OIG-24-A-07, Status of Recommendations: Audit of the U.S. Nuclear Regulatory Commission’S Safety Inspections of Class II Research and Test Reactors, Dated, May 30, 2024, Dated, May 30, 2024
| ML24151A539 | |
| Person / Time | |
|---|---|
| Issue date: | 05/30/2024 |
| From: | Virkar H NRC/OIG/AIGA |
| To: | Raymond Furstenau NRC/EDO |
| References | |
| OIG-24-A-07 | |
| Download: ML24151A539 (1) | |
Text
NRC Headquarters l 11555 Rockville Pike l Rockville, Maryland 20852 l 301.415.5930 nrcoig.oversight.gov MEMORANDUM DATE:
May 30, 2024 TO:
Raymond V. Furstenau Acting 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:
DEPUTY EXECUTIVE DIRECTOR FOR REACTOR AND PREPAREDNESS PROGRAMS, MEMORANDUM DATED MAY 14, 2024 Attached is the Office of the Inspector Generals (OIG) analysis and status of recommendations as discussed in the agencys response dated May 14, 2024. Based on this response, recommendations 1.1 through 4.1 are open and resolved. Please provide an updated status of the open, resolved recommendations by January 30, 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, Acting ADO T. Govan, Acting 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 NRCs current timekeeping system.
Recommendation 1.2: Establish guidance and training for recording and approving the RTR inspection hours to specific CACs.
Agency Response The Office of the Chief Financial Officer (OCFO) will begin Dated May 14, 2024:
updating Management Directive 10.43, Time and Labor Reporting, dated January 23, 2020, to reflect the changes to the new Human Capital Management Cloud System.
Target Date for Completion: June 30, 2025 The anomalies associated with inspection hours data that were noted in the OIG report are issues that have occurred during the transition of the inspection program to RPS and have been experienced in similar information technology system transitions. Because the issues were anticipated and accounted for, they did not result in incorrect billing of any RTR licensees and did not impact the tracking of inspection data for future planning and budgeting. The staff has internal controls for fee billable RTR inspection hours, which are in place to validate and certify billable staff hours and contractor charges. The validation process helps the NRC ensure timely and accurate billing for fee-paying licensees and assists with meeting the target error rate of less than 1 percent.
The staff conducted inspector training for labor cost string (i.e., CAC/EPID/Docket) creation within RPS and developed a desk guide to support the transition to RPS. The issues experienced during the transition and observed by OIG have largely been resolved. The staff plans to enhance relevant guidance to further clarify the process for creating, recording, and approving inspection hours where appropriate.
Target Date for Completion: December 31, 2024.
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 Recommendations 1.1 and 1.2 (continued):
OIG Analysis:
The proposed actions meet the intent of these recommendations. The OIG will close these recommendations upon reviewing the updated Management Directive 10.43, Time and Labor Reporting, dated January 23, 2020, desk guide used to support the transition to the RPS and additional enhancements to relevant guidance clarifying the process for creating, recording, and approving inspection hours. 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) 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.
Recommendation 2.3: Periodically review the RTR training program to ensure consistency, effectiveness, and relevance.
Agency Response All staff members who perform RTR inspections are Dated May 14, 2024:
qualified and have completed post qualification and refresher training. The staff agrees with OIGs observations for improving qualification tracking and clarifying training requirements. The staff plans to enhance RTR inspector training by including instructions on recording and tracking required training, in accordance with Office of Nuclear Reactor Regulation Office Instruction ADM-504, Revision 4, Qualification Program, dated April 10, 2023, and Inspection Manual Chapter (IMC) 1245, Qualification Program for Reactor Inspectors, effective May 15, 2023.
The enhancements will include the tracking of post-qualification and refresher training requirements as specified in IMC 1245, Appendix D1, Maintaining Qualifications, effective November 6, 2023.
Additionally, as a result of the NRCs response to the recent OIG special inquiry on RTR oversight (Agencywide Documents Access and Management Systems (ADAMS)
Accession No. ML23272A039), many enhancements to the training program are underway. The staff will periodically revise the RTR training program to reflect new training needs of the RTR staff as determined by changes to policy or procedures, or both. The NRC staff plans to update the RTR inspector training and implement the tracking of post-qualification and refresher training.
Target Date for Completion: December 31, 2024.
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, 2.2, and 2.3 (continued):
OIG Analysis:
The proposed actions meet the intent of these recommendations. The OIG will close the recommendations upon reviewing updates to the RTR inspector training program and the implementation of tracking requirements for 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 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 RTR inspection data are documented and are available Dated May 14, 2024:
ADAMS and other sources. To further improve inspection data management and retrieval, the NRC is already making efforts to ensure inspection information is centrally retained in RPS. Current improvements include creating a report template for the RPS report generator tool, expanding the use of RPS from scheduling inspections to inspection data management, tracking inspection findings and follow-up items, and creating program performance reports. The staff will update the plans and schedule to complete the transition of the RTR inspection program into RPS to improve the efficiency of program implementation and management of the program data in one central location.
Target Date for Completion: December 31, 2024.
OIG Analysis:
The proposed action meets the intent of this recommendation. The OIG will close the recommendation upon validating the completion of the transition of the RTR inspection program into the RPS. 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 4.1:
Periodically review and update the RTR inspection guidance in accordance with IMC 0040.
Agency Response The staffs actions to address this finding are reflected in its Dated May 14, 2024:
response to the OIG special inquiry into the NRC oversight of RTRs (ADAMS Accession No. ML24030A502). The staff will incorporate guidance enhancements in IMC 2545, Research and Test Reactor Inspection Program, effective June 1, 2020, for performing the periodic review of IMCs and inspection procedures for RTRs.
Target Date for Completion: December 31, 2024.
OIG Analysis:
The proposed action meets the intent of this recommendation. The OIG will close the recommendation upon reviewing guidance enhancements to IMC 2545, Research and Test Reactor Inspection Program, effective June 1, 2020. This recommendation remains open and resolved.
Status:
Open: Resolved.