ML20081L247

Office of the Inspector General.Semiannual Report.October 1990 - March 1991

ML20081L247
Person / Time
Issue date:	04/30/1991
From:	NRC OFFICE OF THE INSPECTOR GENERAL (OIG)
To:
References
NUREG-1415, NUREG-1415-V03-N02, NUREG-1415-V3-N2, NUDOCS 9107030211
Download: ML20081L247 (34)

Text

&!,"cDi t.I 3.

_bjf,

hk m

N n

.../

........;,,.?,

.x,

-.,4 m--

s.

=CA,.- -

_J.J

., d v..

g ~ :. 3

.m 4,. o,

e wp w,,. 3.y j

j r ],. c xpggj

%gdl.g 4

pL -

ank

+

s

~e.5%

• e*A.

4 %r 4%

1. egya y$gsn <r L%

r 4

w n'

s s*

~g g

@w[ d d 8];g.3, y.-

~,',afa

,$:g ]e@J

$M,sua4pdlik1 it s

y V*

• gg

~

7 e

..h.._

.g "_

-wh

't

. m e..,' "fk '

,5!~ma:~

hib~;

p-fi SIEd '

~

![i 7

q

~

4 c

we=

w, '

~

~

9, yy n

smhg**tr aw

_ KwW' wad a iTw

. $y u p e

W i

R Jg&p

• tem L

sgp y

e t

a i

d

[h$)ffgj h~

bh

~

pgg ggAS

. e-_.

,s*.-

'u'

=

s

• 'g+9 p, '-,, e-o

~#

gwm w

gp;f$?$gif'Nh U

'j~

?

y,.4~., 9

'w.

$,gl? ggg g

ny gjdh

'8

~

~

a tj i nd$

1ll&M m

i e

ddEERIBEEBB$$

YIA$a%,f MM @S%~}4$6

,dh

[lju%@ fay @8,lj")u$$$$a i

f NN w

u p-v 3

ya 4, n %Q yiQ R;.g { f ni jt/s ~

s

^

m.

b.%.-

r 3-7,w khh@w%%s)g/a ogg

$ijp.

fp

.js 2,7

i 3

4

%lbkiflW

}' % # # t.am C ap k

%,wgn

'4. n..

• n mag -

> '5;. n e

=a N

hf

., w. Cn, 4

r g@ -

g g,.,, %m, s K

n ;

r t

,gg

, f

';i p g

$$i neumd199 g%

me+r = v

~

g-Q}g g g qp

_Jo gh$bf A46M99,) 4,99,ggg

. (o

. p-y,4 f$$%

G

,saw n

y

~:)pg,as

~

i%% y % g [ gf pgp ' - - '

y 9107030211 9104

^

g s;)

Q PDR NUREC 1415 R PDR 3% y& v-am o nsan W...I)5N Q $.. @

L

• y khh yi TN

{

g

MEMORANDUM TO THE CHAIRMAN i

i x.

... e

...1 it is my pleasure to submit to you this semiannual report on the activities of the Office of the inspector General (OIG) covering October 1,1990, i

through March 31,1991. 'lhis report is submitted to you in accordance with Section 5 of the Inspector General Act of 1978.

The work of the OlG staff is directed toward improving the economy and efficiency of the U.S. Nuclear Regulatory Commission's (N RC's) pro-grams and detecting fraud, waste, and abuse in their operation. During this reporting period, we closed 34 investigations and 1 inspection. We also reviewed 32 contract audits and performed 10 internal audits, result-ing in 39 recommendations to improve the etfectiveness of NRC opera-tions. In addition, we identified a total of $472,179 as funds that could be put to better use.

The accomplishments described in this report represent the com-bined efforts of the OlG staff aswell as the continued cooperation of NRC management. We sincerely appreciate your support and look forward to assisting the agency with meeting its important challenges.

Sincerely, N(.h Mamo David C. Williams Inspector General

i LTABLELOF CONTENTS AR REcog 8

g 8

v o

EXECUTIVE SUMM ARY__

4 NRC PROFILE 6

- OFFICE OF TIIE INSPECTOR GENERAL 7

AUDITS 8

INVESTIGATIONS

- 16 SPECIAL FEATURE 22 REGULATORY REVIEW 24 APPENDICES _

26 AUDITS 26 ABBREVIATIONS 30 GLOSSARY 31

~. -.

e

,.w.

4

1. .v.,#..~w..m...

,4.,,.,,.y,_,.-w,-4.y y..w.-,y

,me

,,,.,v,-,-

.vr y-,w-,,

ym-sm-wre.r

EXECUTIVE

SUMMARY

AUDITS During the past six months, the Office of the inspector General issued 10 reports addressing the NRC's programmatic and administrative fune-tions and reviewed 32 contract audit reports issued by the Defense Con-tract Audit Agency. Ten of the contract audits were pre-award audits, and 22 were post award audits. Three of the pre-award audits identified

$282,179 as funds that could be put to better use. As a result of an inter-nal audit, an additional $190,000 was identified as funds that could be put to better use. Below is a summary of selected findings.

E A review of the NRC's emergency planning regulations disclosed that the agency's stated objective of emergency planning required clarifi-cation.

E NRC's internal controls for travel services was designated by the OlG as a significant weakness.

E A review of the NRC's electronic publishing and graphics systems identified $190,000 in savings that could result from improved use of these systems.

E A review of the NRC's implementation of the reporting require-ments of Part 21, Title 10, code of Federal Regulations, disclosed that the agency needs to improve the management of industry reports.

E A review of the NRC's nuclear documents system revealed that the system failed to meet the needs of its users because of insufficient plan-ning and a lack of interoffice coordination.

INVESTIGATIONS From October 1,1990, through March 31,1991, the OlG initiated 35 new investigations and closed 34 investigations. As of March 31,1991, 1

- 37 investigations were in progress. Some of the investigations are high-lighted below.

E The 010 received an allegation that an NRC supervisor was placing numerous personal calls on the Federal Telecommunications System.

This allegation was substantiated.

5 The GIG received an allegation that NRC staff improperly influ-enced a decision issued by the Atomic Safety and 1 icensing Board.This allegation was found to be untrue.

W The OlG investigated a threat against a licensee employee allegedly made by a co-worker. Although the alleged threat was not substantiated, it was ultimately determined that the subject of the investigation made false statements to Federal investigators.

4 Nucumu urotnxiony couMisSION

4 l

i

- O The OlG received an allegation that an NRC employee created coun-1

~

terfeit documents in an attempt to increase the amount of a purchase or-der.Ourinvestigation revealed that the employee did not act with intent to defraud the Gavernment and lacked props training in funding proce-i dures.

O The OlG received an allegation that managers at a nuclear facility withheld pertinent documents from the NRC. The OlG determined this was not an isolated incident and that certain plant managers were negli-I gent in providing documents to the NRC.

O OlG inspectors reviewed the NRC's regulation of a holder of a byproduct material license whose previous business practices had posed a threat to ine health and safety of the public.The O1G inspection did not substantiate the licensee's claim of unfair treatment by the NRC.

o y a i-f: 11

}

gh 3

w; pk

{Q $;

i-gy m pp

' u!O MI

[-

e

i;.

Chairman Carr and Inspector General David Williams meet to discuss issues pertinent to NRC operations.

I i

l l

OFFICE OF TIIE INSPECrOR GENERA 1.-SEMIANNUAL. REPORT 5

l

NRC PROFILE l

l The U.S. Nuclear Regulatory Commission was established by the Energy Reorganization Act of 1974, as amended; the Nuclear Nonproliferation Act of 1978; and in conformance with the National Ensironmental Policy Act of 1969, as amended.

This legislation requires the NRC to regulate the following actisi-ties: commercial nuclear power plants; research, test, and training reac-tors; fuel cycle facilities; medical, academic, and industrial uses of nu.

clear materials; and the transport, storage, and disposal of nuclnt materials and wastes. In regulating these activities, the NRC shares a common respc.nsibility with its licensees to protect our national security and to assure the public health and safety.

