OIG-24-A-06, Audit of the U.S. Nuclear Regulatory Commissions Security Oversight of Category 1 & Category 2 Quantities of Radioactive Material, Dated March 25, 2024: Difference between revisions

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#REDIRECT [[OIG-24-A-06, Status of Recommendations: Audit of the U.S. Nuclear Regulatory Commission’S Security Oversight of Category 1 and Category 2 Quantities of Radioactive Materials, Dated, November 13, 2024]]
| number = ML24085A694
| issue date = 03/25/2024
| title = OIG-24-A-06 Audit of the U.S. Nuclear Regulatory Commissions Security Oversight of Category 1 & Category 2 Quantities of Radioactive Material, Dated March 25, 2024
| author name = Virkar H
| author affiliation = NRC/OIG/AIGA
| addressee name = Furstenau R
| addressee affiliation = NRC/EDO
| docket =
| license number =
| contact person =
| document report number = OIG-24-A-06
| document type = Audit Report
| page count = 1
}}
 
=Text=
{{#Wiki_filter:Audit of the U.S. Nuclear Regulatory Commissions Security Oversight of Category 1 and Category 2 Quantities of Radioactive Material OIG-24-A-06 March 25, 2024 All publicly available OIG reports, including this report, are accessible through the OIGs website at:
nrcoig.oversight.gov
 
NRC Headquarters l 11555 Rockville Pike l Rockville, Maryland 20852 l 301.415.5930 nrcoig.oversight.gov MEMORANDUM DATE:
March 25, 2024 TO:
Raymond V. Furstenau Acting Executive Director for Operations FROM:
Hruta Virkar, CPA /RA/
Assistant Inspector General for Audits
 
==SUBJECT:==
AUDIT OF THE U.S. NUCLEAR REGULATORY COMMISSIONS SECURITY OVERSIGHT OF CATEGORY 1 AND CATEGORY 2 QUANTITIES OF RADIOACTIVE MATERIAL (OIG-24-A-06)
Attached is the Office of the Inspector Generals (OIG) audit report titled Audit of the U.S. Nuclear Regulatory Commissions Security Oversight of Category 1 and Category 2 Quantities of Radioactive Material.
The report presents the results of the subject audit. Following the February 15, 2024, exit conference, agency staff indicated that they had no formal comments for inclusion in this report.
Please provide information on actions taken or planned on the recommendations within 30 days of the date of this memorandum.
We appreciate the cooperation extended to us by members of your staff during the audit.
If you have any questions or comments about our report, please contact me at 301.415.1982 or Mike Blair, Team Leader, at 301.415.8399.
 
==Attachment:==
As stated cc: J. Martin, Acting ADO J. Jolicoeur, OEDO
 
i Results in Brief Audit of the U.S. Nuclear Regulatory Commissions Security Oversight of Category 1 and Category 2 Quantities of Radioactive Material OIG-24-A-06 March 25, 2024 The NRC provides adequate physical security oversight of category 1 and category 2 quantities of radioactive material; however, opportunities exist to strengthen enforcement activities related to Title 10 Code of Federal Regulations (C.F.R.) Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material (Part 37).
NRC management should implement control activities to ensure the agency uses quality information in regulatory decision-making. The Enforcement Policy and Enforcement Manual serve as the principal controls for the NRCs enforcement program; however, nearly 21 percent of staff use the informal Office of Nuclear Material Safety and Safeguards (NMSS) guidance to determine the severity level of Part 37 violations. This has occurred because the Enforcement Policy and Enforcement Manual do not comprehensively address Part 37.
Consequently, enforcement actions could be inconsistently determined across the NRC.
This report makes three recommendations to strengthen Part 37 enforcement guidance. These recommendations call for updating the NRCs Enforcement Policy and Enforcement Manual to address Part 37, and to revise and update supplemental guidance relating to Part 37.
What We Found What We Recommend Why We Did This Review The U. S. Nuclear Regulatory Commission (NRC) has established requirements for the physical protection program for any licensee that possesses an aggregated category 1 or category 2 quantity of radioactive material. These requirements provide reasonable assurance of the security of category 1 or category 2 quantities of radioactive material by protecting these materials from theft or diversion.
During inspections, NRC inspectors verify licensees effectiveness in implementing the requirements promulgated in NRC regulations.
Noncompliance with regulatory requirements is assessed according to the NRCs Enforcement Policy.
The consequences of a violation vary depending upon the severity level of the violation.
The audit objective was to determine whether the NRC provides adequate security oversight of category 1 and category 2 quantities of radioactive material.
 
