ML20169A269

From kanterella
Revision as of 12:59, 22 June 2020 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
OIG-20-A-11-Audit of Nrc'S Nuclear Power Plant Surveillance Test Inspection Program, Dated June 16, 2020
ML20169A269
Person / Time
Issue date: 06/16/2020
From: Baker B
NRC/OIG/AIGA
To: Margaret Doane
NRC/EDO
References
OIG-20-A-11
Download: ML20169A269 (16)
v • d • e


Text

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program OIG-20-A-11 June 16, 2020 All publicly available OIG reports (including this report) are accessible through NRCs Web site at http://www.nrc.gov/reading-rm/doc-collections/insp-gen

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OFFICE OF THE INSPECTOR GENERAL June 16, 2020 MEMORANDUM TO: Margaret M. Doane Executive Director for Operations FROM: Dr. Brett M. Baker /RA/

Assistant Inspector General for Audits

SUBJECT:

AUDIT OF NRCS NUCLEAR POWER PLANT SURVEILLANCE TEST INSPECTION PROGRAM (OIG-20-A-11)

Attached is the Office of the Inspector Generals (OIG) audit report titled Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program.

The report presents the results of the subject audit. Following the June 8, 2020, 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 each of the recommendation(s) within 30 days of the date of this memorandum. Actions taken or planned are subject to OIG followup as stated in Management Directive 6.1.

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) 415-5915 or Paul Rades, Team Leader, at (301) 415-6228.

Attachment:

As stated

Office of the Inspector General U.S. Nuclear Regulatory Commission Defense Nuclear Facilities Safety Board OIG-20-A-11 June 16, 2020 Results in Brief Why We Did This Review Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program NRCs resident and region-based inspectors conduct surveillance What We Found test inspections at operating nuclear power reactors to: NRC should ensure reliability of data used to support inspection program management. However, surveillance test inspection

1. Verify that surveillance labor hours documented in the agencys Human Resource testing activities provide Management System do not match with data generated from objective evidence that risk NRCs Replacement Reactor Program System. This occurs because or safety significant structures, systems, and NRC lacks guidance stipulating the periodic review of surveillance components (SSCs) remain test inspection hours in the Replacement Reactor Program System.

capable of performing their Improving data quality from the Replacement Reactor Program intended safety functions and System can enhance the effectiveness of inspection monitoring in maintain their operational the Reactor Oversight Process Self-Assessment Program.

readiness consistent with their design and licensing bases. What We Recommend

2. Verify that testing activities This report makes two recommendations to support periodically provide objective evidence reviewing surveillance test inspection hours in the agencys that Diverse and Flexible Replacement Reactor Program System.

Coping Strategies (FLEX)

SSCs remain capable of performing their intended functions and maintain their operational readiness consistent with their licensing bases.

The audit objective was to assess NRCs conduct of surveillance test inspection activities relative to inspection procedure 71111.22 requirements.

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program TABLE OF CONTENTS ABBREVIATIONS AND ACRONYMS .......................................................... i I. BACKGROUND ................................................................................ 1 II. OBJECTIVE ...................................................................................... 3 III. FINDING ........................................................................................... 3 NRC Inspection Labor Hour Data Needs Periodic Quality Assurance Checks .............................................................................................. 3 Recommendations ........................................................................... 6 IV. AGENCY COMMENTS ..................................................................... 7 APPENDIXES A. OBJECTIVE, SCOPE, AND METHODOLOGY ................................. 8 TO REPORT FRAUD, WASTE, OR ABUSE ............................................. 11 COMMENTS AND SUGGESTIONS .......................................................... 11

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program ABBREVIATIONS AND ACRONYMS FLEX Diverse and Flexible Coping Strategies HRMS Human Resources Management System NRC Nuclear Regulatory Commission OIG Office of the Inspector General RRPS Replacement Reactor Program System SSCS Safety-Significant Structure, Systems, and Components i

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program I. BACKGROUND Surveillance Test Inspection Program As part of the U.S. Nuclear Regulatory Commissions (NRC) Reactor Oversight Process Risk-Informed Baseline Inspection Program, 1 NRCs 0F resident and region-based inspectors conduct surveillance test inspections at operating nuclear power reactors to:

1. Verify that surveillance testing activities provide objective evidence that risk or safety significant structures, systems, and components (SSCs) remain capable of performing their intended safety functions and maintain their operational readiness consistent with their design and licensing bases.
2. Verify that testing activities provide objective evidence that Diverse and Flexible Coping Strategies (FLEX) 2 SSCs remain capable of 1F performing their intended functions and maintain their operational readiness consistent with their licensing bases.