To accomplish this mission, the NRC employs approximately 3350 technical, scientific, and administrative personnel in the Washington, D.C., commuting area and five regional offices. The total budget for fis-cal year (FY) 1991 is $484 million.

T18. H -

AB q.........,.....

1 I

]

yy,,

*la, awr

• = =

l i

-.n.v.

n.,

,,,,g -.:

=

=

o==

--=1 m.,

m,,

['OTI

" tJf6.

!'11t:t i

- ~ai a-

= =

- = = -

• ':1f,"Ji I

I l

I I

I I

I I

=7.fi,>

=%

=.L7.'

(MTL.i

%:=.:-

=,v,

= n = :.

SAPTf 443ci l

l l.ts', = c.]

.='.':,7 = l 1

I I

I

,,g.,

.g j,,,,;g.,

j[l

,~,

I

-J L

b NUU1. EAR REGt !! Al ORY COMMissl( >N

OFFICE OF THE INSPECTOR GENERAL The Inspector General Act of 1978, as amended, established independent and objective offices within departments and agencies to improve econ-omy and efficiency within Federal programs and to detect and prevent fraud; wast, and abuse within their operation.

To carry out this mission within the NRC, the Office of the Inspector General (OIG) received authorization for 32 positions for FY 1991 with a budget of approximately $4 million.The organizational chart of the 01G is as follows.

? Office of the' Inspector General r

I Assistant inspector Assistant Inspector Assistant inspector General General General for Audits for Operations,

for investigations Planning and Investigative Analysis

=

Staff Team A Administrative Technical Investigative Audit Staff Audit Staff leam B Investigative Team C l

1-OITICE OF TIIE INSPEClOR GENERAL.-SEMIANN11AI. REPoirl 7

I AUDITS g

SUMMARY

OF SIGNIFICANT AUDITS During the past six months, we issued 10 reports covering the NRC's pro-grammatic and administrative functions. In addition, we reviewed 32 contract audit reports issued by the Defense Contract Audit Agency.

Ten of the contract audits were pre-award audits, and 22 were post-award audits.Three of the pre-award auditsidentified $282179 as funds 3

that could be put to better use. As a result of an internal addit, an addi-tional $190,000 was identified as funds that could be put to better use.

c k.___ivs 4

.n f

yy

~

w

. jE\\

l.

)

3l'

'M N

g k,

s 4-

? -...

S?.5T

1....

Tom Barchi, Assistant inspector General for Audits, and Senior Auditor Bob Shideler meet to discuss audit planning.

NRC's Management In passing the Energy Reorganization Act of 1974, Congress cre-ofIndustry Reports ated improvements for the nuclear industry to detect and report on the Needs Improvement use of defective parts. Under Section 206 of the act, a vendor or a licen-l see is required to notify the NRC promptly whenever a defective part that could pose a substantial safety hazard has been supplied to an NRC li-censee.

To satisfy this legislative requirement, the NRC issued a regulation entitled " Reporting of Defects and Noncompliance," Title 10, Code of Federal Regulations, Part 21 (10 CFR Part 21). In addition, as a result of the accident at the Three hfile Island Nuclear Station (ThfI)in 1979, the l

NRC committed to the President's Commission on TNIl to improve l

these regulations by clarifying the reporting guidelines. The goal was to improve reporting uniformity and to provide for an earlier identification l

8 NUCI. EAR REGUl ATORY CCMIMisslON

e of_ defective parts and an earlier correction of problems associated with these parts: The NRC committed to complete these regulatoty resisions

by August 1980.

We conducted an audit to determine whether the NRC's regulations rand proposed revisions were adequate to ensure compliance with Section i

206 of the act. Additionally,we reviewed whether the NRC's management of industry reports was adequate to ensure prompt resolution of any re-ported defects, j

We found that the NRC needs to improve the management of reports filed by licensees and vendors to provide a more accurate, reliable, and ef fective system. Furthermore, we concluded that the NRC needs to fulfill its conunitment to the President's Commission on TMi by completing the regulatory revisions.

NRC management has reviewed our recommendations and is cur-rently in the process of implementing them.

The OlG reviewed tiie NRC's document storage and retrieval system, NRC Needs to

- the Nuclear Documents System (NUDOCS). We conducted this review to linprove its determine if the NRC was receiving the maximum benefit from the system.

1)oclunent Storage We concluded that NUDOCS was an improvement over an earlier storage and Retrieval Systent and retrieval system m terms of its usefulness and service. Ilowever, we found that the NRC failed to derive the maximum benefit from NUDOCS

' because the system was not fully utilized.

In December 1989, while we were in the process of reviewing NUDOCS, the system was replaced by the Nuclear Documents System /

Advanced Design (NUDOCS/AD). This new database was developed to provide NUDOCS with greater flexibility. As the integration of NUDOCS/AD began, we incorporated a review of the new system into our ongoing work. We concluded that because ofinsufficient planning and

a lack ofinteroffice coordination,

he system failed to meet the needs ofits users.

As part o.'our audit, we examined the need for the NRC to have other

~ separate data storage and retrieval systems. The NRC maintains four ad.

ditional document storage systems at a cost of over $120,000 annually.

As a result of our work, the NRC has committed to conduct " user needs" studies before making any substantial changes to NUDOCS/AD.

In additi<m, the four independent storage and retrieval systems are being reviewed by the NRC for possible consolidation with NUDOCS/AD.

OFTICE OF THE INSPECIOR GENERAt.-SEMtANNtIAL REPoltT 9

l l

A Review of NRC's The NRC's electronic publishing and graphics senices are divided Publishing and between two offices. We conducted a resiew to determine the etficiency nd the economy of operating and maintaining separate senices and to Graphics Services assess the costs associated with each office's program. We also resiewed the agency's policies for maintaining two separate electronic systems to proside these sersices.

We concluded that the NRC had taken a major step forward in the electronic publishing and graphics media services. With the purchase of the Kodak Ektaprint Electronic Publishing System (KEEPS)and the in-terleaf Graphics System, we determined that the NRC's publishing and graphics costs have been reduced, llowever, we identified that an addi-tional annual savings of over $190,000 can be achieved through the im-proved operation of KEEPS and with better coordination between the two systems. NRC management is currently implementing our recom-mendations to accomplish this objective.

NRC's Stated in 1980, the NRC amended its regulations to require that "No oper-Objective of ating license for a nuclear power reactor will be issued unless a finding is mad by NRC that the state of onsite and offsite emergency prepared.

Emergency Planning ness provides reasonable assurance that adequate protective measures A,ceas Claripca'io" can and wiii be raten in the event or a radioiogicai emergency. iiefore that time, the NRC believed that a plant's safety systems were adequate to protect the public from a release of radiation.The accident at Three Niile Island in 1979 demonstrated that a nuclear plant's safety systems alone were not adequate to protect the public. As a result, the NRC modified its regulations to require that all operating nuclear plants have an approved emergency plan.

At the request of Congress, the OlG initiated a review of the NRC's emergency planning regulations. We found that the NRC's stated objec-tive of emergency planning is not consistent with the objective stated in NRC's regulations.

We also learned that the NRC had determined it could conduct its own review of offsite emergency plans. We questioned the NRC's authority in this respect because the President had assigned the lead role for offsite emergency planning to the Federal Emergency Nianagement Agency (FEN 1 A). Furthermore, the Congress expressly provided for FENI A's role in this process.

The OlG recommended that the NRC modify its stated objective of emergency planning and determine whether the NRC has the authority to conduct its own reviews of offsite emergency planning. The recom-mendations should result in clarifying the level of protection afforded the public in the event of a radiological accident.

IU NI 4 't.1 alt itlBI!! Al( >itY COM MI% ION

l musuunusunnusumummer I

I i'

i

=)

e T

w

=m x

.-c s "-

s.

n1

n; e

amams a

.6

.a.

-,,.?. ;Q.,.[

y n

OlG Auditors en route to Congressional briefing to discuss audit on NRC's emergency planning regulations.

