ML20057B717
| ML20057B717 | |
| Person / Time | |
|---|---|
| Issue date: | 03/24/1992 |
| From: | Gusack B NRC |
| To: | Jacqwan Walker NRC |
| Shared Package | |
| ML20057B712 | List: |
| References | |
| FOIA-93-130 NUDOCS 9309230180 | |
| Download: ML20057B717 (9) | |
Text
'
o NOTE TO: John Walker Financial Systems Staff, DAF cwML w FROM:
\\ Barbara Gusack Senior Budget Analyst, DBA DATE:
March 24,1992
SUBJECT:
WORKPLAN FOR THE TASK ON THE NUCLEAR WASTE FUND The Director and Deputy Director of DBA and I have reviewed the Workplan for the Agreed-Upon Procedures Review of NRC's Methodology for Allocating Costs to the Nuclear Waste Fund. The attached mark up reflects DBA's comments.
l In particular, the only work DBA wants the contractor to perform in task 3 are the last two j
bullets in task 3.a. The agency has already determined which NRC offices conduct NWPA l
activities which are to be charged to the Nuclear Waste Fund. DBA is interested in having the contractor review the records those offices use in preparing their quarterly reports on NWPA activity and the records the offices who are charged directly to the NWF nse to identify non-NWPA activities and receiving an opinion on whether the offices' methodologies are acceptable.
l In task 4.d. we want the contractor to include M year in their review. Also in task 4, we l
would like a step in which the contractor assesses the reasonableness of the Division of Accounting and Finance's procedure for reclassifying NWF costs and payments.
These changes, especially the deletion of some of the work in task 3, should result in revised estimated hours and direct labor costs.
If you have any questions concerning these changes, please give me a call.
cc:
P. Rabideau, DBA J. Evans, DBA A. Rossi, DAF o Z A17'0 1
g 9309230180 930505 ~
g
1 j
l UORKPLAN FOR TH2 AGREED-UPON PROCEDURES REVIEW OF THE NUCLEAR RECTLATORY COMMISSION'S METHODOIDGY FOR ALLOCATING COSTS TO THE NUCLEAR WASTE FUND 1
A.
Authority for Anreed-Unon Procedures The Nuclear Regulatory Commission (NRC) has contracted with Cotton &
i Company (via Contract No. J-9-G-2-0014) to provide professional accounting and auditing services. NRC has issued Task Order No. 3 titled Agreed-Upon Procedures Review of Allocation Methodology. All aspects of the review should be coordinated with NRC through Mr. John Walker, the task monitor.
B.
Background
NRC's High-Level Nuclear Waste Regulation Program activities are mandated by the Nuclear Waste Policy Act (NWPA) of 1982 and the Nuclear Waste Policy Amendments Act (NWPAA) of 1987.
NRC has regulatory responsibility for high-level waste disposal. NRC receives an annual appropriation from the Nuclear Waste Fund (NWF) for these activities, which is included in its salaries and expense appropriation. NRC received a $1-7,857,000 WF appropriation in FY k N SC^
3 4'9/1.,ese 1991 and arrg$1BW2TOOO appropriation in FY 1992. Because these funds are received from a separate funding source (NWF), NRC must distinguish between obligations, payments, and expenses for NWPA and non-NWPA activities on i,ts accounting system.
ON R& &, & q "A.
,r.
L
\\
following NWPAgcostsjWw/
s l
NRC accounts for the Salaries and benefits Program support Travel Administrative support i
J gR, unique budget and reporting (B&R) numbers to identify these as NVPA costs. NWPA travel and program support are recorded as such when the funds are obligated.
Salary and benefit obligations related to NVPA full-time equivalents (FTE) for the Division of High-Level Waste Management and the Licensing Support System Administrator are recorded as such on the payroll system. Other offices that work on NWPA-related activities prepare quarterly reports on direct staff hours expended on these activities. These reports are used to transfer salary and benefit, costs.to the NWF, using average salary and fringe benefit rates.
