ML20031D198
| ML20031D198 | |
| Person / Time | |
|---|---|
| Issue date: | 09/23/1981 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Moffett T HOUSE OF REP., GOVERNMENT OPERATIONS |
| Shared Package | |
| ML20031D182 | List: |
| References | |
| NUDOCS 8110130080 | |
| Download: ML20031D198 (5) | |
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UNITED STATES j.), W ). j NUCLEAR REGULATORY COMMISSION e, h
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W ASHIN GTON. D.C. 20555
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September 23, 1981 OFFICE OF THE CHAIRMAN The Honorable Toby floffett, Chaiman Subcomrriittee on Environment, Energy and Natural Resources Committee on Government Operations United States House of Representatives Wa shington, D.C.
20515
Dear Mr. Chaiman:
In accordance with Section 236 of the Legislative Reorganization Act of 1970, enclosed is NRC's response to the recommendations addressed to the Chaiman, NRC, in the General Accounting Office's report entitled,
" Improvements Needed In The Nuclear Regulatory Commission's Office of Inspector and Auditor," dated July 9,1981.
Sincerely, M
Nunzio J all n
Chairmand V
Enclosure:
Response to GA0 Recommendations cc:
Rep. Joel Deckard 40130080 010923
>R COMMS NRCC
,,ORRESPONDENCE PDR
Response to GA0 Report Entitled " Improvements needed in the Nuclear Regulatory Commission's Office of Inspector and Auditor" (DfD-SI-72)
Recommendation To improve OIA's effectiveness, we recommend that the Chairman, NRC, require the Director of that office to develop a systematic planning and prioritization process for both audit and investigative work which complies with OMB criteria and GA0 guidance;
Response
On June 15, 1981, the Commission directed the Director, 0IA, to "In the future, present the OIA audit plan in a fomat which more closely follows the guidance in OMB Circular A-73."
This will begin with the preparation of OIA's calendar year 1982 audit plan.
DIA's investigative program responds to allegations referred to 0IA; OIA As'a result, generally does not initiate investigations independently.
OMB and GA0 guidance cannot nomally be used in planning OIA's investi-gative workload.
Establishing investigative priorities will remain a matter of judgement by OIA management based on factors such as health and safety implications, expressed Commission interest and statutory requirements.
Recommendation concentrate its investigative resources on work aimed at eliminating t
fraud and waste within NRC;
Response
We believe 01A's investigative resources are already concentrated on eliminating fraud and waste in NRC.
Nonetheless, in the future OIA will evaluate ways to improve efforts in these areas.
R_ecomr enda tion avoid assigning auditors to investigative work; Response _
It is 6he policy of the current DIA director that auditors will perfom auditv snd investigators will perfom investigations unless there is a There bona fide need for an auditor's expertise on an investigation.
have been few instances since 1978 in which auditors have been assigned to investigations.
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2 Recommenda tion establish a process of coordination between the audit and investi-gative groups in identifying possible assignments, and clearly communicate that process to the OIA staff;
Response
OIA rranagement will establish a policy whereby suggestions from the audit group to investigative group, or vice versa, identifying potential matters for investigation or audit will be more closely controlled and monitored.
This process will be documer.ted in the OIA handbook currently being developed for the guidance of the OIA staff.
Recommenda tion develop fomal guidance for the staff to follow in carrying out its work;
Response
An 0IA handbook setting out DIA policies and procedures for the staff's guidance was under development at the time of the GA0 audit.
01A management is currently reviewing this handbook.
The Commission has directed that the handbook be completed by December 31, 1981.
Recommendation institute a fomalized system of control over assignments where milestones and staff resources are established for completing critical steps and periodic job reviews are held to evaluate the status of assignments; Respons1 An 0IA Audit Milestone and Resource Schedule, which provides for job reviews, has been developed to schedule and monitor audits.
This system went into effect August 5,1981.
Recommendation establish and adhere to requirements regarding the follow-up on audit reports, and see to it that office direct 1rs respond in writing to 01A investigative reports.
Response
On August 6,1981, NRC revised its audit report follow-up system to fully document compliance with OMB Circular A-73. OIA's handbook, mentioned above, will establish requirements and guidance to the staff on conducting follow-up reviews on reports.
A follow-up schedule for
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al'i rep rts will be established, but reasonable judgement must be used in adhering to the schedule because of the small size of the OIA staff and the possibility of unplanned higher priority work.
DIA will perfom moTPtisc1y follow-up reviews in the future, however.
s The sthff ha's established a procedure to assare that required responses to OIA investi ative reports are made.
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'" Fecemmear' tton In addition, we recommend that the Chaiman, NRC, explore the possibility of assigning non-appropriate employee complaint cases and equal employ-This will allow ment"ooportunity allegations to some other NRC office.
Ine DIA investigative staff to give greater attention to eliminating fraud and we. te within NRC.
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- Response The rept,rt does not support the finding that too much time has been spent on employee complaint and EE0 cases.
Furthemore, GA0's recom-mendation :; imply proposes transferring work from OIA to some other
' unspecified office.
If other offices had excess manpewer it wo:ild be more appropriate to transfer staff from that office to GIA rather than transfer this function.
Recommendation initiate immediate action to establish a more formal process for seeking agency officials' comments on 01A draft reports.
Any exception to this fomal process--such as the use of an infomal draf t to obtain comments--should be clearly disclosed in the final report.
Response
The OIA handbook will document the fomal process for seeking agency comments on draft DIA audit reports. The handbook will also ::pecify documentation requirements for the agency comment process in both the report and work papers.
Exceptions to the formsl process will be clearly documented in the work paper files ana to the extent necessary in the final report.
Recommendation direct DIA to issue its reports if program offices are untimely in providing their comments and require OIA to reflect in its reports any changes made based on program office comments.
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Response
OIA has issued and will continue to issue its reports without the Executive Director for Operations' (ED0) comments if it is believed the EDO is unreasonably delaying comments. DIA will not issue reports to the Commission without ED0 comments only because the E00 misses a response deadline. That process would not fairly consider other pressures on the program offices and the ED0 and would result in too many issues being unnecessarily elevated to the Commission.
DIA's final reports wiil identify significant changes made as a result of program office comments.
Recommendation discontinue the practice of OIA conducting joint investigations with other NRC offices.
Response
Except during the TMI emergency, when the interview skills of OIA's audit and investigative staff were needed on the various NRC investigations of the TMI accident, 01A has not conducted joint investigations. While we agree with the general principle that DIA should not routinely be involved in joint investigations with other NRC offices, wa don't agree that this has been a " practice" which needs to be discontinued.
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