The Federal Managers' Financial Integrity Act (FM FI A) was enacted Implementation of on hptember 8,1982,in response to continuing disclosures of waste, loss, the Federal unauthorized use, and misappropriation of funds or assets associated with Managers' Financial weak internal controls and accounting syste;.~ The act requires Federal In"'giity Act managers to establish a continuous process for evaluating, improving, and reporting on the internal controls and accounting systems for which they are responsible.The OlG annually performs a review of the process used by the NRC to evaluate these internal controls and financial management systems and to assess their compliance with the Office of M anagement and Budget's (OMB's) guidelines.

On the basis of our resiew,we determined that the NRC has complied in part with the FM FI A. We are satisfied that the internal control system requirements of the FMFI A have been met but concluded that the NRC has not fully complied with the financial management system require-ments of the act. OMB established guidelines that require detailed re-views of all financial system components and subsystems at least once every three years. The N RC has identified eight management financial sys-tems that require detailed reviews to conform with the act and OMB guidelines. In December 1990. we reported that the agency did not OfTICE OF Tile INSPECTOR GENERAL.-SEMIANNIlAI. REPORT 11

conduct a detailed evaluation for six of the eight systems and failed to follow OMB guidelines for the remaining two.

We recommended that the NRC staff responsible for the financial evaluations be better trained and that additional guidance, planning, and monitoring be prosided by management. Additionally, we identified problems in the agency's travel accounting system that we determined to be significant. NRC management is taking corrective action.

AUDITS IN PROGRESS The following audits were in progress at the end of the reporting period:

E Review of NRC's Prompt Payment Process-The Prompt Payment Act of 1982, as amended, requires Government a6encies to pay bills promptly. The OlG is assessing the NRC's compliance with this act.

p,Ih 34 I

rasan t

r...

?

- [y*$ )..

~ ~

)

""*NR

<d s

~

OlG auditors brief Division of Accounting and Finance managers during exit conference on NRC's prompt payment process.

E Review of NRC's Debt Collection Process-The Debt Collection Act of 1982 was enacted to improve the collection of debts owed to the Federal Government. The OIG is assessing the NRC's compliance with this act and reviewing its implementing regulations.

E Review of NRC's License Fee Management Program-The OlG is evaluating the process used by the NRC to (1) accumulate the costs that form the basis for license fees and (2) subsequently bill licensees for services rendered.

I 1

12' NUCLl:AR REolil AIORY COMMISslON

t E

Review of NRC Procedures in llandling the Employees Legal Pro-ject's (ELP's) Allegations Regarding Seabrook-The ELP alleged that the Seabrook nuclear plant located in New i lampshire was unsafe and that the NRC had not adequately addressed ELP's allegations. The OlG is conducting two audits to determine whether NRC handled the allegations appropriately.The OlG is reviewing both the NRC staff procedures and she Commission procedures in responding to the allegations.

E Review of the Procurement Practice of the Advisory Committee on Reactor Safeguards (ACRS)-The ACRS relies heavily upon goods and services secured from outside sources in performing its work. This review assesses the ACRS' compliance with procurement policies and regula-tions in obtaining these goods and services.

E Review of the Safety Issues hianagement System (SIMS)-SIMS is a tracking and monitoring system desigred to manage nuclear plant safety issues, including generic safety issues associated with the accident at the Three Mile Island facility. OlG is examining the system to determine the accuracy ofits database and the process for validating the licensees'imple-mentation of corrective action.

1 '

nc r

mg;

=

w "

.. m g : x -

] Tig 7

i pin

,p 9

9:

a j

y y

.. a f;

J

- pg:

.,, :. m y'y 4%

i

/

g M

t I;

I.

rw Ib,..J j =g sensammer w

+ - -

cy OlG auditors obtain information from an NRC staff member concerning the Safety issues Management System.

E Review of NRC Staff Actions in Resolving issues Contained in the Confirmatory Action Letter Related to Pilgrim-Due to operational problems, the Boston Edison Company (llECo) shut down the Pilgrim nu-clear plant on April '12,1986. NRC subsequently issued a confirmatory action letter to address technical issues and Io confirm the utility's intent to OFFICE OF TiiE INsPEClOR GENERAL.-sEMIANNIIAL REPOlfl 13

)

i keep the plant shut down until NRC approved its restart. A citizens group i

alleged that NRC and BECo have not adequately resolved the issues that caused the shutdown. 010 is reviewing how NRC resolved those issues.

AUDITS The NRC's dependence on commercial contract activity is relatively limited. Thus, reported questioned costs and savings are inhc. 9 v 1

smaller than those reported by most other agencies.

During the reporting period, the OIG reviewed 32 contract audit re-ports. The following tables depict the cost savings from the contract audits and one internal audit.

Table i OITice of the inspector Generni Reports Containing Questioned Costs (Dollar Value)

Number of Questioned Unsupported Reports Reports Costs Costs A. For which no management 0

0 0

decision had been made by the commencement of the reporting period B. Which were issued during 11*

468.6(4 0

the reporting period Subtotals (A + B) 11 468/4M 0

C. ' For which a management 9

468.6(4 0

decision was made during the reporting period:

(i) dollar value of disallowed 9

4684/M 0

costs (ii) dollar value of costs not 0

0 0

disallowed D. For which no management 2

0 decision had been made by the end of the reporting period E. Reports for which no manage-0 0

0 ment decision was made within six months of issuance

• The figure differs from number of reports reviewed because 11 reports had no ques.

tioned costs.

' Questioned costs for the reports are currently under review. The agency with pre-dominant interest (on the basis of unliquidated dollar amounts)is responsible for ne-gotiating final indirect rates which will be bindmp on all agencies.

14 Nt!C1. EAR REGUI.YIORY COh1NilSslON

~.

Table ll Office of the inspector General Reports issued With Recommendations That Funds lie Put to lletter Use Dollar Number of Value Reports Reports of Funds A. For which no management decision had 1

25,725' been made by the commencement of the reporting period II. Which were issued duting the reporting period 4"

472.179 Subtotals (A + 11) 5 497.904 C. For which a management decision was made 4

440 % 7 during the reporting period:

(i) dollar value of recommendations that were 4

440, % 7 agteed to by management (ii) dollar value of recommendations that were 0

0 not agreed to by management D. For which no management decision had been 1

61,030 made by the end of the reporting period E. Reports for which no management decision was 0

0 made within 6 months of issuance

'The beginning figure of funds put to better use ($25,725)was revised during the current reporting period to $29,818. Negotiations with the contractor and further discussion with DCAA resulted in substantial agreement with the recommendation. The differ-ence in the original dollar amount and the final figure is the result of (!)a reduction of

$18,258 from the original total and (2) a revision in the contractor's required travel in the amount of $22.351.

"Seven other pre-award audit reports reported either zero funds were available for bet-ter ase or no contract was awarded.

OITICE OF Tile INSPECI OR GENER Al.-SEMIANNIJAl. REl' ORT 15

INVESTIGATIONS

SUMMARY

OF SIGNIFICANT INVESTIGNI'lONS During this reporting period, the 01G received 116 allegations, com-pleted 34 investigations, and referred 5 cases to the Department of Jus-tice. A summary of our most significant investigations follows.

,.7.

F f

7 7

if i

L,

.c n

c-\\

\\M 3

m a: A; -

L s

OlG investigators review case findings.

Licensee Failed to The OlG received an allegation that plant managers at a nuclear fa-Provide Requested cility deliberately withheld documents from the NRC that revealed seri-Documents to NRC ous problems of a technical nature. Our investigation disclosed that the NRC inspector did not receive certain pertinent documents that plant nspectors managers had promised to provide.The OlG staff also determined that managers were negligent in failing to ensure that the NRC inspector re-ceived all of the documents he had requested. The 010 staff found that on two previous occasions NRC inspectors had not received documents requested from plant managers.

