ML20101D326

Office of the Inspector General.Semiannual Report,October 1, 1991 - March 31,1992

ML20101D326
Person / Time
Issue date:	04/30/1992
From:	NRC OFFICE OF THE INSPECTOR GENERAL (OIG)
To:
References
NUREG-1415, NUREG-1415-V04-N02, NUREG-1415-V4-N2, NUDOCS 9206120319
Download: ML20101D326 (41)

Text

{{#Wiki_filter:f .t: l}ff{j- ' g,- ff"~j,; ~ f,4 y~ [j - '~~' ',, d )\\g!' i}L& a

• T 5g

,y, NNfWig gg s o,,

l y,, t km ) sg O, b'lll;,!1,ll ry 3q d g-[i;.

• ~~

3; f hys*. r T&# 5 ; n -, t J ng';/jte ^J g $ y'lVNkpJ 'i2;,; ~ - ~

a 3 -l*

6..

. *i

• ~'

sr-- .g, n. .. ( .' ee :,

y

',b p

_.g,

,,. o ../ -,.,, 9,,,., u ,~, .. -...f.

., '. t. '-

V,, 1. s.. .,g

1. Da.

y s-s= , \\, ~ i i

s.,...-

./, ,. =,.,3 - q i,... h " 0. ,' g,. >, -.-. i C, 4.'* c.' y, P N, , *(/b8*..J '. ; 4 ';.,. s .,,. i,.. -,

7. : s: m.

.:. - s .4 4 v2 i. 1, ...;, ~. v .yr, - 'g ^ t 1.. ) y ). 'I ( J l ' ,x .) j n.. ., "; '.., f. .~ ,f ,0 v 1 ,l 5,..,,h 8' ~ '.....,.. -. -, ',,.," ',- g..- m t.' l'- ,, ' ;;, 4~.....,,, . - l;*. ~. - 1 - + 3 s ..t .v. 9, i' ,s.

, j p.

..,,.j- .t

i..

,,. 3..

• ,.. ~-

4. M f' E ..,/...'..,;. . t ...;,..r. -.....< s. ,. '... ', J. ; o.. e J., L ? [ .. yv. t I .'i,.. d l,., 4..+' 0 ^ yg,,, ... - ' y...,_ p .[ ',! u, <go 3, y-Jg.i ..'. l 3. - y . f.. .; a y,;c, .s . is .T<. ; ' i.

• i

.., 4' F n w -, 0, t g s.., 4 ;,,.,., ,~ ' , \\. .) \\ - ' '

• h.,y, ',,'. 5 ','

'"h ' s !,t '. '. , q ' '; g' ' '.Y 'f n - (,.). -j l7. J

{ :..

'*s r. j., s , D.: ,p - ). .J hj,[",. ','. i _ * [ '.g };(,, 33

g,g ;;

'., i

• 9.

p I,. c \\s ' n. ~ .. n. 9 l4% ..i * .l '". ' ,f' ' u .k,, , ?g,e 4 .t f, ", -q* q

• /.. ' '.

,jg f O ' e ].' eI,' J &f .'f 3 i[ '.'} J.', U.$g d.7. - - [ Jh...h. ) ' H'.[ i f,. . $h 3 .'[. a.~ u a ~s x

* ?

8 .x, s. s. -.,, g,,.., t... .m r e- ',[.# T f ,. -,.,..y., n I g-s ,n.

4..

s-s

p. ;

c.., ( . i ;.. - 0,. ..o .%,7., ', ,4.- b ;) ~* vQ ' q ..,, g., ,~ .'r.:,- , J_ ! q.n.. ),:. .. c;.f : b g' - (' [L.,.,. q..... y L.'. y 1 .s.,..,y e. '#,','...a,.

• -l' 8

-,,, ~ :... j, ,f i. 'e ,s- , p A,( ', i,,. ..N la e- , g. f. 1-. ; ' r. ) ', ', 3 ,. he. - .4',<e if o. ..,l' 'l.' ~* * h g  :. ' ..'g, ~ f.7.. f ',, ? - ' 'I k** c

- 3*,-

9., .;g, ' <, a r e .,,;[.*,..', '. j qc. ..- ~., ;. ;..,4. .y-n d ',ed. [' ', ' ;' ' f .) i * 's 7. \\ ;r.'. (; .j' * ; p _' ..~:',a , ' 'r ! n ~1 *., ,. y [ g -i,T

?'

, [ y. ' . ' - ' ' '. '... f '. '. *c, ' x. ,) .*: ' o ,'. i [.,..... g, - 3., .. j.; 2; - gq 4$ ,,. h,., + '. gw.<... * * { -) 3 y, ,g '* 3 .,e g .y. .',I' 1,J '. , l.- -. 7,, d .v t e. r I . ~ . b4 l' - L. '.. w. [... ' v. ' .; ; ;.). ? j T ' '. ^ I ; 7. I...

y. ;'.ll,,

_., y., ;,

• p

= ,,c QG..... o a .,,, y.: ; r f,,,.; ...,. ~. . s. e, ',.' s ,..s, ,;i,,','....'I',.,':<,.e',g+ .hi,,, g '.3,',.... 5.-. .,-*.i...,... 4' ,1,i.',',,,,. ..,s s e - , i, + .i

• • k'

,i,, " .+, ,,,\\ F'. F ,, -s g..' 3, .w; ..' j* h '[ n, r E .j.,, %,.'*,(' t,.j, Q. '. J ' ' [Mi ' ja s..'.., *.,,.j * '1 ' g,y ( e '*t.. i .,o , =,,- (g., .e 9 g, ,/ q ,g ,. *,,]g ' -E S,. [ '.., a'I', ';I Y'..,' 3 / {.,, ", g :.'. ' E. f,.'. J,,, 'P g 8, ~ u,-+.a \\'.fi,. ,, f,' . *.. -,:,-, it -1 4 1 2,. . g. .; _ a p, ','s. $[.. l [ ;,, I,~ ,4 i -. * \\L:..., '. : L Y.' 'a u u ~. ?., a', m+- .l F . S..,. '..,.,,,

4,

- 'a sa ,',.*..,).;s.,,',[ ] ] '!f '*f,.,./,.., y,,7f v - e .) 7' i ;, i f ;.,, ; '.L, l ',. [ g

• 'y

-? - :;; I... y, _..,., A ~-.,.. j s,. - (;,a ~.; O.i ;...<.'*

A 9

,f ' -? j.,,,' *.-.. ' ',4,,, 'q , (, ' ;, .,.., e J,,., .- '.4 I', '..>/'.,.'y.',*.,,.4 - /, '. i., p C ', ',., ( ..' [, l d ' * ".'.[ ,..[, ',,' ),y O% I ' L % ' [. [. '., ,,6 3 J, ( ;., #-; (, ,Q y 1, 3

. W W.i 9

% % #m.w.m.w;. M M, QMARCH3&g$yu%n%g;# twn v. .w, m.m.e em%;e ca w.m.m.m.e.,. g. d,.,.,.n c, w .;.m. t .g a y. 3 w. J. o.3... a.g.

v.. g. g..

n 3 y j g ..g., l. x., .. y. p. .y -a e a,.,. .) 1.-.- '... f. 4._ ,,(,,,. [. e.. y a. p 5 ,3,.

Munon,movu ro run cu,unu,w I am pleased to submit to you this semiannual report on the activities of the Office of the Inspector General covering the period October 1,1991, through March 31,1992. This report is submitted to you in accordance with Section 5 of the inspector General Act of 1978, as amended. The accornplishments described in this report represent the combined ef-forts of the 010 staff and the U.S. Nuclear Regulatory Commission (NRC) man-agement. We sincerely appreciate the agency's full cooperation and suppor t. We look forward to continuing this r elationship in striving to achieve the highest lev-els of integrity and efficiency in the programs and operations of the NitC. Sincerely, & aivute C % L David C. Williams Inspector Gencial

ABLE OF CON 11sNTS p ntou, +

• • +2 EXECUTIVE SUAfA1ARY 4

THE U.S. NUCLEAR REGULATORY 7 COhihilSS10N THE OFFICE OF THEINSPECTOR GENERAL 9 THEFEDERAL AfANAGERS' FINANCIAL INTEGRITl'ACT 10 THE AUDIT PROGRAhi 12 THE INVESTIGA71VE PROGRAh1 20 REGULATORYREVIEW 27 OlllER ACTIVITIES 28 SPECIAL FEATURE: NRC'S OFFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA 32 APPENDICES 34 AUDITLIS11NGS 34 1 ABBREVIATIONS 38 i GLOSSARY _ 39

Execurive svuuaur A UDITS During the past 6 months, the Office of the In'.pector General (OlG) issued 7 reports addressing the NitC's programmatic and administrative functions and reviewed 49 contract audit reports issued by the Defense Contract Audit Agency. This work resulted in five recommendations to improve the efficiency and effectiveness of NilC operations and the identification of over $88 thousand as funds that could be put to better use. An additional $42.4 thousand was identi-fied as questioned costs llelow is a summary of selected findings. 5 The 010 reviewed NRC's oversight of the new commercial 1acilities man-agement contract for NitC's One White Ilint North building. The 010 con-cluded that, in general. NRC has adequate contract management controls in place but that insufficient attention has been given to two areas: quality assur. ance inspections of contractor performance and the implementation of the Emergency Protection Plan. E The OlG conducted a review to determine whether NRC had improperly withheld employee health benefit payments from IlealthPlus of Maryland. The 010 determined that the NRC's procedures for withholding both employee and Government portions of health premiums in this case were inadequate and not in total compliance with Office of Personnel Management (OPM) regulations. xine.me reint su. T2 """?"i ~ '? ?" ',^ ? ='"'~% V*v ~" drar Station in Scriba, W /*l.l bfW N8fk. g % ?J -- 4'

nglQ$0.$$$h,.