ii ABBREVIATIONS AND ACRONYMS................................................................ iii I.
BACKGROUND............................................................................................ 1 II.
OBJECTIVE.................................................................................................. 7 III. FINDING..................................................................................................... 7 The Enforcement Policy and Enforcement Manual Do Not Comprehensively Address Part 37....................................................... 7 IV. NRC COMMENTS...................................................................................... 12 OBJECTIVE, SCOPE, AND METHODOLOGY.................................................. 13 TO REPORT FRAUD, WASTE, OR ABUSE....................................................... 16 COMMENTS AND SUGGESTIONS................................................................... 16 NOTICE TO NON-GOVERNMENTAL ORGANIZATIONS AND BUSINESS ENTITIES SPECIFICALLY MENTIONED IN THIS REPORT......................... 16 TABLE OF CONTENTS
 
iii ADAMS Agencywide Documents Access and Management System C.F.R.
Code of Federal Regulations IAEA International Atomic Energy Agency MSIF Materials Security Issues Forum NCV Non-cited Violation NMSS Office of Nuclear Material Safety and Safeguards NRC U.S. Nuclear Regulatory Commission OE Office of Enforcement OIG Office of the Inspector General Part 37 Title 10 of the Code of Federal Regulations Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material SL Severity Level ABBREVIATIONS AND ACRONYMS
 
1 A radiation source is a radioactive material or byproduct that is specifically manufactured or obtained to use in different applications, such as medicine, industry, agriculture, research and education, and some military applications.
Many are in the form of sealed sources with the radioactive materials firmly contained or bound within a suitable capsule or housing. The risks posed by these sources vary widely, depending on such factors as the radionuclides used, the physical and chemical form, and the activity.
As the regulator for the civilian use of radioactive materials, the U.S. Nuclear Regulatory Commission (NRC) has established the requirements for the physical protection program for any licensee that possesses an aggregated1 category 1 or category 2 quantity of radioactive material. Licensee adherence to these requirements provides reasonable assurance that category 1 or category 2 quantities of radioactive material will be protected from theft or diversion. The NRC considers category 1 and category 2 quantities of radioactive material to be risk significant. Along with its partners in the Agreement States,2 the NRC took steps to strengthen the security of these materials immediately after the terrorist attacks of September 11, 2001.
1 Under 10 C.F.R. section 37.5, Definitions, the term aggregated means accessible by the breach of a single physical barrier that would allow access to radioactive material in any form, including any devices that contain the radioactive material, when the total activity equals or exceeds a category 2 quantity of radioactive material.
2 Agreement States are states that have entered into agreements with the NRC under section 274 of the Atomic Energy Act. Under an agreement, the state has the authority to license and inspect specified categories of byproduct, source, or special nuclear materials used or possessed within their borders.
There are currently 39 Agreement States.
I. BACKGROUND
 
2 Figure 1: NRC and Agreement States Source: NRC Definitions Category 1 material The International Atomic Energy Agency (IAEA) defines category 1 as an amount of radioactive material which, if not safely managed or securely protected, would be likely to cause permanent injury to a person who handled or were otherwise in contact with it for more than a few minutes. It would probably be fatal to be close to this amount of unshielded material for a period of a few minutes to an hour. Sources containing category 1 quantities of radioactive material are typically used in radio-thermal generators, irradiators, and radiation teletherapy.
Category 2 material The IAEA defines category 2 as an amount of radioactive material which, if not safely managed or securely protected, could cause permanent injury to a person who handled it, or were otherwise in contact with it for a short time (minutes or hours). It could be fatal to be close to this amount of unshielded radioactive material for a period of hours to days. Sources containing category 2 quantities of radioactive material are typically used in industrial gamma radiography, high-and medium-dose rate brachytherapy,3 and radiography.
3 Brachytherapy is a radiation therapy procedure during which a sealed radioactive source is implanted directly into a patient being treated for cancer, either temporary or permanent, and the radiation attacks the tumor for as long as the device remains in place.
 
