ML18155A533

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OIG-17-A-23-Audit of Nrc'S 10 CFR 2.206 Petition Review Process, Dated June 4, 2018
ML18155A533
Person / Time
Issue date: 06/04/2018
From: Baker B
NRC/OIG/AIGA
To: Mccree V
NRC/EDO
References
OIG-17-A-23
Download: ML18155A533 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OFFICE OF THE INSPECTOR GENERAL June 4, 2018 MEMORANDUM TO: Victor M. McCree Executive Director for Operations FROM: Dr. Brett M. Baker /RA/

Assistant Inspector General for Audits

SUBJECT:

STATUS OF RECOMMENDATIONS: AUDIT OF NRCS 10 CFR 2.206 PETITION REVIEW PROCESS (OIG-17-A-23)

REFERENCE:

DEPUTY EXECUTIVE DIRECTOR FOR REACTOR AND PREPAREDNESS PROGRAMS MEMORANDUM DATED MAY 14, 2018 Attached is the Office of the Inspector Generals (OIG) analysis and status of recommendations as discussed in the agencys response dated May 14, 2018.

Based on this response, recommendations 1 and 2 are resolved. Please provide a status update for these recommendations by November 16, 2018.

If you have questions or concerns, please call me at (301) 415-5915 or Paul Rades, Team Leader, at (301) 415-6228.

Attachment:

As stated cc: R. Lewis, OEDO H. Rasouli, OEDO J. Jolicouer, OEDO J. Bowen, OEDO EDO_ACS Distribution Resource

Audit Report Audit of NRCs 10 CFR 2.206 Petition Review Process OIG-17-A-23 Status of Recommendations Recommendation 1: Develop controls to ensure formal assessments are performed and are documented for future use.

Agency Response Dated May 14, 2018: The staff agrees with the recommendation.

NRC Management Directive (MD) 1.1, "NRC Management Directives System," dated March 25, 2016, requires the staff to review and reissue, or to certify as still relevant, all MDs at least every 5 years unless an extension of the MD's expiration date has been approved. Before the October 2000 version of MD 8.11, "Review Process for 10 CFR 2.206 Petitions," the staff performed and documented formal assessments of the 10 CFR 2.206 petition review process as part of the periodic review and revision of MD 8.11. Between 2009 and 2017, the staff performed formal and informal assessments and implemented changes on various portions of the 10 CFR 2.206 petition review process. These assessments have also supported the ongoing revision of the October 2000 version of MD 8.11, which the NRC expects to issue by November 2, 2018.

Planned Action: The Office of Nuclear Reactor Regulation (NRR) staff is developing guidance and controls that will allow the staff to perform and document periodic assessments of the 10 CFR 2.206 petition review process.

Formal and informal assessments will continue to support enhancements to the process and future revisions of MD 8.11. However, the staff will define and decouple the frequency of periodic assessments from the review requirement in MD 1.1 to ensure that the NRC performs them on a consistent schedule.

The staff extended the target date for completion to account for the extension of the date to revise and issue MD 8.11, as addressed in Recommendation 2.

Audit Report Audit of NRCs 10 CFR 2.206 Petition Review Process OIG-17-A-23 Status of Recommendations Recommendation 1 (contd):

Target date for completion: August 31, 2018 Updated target date for completion: March 29, 2019 CONTACT: Perry H. Buckberg, NRR/DORL (301) 415-1383 OIG Analysis: The actions described above meet the intent of this recommendation. OIG will close this recommendation after reviewing the revised guidance and verifying that it specifies measures for performing and documenting formal programmatic assessments in support of the 10 CFR 2.206 petition review process. This recommendation is resolved.

Status: Resolved.

Audit Report Audit of NRCs 10 CFR 2.206 Petition Review Process OIG-17-A-23 Status of Recommendations Recommendation 2: Clarify the criteria for reviewing and rejecting petitions.

Agency Response Dated May 14, 2018: The staff agrees with the recommendation.

The NRC staff recognized the need to clarify the criteria for reviewing and rejecting 10 CFR 2.206 petitions as part of the ongoing revision to MD 8.11. The staff has developed and incorporated revised criteria and has updated initial screening criteria in the proposed revision to MD 8.11.

Planned Action: The NRC staff will implement revised and clarified criteria upon approval and issuance of the revised MD 8.11. The expected date for NRC staff to revise and issue MD 8.11 was extended to allow the staff to consider additional external stakeholder feedback received and to respond to Commission direction in Staff Requirements Memorandum (SRM) M180208 dated February 20, 2018.

The SRM M180208 identified additional items for staff consideration and clarification in its revision of MD 8.11.

The target date for completion is updated to reflect the date of issuance of the revised MD 8.11, which staff expects to occur by November 2, 2018.

Target date for completion: April 30, 2018 Updated target date for completion: November 2, 2018 CONTACT: Perry H. Buckberg, NRR/DORL (301) 415-1383

Audit Report Audit of NRCs 10 CFR 2.206 Petition Review Process OIG-17-A-23 Status of Recommendations Recommendation 2 (contd):

OIG Analysis: The actions described above meet the intent of this recommendation. OIG will close this recommendation after reviewing the updated version of MD 8.11 and verifying that it includes clarified criteria for staff review and rejection of 10 CFR 2.206 petitions. This recommendation is resolved.

Status: Resolved.