Alleged Threat The OlG received information that a nuclear power plant employee Ac:ainst Nuclear was verhally threatened by a co-worker. At the time of the alleged tbreat.

Power Plant the employee had been providing information to the NRC and the OlG about safety hazards at the plant. The employee interpreted the alleged

• P U#

threat as a message from plant managers that the employee should n longer cooperate with NRC investigators.

Insufficient inf ormation was developed o substantiate that the al-leged offender intended to threaten or haru the en;;doyee or to convey any message from the plant's manager

• It. we, mer determined that Ib NtK'I.lMk RI Gl:1 sl f.)RY COMM isti F1

i s

1 I

during the 010 investigation the alleged offender made false statements to Federal investigators. The U.S. Attorney declined prosecution of this matter; however, the NRC is considering administrative sanctions against the alleged offender.

The Atomic Safety and Licensing Iloard Panel (ASLilP) conducts Alleged linproper Commission hearings and performs other regulatory functions authorized Ingaence With by the Commission. In November 1989, the ASLBP issued a decision Licensing Board (LDP-89 32) authorizing issuance of a full-power license to a nuclear pecjgjgy power plant.

After the decision was announced, the OlG received an allegation that the ASLBP licensing decision was improperly innuenced by certain 1

NRC Ileadquarters stalf. Specifically,it was alleged that between the day l

the panel's decision was signed on November 9,1990, and the day the deci-sion was announced on November 13,1990, the NRC staf f used undue in-Quence to affect the licensing board's decision. No evidence was devel-oped that substantiated this allegation.

The OIG investigated an allegation that an NRC employee counter.

Incestigation of feited documents to increase funding under a blanket purchase agreement hnproper Purchasing (BPA). Our investigation revealed that the employee created counterfeit Procedures documents to support a BPA for agency delivery services. Ilowever, we also found that the employee was unfamiliar with funding procedures con.

cerning a BPA purchase order, and we developed no evidence to indicate tha: the employee had attempted to defraud the Government, Subsequent to our investigation, the employee and other branch members were trained in project acquisition to prevent similar future occurrences.

The OIG received an allegation that an NRC employee had used the Abuse of Federal

.NRC Federal Telecommunications System (FTS) to place frequent per-Telecorninunications sonal long-distance calls. Our investigation confirmed that over a 5-year Systein Calls period, the employee had used the FTS to place more than 200 personal telephone calls.

The U.S. Attorney's office declined prosecution in this matter; how-ever, the NRC is considering administrative action, The holder of an NRC byproduct materiallicense complained to the Licensee Complains OlG of disparate treatment received from the NRC and charged NRC in-ofDisparate spectors with incompetency and negligence while per forming inspections Treat /nent By NRC of the licensee's facilities.The licensee had been penalized by the NRC on fyyppefg,y several occasions for conducting business in a manner th.it posed risks to the public's health and safety. The OlG inspection did not substantiate that the licensee received unfair treatment from the NRC. nor did it reveal l-any misconduct, negligence, or incompetence on the part of the NRC in-l spectors.

[

OFFICE OF TIll'INsPEclok GENERAL --sLs!! ANNI ML RLPOR I

]7

INVESTIGATIVE STATISTICS ALLEGATIONS Source Number NRC employee 27 NRC management 31 Congress 1

Other Government agencies Intervenor 8

General public 11 Media 0

010 investigation / audit 0

Contractor 0

Regulated industry (licensee / utility) 24 Anonymous 12 Total 116'

'Of the 116 allegations,33 resulted from hotline calls.

Allegations Number Carried forward from previous period 9

Received during this period 116 Total 125 Disposition Number Closed Administratively 22 Referred for OIG investigation 55 -

Referred for 010 inspection 2

Referred for OlG audit 3

Referred to NRC management / staff 40 Referred to external agency 3

Pending review or action 1

Total 126'

'One allegation resulted in the opening of two 010 investigations.

18 NtJCIIAR REGIII.NIORY COMMISSION

SOURCE OF ALLEGATIONS NRC Management NRC Employee Other 3%

Anonymous intervenor 10%

Regulated Industry General Public 21 %

CLASSIFICATIONS OF INVESTIGATIONS Open Investigations by Type Intemal Fraud 6%

Falsification of Records / Statements NRC Programs 37%

Misuse of Government 6%

Property 9%

Conflict of Interest Management, Misconduct Other and Abuse ggg 23 %

l.

l-l OFFICE OF THE INSPECTOR GENERAL-SEMI ANNUAL, REPORT 19

INVESTIGATIONS Status of Investigations Number Carried forward as of 9/30/90 46 Opened during this period 35

(

Closed during this period 34 Number in propress as of 3/31/91 47 Carried in forward Progress Classification of Investigations 9/30/90 Opened Closed 3/31/91 A - Conflict of interest 6

3 3

6 B - Internal fraud 8

2 5

5 C - Contract / contractor related 9

0 3

6 misconduct D - Falsification of records or 3

3 3

3 statements E - Theft-related offenses 3

1 3

1 F - Misuse of Government 0

2 2

0 property G - Actions affecting safety or 8

13 10 11 NRC programs H - Management misconduct 9

8 3

14 and abuse 1 - Other 0

3 2

1 Total 46 35 34 47 REFERRALS Sent to the Department of Justice (DOJ)

Number Pending DOJ decision as of 9/30/90 3

Sent ta DOJ during period.

5 Pending DOJ decision as of 3/31/91 3

Total 11 Disposition of DOJ Referrals Number Subjects accepted for prosecution 0

Declinations 5

Indictments O

Convictions 0

Total 5

l 20 NUCI. EAR REGll!ATORY COMMISSION

NRC ACTIONS TAKEN IN RESPONSE TO OlG INVESTIG ATIONS The NRC took two administrative actions in response to OIG investiga-tive reports that were issued in a previous reporting period.

An investigation involving an NRC-sponsored symposium had dis-closed that funds were not properly controlled, appropriate contracting procedures were not followed, and the agency lacked formal guidance on this matter The Office of Administration published a new directive.

" Conferences and Conference Proceedings," to comply with an OlG re-port recommendation that guidance be provided to ensure that employees use proper funds control and contracting practices when planning and conducting NRC-sponsored events.

In the second instance, an OlG investigation disclosed that a staff member had provided substantial assistance to a petitioner in drafting a petition and in reviewing subsequent revisions of the petition. The con.

duct of this staff member raised significant policy concerns for the NRC.

The Executive Director for Operations issued an amendment to regula-tions under 10 CFR Part 2 concerning procedures to be used in filing a petition for rulemaking with the NRC The amendment clarified the type of assistance the NRC staff may provide to prospective petitioners.

OFFICE OF TiiE INSPEClOR GENER Al.-SEMI ANNI!.sl. R EI't ilfl 21

SPECIAL FEATURE m-NRC Federal The audit mission of the Office of the inspector General (OiG) is di-Advisory rected principally toward (1) improving program management, (2) en-Committee, suring the integrity of the N RC's regula tory programs, and (3) preventing and identifying fraud, waste, or misuse of agency funds by agency em-playees. The OlG also resiews legislative and regulatory proposals and issues recommendations concerning their effect on the economy and efficiency of NRC programs abd operations. In this capacity, the OlG advises the NRC Chairman and the Congress about problems and defi-ciencies it may identify with NRC's administration of agency programs and on the necessity for corrective actions.

Federal advisory committees also play an important role in assuring that Government officials have access to information and advice on a broad range ofissues affecting Federal policies and programs. The NRC has six advisory committees that provide recommendations for agency programs.

Each committee has a specifically defined objective and scope un-der which it provides recommendations to the NRC. The current active advisory committees at NRC are as follows:

E The Advisory Committee on Reactor Safeguards reviews and re-ports on safety studies, facility license applications, generic issues, and other matters referred to it by the Commission. On its own initiative, the Committee may conduct reviews of nuclear facility safety-related issues.

It also has the authority to initiate reviews of other issues that it deems appropriate. Upon request, the committee provides advice and recom-mendations to the Defense Nuclear Safety lloard and the Department of Energy (DOE).