3 List of Category 1 and Category 2 Materials Part 37, Appendix A, identifies 16 category 1 and category 2 radioactive materials. The NRC has 133 category 1 and category 2 radioactive material licensees under its jurisdiction.
Figure 2: Title 10 C.F.R. Part 37, Appendix A Radioactive material Category 1 (TBq)
Category 1 (Ci)
Category 2 (TBq)
Category 2 (Ci)
Americium-241 60 1,620 0.6 16.2 Americium-241/Be 60 1,620 0.6 16.2 Californium-252 20 540 0.2 5.40 Cobalt-60 30 810 0.3 8.10 Curium-244 50 1,350 0.5 13.5 Cesium-137 100 2,700 1
27.0 Gadolinium-153 1,000 27,000 10 270 Iridium-192 80 2,160 0.8 21.6 Plutonium-238 60 1,620 0.6 16.2 Plutonium-239/Be 60 1,620 0.6 16.2 Promethium-147 40,000 1,080,000 400 10,800 Radium-226 40 1,080 0.4 10.8 Selenium-75 200 5,400 2
54.0 Strontium-90 1,000 27,000 10 270 Thulium-170 20,000 540,000 200 5,400 Ytterbium-169 300 8,100 3
81.0 Source: NRC Regulatory Requirements Title 10 C.F.R. Part 37 In 2013, the NRC published Part 37 to outline the specific requirements for access to material, use of material, transfer of material, and transport of radioactive material. Part 37 requirements focus on three different physical protection areas of category 1 and category 2 radioactive material:
* Background investigations and access authorization program;
* Physical protection requirements during use; and,
* Physical protection in transit.
 
4 Security Oversight During inspections, the NRC inspectors determine whether licensees effectively implement the requirements promulgated in Part 37 relative to the three focus areas listed above. Inspection Manual Chapter (IMC) 2800, Materials Inspection Program, and Inspection Procedure (IP) 87137, 10 C.F.R. Part 37 Materials Security Inspection Programs detail the security inspection guidance.
While IMC 2800 establishes the inspection program for Part 37 licensees, NRC inspectors follow IP 87137 guidance during inspections to determine licensees compliance with NRC requirements. This is done through direct observation of work activities; testing of communications, monitoring and detection systems; and, interviews with licensee workers.
Enforcement Program Two goals of the NRCs enforcement program are to emphasize the importance of compliance with regulatory requirements and to encourage prompt identification and comprehensive correction of violations. The enforcement program is also intended to meet the agencys performance goals. Violations are identified through inspections and investigations.4 Violations are subject to potential administrative or civil enforcement action and may also be subject to criminal prosecution.
In the NRCs traditional enforcement process, once a violation is identified, the NRC assesses its significance by considering the actual and potential consequences of the violation. Once the significance of the violation is determined and other relevant factors are considered, the violation is dispositioned.
4 The NRCs Office of Investigations develops policies, procedures, and quality control standards for the investigation of licensees, applicants, their contractors, or vendors. The Office of Investigations has field offices in each NRC Region that plan and conduct these investigations.
 
5 During calendar years 2021 and 2022, the NRC identified 77 security violations by its Part 37 licensees. See Figure 3 for a breakdown of Part 37 violations by region5 and severity level.6 Figure 3: NRC Issued Part 37 Violations in 2021 and 2022 Severity Level (SL)
Region Total by SL Escalated Enforcement Region I 7
Region III 9
Region IV 3
Total 19 SL-IV Region I 12 Region III 20 Region IV 22 Total 54 SL-IV NCV Region I 2
Region III 2
Region IV Total 4
Grand Total 77 Source: OIG Generated Responsible Offices Office of Nuclear Material Safety and Safeguards The Office of Nuclear Material Safety and Safeguards (NMSS) is responsible for the licensing and regulation of facilities and materials associated with the processing, transport, and handling of nuclear materials. The NMSS promotes safety and security by implementing regulatory programs for licensing, inspection and assessment of licensee performance, events analysis, enforcement, and identification and resolution of generic issues.
5 The NRCs four regional offices are located in King of Prussia, Pennsylvania; Atlanta, Georgia; Lisle, Illinois; and Arlington, Texas. Inspectors in Region I, III, and IV conduct Part 37 inspections. Region I also performs inspections in Region II, while Region II is responsible for fuel cycle facilities in all regions.
6 Violations are ranked via severity levels I through IV, with level I being the most significant and level IV being the least significant. Severity levels I through III are referred to as escalated enforcement. Non-cited violations (NCV) are those that are reported, but no citation is sent to the licensee.
 