Resident and region-based inspectors are required to conduct 13 to 21 surveillance test inspection samples per nuclear power reactor site annually. In calendar years 2018 and 2019, NRC conducted 1,059 and 1,036 samples, respectively. Additionally, NRC met the annual sample requirements per nuclear power reactor site.

1 NRCs Reactor Oversight Process Risk-Informed Baseline Inspection Program is the minimum inspection oversight for all power reactor licensees.

2 In the aftermath of a major earthquake and tsunami causing the Fukshima Dai-ichi accident, the nuclear power reactor industry and NRC worked to define and deploy strategies that will enhance their ability to cope with conditions resulting from beyond-design basis external events. The purpose of FLEX is to outline the process to be used by individual licensees to define and implement site-specific diverse and flexible mitigation strategies that reduce the risks associated with beyond-design basis conditions.

1

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program NRCs Surveillance Test Inspection Roles and Responsibilities NRCs Office of Nuclear Reactor Regulation is responsible for the overall management, support, and oversight of surveillance test inspections, including updates of surveillance test inspection procedures. The Division of Reactor Oversight within the Office of Nuclear Reactor Regulation revises reactor inspection procedures and oversees regional implementation. NRC inspectors are responsible for performing surveillance test inspections, while regional managers are responsible for ensuring surveillance test inspections are completed in accordance with agency guidance. NRC has budgeted 5,700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> for surveillance test inspections, which is equivalent to approximately 3.8 Full-time Equivalents. 3 2F 3

At an agency level, NRC has budgeted 2,993 Full-time Equivalents for Fiscal Year 2020. Full-time Equivalent is a human resources measurement equal to one staff person working full-time for one year.

2

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program II. OBJECTIVE The audit objective was to assess NRCs conduct of surveillance test inspection activities relative to inspection procedure 71111.22 requirements. Appendix A contains information on the audit scope and methodology.

III. FINDING NRC conducts surveillance test inspection activities in accordance with inspection procedure 71111.22 requirements. However, NRC could benefit from implementing guidance to periodically review surveillance test inspection hours in the agencys Replacement Reactor Program System (RRPS). 4 3F A. NRC Inspection Labor Hour Data Needs Periodic Quality Assurance Checks NRC should ensure reliability of data used to support inspection program management. However, surveillance test inspection labor hours documented in the agencys Human Resource Management System (HRMS) 5 do not match with data generated from RRPS. This occurs 4F because NRC lacks guidance stipulating the periodic review of surveillance test inspection hours in RRPS. Improving data quality from RRPS can enhance the effectiveness of inspection monitoring in the Reactor Oversight Process Self-Assessment Program.

4 RRPS is a web-based application that is designed to, among other things, capture inspection activities.

5 HRMS is NRCs time and labor system.

3

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program What Is Required NRC Should Ensure Reliability of Data Used to Support Inspection Program Management According to Federal Government What is internal control?

internal control guidance, 6 agency 5F Internal control is a process used managers are responsible for by management to help an entity ensuring processed data is achieve its objectives.

accurate, complete, accessible, and timely. Agencies use such How does internal control work?

information to make informed Internal control helps an entity decisions regarding use and

  • Run its operations efficiently prioritization of resources, as well as and effectively evaluating agency performance and
  • Report reliable information potential risk areas that could affect about its operations and, efficiency and effectiveness.
  • Comply with applicable laws and regulations.

What We Found Surveillance Test Inspection Hours Documented in HRMS Do Not Match with Data Generated from RRPS OIG analyzed surveillance test inspection labor hours documented in the agencys HRMS and RRPS for calendar years 2018 and 2019, and found data discrepancies 7 among all four regions.

6F 6

Government Accountability Office, Standards for Internal Control in the Federal Government, GAO 704G, September 2014.

7 This is the fourth audit report where OIG has found unreliable data generated from RRPS. The other three audit reports that found unreliable data are: Audit of NRCs Special and Infrequently Perform Inspections (OIG-18-A-13), Audit of NRCs Process for Modifying and Communicating Standard Technical Specifications (OIG-18-A-15) and, the Audit of NRCs License Amendment Request Acceptance Review Process (OIG-19-A-05).

4

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program The discrepancies for Regions II, III, and IV were approximately two percent or lower for both years. However, Region I data discrepancies varied by 14.6 percent and 11.5 percent in 2018 and 2019, respectively.

Figure 1 shows surveillance test inspection hours documented in the two data systems for 2018 and 2019, along with the data discrepancies measured in nominal and percentage terms. 8 7F Figure 1: Surveillance Test Inspection Hours Comparison Between RRPS and HRMS 2018-2019 Source: OIGs analysis of HRMS and RRPS data.

