ML20057C055

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Responds to 920417 Request for Clarification of Scope of Review of NRC Methodology for Allocating Costs to Nuclear Waste Fund Under Task Order 3.Informs That NRC Allocates Portion of Support Costs Based on FTEs
ML20057C055
Person / Time
Issue date: 06/08/1992
From: Jacqwan Walker
NRC
To: Reed E
AFFILIATION NOT ASSIGNED
Shared Package
ML20057B712 List:
References
FOIA-93-130 NUDOCS 9309270014
Download: ML20057C055 (3)


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UNITED STATES l

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E NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 o,,...../

,o N N 0 B 1992 i

Ms. Ellen P. Reed Cotton & Company 100 South Royal Street Alexandria, VA 22314 1

Dear Ms. Reed:

This is in response to your letter of April 17, 1992, in which you requested clarification of the scope of your review of NRC's Methodology for Allocating Costs to the Nuclear Waste Fund (Task Order No. 3).

Through our meeting with your representatives on March 12, 1992, our markup of.

your draft workplan, and our subsequent entrance conference with your representatives on April 3, 1992, we endeavored to make clear what-we expected of Cotton & Co. in accomplishing Task Order No; 3. _Specifically, the Division of Budget and Analysis (DBA) is not interested in having you conduct a aeneral audit of the Nuclear Waste Fund (NWF) activities.

DBA is also not-interested in having you determine what. activities within the NRC budget are legitirpately chargeable to the NWF. DBA is interested in having you examine certain specified methodologies used by the NRC in allocating direct and indirect expenses to the NWF. DBA's desires were reiterated at the April 15,-1992, meeting.

In light of the dialogue noted above, DBA was surprised at the reference in your April 17, 1992, letter that you somehow.just found out about their desires at the April 15 meeting. The follosing should provide further clarification.

General Statement of Contractor Tasks For those offices already identified by the NRC for allocation of expenses to the NWF, you are to determine if the methodologies employed by those offices to identify direct FTEs expended in NWF work are acceptable.

In addition,-you should determine if the methodologies employed by-the NRC to allocate salaries i

and benefits and administrative support costs to the NWF, based on the expended direct FTEs, are acceptable.

Specific Ouestions to be Answered by the Contractor The NRC has identified certain NRC organizations for which resources have been budgeted in the High-Level Nuclear Waste Regulation program in the NRC budget and whose expenses of operation are to be recovered from the NWF.

For some of those organizations, the entire organization works exclusively or almost exclusively on activities for which expenses can be recovered-from the.NWF.

The salaries and benefits expenses for such organizations are available directly from the NRC accounting system.

In that case, the questions to be answered by you are:

1) What methodologies are used by such offices to identify time spent on activities which cannot be charged to the NWF7 2) Are 9309270014 930505 "

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Cotton & Co. those methodologies sufficiently accurate in identifying FTE expenses which should not be charged to the NWF7 3)

Is there adequate documentation to support the expenses which are being allocated to the NWF? 4)

If.not, what changes would you recommend to correct any noted problems?

The remaining organizations for which NRC has determined that expenses of operation are to be recovered from the NWF do not. work-exclusively or almost exclusively on NWF activities.

Such organizations provide quarterly reports of FTE expenditures on NWF activities to the Office of the Controller.

For those offices, the questions to be answered by you are:

1).What methodologies are used by such offices to identify time spent on activities which can be charged to the NWF? 2) Are those methodologies sufficiently accurate in identifying FTE expenses which should be charged to the NWF7 3)

Is there adequate documentation to support the expenses which.are being allocated to the NWF? 4)

If not, what changes would you recommend to correct any noted problems?

Those offices where FTE expenditures must be multiplied by factors to determine salaries and benefits expenses to be charged to the NWF, you should answer the following questions:

1) How are the factors determined? 2)'Are

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those factors sufficiently accurate in identifying the salaries and benefits expenses which should be charged to the NWF? 3)

Is there adequate documentation to support the expenses.which are being allocated to the NWF?

4)

If not, what changes would you recommend to correct any note'd problems?

For all offices where salaries and benefits expenses are charged to the NWF, NRC allocates a portion of headquarters administrative support costs to the NWF based on the FTEs expended by such offices in accomplishing NWF activities. You should answer the following questions:

1). Is it reasonable to use the total headquarters administrative support pool as the basis for allocating expenses to the NWF7 2) Are the methodologies used to allocate a portion of administrative support pool expenses to the NWF sufficiently accurate? 3)

Is there adequate documentation to support the expenses.which are being allocated to the NWF? 4)

If not, what changes would you recommend to correct any noted problems?

Some of the expenses associated with NWF activities (obligations, costs, and payments) are transferred from non-NWF activities in the NRC accounting system to NWF activities at the end of the fiscal year, based on the allocation methodologies discussed above.

You need to answer the following questions:

1) Are the methodologies used to affect such transfers reasonable? 2)

Is there adequate documentation to support the expenses which are being allocated to the NWF? 3)

If not, what changes would you recommend to correct any noted problems?

After obligations are posted against the NWF activities in the NRC accounting system, it sometimes becomes necessary to deobligate some of the administrative support obligations upon which the expenses allocated to the NWF are based.

In that case, you should answer the following questions:

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Cotton & Co. 1) Are the methodologies used to allocate a portion of such administrative support pool deobligations to the NWF sufficiently accurate? 2)

Is there adequate documentation to support the expenses which are being allocated to i

the NWF7 3)

If not, what changes would you recommend to correct any noted problems?

This clarification should enable you to proceed with the work under Task Order No. 3 and to complete the work, as soon as possible.

DBA considers this clarification to be within the scope of the original task order.

If you need r

any additional information or clarifications please let me know.

j CEIGINAL SIGNED BY John R. Walker Project Officer bcc:

R. Scroggins, OC J. Funches, OC Contracting Officer OC/DBA RF OC/DBA SF BFE-40.5.2

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