6
* The Division of Materials Safety, Security, State, and Tribal Programs within the NMSS works to ensure the safe and secure use of radioactive materials in medical, industrial, and academic applications for beneficial civilian purposes. This division has the programmatic oversight of the regional materials licensing, inspection, and enforcement activities, including establishing policy and procedures, events assessment, and allegations management.
Office of Enforcement The Office of Enforcement (OE) promotes the NRCs mission by leading in the development and oversight of policies and programs for enforcement, allegations, and safety culture, and by supporting their implementation. The OE oversees, manages, and directs the development and implementation of policies and programs to enforce NRC requirements. For example, the OE is responsible for maintaining the Enforcement Policy and the Enforcement Manual. When a violation appears to be of a high severity level, the OE engages with the NMSS, regional staff, and staff from other relevant NRC offices, convening a panel to determine if escalated enforcement is warranted.
Regions I, III, and IV The regional offices conduct security oversight through licensing and inspection of material licensees. Each region has an enforcement team, which implements the NRC Enforcement Policy in the region and coordinates allegation and investigation activities. If regional inspectors identify instances of noncompliance with Part 37 requirements, they determine the severity level of the violation in coordination with management and the regional Allegation Coordination and Enforcement Office and issue the licensee a notice of violation.
 
7 The audit objective was to determine whether the NRC provides adequate security oversight of category 1 and category 2 quantities of radioactive material.
The NRC provides adequate physical security oversight of category 1 and 2 quantities of radioactive material; however, opportunities exist to strengthen the assessment of enforcement activities.
The Enforcement Policy and Enforcement Manual Do Not Comprehensively Address Part 37 NRC management should implement control activities to ensure the agency uses quality information in regulatory decision-making; the Enforcement Policy and Enforcement Manual serve as the principal controls for the NRCs enforcement program. However, nearly 21 percent of staff use the informal NMSS guidance to determine the severity level of Part 37 violations. This has occurred because the Enforcement Policy and Enforcement Manual do not comprehensively address Part 37. Consequently, enforcement actions could be inconsistently determined across the NRC.
The Enforcement Policy and Enforcement Manual Should Serve as Controls when NRC Staff Determine the Severity Level of Violations According to the U.S. Government Accountability Office Standards for Internal Control in the Federal Government, management should use quality information to achieve the entitys objectives. In addition, management should periodically review policies, procedures, and related control activities for continued relevance. If there is a significant change in the agencys process, management should review this process in a timely manner after the change to determine that the control activities are designed and implemented appropriately.
II. OBJECTIVE III. FINDING What Is Required
 
8 The NRCs enforcement program is the mechanism for ensuring accurate disposition of violations. The NRCs Enforcement Policy sets forth the general principles governing the NRCs enforcement program and the Commissions expectations regarding the process to be used by the NRC to assess and disposition violations of NRC requirements. The application of the NRCs Enforcement Policy helps ensure that associated enforcement actions properly reflect the safety or security significance of the underlying violations.
In addition, the Enforcement Manual is a tool to assist NRC staff in implementing the Commissions enforcement program consistent with the NRCs Enforcement Policy. Intended for internal use by the NRCs staff, the Enforcement Manual contains procedures, requirements, and background information used by the staff that develop or review enforcement actions.
Nearly 21 Percent of Staff Use Informal NMSS Guidance to Determine the Severity Level of Part 37 Violations All staff involved in Part 37 oversight use the enforcement process detailed in the Enforcement Policy and associated Enforcement Manual guidance to determine the severity level of violations. However, 21 percent of staff also use informal guidance to determine the severity level of Part 37 violations.
This informal guidance, in the form of a spreadsheet, provides examples of violations and their severity levels, with the direction that any SL-IV disposition not matching the examples on the spreadsheet would be brought to an enforcement panel with the OE and the NMSS to determine the severity level. (Note: All SL-III and higher dispositions are required to be brought to a headquarters enforcement panel.)
According to inspectors and enforcement specialists, before the NMSS issued the spreadsheet, it was difficult to consistently determine Part 37 violation severity levels. As one experienced inspector reported, if inspectors had a potential violation, they might be challenged in how to assess it, and they may spend a lot of time doing so. As a result, the NRC established a dedicated subgroup called the Materials Security Issues Forum (MSIF) in 2014.7 Forum members met weekly to evaluate violations in a manner designed to achieve 7 The MSIF members involved in developing the spreadsheet were from the NMSS, the OE, and the Office of Nuclear Security and Incident Response.
What We Found
 
