OIG-24-A-07, Status of Recommendations: Audit of the U.S. Nuclear Regulatory Commissions Safety Inspections of Class II Research and Test Reactors, Dated, February 28, 2025
| ML25059A133 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/2025 |
| From: | Virkar H NRC/OIG/AIGA |
| To: | Mirela Gavrilas NRC/EDO |
| References | |
| OIG-24-A-07 | |
| Download: ML25059A133 (1) | |
Text
NRC Headquarters l 11555 Rockville Pike l Rockville, Maryland 20852 l 301.415.5930 nrcoig.oversight.gov MEMORANDUM DATE:
February 28, 2025 TO:
Mirela Gavrilas Executive Director for Operations FROM:
Hruta Virkar, CPA /RA/
Assistant Inspector General for Audits & Evaluations
SUBJECT:
STATUS OF RECOMMENDATIONS: AUDIT OF THE U.S.
NUCLEAR REGULATORY COMMISSIONS SAFETY INSPECTIONS OF CLASS II RESEARCH AND TEST REACTORS (OIG-24-A-07)
REFERENCE:
DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION, MEMORANDUM DATED JANUARY 30, 2025 Attached is the Office of the Inspector Generals (OIG) analysis and status of recommendations as discussed in the agencys response dated January 30, 2025. Based on this response, recommendations 1.2 and 3.1 are closed. Recommendations 1.1, 2.1 through 2.3 and 4.1 remain open and resolved. Please provide an updated status of the open, resolved recommendations by October 31, 2025.
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: J. Martin, ADO D. Lewis, DADO J. Jolicoeur, OEDO OIG Liaison Resource EDO ACS Distribution
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS SAFETY INSPECTIONS OF CLASS II RESEARCH AND TEST REACTORS Status of Recommendations (OIG-24-A-07) 2 Recommendation 1.1:
Update and implement guidance applicable to the U.S.
Nuclear Regulatory Commissions (NRCs) current timekeeping system.
Agency Response NRC Staff Action: Update Management Directive (MD)
Dated January 30, 2025: 10.43, Time and Labor Reporting, to reflect the changes to the new Human Capital Management Cloud System.
Target: 6/30/2025.
Status: The staff has revised the schedule for completing the updated MD 10.43 from June 30, 2025, to September 30, 2025. The update of MD 10.43 is on track for completion by the revised date.
OIG Analysis:
The proposed actions meet the intent of this recommendation. The OIG will close this recommendation upon reviewing the updated Management Directive 10.43, Time and Labor Reporting to ensure that it reflects the new changes to the Human Capital Management Cloud System.
This recommendation remains open and resolved.
Status:
Open: Resolved
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS SAFETY INSPECTIONS OF CLASS II RESEARCH AND TEST REACTORS Status of Recommendations (OIG-24-A-07) 3 Recommendation 1.2: Establish guidance and training for recording and approving the Research and Test Reactors (RTR) inspection hours to specific Cost Activity Codes.
Agency Response NRC Staff Action: Enhance relevant guidance to further Dated January 30, 2025: clarify the process for creating, recording, and approving inspection hours in the Reactor Program System (RPS).
Target: 12/31/2024.
Status: Complete. The RPS training videos and a desktop user guide is available in the RPS system under the How Do I? tab. Additionally, the Non-power Production and Utilization Facility (NPUF) Oversight Branchs RPS Training Material - How to Guide? provides supplemental instruction to the NPUF inspectors and is maintained in the NPUF Licensing and Oversight SharePoint site. The staff enhanced the instructions for creating, recording, and approving inspection hours and completed the revisions to the guide on July 2, 2024.
OIG Analysis:
The OIG verified the supplemental instruction provided on the NPUF Licensing and Oversight SharePoint site.
Additionally, the OIG verified RPS training videos and the RPS-Inspection desktop guide to aide staff in recording and approving RTR inspection hours to specific Cost Activity Codes. This recommendation is closed.
Status: Closed
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS SAFETY INSPECTIONS OF CLASS II RESEARCH AND TEST REACTORS Status of Recommendations (OIG-24-A-07) 4 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.
Agency Response NRC Staff Action: Enhance the RTR inspector training Dated January 30, 2025: program to ensure the recording and tracking of required training, including the track of post-qualification and refresher training. Target: 12/31/2024.
Status: Partially complete. The staff completed a review of the training program and identified post-qualification and refresher training enhancements for implementation. The staff is coordinating these training enhancements along with the improvements to inspector training and inspection procedures identified in a separate NRC response related to the OIGs special inquiry into the NRCs oversight of RTRs (OIG Case No.12100162). The enhancements being made to the RTR inspector training include revising Inspection Manual Chapter (IMC) 1245 Appendix C5 Research and Test Reactor Technical Proficiency Training and Qualification Journal, to include computer-based training from the basic class for safety culture assessors as required post-qualification and refresher training. Additionally, the RTR inspectors are being included in site access refresher training in the NRCs Talent Management System (TMS).