M N1 m <W
.l e
nn-e-
/
w'wm
.WMo r b D
Mws b, n
Administrative support costs.iire allocated on the basis ofdNPA FTEs to t
4 total agency FTEs (excluding the Office of Inspector General).
The administrative support pool includes obligations incurred by the Offices of Administration, Information Resources Management, Personnel. Analysis,"and Evaluation of Operational Data,and Executive-Director-for-Operations.
~
U_ LM,
n_ i 1:
@ ( g~
C.
Obiectives m
, r_
/ pw c.
L%%5.
b
)
The precise objective of this task is to determine!.,1f NRC's' allocation _ /
s methodology results in a reasonable and equitable allocation of/ costs.ito thes NWF and to make recommendations for any necessary changes.
ad @ gdA d[
k L(;1._Mt. dad,.Q cwMd.u
@w mw 3
- f. +.
N 4
%g g
w
D.
Review Personnel David L. Cotton, CPA, will direct the review.
Ellen P. Reed, CPA, will manage the engagement. Additional staff will be assigned as needed.
E.
Milestones / Planned Dates The review milestones and planned dates are as follows:
Entrance conference 03/23/92 Complete fieldwork 04/10/92
'y g;c,_;x_
Submission of draft report 04/24/92 (
Submission of final report 05/01/92
j i
l AUDIT STEPS FOR THE ACREED-UPON PROCEDURES REVIEV 0F THE NUCLEAR REGULATORY COMMISSION'S XETHODOLOGY FOR ALLOCATING COSTS TO THE NUCII.AR VASTE FUND WP Initial Ref 1.
Plannine. Scheduline. and Entrance Conference a.
Review the following background information:
Nuclear Waste Policy Act of 1982.
e Nuclear Waste Policy Act Amendments of 1987
=
NRC memorandums on the NWF cost allocation methodology
=
NRC's Fiscal Year (FY) 1991 report on resources exper.ded a
for NWPA activities.
b.
Contact John Walker and schedule an entrance conference with Division of Budget and Analysis staff, c.
Hold entrance conference and arrange points of contact.
2.
Understandine the Allocation System: After the entrance conference, meet with budget.and accounting personnel to obtain and document an understanding of NRC's methodology for identifying and recording obligations for NWPA program support, travel and
/ y, personnel (salaries and fringe benefit) coets. Review the records maintained to support these charges.
Determine what costs arE~ S h e included in the headquarters administrative support obligations allocated to NVPA on the basis of NWPA-related FTEs.
3.
Review of Activities km %hA$
Obtain3 tha current-NRC f"nt 74 nna Morganizatimrcharts.
a.
Review-cha-<lescrip ri nn e af each-office %-functions.
Identify those offices that could have a direct or-indirect relationship to NWPA activities.
Interview a representative from each of these offices and determine:
Nacure-of-the ~vork7erformed-by the organization Major-recent projects or accomplishments a
Major _recent-expenditures-~and rfas5ns--
a If the office submits quarterly reports of NWPA-related activities and, if so, the records used to prepare these reports.
If the office has FTEs that are charged directly to the NWF, how time on non-NWPA activities is identified.
l b.
Determine if-each-office-has-a-direct-or-indirect-relationship-to-NWPA activities and rif % if the allocation methodology currently used adequately captures the coste of this offfce's NWPA-related activities.
ApC l
t l
WP Initial,,,Hti 4.
Review of Direct Costs a.
Review the records used to calculate average salary rates for offices with NWPA activities. Assess the reasonableness of using average rates for these' activities.
b.
Determine what costs are included in allocated benefits and how the benefit ratios for each office are calculated.
I Assess the reasonableness and accuracy of these ratios.