5 The Advisory Committee on Nuclear Waste (ACNW) provides ad-vice on managing and disposing of nuclear waste.The committee exam-ines and reports on those areas of concern ret erred to it by the Commis-sion or its designated representatives. Howe' er, on its own initiative, the ACNW may elect to undertake certain studies and reviews that involve issues being examined by the Commission.

5 The Advisory Committee on Medical Uses ofIsotepes is composed of experts who provide advice to the Commission on certain medical is-sues in which NRC's standards may be unclear or inapplicable. The com-mittee also provides advice on rulemaking and other initiatives during critical development stages. The expertise provided by this committee is particularly essential because the NRC staff has no physicians, medical physicists, pharmacists, or practicing medical technologists. During the past year, this committee assisted the NRC staff with developing a rule on quality assurance as it applies to radiation therapy. The 22 NUCIGR Rf!GUI.NIORY COMMISSION

f committee also provided assistance on other issues centering on the medi-cal uses of byproduct material.

E The Nuclear Safety Research Review Committee provides advice to the NRC on general management issues invohing the direction of the NRC's program of nuclear safety research. During the past year, commit-tee reviews on seismic research, human factors, severe accidents, and waste management resulted in improved focus and readjustment of pro-gram priorities that were affected by a diminishing research budget.

E The Licensing Support System Advisory Review Panel was estab-lished to advise the NRC and DOE on the Licensing Support System (LSS), which is being designed. The ISS is an electronic information man-agement system that will contain all documentary materials for use in the Commission's review of any DOE applications for a high-level waste re-pository license. Membership consists of representatives of organizations who are potential parties in a licensing proceeding.

E The Advisory Panel for the Decontamination of Three Mile Island, Unit 2 (TMI-2), consults with and provides advice to the Commission on procedures required for the safe decontamination of the TMl-2 facility.

This panel is comprised of local citizens, scientists, and politicians. The panel functions as a collegial body that hears reports by various organiza-tions and holds internal discussions before voting on various positions or resolutions that are communicated to the NRC.

..A4sw mk

~

Ki:P a.:s

' %xy

-r %g egg y7,;;;p[' Ah wm;ua*4 -

wa.jesd;;ch M ' '. ~7;pw%,MCd' R2#~ gyp w

, y w p ;hmwa r_

m g.

The Three Mile !sland Nuclear Reactor site.

OFFICE OF Tile INSPE 'OR GENERAlcsLMI ANNIJ Al. RI:14 )R'I 23

REGULATORY REVIEW Legislative in December 1990, the NitC issued a Commission Paper containing 10 Proposals for the legislative proposals under consideration by the 102nd Congress. One of lO2nd Congress the proposals con (.rned Section 206 of the Energy lleorganization Act.

Under existing legislation, responsible oth,eers and directors of a busi-ness providing defective components to an NIRC-licensed facility may be fined civilly for failing to notify the NItC of the defect. The proposed amendment would modify Section 206 to include the imposition of civil penalties against the entities as well. The OlG icviewed the proposed amendment and agreed with the NIRC's position. The OlG's repor t enti-tied "lteview of NRC Nianagement if Reportine itequirements Under 10 CFR Part 21" addressed similar concerns and provided a recommen-dation to establish a specific time during w hich a business must identify a defect. This measure would improve the NRC's enforcement program.

Establishment of a The Executive Director for Operations issued a draft Commission ChiefFinancial policy paper concerning the establishment of a Chief Financial Officer Officer at NRC (CFO) at the NRC in accordance with the CFO Act of 1990. Congress passed the CFO Act to bring more ef fective general and financial man-agement practices to the Federal Government. The act requires the NRC to designate a CFO who reports to the head of the agency.

The OlG reviewed the proposed policy paper and noted that the CFO was to be placed at the EDO level,llecause of this dual responsibil-ity, we suggested that CFO responsibilities be clearly identified, and we proposed changes to the CFO organizational chart to reflect the CFO's reporting requirements.

As a result of guidance from ONtB, the EDO withdrew the policy paper noted above and issued a revised paper, The OlG reviewed the revised draft and had no conceptual disagreements with the CFO's re-l sponsibilities as identifica. We agreed with the paper's conclusion that applicable NRC directives should adequately reflect the authority of the CFO and the Deputy CFO for dealing with other agency officials.

l Efforts to Improve Over the past decade, the Office of Ntanagement and Budget l

Financial (ON1B) and the Department of the Treasury have promoted severalini-Management tiatives to improve the usefulness, quality. timeliness, and integrity of fi-ONtB(d man gement information in the Federal Government. As pa

" "'I Systems in s financial information improvement program, interagency teams l

l G,orenunent evaluated the financial systems plans for selected ideral agencies and l

published a report of the results of their evaluation.

l I

l 24 NUCI. EAR REGUI,NI ORY COMMISSION

m W.

~~

The OIG commented on the results of the interagency team's report

-and their recommendations for implementing the program Government-wide. We. expressed support for the report and sugnested methods to re-quire Federal agencies to produce timely, accurate, and mea ingful finan-cial information.

. In November 1990, NRC issued proposed revisions to the agency's Proposed Revisions "Open Door" policy and its policy on " Differing Professional Opinions."

to NRC's "Open These policies govern the expression and resolution of differing profes-I' or Polig'" and to sional views or opinions on matters relating to the agency's mission.They

,,j;g. " Differing s

also provide NRC employees the opportumty and mechamsm (1) to pre-O u[###'U###

U sent their best professional judgments even though they may differ from P nons,,

prevailing staff view. (2) to disagree with a management decision or policy

- position, or (3) to take issue with proposed revisions or established agency pra#es.

The OlG reviewed the proposed revisions and offered suggested changes that would improve management of the program and v.ould pro-vide consistency in the maintenance of records.

L

'I

. OFFICE Of TIIE INSI'ECf0R GENERAL-SEMIANNUAL, REPORT 25

~

APPENDICES AUDITS INTERNAL AUDIT REPORTS Date Title Number 11/20/90 Review of Electronic Publishing and OlG-89A-27 f

Graphics Services Performed in NRC 11/30/90 Review of NRC Managtment of OlG-L A-25 Reporting' art 21 Requirements Under 10 CFR l 12/24/90 Review of NRC's implementation of OlG-90A-13 the Federal Managers' Financial Integrity Act 01/08/91 Survey of Emergency Response Data OlG-90A-8 System 01/16/91 Review of NRC's Nuclear Documents OlG-89A-10 System 01/16/91 Review of NRC's Emergency OlG-90A-14 Planning Regulations and Implementing Guidance 01/14/91 Follow up Review of Actions Taken OlG-88A-22 on OlG's Report Entitled " Review of Contracting for Consultants" 01/22/91 Follow up Review of Actions Taken OIG-90A-20 on OlG's Report Entitled " Review of Cash Receipts Received by imprest Fund Cashier" 01/22/91 Follow-up Review of Actions Taken OlG-87A-20 on OlG's Report Entitled " Review of NRC's Enforcement Program" 03/28/91 Review of NRC's Implementation of OlG-91A-02 "De Anti-Lobbying Act" 26 NUC' EMI 1(I GUlXI 014Y COMMISSION

{

CONTRACT AUDIT REPORTS Funds 01G Ouestioned Put To Issue Costs Better Use Date Contractor (Dollars)

(Dollars) 09/25/90 Williams & Associates 11,454 NRC-02-82-lM4,82-033; 82-Os9; S2-lM6 09/25/90 Williams & Associates 10.074 NRC-02-82-044 82-033;82-039; 82-046; and RO4-84-501 09/25/90 Combustion Engine, Inc.