N" -.g_., .g. .,y.

q. i; :.;p p 7 n-f,1 g

~ J.T l %,j ^' ~ ,4 .9 Y. \\ I r. w& 2Gi Y E The OlG reviewed NRC's reporting of contracted consulting services as r e-quired by Office of Management and lludget (OM11) Circular A-120.The OlG 4 ~

determined that N RC did not report all consulting sen ice contract actions to the Federal Procurement Data System as requited. Ambiguous language in Ohtirs guidance documents appeared to be a factor in NRC's reporting practices. O -The 010 assessed the NRC's Safety Issues hianagement System (SIMS) to determine whether the system's database was complete, current, and accurate. The 010 found that the SIMS database was generally complete and accurate. Ilowever, additional quality assurance features are required to maintain the sys-tem's reliability. - O The 01G reviewed NRC's process for licensing the use of nuclear materials in capsules at a commercial irradiation facility. The 010 determined that in ap-proving the use of these capsules, the NRC may have depended too heavily on i the Department of Energy (DOE)in carrying out its regulatory review activities, especially in its reliance on DOE's testing program. O The 010 assessed NRC's compliance with the provisions of Public Law 101-121 (the Anti-l.obbying Act). The act requires that contract actions for i amounts over $100,000 contain specific certifications and contract clauses. The audit revealed that NRC was not in full compliance with the act because required contract clauses were not included in all contracts. O The 010 assessed NRC's compliance with the Federal Managers' Financial Integrity Act to determine whether NRC has established a program of continu. ous evaluation, improvement, and reporting for internal control and accounting systems.The OlG found that the NRC generally complied with the requirements of the act. INVESTIGATIONS ~ From October 1,1991, through March 31,1992, the OlG initiated 40 new inves-itigations and closed 43 cases. As of March 31,1992,45 investigations were in progress. 010 investigations led to 10 referrals to the Department of Justice and 51 referrals to NRC management for corrective action, lirief summaries of se-lected investigations are provided below. - 0 The OlG received an allegation that an NRC employee had improperly claimed excessive amounts _of overtime, The OlG's investigation substantiated the allegation and uncovered additional false claims made by the employee. The employee was later indicted. 0,The OlG received information that an NRC contracior employee had ' fraudulently used an NRC employee's name tnd social security number to ob. tain credit cards. The OlG investigation substantiated. the allegation and 5

e revealed other fraudulent actions by the employee. This employee was subse-quently convicted. 5 The OlG investigated an allegation that an NitC inspector ignored possible security violations because of a friendship with a plant executive. Fmtheimore. thisinformation wat allegedly brought to the attention of an NitC manager who not only failed to take action, but who also disclosed the alleger \\ identity to the NitC inspector. The OlG's investigation did not substantiate the allegations concerning the manager. OlG did not conclusively determine whether security violations were overlooked. E The OlG investigated the circumstances surrounding the July 1901 emer-gency evacuation of NRC's of fice building in ltockville, Magland The pr esence of strong fumes led to the evacuation. The fumes were attributed to a concrete curing compound used by a construction subcontractor. OlG determine I that the subcontractor was improperly supervised and that the N RC contracting team did not adhere to contract provisions concerning the use of hazar dous materials. E The OlG investigated the accuracy and intent of written responses supplied to Congress by the NRC regarding the welding and radiography program at the Seabrook nuclear power plant. The OlG determined that although there was no evidence of a deliberate attempt by the NRC to provide f aise or inaccurate infor-mation to Congress, the NRC responses were flawed and contained information that had little factual support. E The OlG referted three matters to the NRC's Deputy General Counsel for Licensing and Regulation for consideration under the Program Fraud Civil Remedies Act.The first referral concerned a false statement made to the NRC by a materials licensee during a licensing action. The second referral concerned the investigation of a senior resident inspector accused of making a substantial number of long distance personal telephone calls at the Government's expense. The third referral concerned an OlG investigation into an allegation that an NRC employee filed false claims for overtime and reimbursable items. 6

Tusv.S.svCtuanasouvirOar COMMISSION The NRC was created as an independent agency by the Energy Reorganization Act of 1974, which abolished the Atomic Energy Commission (AECj and trans-Drred the AEC's regulatory function to the NRC. This act, along with the Atomic Energy Act of 1954, as amended, provides the foundadon for the regula-tion of the Nation's commercial nuclear power industry. i ihr NRChea4uartm f v)) re in Rm LriCo, i. Maryland. i; ) qjl .e* !Wi OI:

• e.s.
• g wk lQ (yyp s**Y e

N ges#, @ fl psR* gyy/b: (n g a s #' a aus a ti 4g 6 sea; W r~!$n : 4g a s s! l 4 e,4 a s _m. g[f ' ses' s gf ..1 hij gg ' * *} + M an v m The NRC's scope of responsibility includes the regulation of commercial nuclear power reactors; research, test, and training reactors; fuel cycle facilities; medical, academic, and industrial uses of nuclear materials; and the transport, storage, and disposal of nuclear materials and waste. The NRC carries out its mission by setting standards and requiremenis that licensees must meet to design, construct, and operate safe facilities. NRC's standards and requirements are specified in rules, license conditions, and regulatory guidance. The NRC inspects facilities and takes enforcement action, as necer"try, to ensure that these standards are followed. NRC also conducts research to support, confirm, or refine judgments used in regulatory decisions. 1 7

i 1990 Net Electricity Generated in 1:ach State by Nuclear INmer ?.f-i f wA ~ x.. _ m I g i ~m MT n .w 3A / on 1 J t y ,x -. ~ _ _ g ~%, _ wi. t t g -4 '~i i 53 Nl Q Wi i l{ \\ yf \\ 4 l ,,, W & j% i

w. +j

/ G,g y g. ) I i n. - c w i m L

• , \\a

\\ w I l Y f.. __

\\

l g Od,h]dr us n! g \\ / to l 7 % rw CA {4 (( ]y QEV 'f UO 4 l % s J l l p_ 93 ' dA At -J; S -a y tg _p}'c um s ) .w, 1 ".a

4(

)y 7 E More than 50% (7) /' $[\\ E 25% to 50% (11) 0 1% to 24% (15) U None (17) Notcr Percentages are rounded to the nearest whole number. There are no commercial reactors in Alaska or llawaii. Sourc Nuclear Regulatory Commimon. "Information ihrest." N1111EO-U50 ) l To carry out its mission, the NRC is headed by five Commissioners who are appointed by the President and confirmed by the Senate f or 5-year terms. One Commissioner is designated Chairman by the President and serves as the official spokesperson for the Commission. The NRC staff, headed by the lixecutive Director for Operations, carries out the policies ard decisions made by the Commission. The NRC has approximately 3,300 full-time employees in the Washington, D.C., commuting area and the five regional offices located near n'hiladelphia, Atlanta, Chicago, Dallas, and San 1 rancisco. I:or fiscal year (FY) 1992, the agency's estimated budget is $512.5 million.1 1tLS. Nuclear Regulatory Commission, NtiltEG-11% Vol. 8. "lludge' Esumates for t hal Year 1Y0 ' 8

Tus ovvice av run insrucron GuNuRAL The NRC's Office of the inspector General was established as a statutoly entity on April 15,1989, in accordance with the inspector General Act of 1978, as amended in 1988. It is one of 26 such entities within the Executive tiranch.The Inspector Generalis appointed by the President of the United States with the advice and consent ef the Senate.To ensure the independcace of the office.the Inspector General may only be removed by the President, with the reasons com-municated to both the llouse and the Senate. NRC's Inspector General reports to and is under the general supervision of the NRC Chairman but operates with independent budget authority. v0 -m. OlG auditors i1ma Allen. ~ Fen Leily.andJudy lan-m *=~ hards daruss p=rvgrarn is. 5Wl? sses wuk hRt' Regwnal Gl R q& 3 a d...u,,,,,,, 3,, ar, g. 11,arter in Adaasa. Geor. QL l&l?@d, ~ p .,L 3 , A, V b j adinMa u. 2. ~ One of the primary goals of the OlG is to assist the NRC in operating more effec-tively and efficiently by identifying ways to improve the NRC's programs. To ac-complish this objective, the OlG conducts agency audits, inspections, and inves-tigations and makes recommendations to NRC management as appropriate. The Inspector General has oversight responsibilities for the efficient and effec-tive operation of agency programs and for the conduct of NRC employees and contractor personnel.The 010 generally does not have oversight responsibili-ties for the conduct of NRC licensees and a,,plicants.or their vendors or contrac-tors. The NRC administers this program through its Office of Investigations. The NRC Office of the Inspector General was authorized 37 positions during FY 1992 with an estimated budget of approximately $3.7 million. For FY 1993, the OlG has requested a budget appropriation of approximately $4.6 million and 41 full-time equivalent positions. l 9

Tau mun,1uun,1Gunswuncw 1 INTEGRI'lYilCT The Federal hianagers' Financial Integrity Act (Fh1FI A) was enacted in 1982 in response to continuing disclosures of waste, loss, unauthorized use, and misap-propriation qf funds or assets associated with weak internal control and account-ing systems. Congress believed such abuses hampered the ef fectiveness and ac-countabilityof the Federal Government and eroded the public's confidence.The Fh1FI A requires Federal managers to establish a continuous process for evalu-ating, improving, and reporting on the mternal control and accounting systems for which they are responsible. The FhiFIA contains separate requirements for evalusting Federal agency in-ternal control systems and financial management systems. The results of the OIG reviewindicated that N RC has generally complied in a reasonable and pru-dent manner with the requiremen's of the PhlFIA, Nuclearpower plant em. ~"a,_,,- ~ ~~'** ployers monilot plant operatwns. ' b h./ k ' M . yk,,...sf',-"k' & n. y {g,y t y3 gn ..g g:fmg?