,.,e& RMA & *31IN I
5 1
i Based on our unders g ef NRC's system of identifying c.
direct NWPA/ costs,f assess if this system is adequate to identify e R direct gases associated with NVPA activities.
s 3H-w d.
Review NRC's method for deobligating NWPA-related costs.
?
Assess the reasonableness of this method and determine if it adequately identifies and deobligates all NWPA-related costs.
l S.
Review of Headouarters Administrative Suncort Review the obligations included in the headquarters M.w a.
administrative support eest pool.
Determine if the coees in the pool all have the same or a similar beneficial or causal relationship to NRC's NVPA and non-NWPA activities. Assess l
whether the pool includes all allocable costs / obligations.
b.
Review the records used to calculate agency-wide FIEs.
Determine the reliability and accuracy of these records.
Based on our understanding of NRC activities, assess the reasonableness and equitability of FIEs as_a base for y
7 q
allocating administrative supportjcosts,tand consider if i
')
i another base might be better for allocating these cases.
i j
n
/
\\S4 crn.u-a i
,M.b=9 6.
Su-ry and Conclusion Work O
a.
Prepare a summary memorandum of all areas identified where NRC's system does not adequately identify and allocate NWPA-relatedicosta. For each of these areas, recommend a specific corrective act h " r A
MNu 5's x
b.
Hold a conference with NRC representatives and obtain their comments and opinions on the feasibility and reasonableness of each recommendation. Consider any necessary revisions to these recommendations as a result of their input.
Prepare a draft report on the results of our review and any c.
recommended corrective actions.
d.
Submit the draft report and workpapers to the engagement partner for review.
e.
Submit the draft report to the task monitor.
f.
Receive and resolve any comments on the draft report.
l
o WP Initial M i
i i
g.
Submit a fully cross-indexed draft along with workpapers to the assigned report referencer.
l h.
Resolve all referencing comments.
i.
Finalize the report.
J.
Prepare all staff evaluations.
i i
l 4
i i
i 1
COTTON & COMPANY ESTIMATED PERSON-HOURS BY TASK / PHASE FOR REVIE7 0F NRC'S METHODOLOGY FOR ALIACATING COSTS TO NWF Est==ted Hours 4
Task / Phase Partner Mananer Senior Staff Suonort Total 1.
Plannf-Scheduling, and Ent Me Conference 6
6 0
2 2
16 2.
Understanding the Allocation System 1
6 0
8 0
15 3.
Review of Activities 2
40 0
80 0
122 4
Review of Direct Costs 1
16 0
8 0
25 l
S.
Review of Headquarters Administrative Support 1
16 0
8 0
25 6.
Summary and Conclusion M
_.2.2 3
2 3
60 Total gj, Q
j Q
j M
i e
i i
.,,,.___i
i COTTCN & COMPANY DIRECT LABOR COST ESTIMATE Hours Houriv Rate Cost Partner 25
$59.56
$ 1,489.00 Manager 104 55.98 5,821.92 Senior 8
34.08 272.64 i
Staff 118 24.61 2,903.98 Support Staff 8
30.38 243.04 212
$10.730.58
- 0TQN i i
- 0MF CN Y TEL.10.N3-936-0941 Apr 14 42 12:50 No.002 F.01:<0?
nL--,...N8L-3 N..Y CrnrnmPusuc AccousTavs 100 Sotrrw Row Sracrr
- Atneam Vmerm M314 t703Wh&01 To Komea703W6 0941
- o. t ca ~ cm n.~ w,_, ca s.
., o,,,,., < n
<.,-., n. ~..... ua C e tsHans4ArtCPA
AP d/ L.- 2, lk k I.,
i
. JcArd (OAL V.E R-To:
MeC 1
~.
,f'
,i FROM:
0 4 M d S M A Y(4,) M Y
,,f N
lb9M(Alh-eb J
1
SUBJECT:
1
)
l, COMMENT:
~
TOTAL NUMBER OF FACES: b (Including Cover Sheet)
.