Contract not awarded Proposal for RER RS-AED-90-303 09/25/90 Accident Prevention Group 0

Proposal for BAA-RES-90-055 09/25/90 Graduate School, USDA 0

NRC-10-86-213 09/27/90 Merex Incorporated 176,745 Proposal for RS-NRR-90-033 09/27/90 Logical Technical Senices O

Corporation NRC-33-83-453 OW27/90 Mathtech. Incorporated 0

NRC-33-86-263 10/03/90 Graduate School, USDA 0

N RC-10-86-213 10/10/90 Orkand Corporation 0

NRC-39-84243-1 10/10/90 Tet, Incorporated 44,404 Proposal for RS-NRR 90-028 10/16/90 SRI, International 0

NRC-04-81-211 10/24/90 Smithsonian Institution 94,830 N RC-02-8&O06 10/24/90 MITRE Corporation 0

N RC-04-87-399

/

10'24/90 Maxirna Corporation Costs under review NRC-10-84-247; M-257:

and 33-85-324 Of FIG OF THE INSPECIUR GENIMIAlc $EMIANNtal. REPS ik i 27

lunds

~

010 Ouestioned Put To issue Costs lletter Use Date Contractor (Dollars)

(Dollars) 10/24/90 International Technical 3ery.

0

-i NRC4487-395 12/07/90 S. Levy, Inc.

17,897 NRC-N-84-139 12/12/(X)

Westinghouse Elec. Corp.

Costs under review NRC-04-824)20 12/12/90 Statistica, Inc.

(8,120]

NRC-39-88-211: 88-241 02/21/91 United Engineering and 0

Constructors, Inc.

NRC-33-85-311 02/22/91 Itasca Consulting Group, Inc.

17,520 NRC-02-s!4102 02/26/91 International Technical Serv.

O NRC-03-86 053 02/26/91 hiaterial lingineering 272,415 Association NRC-04-84-102 02/26/91 Automation Management 0

Consultants Proposal for RS-IRht 91-183 03/06/91 Femme Comp. Inc.

O Proposal for RS-IRht-91-183 03/11/91 hieridian Corp. Inc.

O Proposal for RS-lRht-91-183 03/14/91 J, A. Reyes, Association 0

Proposal for RS-IRht-91-183 03/14/91 Science Applications int'l

[4,501]

Cor NRCp.02-81-040 03/14/91 ANCO Encineering 0

NRC-04-82-025 03/19/91 Science & Engineering 61,030 Association, Inc.

Proposal for RS-RES-90-108 28 NtJCI. EAR RI.GUIATORY COMMISSION

l l

Iunds OlG Questioned l'ut To Issue Costs licitri Use llate Contractor (1)ollar s)

(llollat s) 03/19/91 Scientech, Inc.

O l'roposal for itS-III.S-Mi-108 03/31/91 Williams A: Asuiciates 57.035 NitC-02-844H4; 824M6;83-033; 110 4-84-501

.abiotat

$468#l4 52x2,179 INTL!!1NAl, AUDIT ltlil'OllT 11/2091 lleview of liwetronic 0

1% U N Wl' l'ublishin' and Graphics Services I crlormed in NitC Subtotal 0

5 IMI,G ul TOTAL.

546SR4 5472.179

'I'rinting costs savings.1)oes not rencet unplementation costs.

OITICE OF'lllE INSP!ITOil GI:NLi( Al.-SI'.MI ANN 11 Al 1(I POffl 29

i AHilREVIATIONS

=

t' ACNW Advisory Committee on Nuclear Waste ACRS Advisory Committee on Reactor Safeguards t

AStilP Atomic Safety and Licensing lloard Panel BECo lloston Edison Company DPA blanket purchase agreement t

i CAL confirmatory action letter CFO Chief Financial Officer CFR U.S. Code of Federal Regulations ^

t DCAA U.S. Defense Contract Audit Agency DOE U S. Department of Energy DOJ U.S. Department of Justice EDO Executive Director for Operations l

ELP' Employees Legal Project FEh1A U.S. Federal Emergency hianagemmt Agency Fh1FI A Federal hianagers' Financial integrity Act FTS Federal Telecommunications System FY fiscal year 10 Inspector General KEEPS Kodak Ektaprint Electronic Publishing System-LSS.

Licensing Support System NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation -

NUDOCS Nuclear Documenis System NUDOCS/AD Nuclear Documents Sptem/ Advanced Design i

OGC Office of the General Counsel OlG Office of the Inspector General

' Oh1B Office of hianagement and lludget SihtS.

Safety Issues hianagement System Thil Three htile Island Th11-2 Three hiile Island, Unit 2 3 01 NUCLEAR RLGill ATORY COMMISslON

musumunuuuuuuuuuuur GLOSSARY llLANKET PURCilASE AGREEN1ENT (llPA). A simplified method of meeting anticipated, repetitive needs for supplies or services by establish-ing " charge accounts" with qualified sources of supply. IIPA's are de-signed to reduce administrative costs in accomplishing small purchases by eliminating the need for issuing individual purchase documents.

CONFIRS1 ATORY ACTION LE' ITER (CAL). A letter from the NRC to a licensee confirming a licensee's agreement to take certain inunediate, short term actions that also specify the actions to be taken.

ELECTRONIC PUllLISillNG SYSTEht. A computerized system for the creation, typesetting, page makeup (for text and graphics), and output on a laser printer of finished pages ready for the printing press.

FINAL ACTION,The completion of all management actions discussed in management decisions concerning aud recommendations end findings.

Final action occurs when managemem ssues a decision.

FUNDS PUT TO IIE1TER USE. Funds identified in audit recommenda-tions that could be used more efficiently by avoiding unnecessary ev penses.

LICENSING SUPPORT SYSTEh!(LSS). An electronic information sys-tem that will contain all documentary mateiials for use in the Commis-sion's review of Department of Energy (DOE) high level waste repository license applications. The LSS will be developed by DOE and will be used by all interested parties during the technical and adjudicatory review proc-ess.

51ANAGEh1ENT DECISION. hianagement evaluation of audit recom-mendations and findings. A final decision is issued that is based on man-agement's response to recommendations and findings.

NUCLEAR DOCUSTENTS SYSTEhi/ ADVANCED DESIGN (NUDOCS/

AD).The agency's cennalized, automated document search and retrieval system for regulatory, licensing, and adjudicatry information.

QUESTIONED COST. A cost questioned as a result of an alleged viola-tion of law, regulation, contract, or agreement governing the espenditure of funds (costs unsupported by adequate documentation or funds for a particular purpose that are unnecessary or unreasonable).

UNSUPPORTED COST. A cost questioned because of a lack of adequate documentation at the time of the audit.

OftlR OF TlifiIN5PLClOR GI.1NiiRAt-SEMI ANNUAL REPORT 31

w w.gevpaws. -

Tile INSPECTOR GENERAL HOTLINE The lloiline Program provides access to tbe Office of the Inspector Gen-eral through the use of a toll free number (1800-233 3497).The number may be dialed from a Federal Telecommunications System line or

/

through commercial lines. The OlG staff is available to answer calls Monday through Friday, between 10.00 a.m. and 4:00 p.m. (Eastern Standard Time). Our staff is trained and equipped to protect employee confidentiality. Individuals wishing to provide information to the OlG llotline Program may also write to the address below.

The Office of the Inspector General Attention: The Ilotline Program Mail Stop MNIIII 6715 Washington, D.C. 20555 llOTLINE NUM13ER:

1-800-233-3497 32 Nucuan luioulxiony COMMISSION

(

k',4 9

, i.

• e. - i 44i / - - q .' ' (.,,'.

.',.g%hA (f f(.

1. ,, 1., / M, - ( ['

- l' 'e ) '. '

,a l'l [. ' f ,',  ; i. - -,' ',. l.

'W

'.S g i g ' ;. c

'g 'g, p'

',, ', '.',' j.... 3

'4 e

l

i i *,4 %. t. g.G f /', ' M '.g / '. '.

- 3,,,

v'.,. '-

3,".'.

~ /

) (' '

a

,<t

.y <,,

1, li : '

.8,1

,j g,i g,,<

d.

i

=#

i

,gn

,.s a

..\\

0,

', ' f,,1, y. 9el s

< sso

,ggy y.