9 consistency on the identification and citation of all apparent violations resulting from inspection findings associated with Part 37.
After gaining experience with Part 37-related enforcement, MSIF members developed a spreadsheet summarizing the precedents from cases identified in previous Part 37 MSIF and enforcement panel meetings. The spreadsheet was intended to be used as a guide for dispositioning violations in a consistent manner without the need for continued MSIF meetings. It was not intended to replace future updates to the Enforcement Policy and Enforcement Manual, which were expected to include Part 37 severity-level examples. The final version of the spreadsheet was made available in 2018 when the MSIF was retired.
The Enforcement Policy and Enforcement Manual Do Not Systematically Address Part 37 The Enforcement Policy and Enforcement Manual do not systematically address Part 37. The Enforcement Policy only mentions Part 37 at a very high level, while the Enforcement Manual does not mention Part 37 at all.
Additionally, though the policy was updated in March 2023 and the manual was updated in December 2022, neither contains any of the examples included in the NMSS spreadsheet. Of the 19 enforcement and inspection staff interviewed by the OIG, 42 percent stated the recent policy and manual revisions do not contain sufficient examples.
A senior enforcement specialist stated the NMSS spreadsheet was only supposed to be a temporary aid until the policy and manual were updated to include more detailed Part 37 language; however, this update has not been made. Additionally, another senior inspector commented that regulation by spreadsheet was not appropriate. According to OE staff, the OE did not review the NMSS spreadsheet for approval. As of April 2023, OE staff was unaware of any plans to include more detailed Part 37 language in future updates to the Enforcement Policy and Enforcement Manual.
While the spreadsheet has been helpful for many, the spreadsheet is not listed on the OE webpage, along with the Enforcement Policy, Enforcement Manual, and other enforcement-related material. In addition, the policy and manual do not reference the spreadsheet. The spreadsheet is only available to Why This Occurred
 
10 the agencys staff by searching the non-public version of the NRCs Agencywide Documents Access and Management System (ADAMS).8 In addition to the 21 percent of staff who use the spreadsheet, an equal percentage was unaware of its existence.
Enforcement Actions Could Be Inconsistently Determined Across the NRC Because the Enforcement Policy and Enforcement Manual lack agencywide guidance specific to Part 37, these program documents may not function effectively as program controls, potentially leading to inconsistent determination of enforcement actions for Part 37 violations. For example, a long-tenured inspector recalled that there have been at least two cases when a regional office and NRC headquarters did not agree on the severity level of proposed violations and headquarters returned them to the region. The regional branch chief eventually issued the violations even though regional staff wanted each violation to be issued by NRC headquarters at a higher severity level. According to the inspector, this was due, in part, to the lack of Part 37 updates to the Enforcement Policy and Enforcement Manual since Part 37s inception in 2014.
Enforcement actions may also be inconsistently determined if the staff uses different guidance documents. Although the NMSS compiled its spreadsheet to increase efficiency and consistency among the regions, staff could determine the severity levels of Part 37 violations inconsistently if some use the spreadsheet while others only use the Enforcement Policy and Enforcement Manual.
Knowledge transfer could also be negatively impacted. As more experienced employees leave the agency, it is important that new employees have accurate and detailed information at their disposal to help assess Part 37 violations.
Updating, formalizing, and making the spreadsheet readily available will benefit new staff and those responsible for training them. Meanwhile, updating the Enforcement Policy and Enforcement Manual will help achieve 8 ADAMS is an electronic document management system that maintains the NRCs official program and administrative records in a centralized electronic document repository.
Why This Is Important
 
11 consistency in the identification and citation of all proposed violations and better align the NRC staffs actions with Part 37.
Recommendations The OIG recommends that the Executive Director for Operations:
1.1.
Update NMSS informal guidance, as needed, with up-to-date examples for staff to consistently determine the severity level of Part 37 violations; 1.2 Pending the update of the Enforcement Policy and Enforcement Manual, ensure the periodically updated NMSS supplemental guidance is readily accessible and is available to all staff responsible for Part 37 enforcement activities; and, 1.3 Update the Enforcement Policy and Enforcement Manual to specifically reference Title 10 C.F.R. Part 37 requirements; include in these updated documents any necessary references to the newly updated informal guidance; and, disseminate the updated documents for staff consideration when determining the severity level of Part 37 violations.
 
