareness training to disseminate CFSI-related information to regional and resident inspection staff in March 2022.
Future awareness training will be offered as needed. 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: March 2023.
Point of
Contact:
Deanna Zhang, NRR/DRO.
OIG Analysis:
On October 5, 2022, the OIG received and reviewed a copy of the CFSI awareness training presented to regional and resident inspection staff on March 30, 2022. The other proposed actions meet the intent of this recommendation.
The OIG will close this recommendation upon reviewing the revisions to IMC 1245 Appendix A, IMC 1246 Appendix B2, and IMC 1246 Appendix B3 to include an individual study activity on the topic of CFSI. This recommendation remains open and resolved.
Status:
Open: Resolved.
Audit Report AUDIT OF THE NRCs OVERSIGHT OF COUNTERFEIT, FRAUDULENT, AND SUSPECT ITEMS AT NUCLEAR POWER REACTORS (OIG-22-A-06)
Status of Recommendations 10 Recommendation 8:
Develop a knowledge management and succession plan for CFSI.
Agency Response Dated September 20, 2022:
The Office of Nuclear Reactor Regulation, Division of Reactor Oversight, Operational Experiences Branch, will assign new members to the CFSI TRG. These new members will receive training on CFSI awareness and the CFSI TRG processes. The NRC staff is also updating the NRCs Nuclepedia page on CFSI to incorporate additional information related to CFSI. The NRC staff will continue to ensure the identification, capture, retention, transfer, use, and reuse of relevant critical knowledge associated with CFSI.
The staff will complete this action by November 2022.
Point of
Contact:
Deanna Zhang, NRR/DRO.
OIG Analysis:
The proposed actions meet the intent of this recommendation. The OIG will close this recommendation up reviewing the updates to the NRCs Nuclepedia page on CFSI, ensuring relevant critical knowledge associated with CFSI is captured.
Status:
Open: Resolved.