'... ,, -,j y

s a

.f n '

'l+

a

.,,, g, F l l,.,

.s

- i s

s..

P.*.. d.,,

.c

. =.

a, i.

e.n:i

).

o t

, %..a '

.S.

i,5 i *

't,-

i g,

.g rf ee<

,, 6

-;., ;, /.'.y 4

.f

-

• g',

)

4 4..'....'

p,c gy:

4 f.,.

s j,

/

,,' x, '. y *.,,. ;, (l

'e s +

u..-

q.

-e

• , g *..'.8, m#

9'..-

s

..I

..-4 p-

,,**b*+

,g.

.. i l

y.

i

,._..,... j;.

,s

,(.,.,.44

,,...i.,-,..-,,,,.,_,....

4*.-

/

.,, ym ;

- s

.o

, <'e e*j.

'O

.p 3

-'1'.

.. l, {* *..

'?

.-[$..

'.,, 4 i

6

./_

,i

, _ ': t '

~!.,.

.. -, ' e : f..., %c 4

.r g3I "

j:-

1....

N"'.,. h..,,. r,*. - ' _

4 1.,

.s,.

g '- s.

~ ~. *.

,? --,, -

i

\\

O

- '.,,. g,f-4,,..

', ~. h,

, /g r

e<

4 1

, ;.,,~....:

x., %

,a v.

.,.., 4 ;. j.gp], fr a '.py.,,,

1

,,,'t A,d,

i. '- ,

'1,*

4" hA,

A,,,

o

'p, p[-,

y s

'/, *

• j,-- N,, \\ 1.

i '- 1*

. g f, y,}'.

,y

. Q, ;

b..

..: n,.'tyWl,

-'; 1l

. o., ; '. y, " { Qg; a.?,

pK

' e l-

' -;. : *y,cn.c; y

[~~.

..' ( '.

,c L.7.,

,3 j.

J.

y.,.

p..,,,.

...k

'*.,.(,'

... { ' f, j. [).a.

, a' p ;,',,,.'..

'l

.... [' ' *.,.

I 2

.f y,fi

..g.,,.-

. j j ' '.

. ;. ' '. c....,

(

.e'

,f I.

_..... ; - e q 'd),.. c, _.. -, ';

T.

q-

.r-f,;.~,y

.a

' f. *..

', M I,.**.'**

, ',, '.*.,..?,.

,,f].

.6 e ',4,,,

',8

' g ' '., '

','[

i; ;' _

y, ' ;

' '., / '.. p.,

':' p. Q*'ye ' ' ' l: ^.;..f l3

• 4

.i y, ' q ' ' % '"%,. ' f,3,' l,, '*bh ' W A 'h'., ' 'j.. %.

',. %

i -

I '., '. J. ' ', o

.,)',

L*

~.

'. ' ~

G

(--

F u

l[l.9 /..;*.' '. '. -

f,,

g

,'*,.',y'

• , )

,,.,,./..i i

• '3 t,,.,.,

'y.

j ;

? j, @f,; :; -

- { 9 '.p a,u,*

?'

1 li 8 i., p

..,L

.g.,

.'..,,. g ;. <. - '

~.

s'i A"

,.v

,g,

..r

-'N

.. ;; -.+._,,,,

.g*,',,; ', '..*

%3

k..

e

,a 1

'a

,j 6.

Dg.,,M.

as

, ***/

5 e

,..,',,e y.,

8 6.

..a,

g,

..,t

.n-

.a r.-

6.

a s..

e'

,.-,, e., j

..k o

,- ;.. ~

,5 5 -

, g-

,,{

f.

4 9,

..'.4,

'.'..2 t-3q "

.,,t

. O ',v, '

.,N

.. "[

j q 4. a-I,'e',

',.,'s',

St,.

)

.,.' ),,. ~. 4,.,4

=

,a

-g

, f,ik,. ' b [,.L

}. l*,)

+7

'.*.E

-' g*

'/, -

t',

a,

',' '. 4. ;,,,,*.J '. *, l. i ( h' k +,, ', l 'yl ',.

g -

• U ".

c,s.-

es i.

~

L,,,.*. o).,.,

,.' 't

.f.,,',:.<.,*'.~t'.

e'.

• =

s,

...t.

,t, t

o,.., e.v,

., =.

us

.,..g 4

_...i

.., 4 3

ef,.

e

,h

. f d.

q'

,1.

o.

4 ' ~ ',,,

',J'*'

6 -...

. t.,,.

,,.,.,.., +.

8 f.

,,. *,;j' 2 6

J,. ([,..,j,

t,*

+

. c

.t 5

g 7,

1

- 4 i,.'

3'

d..',,'

,Ype

.,.. ** g s.,

-'.. ~,.

• .o 1

'".r.

1- (, ;

.t i '} ~

e i -

,. ( '

,a a

. 9

,,s,,,

J.

/

,* ', i=-, f., *. /

,y. *, ;p

-.'3 n..,

-e,

.l, g

a j,,,,,

e

4.,,

.. e ;

, s.'.,

(

?*

, - ' i

,j'.,

i s.,,.. -....

.5 it f,

,./,-

-f e-8

• ),,

g.

-,5 3-m 1*

s,

,).,

l...,.-.

e 5

('.

p..

.s g

c..A.

L \\.

s,,. ~ '.

.J,. ',,

• I; -.

r

,e*

i.

.',f,',t..-

-),

,e

, '.}, '.i e..

6 4

],.

6 ..., '. -,,*

1 - -,

f

.c 3

1

,,,; a's,.,'

1

-I

,, - =,,

9.

,..,..-

s.

r,.

<y

' ' '.'.4

,o,

V' :...-,.-.

c.

e.

c.

- i....

.. :s[>

^

'ic I.. '.

's

.t a.-

...t

'.'M,,,

'./ j., **

..e

'.s

,g.

q w'

.r.,

J

, :. :l '.-' '.

. c. #.,

,s

,, 'z,_..'.._,r

._......-..f :-

3:< _ ;-_- u.

..e

.,y_

o

.. ~.

i"....

A.

p,

, g*,,, l,,.

4,.

4

. i,.,.

.'4

,,,. M...,,

P

... '., a. q - t, o...-

', i.

y,'

.t,.

,p*

,.'a'*

.s

p

,t

= ' '.. ',. '

,i.'.A'

'* I

??*

.W

. s.. 4,

.)

+

..i '.'

. : g.., ' ; 4

-i..,,. '., '..

.- '.. h....-

ayr..

s

+.

I-

• i, ' '

,v'y

.. i

- '.g

/

e

• 6,*

1

44. P _.,, ', - "

4-Ii

!=

t s

• ,s.

.d

,'.,'t, !*,

,..f i

4 e

,-, c

+

,'+,

L f*

g

,',s

.. 4 l

F o

g-

,e 5

s.'+-

,4, - g

',.,. '..4

,b,

,, c,

. '. -,,, '....,,g

.a,

.,,. *,.e

. *,!i n' * ';-.

.,,.... 1,. g.

• 4.

f.

• iq n

s,.

'e p

..t s*

e........,.

s.,.

• e-

.s l 'c.

c.

,4

'r, ', '.,

',s

,.*,,(4'

-,=..

4'

-,,, ys I'.

,4,f

',1., '. *,,. ',.. ',, '., * ', ' ' '*e.,, - * /, *,

.,. -, 51 e *..

(

j i +

,g 4

4. '.',... 4 C'-

, ;**j k-9:

,3.,.,<.

3' i,'1',,,

6,

• /

,j,.. -

.2 g-,,. N ',,,...-. - '

s

....t,',,*

.,-.,t

.,g*,

8

,~.

s, d.

,',1.

, d

',.i*,'.,.',e..',,,

,, 'j i,.,

..'.'.,7,

+

g

. e

-.. i' t

,e g.

-9

., :,e f ; Q l... < ',,,.,, ;.. h',.l ' I

,,..p,,....