• y

.Ma**e. s + s / ' s e - tuM.., ?;

• .. l a ia,gi; l

m.g n.-..__ M.. $?Mh' QQ;ghg;% $s ~ {<' .j% % dims!$$h. Ic im w in the area of internal control reviews (ICRs), Oh1B Circular A-123 requires agencies to develop a management control plan (h1CP) or a set of plans that would be updated annually. The h1CF describes the agency's risk assessments, planned actions, and internal control evaluations that are to be carried out to provide assurance that the FMFIA is being implemented. In 1991, NRC re-viewed 16 of a possible 18 assessable " units" scheduled for review. '1 he OlG re-viewed all of the reports issued for these internal control reviews. OIG aim 10

a:sessed the available supporting documentation for five of the ICRs and dis-cussed the reviews with the individuals who performed them. Ilased on the re-sults of these reviews and discussions,010 believes the reviews were performed satisfactorily. In the area of financial systems reviews. OMil guidance sets out a review pro-gram that includes a combination of three elements: (1) application of existing knowledge of the overall system,(2) a limited review of system components, and (3) a detailed review of the individual systems. NRC performed one detailed re-view and five limited reviews in 1991. 'Ihe detailed review was performed on the payroll management system. Limited reviews were performed on the accounts - receivable system and on all three modules of NRC's integrated financial man-agement information system: travel, Government / commercial, and budget exe-cution. A limited reviewwas also performed on the payroll managemergstem; i this limited review served as a followup for the earlier detailed review. 017 as-sessed the findings for all of the reviews conducted by NRC and discussec ik + review procedures with the individuals who conducte.d the reviews.11ased on the results of these discussions and the assessments of the supporting documenta. tion 010 believes that the NRC financial system reviews were performed satis-factorily. - The OlG also examined NRC actions in response to recommendations con-tained in previous 01G FMFI A audit reports. In its 1990 FMFI A audit report, OIG recommended that NRC's license fee billing system be completed in a l timely manner. The system is scheduled to be implemented in FY 1993. The 1990 01G report also made four recommendations regarding NRC's financial I systems review process. The OlG noted a number of weaknesses with NRC's A-127 reviews, particularly concerning personnel training, quality control, and - l scheduling. NRC took corrective actions in 1991 to address these weaknesses. Preliminary findings of an ongoing audit concerning contract closcouts, how-ever, suggest that agency corrective action is necessary in one other area. The OlO noted a large backlog of completed contracts without the required closcout reviewsmandatedby he Federal Acquisition Regulation. After the auditiscom- 'I pleted, the OIG wil! pident its findings and associated recommendations to the appropriate agency afficials. v. f-11

__.~ __ _. IILLAUDIT PROGRAni In a presious reporting period, the 010 made several recommendations to NRC managemcyt tode:er the unauthorized use of the FederalTelecommunications Splem 'lhe NRC it resiewing the cost-effectiveness of the OlG secommend 9 tions and is esivcqed to complete its study in June 1992. In addition, the 01G pruiously recommended that the N RC develop an automated license f ee hilling sywm. NRC ;s ir, the final stages of developing the syste m, with co.aplete imple-mvntation upected in early FY 1993, During this iepoiting period, the 010 completed 7 :mditsadd essing the NRC% administrative and progranunatic functions and resiewed 49 contract audit re-portsissued by the Defense Contract Audit Agency.These audits resulted in five recommendations to NRC management and the identification of $8SA58 as funds that could be put to better use. An additional $42A22 was identified as eyestioned costs. Summaries of the internal audit reports are provided below. AllDIT SUhla1ARiliS Review of Cornmercial Facilities hianagementfie One IVhite Flint North The NRC usescontractual senices for the management of its headquarters of-fices at the Ore White Flint North (OWFN) building in Rockville, Statyland. The OlG reviewed the adequacy of NRC's controls over its management of OWFN with regard to (l) the approval process for requesting management serv-ices,(2) the evaluation of contractor performance,(3) the acceptance of woik performed, and (4) assessment of the reasonableness of selected contractor charges.The OlG found that the NRC generally has adequate controls ir place over these four performance areas. Ilowever, the 010 found two areas that needed attention from N RC management: quality assurance inspections of con-tractor performance and execution of the timergency Protection Plan for OWFN.The responsible program managers have initiated corrective actions in response to the deficiencies noted during the audit. NRC Improperly IVithheld Employee llealth Hemfit Payments Frinn HealthPlus of Alaryland llealthPlus of htaryland, a participant in the Federal Employees' ilealth liene-fits Progra u (FEllllP), submitted a claim to OPhi alleging that the Federal Government owed $2.4 million in unpaid premiums for the period January 1, 1988, through December 31,1990. The NRC's share of the alleged $2A million was $1,550. At the request of OPhi, the OlG reviewed the IleahhPlus claim to dete.mine the validity of the claim insofar as NRC is concerned and to identify l the causes of any nonpayment. i l 12 ) o l l-

OlG's resiew substantiated approximately $1,200 of the $1,550 that IlealthPlus claimed was underpaid by the NRC. in its review,01G found that two factors contributed to NRC's failure to properly submit health iasurance premiums to OPM. First,when an NRC employee enters a nonpay status, NRC stops forward-ing the Government's share of the employee's health insurance premium to OPM until the 'mployee returns to work. This action is not in compliance with OPM regda6r, which require agencies to continue forwarding the Govern-ment's sharc of an empicyee's; mmium to OPM during periods of nonpay status. The OlG also found that the N RC drJ rv.n follow sound accounting procedur es in that the NRC haa no provision for an account rcteivable ta handle the accrual of an employee's share of health insurance premiums due. To ensure NRC's compliance with OPM regulations, OlG recommended changes in the NRC procedures for collecting and forwarding employee heal h t insurance premiums to OPM when employees are in a nonpay status. OlG also recommended that the NRC ensure that employees remit their share of premi-ums incurted while in a nonduty status and that NRC promptly forwnd the G ov-crnment share of premiums to OPM. Review of Contractingfor Consulting Scryices Public Law 97-258 requires that the OlG report annually to Congress regarding NRC's use of consulting senices. Office of Management and Budget (OMll) Circular No. A-120 sets out policy, responsibilities, and practical guidance that specifically require agencies to (1) accurately and completely report information on consulting services to the Federal Procurement Data System (FPDS) and (2) establish effective management controls relating to the procurement and ad-ministration of consulting services. OlG's review assessed whether the N RC was in compliance with the provisions of OMB Circular A-120. The OlG found that NRC had not reported to the FPDS all consulting service contract actions that occurred during the first 6 months of FY 1991. Specifically, OlG identified five contract actions that met the consulting definition and that should have been reported to the FPDS. Ilowever, only one of the five actions was reported. NRC officials explained that these discrepancies resulted from dif-ferences in the interpretation of ambiguous OMil guidance. OMB has recog-nized this problem and has proposed a change in policy to correct it. OlG also found that guidance for seven of nine management controls required by OMil Circular A-120 had been developed and implemented. The N RC is de-veloping guidance to implement the two re maining controls for wor k placed with the Department of Energy's (Doll's) national laboratories. 13

1 01G recommended that the resiew and approval responsibility for all project l management guidance and procedures developed by program offices regarding consulting senices be assigned to NRC's contracting function. This centralim tion of review should strengthen NRC oversight. It will also provide consisteney in the procurement process and in the administration of work orders placed with DOE national laboratories. Review ofNRC's Safety issues Managernent Systern The N RC's Safe ty issues M anagement hystem (SIMS) tracks the status of safety-related corrective actions at commercial nuclear power plants. SIMS is used by the Office of Nuclear Reactor Regulation (NRR) as a management information system to ensure the timely resolution of both safety and regulatory concerns. SIMS provides NRC management with a single source of validated information i on t ie status of generic safety issues. It contains information concerning generic safety issues being reviewed by the NRC that, when resolveJ. may result in the - imposition of requirements or actions on licensees of nuclear power plants. The system also contains records of specific plant licensing actions. NRC has com-pleted a $500,000 SIMS "Get Well Plan" to correct errors in the SIMS database. OIG conducted a review to determine whether the AMS database was com-plete current, and accurate. Although the 01G fou.A Qai the data in the SIMS database was generally complete and accuiate, the SIMS "Get Well Plan" did not include the establishment of an adequate quality assurance program. This quality assurance program is essential to ensure the continued integrity of the corrected databsse and to protect NRC's"Get Well Plan" investment.The OlG recommended that NRC develop procedures for ensuring that all data is com-pletely and accurately entered into the system. Review of" Lessons Learned"Froin Licensing of DDR 1l'ESF Capsules NRC is resnonsible for authorizing the distribution and use of byproduct mate-rial in a seated source. la mid-1980, Ihe Department of Energy (DOE) requested the NRC to approve the Waste Encapsulation Storage 1:acility (WESF) capsule for use in commercial irradiators. The WESF capsule was originally designed and fabricated to store cesium-1~ ', a byproduct of the nuclear weapons pro-

gram, in _1985,after reviewing information obtained from a demonstration project and otherinfornstion received from DOE, NRC approved the use of the WESl; cap-sule at other irradiator facilities. In January 1986, the State of Georgia, an NRC Agreernent State, subsequently licensed a facilityin Decatur. Georgia. to use the 14

~ _ _ _ _ = _

WESF capsules in a commercial application. Two years tater, a leak was discov-ered in one of the capsules at the Decatur facility. Agreement States Apx i ff. WA. (ME ) r-~~.- -) rq f k - ND e.7 - VT,Ni / ut y, m 9,, (r D"[d 08- \\wi) ny j O s0 N, uA j ~~ MLJJQk$p g NE ,.a. / (nj vic . b1 [. ", T ~ . it IN o s' 'co .3 gy

