UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

MEMORANDUM TO: 

f 

FROM: 

SUBJECT: 

REFERENCE: 

May 18, 2016 

r fo 

n . Dingbaum 

Assi tant Inspector Genera 

STATUS OF RECOMMENDATIONS: AUDIT OF NRC'S 

OVERSIGHT OF SPENT FUEL POOLS (OIG-15-A-06) 

DIRECTOR, OFFICE OF NUCLEAR REACTOR 

REGULATION, MEMORANDUM DATED MARCH 24, 2016 

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

recommendations 1, 2, 3, and 4 as discussed in the agency's response dated March 24, 

2016. Based on this response, recommendations 1, 2, and 3 are resolved and 

recommendation 4 is now closed. Please provide an updated status of the resolved 

recommendations by November 18, 2016. If you have questions or concerns, please 

call me at 415-5915, or Sherri Miotla, Team Leader, at 415-5914. 

Attachment: As stated 

cc: R. Lewis, OEDO 

H. Rasouli, OEDO 

J. Jolicoeur, OEDO 

J. Bowen, OEDO 

EDO ACS Distribution Resource 
Audit Report 

AUDIT OF NRC'S OVERSIGHT OF SPENT FUEL POOLS 

Recommendation 1 : 

Agency Response Dated 

March 24, 2016: 

OIG Analysis: 

Status: 

OIG-15-A-06 

Status of Recommendations 

Provide a generic regulatory solution for spent fuel pool 

criticality analysis by developing and issuing detailed licensee 

guidance along with the U.S. Nuclear Regulatory Commission 

(NRC) internal procedures. 

The staff is currently reviewing Revision 1 of NEI 12-16 

(Agencywide Document and Management System (ADAMS) 

Accession No. ML 14112A516), which will form the basis of the 

regulatory guide. The NRC staff has submitted requests for 

additional information to the Nuclear Energy Institute and is 

awaiting a complete set of responses. In addition, the NRC 

staff has begun the draft regulatory guide process in 

anticipation of a final revision to NEI 12-16, scheduled for 

completion this year. 

CONTACT: Amrit Patel, NRR/DSS 

(301) 415-5893 

The actions proposed by the agency meet the intent of the 

recommendation. This recommendation will be closed upon 

the Office of Nuclear Reactor Regulation's issuance of the 

regulatory guide and revisions to NUREG-0800. 

Resolved . 
Audit Report 

AUDIT OF NRC'S OVERSIGHT OF .SPENT FUEL POOLS 

Recommendation 2: 

Agency Response Dated 

March 24, 2016: 

OIG Analysis: 

Status: 

OIG-15-A-06 

Status of Recommendations 

Develop and implement spent fuel pool inspection guidance at 

operating reactors. 

On October 30, 2015, the staff issued the initial version of 

Inspection Procedure (IP) 60715, "Spent Fuel Safety at 

Operating Reactors," (ADAMS Accession No. ML 15247A049). 

Regional inspectors may use this inspection procedure to 

review infrequent major activities in the spent fuel pool or to 

evaluate emergent technical issues not related to licensee 

performance. These inspections are not part of the baseline 

or supplemental inspection program elements and Regional 

Administrator authorization is required for their 

implementation. 

This action is complete and Recommendation 2 should be 

closed. 

CONTACT: Juan Peralta, NRR/DIRS 

(301) 415-2858 

The actions taken by the agency do not meet the intent of the 

recommendation . While a spent fuel pool inspection 

procedure has been created, it does not contain any specific 

entry conditions/prerequisites. This procedure lacks visibility 

and may never be used the way it is currently written. OIG 

was careful not to recommend the procedure be part of the 

ROP baseline inspection program or be conducted on any 

specified periodicity. The intent was to create a procedure 

that may easily be used at the discretion of the inspector. This 

recommendation will be closed upon NRR creating entry 

conditions for the new spent fuel pool inspection procedure. 

Resolved . 
Audit Report 

AUDIT OF NRC'S OVERSIGHT OF SPENT FUEL POOLS 

Recommendation 3: 

Agency Response Dated 

March 24, 2016: 

OIG Analysis: 

Status: 

OIG-15-A-06 

Status of Recommendations 

Develop an enforceable neutron-absorbing material aging 

management program. 

The generic letter requesting information on monitoring of 

neutron-absorbing materials in spent fuel pools was provided 

to the Commission as an enclosure to SECY-16-0034, 

"Issuance of Generic Letter 2016-xx, 'Monitoring of NeutronAbsorbing Materials in Spent Fuel Pools,"' dated March 16, 

2016. In addition, the staff has now received an OMB 

clearance number per the Paperwork Reduction Act for 

issuing the generic letter. The staff intends to issue the 

generic letter in April 2016. 

CONTACT: Scott Krepel, NRR/DSS 

(301) 302-0399 

The actions proposed by the agency meet the intent of the 

recommendation. This recommendation will be closed when 

NRR completes'its analysis of (1) licensee responses to the 

generic letter and (2) develops an enforceable neutronabsorbing material aging management program based on the 

analysis. 

Resolved . 
Audit Report 

AUDIT OF NRC'S OVERSIGHT OF SPENT FUEL POOLS 

Recommendation 4: 

Agency Response Dated 

March 24, 2016: 

OIG Analysis: 

Status: 

OIG-15-A-06 

Status of Recommendations 

Update Inspection Manual Chapter 2561 and Inspection 

Procedure 60801 . 

On January 11 , 2016, the NRC issued Revision 1 to IP 60801 

(ADAMS Accession No. ML 16008A819). The revision was 

coordinated with all regional offices, the Office of Nuclear 

Security and Incident Response, and the Office of Nuclear 

Reactor Regulation (NRR) to ensure that the new revision is 

aligned with IP 60715, which was developed as part of the 

NRR action for Recommendation 2. 

The final revision of IMC 2561 is dependent on the completion 

of revisions to other core and discretionary inspection 

procedures. The revision to IMC 2561 pertaining to IP 60801 

will be administrative, reflecting the revision to IP 60801 and 

other IP changes. The staff will complete the revision to IMC 

2561 when the agency issues all of the decommissioning core 

inspection procedures. Therefore, the staff has addressed the 

recommendation by implementing IP 60801 while continuing 

to manage the revision of IMC 2561. 

This action is complete and Recommendation 4 should be 

closed. 

CONTACT: Bruce Watson, CHP, NMSS/DUWP 

(301) 415-6221 

The actions taken by the agency meet the intent of the 

recommendation. This recommendation is now closed. 

Closed .