',.. Q.,'..7 [

1,,e 4

y ;,.,

3 3

..,.b j

{

/,..;....,

([

,... [

1 p'.. '

' 5 ; },.,. ?,,

Lc,' -

f.l,..,,$

j

' - -a

..;'... ' -. ;, = 1 -

f.

-. :s '

s.'

~:

?-

. ;, '.q.1;

'.',. 't A. ;,,n-.%,-'

if,'

c

',.('

+

,..,;,k.,.',....,.,.,.?.'

'7.

4. g,.,... > 4

.i ;.

.s. 1 :,. - '

.r.*i

.,-. *,..p. 6, **

t f,,

?

4;./-4.'

-,f

%. n.;

\\,. 4..i t.

+9,..

- e.

.4

. - -..i s

,,i a

..t

.c p

. j,

..,y

?

3 4.. :,...

.g s

J..,

,,.s.

4 ~..

,.i - ;f,, '

,r j * ) ;' a,

e ',,.a E.

f!'.

i,,.

• '[

'[.t g,.

g'.+ ',,.o

.c g.,'., ".,,

,.i'/,,' f '..'.

l,

' l,

.,j,.

.,.,N,. 3., -4

. s,. + -....'.;, j. - -i-

,. i., }. y',. i.,...,.,,c

.<s..

. vi p-.,..,.ss',.

e e -

l.+q ; -

.e q-

.,. 7

• a.

+i.

.,y..,;;..L-

..,,,.. - ;. d :g-i.,,s 4

c.,

• e 4,

4,.

. ". : - t s

J

.e.

.. r (. - ;. "r'. 3../ '., 9.-,'.i,*L'-

, :c

.hs.

.. c ',;,

-.;..... l,.. j *.....

y, m. < 4 '., s -,W..,- i--

,n '

.~

.7.

g

?

,.. c ', 'e,

• ...., =

.,v p, -

., c, n..

.c

.. ;.. :. yV '. i 5,,

,:....i.6.,',l,+.

. '.;: '*, i ';...

.p.

p, /'., -,, ( {,

l j.,t.g*..

, p

, z',',; ;.,L

.,'+8;

\\

h

.,- +,., '. - ;,.

.li..'

.,*...,5.. st 4, c 4.-

,,,s nr

• g.,;,.,,q,g '

.t e

.,,;.,, ;., f

• j p, > S 4,..,,6.,,,-

y.g (, 3,,i, v..

=

1

,,...,.*i..

. g#

y, r,.3

• e 't.I, g.s b,

t,

,,I, c

t t,...,

.sc'.

g4,'iA.,..

'.,.,,. -...., 4 y

,.,..s..i.,.-

t'.Of

.t

(

.4.

...o - e

.s ,'

,d

• L,c-,.

','t,.-

i.-

.y

.,g

' ' k \\,' g+ +

. f s

..5 9,,

- 9 ' %p,a;. e. gt',J. a '. -

--W {.. g a T.

f-t

..'s.,

t 9

C i..

48*'...C.g'..i "s,,*.,

g. ',f

.5.,

,o,',

3

=

j",'..g.

9, ei -

..4*

• -f,,,,,..

.., he

.'y

'G,

c. (,' -

4,-

1aaj,,'4'

,,..e

• ,,;g j

e

,.s.,...,.,,. t

,-)

4

,n.,,

1..4

.1 g j 5

] ' c'.

4, q,,,.. ;

.. g. s

,y,

<C,

.e,,..

s., y ;,

.g,,., y, 'l.. - ',*.,.p b

g

• a,,.

.l,<

' }: U, ;,.-

's ; ',',**

.,(.f.

, y c,

3. t.

, '..'g

'.,.y,..

-,. l' b. ',l 1.H J. ' y '. 1 g '. #. 1,.

.'**'O

..[ ',:..

s s c ). ' ;;'

m ',E.

g 3,

' '.'...l,;,}', f,, ' c,,:E,. - :.T

,7, '.;v.3

'i :.'; y,,', ' t..s..",i.. ;, y, ',..,...... -,.

..a,... * *j-....

'l,..'.,.).

,'s " ;. '..'

S

.* u

...ae

,p' k,* [e {,f$,, s.4,..; e,. ',, }

.. e.

u -.d....:... -.,.:....,.

e,f

, I ',4.,

-.)-

,,h,,-

.e

+

5<

..I,,,(

- '.,4't- - '

y.e.o, 1.* -.; % '

d,. '.#,

',.,4...',.,,.!

f h,, *

,s-x -.. N. j., g * ***2

-4

• * -J. '., I 'a u w'h[.. *,.,

s..

s-i.' \\.' C,si -,.

f,.,.c.'..',t, J,(.,

'1,a,.

W.' )!. r '(,%. o i.', y., W :.,.,q*l,.

4/.

,. ~..,

i,

t;

.m....,

..< v.

. T'.

.,$+4.,<,..,..,. s..

q '.. N.. n. '.L

'%'Y '%

Q..

..,.s.

1.

....M.. r,.,ty t s.....

s...

<.. i Y'.'.' 'y *,~'.i ?. ;i,*.L '". ' ' l: '. '

r.,

. i-.

n-,

4'i

' - j.

a

...a y _ '. f _. N' % a x,. L.' f' '. '!, W'

,'$ ', ' ', ' ;"*',N' ', s).' ',I*

f...

>,.: ;.'{ j. 'tAe 1 *

- +'

'. ': * * ! 'M,*

0 ^;,.

.,. c

. c

.. e

.n +.:c.

. :w o

[e, -0, M

I

--k

'I.

'4

[..,

1g',

g,

9_

. x ', 'b

, y s.,,e

, p.. ; ',

'p

}

jg,q

.e 4,Y.

. a.m..u:.e y' a

• g

w..,y u,., g

, A _.,, 3 +,y y q

,, ; s..,.....s.,,

.....c;

-. s..x

.2 [

. C, [h'h *e.$.h.[;[;.h

'.[( h N.;,'M { jh ' M.. [i (-1'; k.' ' ),[3 f ; " I (('.,M.t.. - f'i'd ). ' :[. ' ; 9' dJ-l

.. %.,.,.,w e.y.y.x. c.v ;. ;..... a. c.a.,, %. s..%. m,< s./; 7.x.

r..

y.; ~m,. :.o.,.e. ;. %

y. g. ; s.,,,,c..... %.. x.,. ;.?. m 9.8,; n.. A

.4> 3.,.o 4..,.....3.. ' a; sw,.

.n

. ~.v

. c

+.

.s-'

u<. ~e 1.,.,. *. -

.. r

..r

-,. ;.; 7..s.--

...r.-

s '

%a.

. ~2, n, ~ ; p >r-

\\.,...,..[ e. ~ s.. q..x3.. ';,. J i.

% h

. 'w. s. - -

:,p..

c y,m > p[Ji.

.i: a

::.y?

,.. n.. ;.st. j4' :,.., s.. ;rf i

.)

g r" +.4. ; t } q.cA ' c :. a...

&., c v'

m -

,G. v;'.N]y,. 4. s;1 J'.,y

. ;..f v

r L. i..

c.,

a yd.r.g.. &j;', &. y.4 v.'!

..,r ; v..,. M,

y.

p

+..

e s-

x;

.....q c 9 i

. 3 7

y.n v. o 1x

, f; <l 1..' ?y% M

,,c,

. a. m g' :.M. x ' ;e;' W: w. +f,j &. y+g; sm..<.

61%.,o;.

,,r..e

• , V::& '. $..... ;;

n..:.. ; 1 b P' M s.r*.a.%

M ' tM.* A..x :: n[. ii.Q;>.b,, 2:y.:. ;$*^ " h.>2 ' V.m r. c '1 -

y:

3.. z..-

p w. n %.M i~ n. ;.c.y'

..,s 4

. G.e 1, :.7

..y;.>.s,.. p/. p3 n

'c.

7 v

e.

s:

m u. m > :.;.

a Y

@h5:$QMMMM$$$.Y.% & $.5MWQ%$$dMg kh