. / g,m fyA

[ Qy . cA 1 xs-i 93 g;,- ~) nc., x? m -, a K N($017[ d OK EU A AZi~~ -;nu j _. 4 AR N W. ' N 4e -- At ~ _ us ; h,-/ %v ,. In; - .g3 L L r-a\\m'y ..TX ) t,A p m ~ A {c 3j N7 3)rt /.j w.,. 7 L 7 t) L . [] Agroomont Stato (28) E Notest. Data as of 01/31f/2, The NHC is currently considering a request from Maine to become an Agreement State. Ala,ka and flawaii are not Agreement States. Source: Nuc! car Regulatory Commission, "Informaton Digest," NUREG-1350 The OlG determined that NRC may have relied too heavily on DOE in its ap-proval for the use and regulation of WESF capsules. NRC had to rely on DOE regarding the design and fabrication of the capsules because NRC did not have the means to independently test or corroborate information provided by DOE. 15

OlG reviewed the post-incident investigations and found that Imli's Wi!SF program had severalinadequacies that may have contributed to the cause of fail-une of the capsule.OlG also found that NRC depended on I)Oli to conduct peri-odic destructive testing on the capsules to ensure capsule integrity for continued use by commercial irradiators. OlG recommended that in order to strengthen its regulatory effectiveness. NRC explore ways to lessen its dependency on other entities such as Doli, in par ticu-l lar, this goal could be achieved through increased use of independent testing and l improved quality control reviews to corroborate information pr ovided by appli-l cants or manufacturers of sources. Review of NRC's Cornpliance With Section 319 of Public Law 101-121, the Anti-Lobbying Act The Anti-Lobbying Act requires that the inspector General provide an annual report to Congress regarding the NRC's compliance with and the elfectiveness of the requirements of the act.To assess NRC's compliance with the piovisions of the act. OlG reviewed a sample of NRC's FY 1991 contract actions that ex-ceeded $100,000. The review was to determine whether the required tertifica-tions and contract clauses were contained in the contract packages. OlG found that 20 percent of the contract actions did not contain the certifications and con-tract clauses required by the act. OlG considers this to be an unacceptably high level of noncompliance, especially since the 1990 review disclosed no such in-stances of noncompliance. One possible cause for these problems was that the contract package checklist used by NRC personnel to ensure that all required l certifications and clauses are included in contract actions did not mention the certifications and clauses required by the act. l A UDITS IN PROGRESS N Survey of NRC's Management of Inspection Programs-OlG'slong-range goal is to evaluate the effectiveness of NRC's management ofits various safety I inspection programs.This evaluation will include assessments of both the reac-tor and the nuclear material inspection programs. The initial survey stage of the i audit willidentify the inspection universe, provide OlG statf with an understand-ing of the inspection process, develop information concerning allocation of in-spection resources by NRC management, and identify program areas to be cov-ered by detailed audits. E Survey of NRC's Automated Information Systems-The long-term objec-tive of this work is to determine the effectiveness of NRC's management of its 16

i r automated information systems. Through a series of audits. OlG will ascertain whether (1) NRC's automatic data processing systems are effectively and eco-nomically meeting the needs and requirements of NRC offices and (2) the infor-mation system databases are reliable and adequate to support management de. cisions that are based on these databases. ~ i O Survey of NRC's Research hianagement-OlG's goalin conducting this survey is to examine the effectiveness of NRC's research management practices. [ The audits will address procedures used to (1) select contractors and monitor their work, (2) identify and apply research needs and results, and (3) integrate these products into the regulatory process. O Review of NRC's Budget Execution Process-The objective of this review is to determine whether NRC's budget is being executed in an efficient and effec-tive manner.The review will include an examination of the methods employed by l - the NRC to maintain administrative control over its appropriated funds. The re-view will also assess the agency's ability to execute its budget vis-a-vis the origi-nal budget planning assumptions. -O Review of Work Placed With DOE National Laboratories-A substantial portion of the NRC's annual research budget is committed to DOE through con-tracts managed by the Office of Nuclear Regulatory Research (RES). A major l l focus of this audit will be to assess both the effectiveness and efficiency of RES L project management activities. This review will also address the extent to which RES adheres to established policies and procedures for placement of contract work with the DOE national laboratories; l O_ Review of NRC's Allegation hianagement System (AhtS)-The AhtS is a computerized tracking system used to manage allegations received by the NRC about agency-regulated activities. The objective of this review is to determine the adequacy of established AhtS pol cies and procedures and to assess whether i t the AhtS is achieving the purposes and goals defined by the Commission, O Review of NRC's Contract Closcout Process-The Federal Acquisition Regulation requires that agencies close out completed contracts in a specific pe-riod of time The purposes of the audit are to (1) determine the overall status of NRC contract closcouts and (2) review and evaluate N RC's effectiveness in clos-ing out those contracts exceeding $100,000. AUDIT TARLES The NRC's dependence on commercial contract activity is relatively limited. LThus, questioned costs and savings are inherently smaller than those reported by . most other agencies. During the reporting period, the 010 rev ewed 49 contract i audit reports. The following tables depict the cost savings from the contract audits.- i 17- ~ ~. _ _ _ _., _ a

J s Table i Office of the inspector General l Ileports Containing Questioned Cmts* (Dollar Value) Number of Questioned Unsupported Reports lleports Costs Costs ~ A. For which no management 0 0 0 decision had been made by the commencement of the i reporting period B. Which were issued during 5" 42,422 0 the reporting period Subtotals (A + D) 42,422 0 I C. For which a management 4 8.546 0 decision was made during the reporting period: e (i) dollar value of disallowed 4 8.546 0 costs ~(ii) dollar value of costs not 0 0 0 t disallowed D. For which no management 1 33,876 0 I decision had been made by j. the end 6f the reporting period E. Iteports for which no manage. 0 0 0 ment decision was made within six rnonths of issuance

• Table only includes reports containing direct questioned costs.

I. "The figure differs from number of reports reviewed because 27 reports had no questioned costs. I-g i .j ..f L i L. r18- ,-w' + i f. 4 -O y w -w w r e-w e w w -ae w - ~ e ,emer*-n w-=+w**-e

• " " ~ * * + " " * ' " " - * - - " ' ' ' " * " * * " ' ' ' * * ' ' ' ' " - - - ' - ' * " " ' ' " " ' " * - - * " * " " * ~ " " " " " ~ "

' - ~ ~ ' ' ' ' ' ' '

Table 11 Office of the Inspector General lieports issued With iteconunendations That Funds lic Put to lletter Use Dollar Number of Value lleports lleports of 1/unds A. For which no management decision had 1 11.347 been made by the commencement of the reporting penod

11. Which were issued during the reporting period 3'

88,458 " 4 W,805" Sublotals (A + 11) C. For which a management decision was made 2 27.785 during the reporting petiod: (i) dollar value of recotemendations that were 2 27,785 agreed to by managenient (ii) dollar value of recommendations that were 0 0 not agreed to by management D. For which no management decision had been 2 72,020 " made by the end of the reporting period 0 0 E. lleports for which no management decision was made within 6 months of issuance

• 1 ourteen other pre-award audit reports reported either tero funds w et c avail; ble for better use or no contract was ;; warded.

" Dollar figure contains $31,f 67, w hich is the average cost savings value f or a contr act that lias not been awarded. t 19

IlliINVI!STIGATIVE PROGRAM During this reporting period, the 010 received 135 allegations of misconduct. The office initiated 40 new investigations and closed 43 cases. Ten r efer rals were made to the Department of Justice and 51 to NitC management for corrective action. Summaries of ti'e OlG'r. most significant investigations follow. INl'ESTIGATIl'E CASE SLU1AIARIES NRC Employce Indicted Following OlG Ins'estigation 010 investigated an allegation that an NRC employee was improperly claiming excessive amounts of overtime. The employee's travel records were examined, and improprieties were found in connection with the employee's claims against the Government for furniture rental, car rental, house rental, meals and inciden-tal expenses, and private automobile mileage. This investigation also revealed that the employee submitted false overtime claims to the NitC in excess of 100 hours. The approximate amount of false claims filed by the employee was $ 14,000. The findings of this investigation were referred to the United States Attorney's office Southern Judicial District of Georgia. In December 1991, a five-count grand jury indictment was returned against the employee, charging two counts of submitting false claims to the NitC in violation of 18 U.S.C. 287 and three counts of submitting false statements to the NitC in violation of 18 U.SE 1901. These charges are currently pending beiore the United States District Court in Brunswick, Georgia. On February 7,1992, the employee resigned his position j with the NitC. NRC Contract Employee Arrestedfor Credit Card Fraud OlG received information that an NitC contract employee had fraudulently used an NitC employee's name and social security number to obtain er edit cards. Initially, t he c antract employee opened eight credit card accounts. Du ring OlG 's investigation,it was learned that the individual opened four additional accounts using a second NitC employee's name and social security number. This investi-gation revealed that approsimately $10,000 in merchandise was purchased with the fraudulent credit cards. The contract employee was arrested but subse-quently declined to be interviewed by the OlG. The individual later plead guilty to the theft and unlawful use of credit cards.The individual received probation and was ordered to pay restitution. The contract employee was terminated fol-lowing his arrest. 20 1 ~ ' ' " ~ "