12 The OIG held an exit conference with the agency on February 15, 2024.
Before the exit conference, agency management reviewed and provided comments on the discussion draft version of this report, and the OIG discussed these comments with the agency. Following the conference, agency management stated their general agreement with the findings and recommendations in this report and opted not to provide additional comments. The OIG has incorporated the agencys comments into this report, as appropriate.
IV. NRC COMMENTS
 
13 Objective The audit objective was to determine whether the NRC provides adequate security oversight of category 1 and category 2 quantities of radioactive material.
Scope This audit focused on the NRCs oversight of licensee implementation of Title 10 Code of Federal Regulations (C.F.R.) Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material. The audit reviewed security oversight as described in the related guidance, and the means by which the NRC evaluates Part 37 violations severity levels. We conducted this performance audit at NRC headquarters in Rockville, Maryland, from January 2023 to August 2023. Internal controls related to the audit objective were reviewed and analyzed. Specifically, the OIG reviewed the components of the control environment, risk assessments, control activities, information and communication, and monitoring. Within those components, the OIG reviewed the principles of establishing structure, responsibility, and authority organizational structure; assigning responsibility and delegating authority to achieve the entitys objectives; and, designing control activities, including policies for achieving management objectives and responding to risks.
Methodology The OIG reviewed relevant criteria and program control documents for this audit, including, but not limited to:
* U.S. Government Accountability Office, Standards for Internal Control in the Federal Government, GAO-14-704G, September 2014;
* Title 10 of the Code of Federal Regulations, Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material; OBJECTIVE, SCOPE, AND METHODOLOGY
 
14
* NUREG 2155, Implementation Guidance for 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material;
* Inspection Manual Chapter (IMC) 2800, Materials Inspection Program;
* Inspection Procedure 87137, 10 CFR Part 37 Materials Security Programs;
* Enforcement Policy; and,
* Enforcement Manual.
The OIG interviewed 31 NRC staff members, including inspection and enforcement management and staff members at headquarters (NMSS, OE) and in Regions I, III and IV, as well as 12 materials licensees who are subject to Part 37 regulations. The team also interviewed two cybersecurity subject matter experts from Sandia National Laboratories.
The audit team reached their conclusion by analyzing documents such as the radioactive materials inspection manual chapter and its related inspection procedure and inspection reports. The team analyzed various data obtained from NRC staff and contractors to calculate the total number of NRC licensees per region and the number and types of violations issued by the NRC to those licensees. The audit team reviewed a sample of violation letters submitted by the NRC to its licensees. In addition, the audit team tested data from the NRCs Web Based Licensing system to determine the accuracy and validity of the Part 37 data provided by NRC staff.
During a virtual meeting held with the agency staff and a contractor, the OIG tested the accuracy of some of the data received. The accuracy of the sample that included 9 of the 16 escalated enforcement actions issued was confirmed.
We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
 
15 Throughout the audit, auditors considered the possibility of fraud, waste, and abuse in the program.
The audit was conducted by Mike Blair, Team Leader; Tim Wilson, Audit Manager; Roxana Hartsock, Senior Auditor; Connor McCune, Senior Auditor, and William Schuster, Senior Engineer (Technical Advisor).
 
16 Please
 
==Contact:==
Online:
Hotline Form Telephone:
1.800.233.3497 TTY/TDD:
7-1-1, or 1.800.201.7165 Address:
U.S. Nuclear Regulatory Commission Office of the Inspector General Hotline Program Mail Stop O12-A12 11555 Rockville Pike Rockville, Maryland 20852 If you wish to provide comments on this report, please email the OIG using this link.
In addition, if you have suggestions for future OIG audits, please provide them using this link.
TO REPORT FRAUD, WASTE, OR ABUSE COMMENTS AND SUGGESTIONS NOTICE TO NON-GOVERNMENTAL ORGANIZATIONS AND BUSINESS ENTITIES SPECIFICALLY MENTIONED IN THIS REPORT Section 5274 of the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023, Pub. L.
No. 117-263, amended the Inspector General Act of 1978 to require OIGs to notify certain entities of OIG reports. In particular, section 5274 requires that, if an OIG specifically identifies any non-governmental organization (NGO) or business entity (BE) in an audit or other non-investigative report, the OIG must notify the NGO or BE that it has 30 days from the date of the reports publication to review the report and, if it chooses, submit a written response that clarifies or provides additional context for each instance within the report in which the NGO or BE is specifically identified.
If you are an NGO or BE that has been specifically identified in this report and you believe you have not been otherwise notified of the reports availability, please be aware that under section 5274 such an NGO or BE may provide a written response to this report no later than 30 days from the reports publication date. Any response you provide will be appended to the published report as it appears on our public website, assuming your response is within the scope of section 5274. Please note, however, that the OIG may decline to append to the report any response, or portion of a response, that goes beyond the scope of the response provided for by section 5274. Additionally, the OIG will review each response to determine whether it should be redacted in accordance with applicable laws, rules, and policies before we post the response to our public website.
Please send any response via email using this link. Questions regarding the opportunity to respond should also be directed to this same address.}}

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