Finally, relevant topic-specific training is conducted annually during a joint meeting between the NPUF Licensing and Oversight Branches. That training is documented, and attendance is tracked. RTR inspectors completed annual event response training and training on the NPUF rule during December 10-11, 2024. Revisions to IMC 1245 Appendix C5 to reflect the enhancements and the tracking within TMS efforts are in progress. The staff has revised the schedule to complete implementation of these enhancements, including the tracking of post-qualification and refresher training from December 31, 2024, to September 30, 2025.
OIG Analysis:
The proposed actions meet the intent of these recommendations. The OIG will close these recommendations upon reviewing supported evidence pertaining to RTR training guidance for specific
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS SAFETY INSPECTIONS OF CLASS II RESEARCH AND TEST REACTORS Status of Recommendations (OIG-24-A-07) 5 Recommendations 2.1 and 2.2 (continued):
courses and hours for refresher training, and tracking post-qualification and refresher training. These recommendations remain open and resolved.
Status:
Open: Resolved
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS SAFETY INSPECTIONS OF CLASS II RESEARCH AND TEST REACTORS Status of Recommendations (OIG-24-A-07) 6 Recommendation 2.3: Periodically review the RTR training program to ensure consistency, effectiveness, and relevance.
Agency Response NRC Staff Action: Periodically revise the RTR training Dated January 30, 2025: program to reflect new training needs of the RTR staff.
Target: 12/31/2024.
Status: Complete. The NRC staff is identifying training needs and documenting the review of the RTR training program as part of the annual joint branch meeting.
OIG Analysis:
The proposed actions meet the intent of the recommendation. The OIG will close this recommendation upon reviewing and verifying supported evidence that the staff discussed the RTR training program and training needs at the annual joint branch meeting. This recommendation remains open and resolved.
Status:
Open: Resolved
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS SAFETY INSPECTIONS OF CLASS II RESEARCH AND TEST REACTORS Status of Recommendations (OIG-24-A-07) 7 Recommendation 3.1:
Establish a plan and milestones to fully implement the use of the RPS to support oversight of the RTR inspection program.
Agency Response NRC Staff Action: Update the plans and schedule to Dated January 30, 2025: complete the transition of the RTR inspection program in the RPS. Target. 12/31/2024.
Status: Complete. The staff updated the project plan with updated milestones for the RPS Utilization Initiative to reflect the latest status of completed items as of October 1, 2024. The project plan indicates the remaining actions to fully implement use of RPS will be completed by September 30, 2025. The project plan is maintained in the NPUF Licensing and Oversight SharePoint Site.
OIG Analysis:
The OIG reviewed the RPS project plan, which lists the completed items and remaining actions needed to fully implement the use of the RPS program to support oversight of the RTR inspection program. This recommendation is closed.
Status:
Closed
Audit Report AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS SAFETY INSPECTIONS OF CLASS II RESEARCH AND TEST REACTORS Status of Recommendations (OIG-24-A-07) 8 Recommendation 4.1:
Periodically review and update the RTR inspection guidance in accordance with IMC 0040.
Agency Response NRC Staff Action: Enhance guidance for performing a Dated January 30, 2025: periodic review of inspection guidance of RTRs.
Target: 12/31/2024.
Status: Partially Complete. The RTR inspection program will follow the guidance in IMC 0040, Preparation, Revision, Issuance, and Ongoing Oversight of NRC Inspection Manual Documents, for the periodic review and update of RTR inspection guidance. In the NRCs response to OIGs special inquiry into the NRCs oversight of RTRs (OIG Case No. I2100162), the agency stated that it would enhance RTR inspection guidance. The staff completed a review of inspection guidance and identified the following guidance and procedures for revision:
- IMC 2545, Research and Test Reactor Inspection Program
- Inspection Procedure (IP) 69007, Class I Research and Test Reactor Review and Audit and Design Change Functions
- IP 69001, Class II Research and Test Reactors, with regard to committees, audits, and reviews; procedures; and fuel handling
- IP 69002, Class III Research and Test Reactors, with regard to staffing and audits
- IP 69008, Class I Research and Test Reactor Procedures
- IP 69009, Class I Research and Test Reactor Fuel Movement The staff expects to complete the revisions by September 30, 2025.
OIG Analysis:
The proposed action meets the intent of this recommendation. The OIG will close the recommendation upon reviewing the inspection guidance enhancements related to the Research and Test Reactor inspection program This recommendation remains open and resolved.
Status:
Open: Resolved