GIG Investigates Allegations of Disconduct by an NRC Manager and an NRC inspector The OlG received allegations tl'at an NRC manager failed to take action when notified about possible security siolations at a nuclear plant and of related mis-conduct by an NRC inspector. It was alleged that the inspector intentionally overlooked security violations at the plant because of a personal friendship with a plant executive, and when it was brought to the NRC manager's attention, n^ action was taken. It was further alleged that the NRC manager disclosed the al-leger's identity to the inspector. The OlG investigation did not conclusively determine whether or not security siolations were overlooked. Ilowever, the investigation revealeu that this was a common perception at the plant because o' the inspector's friendship with the plant executive. It was established that the inspector notified NRC counsel of the relationship, but the matter was not documented or pursued. This OlG investigation determined that the NRC manager did not disclose the alleger's identity and that the manager took appropriate steps to ensure the alle-gations were entered into the Allegation Management System (AMS). However, the alleger was not advised of the disposition of the matter even though the AMS indicated there was such a notification. In addition,it was established that the alleged wrongdoing by the inspector was not referred to 01G until a followup contact was made by the alleger 2 years later. Improper Supervision of Construction 11'ork Results in Evacuation of NRC lfcad.;uarters In July 1991, the NRC offices at One White Flint North (OWFN) in Rockville, M aryland, were evacuated because of strong fumes in the building.The source of the fumes was a concrete curing compound used in the building by a construction subcontractor. OIG was requested to ascertain whether the construction con-tractor or a subcontractor committed a fraudulent act through product substitu-tion. Further, OlG vas asked to determine whether the subcontractor followed safety procedures stipulated in the contract, particularly the ventilation proce-dure recommended during application of the curing compound. This investigation disclosed no evidence that the curing compound was an un-authorized product. However,it was determined that the prime contractor failed to supersise the work of its subcontractors and that insufficient ventilation by the concrete subcontractor during the curing process led to the buildmg's evacu-ation. I 21

a The OlG determined that the NRC contracting team did not follow contract stipulations pertaining to the planning and use of hazardous materials. Follow-ing an independent assessment of this incident by the Occupational Safety and IIcalth Administration, the NRC was cited for failing to maintain a Material Safety Data Sheet onsite for each hazardous material used during the course of construction work. The NRC withheld approximately $74,000 from the contrac-tor as a result of the contractor's failure to fully comply with the terms of the contract. NRC Response to Congressional Inquiry Found To lie Misicading In February and March 1990, two members of the U.S. Congress submitted l questions to the NRC regarding the welding and radiography program at the i Seabrook nuclear power plant. The questions were related to the~ concerns of a radiography technician who, before his termination in 1984, had been employed by the Pullman-liiggins Company at Seabrook. I NRCemployee inspects -w . t -iy e t y % h. , J.hlc.ilTY i nudear power plant -T 9"irm'"'- &,j l x@ t ~ ~~' %,wg @X ./ i* ... J 3 4

s,gy a.

,, <. 3 . ]g$ 4 y, e V 3g j ~ +: ? f. m 4, fy ,m. 4.T h4%. ' ' ' yy.a4q u,p.n y p i i es** G&n %j?f," x,p; & I Q Q ~mm . yt e j_ 4 m;g[gt _fhj: kpY;NN ~w- ' k 96.b ~ l u _4 gy n . w-- p.8,.f s .r... ...n..e In April 1990,six U.S. Congressmen requested that the OlG conduct an investi-gation. The investigation concerned the accuracy of statements made by the NRC staffin documents submitted to members of Congress regarding the weld examination program at Seabrook. 22

This investigation determined there was no cvidence of a deliberate attempt to mislead Congress by intentionally providing false or inaccurate information. - However, the OlG found there were serious problems in the manner in which congressional inquiries were answered by the NRC staff. The OlG determined that the staff's written responses to congressionalinquiries had little factual support, and in some cases the authors of these iesponses couhl not be identified.Thislack of correspondence control by the NRC staffindicated a weakness in NRC'r, review and concurrence procedures. It was also determined that one NRC response to Congress concerning a settle-ment agreement between the radiography technician and the Pullman-liiggins Company was incomplete. The respvnse did not include consideration of basic documentation needed for a legal review.The investigation further revealed that the NRC had also provided inaccurate information concerning the timeframe in which the review of all Seabrook plant weld radiographs began. In addition, the NRC staff advised Congress that weld radiographs had received a 100 percent review. OIG found this claim to be inconsistent with statements contained in nu-merous NRC inspection reports. As a result of this investigation, the Commission directed that a Lessons 1.carned Task Force be formed. Subsequently, the NRC staff concurred with OlG find-ings. OlG Referrals Under the Program Fraud Civil Remedics Act The OlO referred three matters to the NRC's Deputy General Counsel for Li-censing and Regulation for consideration under the provisions of the Program Fraud Civil Remedies Act (PFCRA). The PFCR A allows an agency, with con-currence from the Department of Justice, to recover up to double the amount of a false claim filed with the agency and to impose up to a $5,000 fine for each written false statement filed with the agency. The first referral resulted from an investigation conducted by NRC's Office of Investigations (01). 01 determined that an applicant for a materials license made a false statement to the NRC, which resulted in a license being gran;ed. The Department of Justice, although noting that referral of the matter was ap-propriate, declined to prosecute.The Office of Enforcement (OE) subsequently issued an order to prohibit the applicant from obtaining an N'lC license or from being named on an N RC license for a period of 1 year.The Inspector General, as the designated official, pursued the matier under the false statement provision of the PFCRA. 23

The second referral resulted from an 010 investigation of an allegation C.t a senior resident inspector (SRI) made a substantial number oflong distance per- - sonal telephone calls and allowed them to be charged to the Government. It was determined that the allegation was true and that the SRI made false representa-tions to the NRC by signing certification that the calls were for official business purposes. The U.S. Attorney's office declined prosecution in favor of adminis-trative action, which is pending concuriently with the PFCRA referral. l 1 The third referral resulted from an OlG investigation into an allegation that an l NRC employee on rotational assignment was improperly claiming excessive. amounts of overtime and had filed other false claims as well. An indictment of this employee was returned by a grand jury and tha criminal action is proceeding concurrently with review of the PFCRA referral. The employee has resigned. 24

IN1'ESTIGATil'E STATISTICS ALLEGATIONS Number Sourec 18 NRC employee 38 NRC management 0 Congress 5 Other Government agencies 10 Intervenor 11 General public 0 Media 2 OlG investigation / audit 2 Contractor 28 Regulated industry (licensec/ utility) _11 Anonymous 135' Total

• Of the 135 allegations. 28 resulted from hotline calls.

Number Allegations - 0 Carried forward from previous period Received during this period 125 135 Total Number Disposition - .17 Closed administratively Referred for OlG inve'stigation/ inspection 60 2 Referred for OlG audit 51 - Referred to NRC management / staff 5 Referred to external agency _0 Pending review or action 135 Total 25

INVESTIGATIONS Status of Investigations Number Pending DOJ action - 1 DOJ declinations-10 Indictments / arrests 2 Convictions 1 PFCRA referrals 3 Total 17 1 NRCADMINISTRATIVEACTIONS Status'of NRC Actions Number Termination / resignations 3 i Suspensions / demotions 1 Other administrative actions ' 23 Total 27 Carried .In Classification of Investigations - Over Opened Closed Progress i A - Conflict ofinterest 7 3 7 3 B - Internal fraud 5 7 4 8 C:- Contract / contractor-related : 2 5 2 misconduct 'D '- Falsification of records or - i4 2 2 4 statements E - Theft-related offenses 2 1 2-1 F - Misuse of Government - 3 1 3 1 property G - Actions affecting safety or _ 8 8. 10_ _6 _ NRC programs H -- Management misconduct 10 9 7-12 and abuse 'I - Other 4 '7 3 8- - Total 48 - 40 43 45- ! 26. L

Recutaroarasview Numerous Federal legislative proposals, as well as Commission policy initia-tives, were resiewed by the OIG during this reporting period. OlO comments on the most notable issues are summarized below. The OlG commented on the draft General Accounting Office (G AO) report en-titled " Employee Conduct Standards: Some Outside Activities Present Connict-of-Interest Issues." The report was prepared at the request of Senator David Pryor, Chairman of the Subcommittee on Federal Senices, Post Office, and Civil Senice; Committee on Governmental Affairs: United States Senate. Sena-tor Pryor was concerned about conflicts of interest that may arise when Federal employees perform similar work both inside and outside the Government. NRC was 1 of 11 agencies selected for review. The OIG provided comments on two substantive errors in the draft report. First, GAO found that NRC failed to re-quire periodic updating of outside activity reports by employees. However, NRC annually requires employees to fill out two forms that require disclosure of out-side activities. The GAO also determined that NRC required reporting of out-side employment only for nuclear-related outside activity. This finding is incorrect as the NRC regulations enumerate other instances in which outside activity must be reported. OGC incorporated OlG's comments into its reply to GAO. Comments were also provided by 01G on a proposed revision to OMB Circular A-50," Audit Followup "The OM B proposal addressed issues such as the desig-nation of an " audit followup official," followup tracking procedures, and a clari-fication of terms as defined in the Inspector General Act of 1978, as amended. The OIG agreed, in general, with OMB's proposal. The OIG commented, how-ever, that the agency audit followup official should also have the primary respon-sibility for maintaining the recordkeeping system necessary to track all audit - findings and recommendations. The OlG stressed the importance of the track-ing system and reiterated the need for clearly designating an official to maintain it. Furthermore, the OIG stated that overall management accountability could also be strengthened by integrating the audit tracking system into the agency's audit followup process. Complete access by the OlG to the agency's tracking sys-tem was considered essential for the proper monitoring of the agency's followup activities.This accesswould also eliminate the need for the OIG to establish and maintain duplicate tracking systems. 27

THER ACTIVITIES During this reporting period, the O1G has also engaged in numerous other ac-tivities. Summaries of selected actisities follow. i Hotline Training Seminar In coordination with other members of the Inspector General (IG) community, the NRC's OlG organized and conducted a Federal llotline Training Seminar in February 1992. Over 100 people participated in this 3-day training seminar. The focus of the seminar was to improve existing Federal llotline Programs and to assist those interested in developing such a program. Topics included interview techniques, procedures for maintaining confidentiality, standardization of cer-tain operating procedures, and other pertinent issues germane to Federal llot-line Programs. Senator James Sasser of Tennessee spoke at a luncheon held dur-l ing the seminar Senator Sasser addressed hotline programs and the accomplish-l ments of the Inspectors General and their role in Federal Government. . Senator James Sasser : ' 3% i% ad.fresses memben of ~N,* . /:. ;s, ._.k' h ~I the inspector General y 4 $s community at a semi. T ( >. p j;_ , p$ nar luncheon, .i. ? k.. } n.- ~ k{ .g ., f: k . t.. b ' 3. L 1, 1. [ }r .[] \\

6.,~.

