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OFFICE OF THE 

INSPECTOR GENERAL 

MEMORANDUM TO: 

FROM: 

SUBJECT: 

REFERENCE: 

October 5, 2016 

Victor M. Mccree 

Executive Director for Operations 

)!__:_~~ 

Steven E. Zane ~ Acting Assistant Inspector General for Audits 

STATUS OF RECOMMENDATIONS: AUDIT OF NRC'S 

OVERSIGHT OF 10 CFR 50.59, "CHANGES, TESTS, AND 

EXPERIMENTS" (OIG-16-A-19) 

DEPUTY EXECUTIVE DIRECTOR FOR REACTOR AND 

PREPAREDNESS PROGRAMS MEMORANDUM DATED 

SEPTEMBER 21 , 2016 

Attached is the Office of the Inspector General's analysis and status of 

recommendations as discussed in the agency's response dated September 21 , 2016. 

Based on this response, recommendations 1 and 2 are resolved. Please provide a 

status update on these recommendations by March 21 , 2017. 

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 NRC'S OVERSIGHT OF 10 CFR 50.59, "CHANGES, TESTS, AND 

EXPERIMENTS." 

OIG-16-A-19 

Status of Recommendations 

Recommendation 1: Implement a structured approach for [Title 10 of the Code of 

Federal Regulations Section 50.59] 10 CFR 50.59 process 

management that includes guidance clarification and 

coordination of program communications. 

Agency Response Dated 

September 21, 2016: We agree with this recommendation. 

The Office of Inspector General points to examples where 

regional and headquarters staff who had questions about 

10 CFR 50.59 guidance did not inform or obtain an answer 

from the 10 CFR 50.59 process owner. The staff has 

planned corrective actions to address both the structure and 

communications aspects of this recommendation. 

While the current "structure" exists in the Generic 

Communications Branch (PGCB) in the Division of Policy 

and Rulemaking (DPR) in the Office of Nuclear Reactor 

Regulation (NRR) as the 10 CFR 50.59 process owner, 

NRR plans to move this responsibility to the Division of 

Inspection and Regional Support (DIRS), targeted for 

October 2016, as part of the first phase of a larger 

restructuring of the office. NRR believes transitioning this 

capability to a branch in DIRS (most likely the Reactor 

Inspection Branch) will better align this capability within the 

suite of support functions to the regions that currently reside 

in DIRS. It will also address the Office of the Inspector 

General (OIG) concerns regarding the staff approaching 

knowledgeable staff in both DPR and DIRS regarding 10 

CFR 50.59 process questions, by housing this support 

function in the division where the regions get most of their 

support. 

As the OIG recommendation regarding program 

communication is both a regional and headquarters staff 

awareness issue, the planned corrective actions are 

intended to address both intended audiences. Using 

communication resources sponsored by DIRS, including a 
Audit Report 

AUDIT OF NRC'S OVERSIGHT OF 10 CFR 50.59, "CHANGES, TESTS, AND 

EXPERIMENTS." 

OIG-16-A-19 

Status of Recommendations 

Recommendation 1 (Con't): 

OIG Analysis: 

Status: 

biweekly call with the regions and other offices and the 

quarterly inspector newsletter, NRR will remind regional 

staff regarding the 10 CFR 50.59 process owner. 

Headquarters staff will be informed via e-mail to all NRR 

Branch Chiefs and Technical Assistants. As the process 

owner and subject matter expert, the cognizant staff in 

DIRS will ask regional and headquarters staff to leverage 

the 10 CFR 50.59 expertise within the responsible branch in 

DIRS. Staff will be reminded to contact the branch when 10 

CFR 50.59 challenges arise to better ensure consistency 

across the agency and provide for program communications 

and guidance clarifications. 

Completion Date: 12/31/2016 

Point of Contact: Christopher M. Regan, NRR/DIRS 

301-415-2768 

The proposed actions meet the intent of this 

recommendation. OIG will close this recommendation after 

reviewing appropriate documentation, and other information 

as needed, to verify that staff have undertaken these 

actions as described. 

Resolved. 
Audit Report 

AUDIT OF NRC'S OVERSIGHT OF 10 CFR 50.59, "CHANGES, TESTS, AND 

EXPERIMENTS." 

OIG-16-A-19 

Status of Recommendations 

Recommendation 2: Implement recurring 10 CFR 50.59 training with an 

emphasis on scope, depth, and periodicity of training. 

Agency Response Dated 

September 21, 2016: We agree with this recommendation. 

The staff has planned corrective actions to address this 

recommendation. Based on staff evaluations of lessons 

learned from the San Onofre Nuclear Generating Station 

steam generator tube event, the staff identified a need to 

develop broad-reaching training to ensure proper 

understanding of the 10 CFR 50.59 process. As a first step, 

staff from NRR conducted training on 10 CFR 50.59 in each 

regional office. Subsequently, the Office of the Chief 

Human Capital Officer (OCHCO) developed a new training 

course to enhance inspector understanding of the 10 CFR 

50.59 process. 

OCHCO subsequently developed an on-demand online 

course in ilearn, and all Reactor Oversight Process 

inspectors completed the course this year. Initial feedback 

indicates the training covers the necessary 10 CFR 50.59 

topics and has enhanced understanding of the rule. 

Based on an occupational assessment of inspector needs, 

OCHCO, in coordination with NRR and the IMC 1245 

working group, will be adding 10 CFR 50.59 process 

refresher training to the reactor technology review courses. 

These courses are attended every 3-to-6 years by 

inspectors qualified to IMC 1245, Appendix C1, "Reactor 

Operations Inspector Technical Proficiency Training and 

Qualification Journal," and Appendix C2, "Reactor 

Engineering Inspector Technical Proficiency Training and 

Qualification Journal," to maintain inspection qualifications 

in accordance with IMC 1245, Appendix 01. Once 

implemented, the staff will periodically review the training to 

determine if new information or requirements are needed. 

This covers the necessary population of regional inspectors 
Audit Report 

AUDIT OF NRC'S OVERSIGHT OF 10 CFR 50.59, "CHANGES, TESTS, AND 

EXPERIMENTS." 

OIG-16-A-19 

Status of Recommendations 

Recommendation 2 (Can't): 

OIG Analysis: 

Status: 

for reviewing 10 CFR 50.59 issues. The staff plans to 

revise IMC 1245 by the end of calendar year 2016 to add 

the new 10 CFR 50.59 training to the inspector qualification 

requirements contained in IMC 1245, Appendices C1 and 

C2. 

The NRR office instruction for project manager 

qualifications (ADM-504) includes 10 CFR 50.59 in the 

position-specific initial qualifications for the Reactor 

Technical Reviewer (Appendix A), License Renewal 

Technical Auditor/Team Leader (Appendix B), Operating 

Reactor Licensing Project Manager (Appendix D), Reactor 

Regulation Project Manager (Appendix E), License 

Renewal Project Manager (Appendix F), Research and Test 

Reactor Project Manager (Appendix J), and Reliability and 

Risk Analyst (Appendix M). The recently developed ilearn 

10 CFR 50.59 training is available on an as-needed basis 

for refresher training. 

Completion Date: 12/31/2016 

Points of Contact: David K. Allsopp, NRR/DIRS 

301-415-3073 

Steven D. Cochrum, OCHCO 

423-855-661 5 

The proposed actions meet the intent of this 

recommendation. OIG will close this recommendation after 

verifying that the upcoming IMC 1245 revision addresses 10 

CFR 50.59 training, and after verifying staff plans for 

periodic reviews to determine if new information or 

requirements are needed. 

Resolved.