Why This Occurred NRC Lacks Guidance to Support Periodic Review Region I had the largest data discrepancy because RRPS was programmed to select only operating nuclear power reactors when producing reports for inspection labor hours. During the fieldwork phase of the audit, NRC staff modified the RRPS report to include both operating and decommissioning 9 nuclear power reactors. Additionally, NRC lacks 8F guidance to support periodic review of data generated from RRPS.

8 OIG found no evidence that the inaccurate labor hours generated from RRPS represent fee billing errors.

9 In 2018, Oyster Creek Nuclear Generating Station ceased operations. Additionally, Pilgrim Nuclear Power Station and Three Mile Island Nuclear Generating Station Unit 1 ceased operations in 2019.

5

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program Why This Is Important Improving Data Quality Can Enhance the Effectiveness of Inspection Monitoring in the Reactor Oversight Process Self-Assessment Program NRC staff relies on data generated from RRPS for the agencys Reactor Oversight Process Self-Assessment Program, which is used to monitor the overall effectiveness of inspection procedures. If the data is inaccurate, it could adversely affect the level of effort prescribed by future inspection procedure revisions.

Recommendations OIG recommends that the Executive Director for Operations

1. Implement policies and procedures to periodically review the completeness and accuracy of data generated from the Replacement Reactor Program System.
2. Periodically test data generated from the Replacement Reactor Program System for completeness and accuracy.

6

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program IV. AGENCY COMMENTS An exit conference was held with the agency on June 8, 2020. Prior to this meeting, after reviewing a discussion draft, agency management provided comments that have been incorporated into this report, as appropriate. As a result, agency management stated their general agreement with the finding and recommendations in this report and opted not to provide formal comments for inclusion in this report.

7

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program Appendix A OBJECTIVE, SCOPE, AND METHODOLOGY Objective The audit objective was to assess NRCs conduct of surveillance test inspection activities relative to inspection procedure 71111.22 requirements.

Scope The audit focused on determining whether NRC met the requirements stipulated in inspection procedure 71111.22. We conducted this performance audit from October 2019 through May 2020 at NRC headquarters in Rockville, Maryland. We analyzed RRPS data for January 2018 through December 2019 period, and compared it to HRMS data representing the same time period to identify discrepancies between the two data sets. OIG used HRMS data as the basis for its audit finding.

OIG performed a data reliability test of HRMS, and determined the data produced from this system provide a reliable basis for analyzing RRPS data. Internal controls related to the audit objective were reviewed and analyzed.

Methodology To accomplish the audit objective, OIG analyzed relevant criteria for this audit including:

  • Government Accountability Office, Standards for Internal Control in the Federal Government, GAO-14-704G, September 2014.
  • United States Code of Federal Regulation Title 10, Part 50, Domestic Licensing of Production and Utilization Facilities.
  • United States Code of Federal Regulation Title 10, Part 50.155, Mitigation of Beyond-Design-Basis Events.

8

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program

  • NRC Order EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, March 12, 2012.
  • NRC Regulatory Guide 1.226, Revision 0, Flexible Mitigation Strategies for Beyond-Design Basis Events, June 2019.
  • Nuclear Energy Institute, NEI 12-06, Revision 4, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, December 2016.

OIG conducted analyses to determine whether the agency met the requirements stipulated in Inspection Procedure 71111.22. OIG also identified surveillance test inspection labor hour discrepancies generated from NRCs RRPS for calendar years 2018 and 2019. We compared labor hours charged for surveillance test inspections in HRMS to surveillance test inspection labor hour data generated by RRPS reports. OIG verified discrepancies between the two data sources and ascertained their causes in discussions with cognizant NRC staff.

Additionally, OIG interviewed NRC staff and management from the regions and headquarters.

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 9

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program objectives. Throughout the audit, auditors considered the possibility of fraud, waste, and abuse in the program.

The audit was conducted by Paul Rades, Team Leader; Avinash Jaigobind, Audit Manager; Tim Wilson, Audit Manager; John Thorp, Senior Technical Advisor; and Ebaide Esoimeme, Senior Auditor.

10

Audit of NRCs Nuclear Power Plant Surveillance Test Inspection Program TO REPORT FRAUD, WASTE, OR ABUSE Please

Contact:

Email: Online 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 O5-E13 11555 Rockville Pike Rockville, MD 20852 COMMENTS AND SUGGESTIONS If you wish to provide comments on this report, please email OIG using this link.

In addition, if you have suggestions for future OIG audits, please provide them using this link.

11

Retrieved from "https://kanterella.com/w/index.php?title=ML20169A269&oldid=2843727"