L ~ S*W .~ e. i r + 4: f. 7 i g kw w Employee Training Course The OIG is participating in the conduct of an NRC course entitled "The NRC: What it Is and What it L)oes."The purpose of the course is to provide employees with a more in-depth knowledge of NRC's operations. The OIG staff contributes to this effort by explaining the function and the mission of the Office of the in-spector General.This presentation includes a description of the 01G organiza-tional structure, as well as a discussion of the 010 s statutory responsibilities. 28

The investigative program is discussed in sufficient depth to acquaint NRC em-playees with the program's three key activities: misconduct investigations, crimi-nal irsestigations, and inspections. The operation of the OlG 1lotline Program is also described, and its "800 number" is provided. The mission of the O10 audit program is also explained by providing information on the types of audits con-ducied: financial, operational, and special project. Audit Plan Issued in October 1991 OlG issued its FY 1992 Annual Audit Plan.This document is the OlG's formal plan of action for managing the audit workload and audit re-sources for FY 1992, The plan considered the interests and concerns of the nu-clear industy, the Congress, the President's Council on Integrity and Efficiency (PCIE), the General Accounting Office (G AO), the Office of Management and Budget (OMB), and NRC senior managers. During FY 1992, the audit staff will conduct both programmatic and financial audits. These audits will meet mandated requirements, including those estab-lished by the Chief Financial Officers' Act of 1990. In addition, the audit initia-tive will address three critical program areas: the NRC's Safety inspection Pro-gram, the Information Resources Management Program, and the Research Pro-gram. Peer Review Assessment An interagency peer review team recently completed a quality control review of OlG's audit activities.The reviewwas conducted in accordance with PCIE crite-ria and generally accepted Government accounting standards. The objectives of the review were to determine whether the NRC's OlG has an internal quality control system in place that (1)is adequate and operating effec-tively,(2) follows established policies and procedures, and (3) meets the annual planning process requirements of OMB Circular A-73. The audit team reviewed OlG audit policies and procedures, planning, and staff-ing functions. The team also reviewed 7 audits selected from the 17 audits com-pleted by the OlG during the semiannual reporting periods ending September 30,1990, and March 31,1991, Also assessed was the OlG's administration of Defense Contract Audit Agency (DCAA) external contract audits. In its report to the OlG, the team concluded that the internal audit controls "are operating effectively and provide reasonable assurance that the OlG is following its established policies, procedures, and Government auditing standards " 29

1 1 Government Fellows Program l During the past year, the NRC nominated an OlG investigator to participate in the 1991-1992 Excellence in Government Fellows Program. Samuel Ilolland, a senior criminal investigator, was selected to participate in the program on the basis of his past achievements in Government and his potential to enter the Sen-ior Executive Senice. Throughout the year, he will meet with top executives from the public and private sectors to discuss issues and exchange ideas related to public service and effective Government. OlG inestigator Sam g ag g Holland (center) was l l l congratulatedl'y his su. pervisor Tom Natch-l ford (right) and NRC Chairman Iran Selin (left)for being selected to participatein the Ex-cellence in Government Fellows Program. g. ic d i i j l ( Fire Protection Training NRC regulations pertaining to fire protection for nuclear power plants are con-tained in Section 50.48 and Appendix R of Title 10 of the U.S. Code of Fedend Regulations. Appendix R requires demonstration of a safe shutdown capability for nuclear plants in the event of a fire. One method forlicensees to demonstrate compliance with this requirement is the separation of redundant safe shutdown systems through the use of fire-rated barriers. Several manufacturers have pro-duced fire-rated barrier material, which has been installed in nuclear power plants by NRC licensees in order to satisfy the requirements of Appendix R.This use and installation of fire-rated material is subject to NRC technical staff ap-proval and periodic inspection. 30

In order for the 010 staff to assess the performance of the NRC technical staffin carrying out their regulatory responsibilities,it is necessary for the OlG staff to obtain an in-depth understanding of certain technical matters.Thus, OIG staff members frequently attend courses that address technical issues. In regard to the OlG's resiew of NRC staff actisities related to the approval and inspection of fire rated barriers, two OlG investigatou attended formal fire pro-tection training that specifically addressed the requirements of Appendix R.The training course was designed for fire protection engineers and covered fire pro-tection systems and materials from initial planning through installation of sys-tems and components in nuclear power plants. The knowledge gained by the OIG personnel attending the training session will provide them with a better un-derstanding of the various factors considered by the NRC technical staff when they make regulatory decisions concerning fire protection at nuclear power plants. 31

L Sesciat usarvas NRC'S OFFICE FOR ANAllSIS AND EVALUATION OF OPERATIONAL DATA The NRC's Office for Analysis and Evaluation of Operational Data (AEOD) was created in 1979, Its mission is as varied and complex as its name suggests. This vital office is linked directly to the operating pulse of all licensed nuclear power plants. Through dedicated phone lines, AEOD maintains an around-the-clock Operations Center to receive, monitor, and if necessary, respond to safety-significant events invohing the use of radioactive materials for both reactor and nonreactor activities. When a significant safety issue arises, NRC teams are de-ployed to the site to conduct either ;m inspection or to perform a more detailed investigation of the event. AEOD manages this effort. As a result, NRC makes either site-specific recommendations or generic industry recommendations when appropriate, in August 1991, the OlG observed an AEOD-directed team conduct an investi-gation at the Nine Mile Point Unit 2 reactor facility in Feriba, New York, The plant had reported an internal failure in its main transformer to AEOD's Opera-tions Center. This tailure resulted in a reduction in voltage that caused five "uninterruptible" power supplies to lose power. Although this failure was brief, important control room instrumentation and other plant equipment were af-fected. In addition, plant operators lost the normally available plant status indi-cators. The automatic reactor protection systems, including the automatic shut-down capability, functioned properly, Nevertheless, this esent underscored the potential safety ramifications of a loss of power. As a result of the investigation, the NRC made several plant-specific recommendations, as well as several ge-neric recommendations to the nuclear power industry concerning equipment maintenance. The Diagnostic Evaluation Program, which is managed by AEOD, plays another important role in ensuring plant safety. In June 1990, a 16-member NRC team spent 4 weeks at the Zion Nuclear Plant in Zion, Illinois. NRC received several indications of an overall decline in performance at the plant, The team's mission was to evaluate the plant's operation and to identify the causes of existing prob-lems. Interviews were conducted and observations were made. The team discov-ered, among other things, an ineffective preventive maintenance program, tech-nical inadequacies, and a lack of necessary teamwork among crew members. 32

...... _ _ -....=. _-. ~...-.-.. _. A &fective transformer ' /1l 1 at the Nine Mile Point yi.~ g. g-; 3 y % ' y-Nuclear Station in ']O 'a L_ _

s 3

• l

} Scriba, New York, is be-i itlf ing p etsared for re. k{${..

Q L,,

li " moral. Q$. -t k -;j q av a 4 c.g b ( W yia m 3-q ,) W} l %l -. {. i \\ k [x fk]N" 1 p e [ .$ $t _$ k l M g, [&.igQ ~ a QL s t /7 g du,ild f h - M.a, w AEOD also develops and provides technical training for NRC staff at the Tech-2 nical Training Center in Chattanooga, Tennessee. The training program enjoys top management support from the program offices and regions because of its responsiveness to NRC needs. The training center and its contracted facilities combine classroom lectures, reactor simulators, and training aidsinto a state-of-the-art technical training program for regulators. AEOD's role in ensuring public health and safety, however. does not stop with its management of the Operations Center and the Technical Training Center, or with its activities at nuclear reactor sites. AEOD is the focal point for the evalu-ation of diverse industry data for the many activities and events associated with the use of nuclear materials. AEOD analyzesindustry trends and patterns, moni-tors corrective actions, and continues to actively seek and resolve root causes of safety-related issues. An example case study that has stimulated NRC and indus- _L tn/ action is the " Operating Experience Feedback Report-Solenoid-Operated Valve Problems." NUREG-1275, Vol. 6. 33

PPENDICES A UDIT LISTINGS thTl:RD11_ Al:DIT REPORTS Ew ,d a k the l'ederal Manageri 1 in.mcial integrity Act for !'N1 12/27'91 Revicw of NRCs Complianc W ah the OlG u2A-H5 Anti-l obbying Act 0007 92 Review of the llcahhPlus t 'iaim UlG-91 A-12 U U24 92 Review of Commercial Facihtics OtG 91A-09 Management of One White Hint %:th OU2R92 Review ol' Contracting for ('onsu:tinz OlG-91 A ih Serviec.s 02/2fi'92 Net (W til "I eMons [ carned" I'ron: Ol(i Ulf\\.05 lacen sine of DOE WESF ('apsuirs 03:03;92 Review of NRR's sa;cn luue ()Ri-W A-m Management System I r e l l i . - - - _ _ ~ _ ~ _ _. _ _ _. _,... _ _ _ _ ~. _ _ _. _ -.... ___ _., _ -. ~ _ \\ 34 j

i 1 l i DNIR \\( l MDII RI IDRIS Q ()ut s;h uR s! l'UI til gg ( 'us t s 15C!IcI k 'C issued Contractor ( l h '" " ' ) d I"10 ' ! L L k l($.}(( SJil l.k3s im !(, ui siPR Awos.ates Inc. N itc itlant N lu '--04.w n2t-11 Of 'll [.11:,tcifuthinal. Inc. II"'I Niuf-u l-w 112, N !W-2nC;2J 11 a: 01 l'aitic Science & lin-li,C-ril:0 (litv:;\\ l!. c C \\ l-;c4 LiJ 4 td l' 5 11JU5 W (kncral E a tri Mlh ) U Njr..a; ~~o_214 l l '('t s '){ Si c a h.s t i lik i i _ N1(('It nLwuf 4 (~ Icportsi 11 sk) 01 Son.tl', $l' Ini. II N R C..n3.si,-.-tr54 g,5 : f ss 11(k: 'll i a:iu:c.\\na!) s s. \\ '^ oi ' L InJ j{S_ (( {T S il' l1-!* 'f ( 4-k b 4 Suclea; lech, dx N RC..ud -'o-2 ii 11F 91 Genc ral lit : < - \\ ! Ilt ) ~1" Nlu~_nt m :15 ll> F W WJc!!nr A ( ' E,"i t i n-Scr we, }{S -- R [- N

• d -li l' 12/19 91 liatic!!c Nit'm al I r i.

l(S _ }-(] M !2 4 I h 12< 23 4; ITASC A ('ons,lu n =. liro.y inc U N[u ---owa m M ly N R( 1.02 M4 4 l ' l 12 & "t saente Arr'tw l internat:nnal R %. } { { -( s..id]_l)E 01 h 92 I)ames .:! h rt Ryfu:s.unnr

---

i---.

u .____..--,=-.~m -,sca.. lunds Uuestioned Put to OlG Costs liciter Use l> sued Contractor ti)ohats.4 ( t h.!!ar q 01/06 92 S. Cohen & Aoosi;ee. In, o RS-RES 92-407 Ol!!3/u2 Cotnputing Atalpis Corp. O RS-1 RNi 01-15.1 0l!!3/92 Niiero Anak sis & !)csien n N RC-t'.Ls.<-05 ; ] 01/.14/92 General I lectne-NFhO S3 2P N RC-04-79.154; NRC iki ~h-2lE 01/14!92 11 Internanoral, Inc n.* lo N RC-(L1-SN 112 01/21/92-. Planning Research Corp. H N RC-lU--S4.2 } l: NR( IO-N2-f b 01'21/02 Rov 1. We3 ton Inc H Niic-LS7-419 O U2 tf9' Arthur 1). I ittle. Ins O RS-RES 92-(07 01/21/92 Atathtech. Inc. U N RC.33 -Sh-263. N RC 0437-400: ( N RC-04-S7-Osn 01.'l/ 2 l'enn3\\!vania Statt Unkers:ts 26,H i l 0 R S-R l.S.-92-040 01/21/92 Eneres Re3earch. Inc 0 RS-RiiS 92-015 I O D3 U92 Ihompson Endocenug & O Testing. Ine: N RC-28-80269 02'04/92 Scicatech. Inc. H R S-R h S-92-4 LI(l 02.07/92 Sc:entech Inc. O RS-RES-92 407 02/11:92 S Im. Inc. 4 U2n RS. R INo:-e10 02/ I % o' Apphed Nianapernent 0 Systems lue. N R( ' 3bl32

I l .w..wmana4we.-w -W" lands Uuest:oacJ Put to OlG ( '" ' t ' Ikt"3 E' il)" d') lssued Contractor j l h tht ' i U 02 IS-92 Engineering Suence at.J A:1h 3.is i NhC nt A12t, 02'IS (C Graduate k hoid USIM U Sl(C-lu..S(--213. N il('-3.i-% -3h i 02 2tv92 liabad and WiLoi l'owct 5" IDI Computine It s _ ld e,a c-0 :n 03.:13"!2 Comex Cor;, ' ' M ~1 N }R C _{ 15-Sh.- I 7() ",12 03 'l I ' \\\\ stCnl dUlonletI!iiTI (.5If % l(C_ T i._tJ \\ lI 7 03/24 $C Encrt:s !<escat cli. In. I" 4 " 1(S-RI:S-COE 03241C llov 12. Weston. Inc. U N [< C-2rw -419

• g l

l 5-II ' '}],-t>>' !# C ' I t: t !!;.1; !'t J !P! it.U.t snc1 <i II. ' N. p *' ? t J ( }{ h l([h 'C I d l. b T. c 's ! ~ - ~ - "4

4. .._-.-._.-4__.

1HilREI 1.-1 Tl0NS Al C Atomic 1:nergy Commission ALOD NRL"s ()f uce for Analysi, and 1 valuation of

();,crational 1)ata AMS Allegation Management System C1() Chici I inancial Ollicer DCAA I!.S. Detense ('omtact Aud!! \\ ce nt) DOE U S. I)ejuttment of I nerm DOJ L LS. Department of Justice Fl:llHP Federal Employees' llealth lienchts Prop am FM FI A I ederal Managers' I inancial Intepity Act iPDS 1 ederal Procurement Data Svstem FY thcal year GAO U.S. General Accountine ()ltice GSA U.S. General Services Admimstration k k g IG Inspector General r M('P nunagement conuol plan c .k n.I k k k s Ik k i NRR NI?(:'s ()ttice of Nuclear Reactm Regalation t s c( k_ ! }e. (r) rl Ih )be OlG NRC s Office of the Invector General OMH U.S. Ollice of Management and liudget OPM U.S. Of fice of Personnel Management OWFN One Wlute Flmt Noith PClli l' resident's Council on Integrity and I fficiency PFCRA Program litatd ('ivd Remedics Act RES NR("s Ottice of Nudcar Regulatory Research SIMS Safety Issues Mananement System SRI sernor resident inspecnu U.S.( ' United States Code 1 l WESF Waste 1 ncapsukuior anJ Storage I aedity 38 l ~ --.

_ ~. _ - - - GLOSSARY . _~ AGREEMEX7 STATIE A State that 1,as mucJ an acicement mth the Nld ' al-lowing the State to regulate the use ut tadnuaise u.ater ul wohm that St.ne. F/NAl AC T/DN. ~1 he completion of all manacement acnon,thsenned in non-i a.tement decisions concernine audit reconunendanons and hnJim x 1 nul m n n occurs when management issues a deersion, F/NANCIAL AUDIT I inancial audits are canicJ out to me' ti clics tis ens - et internal conuol ws: cms. transaenon pr oceru.s. nn.mcui w m ms mJ con tracts. FUNDS PUT TO H/T/TR D!' 1 unds identitied m auf t tucaane..Jan m that could be used more etfie:ently bs avoiaine unnece mn e spt n'es. HOTLINE A toll-tice telepb sne number (lann R : V ' av<nlab!; to a :v-one for the reporting of inadents o! po"abit h aul u n and abus to t' NRC's Office of Inspeaor Gener al. AfANAGEMENT DECIS/DN \\tanagement esaluanon ot at.Jn teson <, Ja

c me nt' tions and fmdmp A final Jec:sion is :ssucJ that is bast d on nu:

sponse to recommendanons and tindmps. PEER RE17 Ell: A icuew (or audit) of the oper anons of an In' cuoriic: a al by representatives tiam other Federal agency in'peao: < ienea! othces m o:s. to as. sew the effecticeness and proceJurcs used bs the subjea 1(L L PERFORMAN('E A UD/T Perf ortnance audib arew the etics us en ss and eth ciency with which management responsib:hne' are carned out. QUESTlDNED COST. A cost quesnoned as a rexult of an alleced u"! anon ot law, regulanon, contract, or a.ereement ros et ning the expendom e et hu (d)5h unsupported bs adequate d(1Cumentatliin ()r tunds IL4 a j' tl ticu!JI puti: $ t that are unnecesary or unreasenab!c). sal'ETF/SSUES MANAGEMENTHN/ EM A tralms and mm a a un: w tem designed to manage nuclear plant safery inues a !.it '. iit M > inat <: th s < UNSUPPOR / l.D ( 71.VT A ciwt que :ninc<l bt caux 4i t mentation at the time of the aud:t.

- ~ .% %,e-,-e,. ,-+4,.-. - .~..m.. .._e.. -_m Tile INSPECTOR GENERAL 110TLINE i A toll-f ree number ( 1,s00-233-3107) was e-tabhshed by the ()ince of the in-s i spector General to pr oside NitC emplo3ces. connactor s.and other s with du ett access to OlG's Ilotline Program. Ilothne procedures and guidelines were care-tully developed to ensute the confidentiality of Nit (' einployees wi,bing to re-por t incidents of possible traud. waste, and abuse within the NltC Trained OlG statt are available to answer calls Monday thr ough I nday. between 10:00 a m. and 4:00 p m. (ca. stern sandard tune). Individuals may abo pr oude infor mation j to hatline personnel bv " riting to the adJten below. 8 l l'.s. Nudear llegulatory Conuniwon I he Othee ut the inspecto: Gt neral iludine Program Mail Stop I W W 542 i Washington. IU ~ 205 45 ll. i 110 i LINE NUMlWit: 1 sonK!33_3497 l 1 I I l l l 40

PPENDICES AUDIT LISTINGS INTERNAL A UDIT REPORTS Date Title Number 12/20/91 Review of NRC's Implementation of OlG-92A4)1 the Federal Managers' Financial Integrity Act for 1991 12/27/91 Review of NRC's Compliance With the OlG-92A-05 Anti-Lobbying Act 01/07/92 Review of the HealthPlus Claim OIG-91A-12 01/24/92 Review of Commercial Facilities OlG-91 A-09 Management of One White Flint North 01/28/92 Review of Contracting for Consulting OIG-91A-08 Services 02/26/92 Review of "Icssons Learned" From OlG-91A-05 Licensing of DOE WESF Capsules 03/03/92 Review of NRR's Safety issues OlG-91A-03 Management System 34

1 CONTRACTA UDIT REl' ORTS Funds Questioned Put to OlG Costs Better Use Issued Contractor (Dollars) (Dollars) 10/02/91 Battelle Memorial Institute O RS-.RES-91-063 10/16/91 MPR Associates. Inc. O NRC-04-SS-092; NRC4WSS-026 11/04/91 El International Inc. 1.091 NRC-04-86-112; NRC-26-87-420 11/04/91 Pacific Science & 0 Engineering Group, Inc. NIfC-04-9(k074 11/05/91 General Electric-NERO O NRC-04-76-215 11/06/91 Sonalysts, Inc, 0 NRC103-86-054 (7 reports) 11/06/91 Sonalysts, Inc. O NRC-03-86-054 (65 reports) 11/06/91 Failure Analysis Associates Inc. O RS-RES-92-048 11/07/91 General Electric-Advance 0 Nuclear Technology N RC-04-76-215 11/07/91 General Electric-NEBO 719 NRC4M-76-215 11/18/91 Modeling & Computing 0 Services RS-RES-92-048 e 12/19/91 Battelle Memorial Institute O RS-RES-924M6 12/23/91 ITASCA Consulting Group, Inc. 0 NRC-02-88-005 (SUB): NRC-02-88-002 12/23/91 Science Application 0 International RS-RES-92-037 01/06/92 Dames and Moore O RS-RES-92-037 35

'ie Funds Questioned Put to - 010 Costs Iletter Use - Issued Contractor (Dollars) (Dollars) - 01/06/02 S. Cohen & Associates, Inc. O RS-RES-92-037 01/13/92 Computing Analysis Corp, 0 i RS-IRM-91-183 i 01/13/92 Micro Analysis & Design o .NRC-03-85-054 01/14/92 General Electric-NEBO 83 217 NRC-04-79-184: NRC-04-76-215 - 01/14/92 El International, Inc, 6.519 NRC-04-86-112 01/21/92 ~ - Planning Research Corp. 0 -NRC-16-M-211; NRC-10-82-356 - 01/21/92 Roy F. Weston, Inc. 0 , NRC-26-87-419 - 01/21/92- .' Arthur D Little. Inc.' O .RS-R ES-92-037 01/21/92 Mathtech Inc. 0- - NRC-33-86-263; NRC-N-87-400; 'NRC-04-87-086 01/21/92 Pennsylvania State University - 26,041 RS-RES-92-040 - 01/21/92-- Energy Research, Inc. O RS. RBS-92-045 01/31/92 Rompson Engineering & L 0 'Testine. Inc. NRC-28-88-269 : 02/04/92 -Scientech, Inc. O RS-RES-92-040 02/07/92 Scientech, Inc.. 0-RS-RES-92-037 - 02/11/92 S. Levy, Inc. . 51,326 RS-RES-92-0401 -02/18/92 Applied Management 0 Systems, Inc. NRC-33-132 36: e" 4 mpgwse9-ver m. &i g=w i qu sg y yqp v yngg m .o+- .y .gy 3, -.g79t-'-N MwP-t'P'""?J

• • 'g-'

l l Funds Questioned Put to 010 Costs Better Use luued Contractor (Dollars) (Dollars) 02/18/92 Engineering Science and 0 Analysis NRC-(WS6-126 02/18/92 Graduate School, USDA 0 NRC-10-86-213; NRC-33-88-364 02/26/92 Babcock and Wilcox Power 50,101 Computing RS-RES-92-040 33,876 Comex Cor[. 03/13/92 NRC-05-S -170 03/13/92 System Automation Corp. 40,153 NRC-33-92-337 03/24/92 Energy Research, Inc. 16,43S RS-RES-92-046 03/24/92 Roy F. Weston, Inc. O NRC-26-87-419 Totals $42,422 $184.059' 'The total douar amount in this appendix differs from the amount in Table II. To avoid overstating potential doEur savings in Table !!, the average potential savings of the four preaward contracts, filed under RS-RES-92-4%). was used. 37

ABBREWATIONS -AEC Atomic Energy Commission -AEOD NRC's Office for Analysis and Evaluation of Operational Data AMS Allegation Management System CFO-Chief Financial Officer DCAA U.S. Defense Contract Audit Agency DOE U.S. Department of Energy DOJ U.S. Department of Justice FEHBP Federal Employees'llealth Benefits Program FMFIA Federal Managers' Financial Integrity Act FPDS Federal Procurement Data System FY fiscal year GAO U.S. General Accounting Office GSA U.S. General Services Administration - ICR internal control review IG Inspector General MCP management control plan NRC U.S.. Nuclear Regulatory Commission F2R NRC's Office of Nuclear Reactor Regulation OGC NRC's Office of the General Counsel OIG NRC's Office of the Inspector General OMB U.S. Office of Management and Budget OPM U.S, Office of Personnel Management OWFN. One White Flint North PCIE President's Council on Integrity and Efficiency. PFCRA Program Fraud Civil Remedies Act RES NRC's Office of Nuclear Regulatory Research [ SIMS Safety Issues Management System L SRI ~ senior resident inspector U.S.C. United States Code L WESF Waste Encapsulation and Storage Facility ' 3.8 - y--e e

GLOSSARY AGREEAfENTSTATE. A State that has signed an agreement with the NRC al-lowing the State to regulate the use of radioactive material within that State. FINAL ACTION. The completion of all management actions discussed in man-agement decisions concerning audit recommendations and findings. Final action occurs when management issues a decision. F/NANCIAL A UDIT. Financial audits are carried out to assess the effectiveness of internal control systems, transaction pr ocessing, financial systems, and con-tracts. FUNDS PUT TO BE7TER USE. Funds identified in audit recommendations that could be used more efficiently by avoiding unnecessary expenses. HOTLINE. A toll-free telephone number (1-800-233-3497) available to any-one for the reporting of incidents of possible fraud, waste, and abuse to the NRC's Office of Inspector General. AfANAGEAfENT DECISION. Management evaluation of audit recommenda-tions and findings. A final decision is issued that is based on management's re-sponse to recommendations and findings. PEER REVIEIV A review (or audit) of the operations of an Inspector General by representatives from other Fedent agency Inspector General offices in order to assess the effectiveness and procedures used by the subject IG. PERFORA1ANCEA UDIT. Performance audits assess the effectiveness and effi-ciency with which management responsibilities are carried out. QUESTIONED COST. A cost questioned as a result of an alleged violation of law, regulation, contract, or agreement governing the expenditure of funds (costs unsupported by adequate docurnentation or funds for a particular purpose that are unnecessary or unreasonable). SAFETYlSSUESMANAGEAfENTSYSTEA1. Atracking and monitoringsystem designed to manage nuclear plant safety issues. UNSUPPORTED COST. A cost questioned because of a lack of adequate docu-mentation at the time of the audit. 39

T THE INSPECTOR GENERAL HOTLINE A toll free number (1-800-233-3497) was established by the Office of the in-spector General to provide NRC employees, contractors, and others with direct access to OlG's 1Iotline Program. Hotline procedures and guidelines were care-fully developed to ensure the confidentia'ity of NRC employees wishing to re-i port incidents of possible fraud, vaste, and abuse within the NRC. Trained OlG staff are available to answer calls Monday through Friday, between 10:00 a.m. and 4:00 p.m. (eastern standard timel Individ"als may also provide information to hotline personnel by writing to the address below. I U.S. Nuclear Regulatory Commission j The Office of the Inspector General l Hotline Program-L Mail Stop EW/W 542 l Washington, D.C. 20555 l 1 HOTLINE NUMBER: 1-800-233r3497 I - 40

'l _. I !~' ~.. .v: . * [:: , G,: 3,,... ~ s.. .n., g r ,,.... -,. y 'Q. s.Q. L. . ' <.; r.L.l ^ g , r -..' h, ,'..a _, _.....: .,.. A c. ;. < .Q.), : 2 ' M.... 's. t y.., 'c_ .,W t +... a. ~; .,.r n: -.., .a,.. ,T ...,*.f,)

a

-,'g ',. ;,.'7.,j. g ,u a ..g u .:,. c e,,.-.. '. -

,-3 f.

. r . c. n L .~ ' ,e 4;- '.,..,.., ;, ^.. .a. , 5 .O .f-p.. ,,, t '? - '. p'1,'. g.,,. ...,..,' x. J. .s' _,,'.1 j .g .'g e, _. - *,,*.;. 7 * -. - + 1,;. y .,.s..- .:'e+. v.... ,-).'... + r ,~, 'q -., -,: -,.= ' '-., ,-,.. ~..k ,. l n ',v'. 4. #

... ~,L....-

s.- a. .9..?. y. 7..,,. s.. t s, -. :- -,. y... ['._,., .c p.. . d- .: -'., y { j' ';e g. .,.. -...... - [ g,.; _... .e.

c..

~ . y;....... - v, .y - n. s.. l* [* '. " > - - ~

• ,. ' * +- "

. ; +; :, ' s ~ - - -. ',,f..,.', e-t L '..., - " ~ a .... :( y.',',r.y,.., .,,e,..- {S ' t: ' .~. ,,.,,,.g,

• p s,.

p.. Q n. ...,3g.,. A f'?f ; g/, g' *. *, ,/,',1- .'[, J [ -g,' y.,.,, / 3.", - r a -..j te , ',,..... - ;,8 f m" [ y,e,' } *t, 0-V l* '.,, g 7-6 _..t ,c.. .y.. e.

.. y

....g: 4+.. ;,.. 4 . y., t,. :.,.;- .p '.,g.p., gs.. , i, ;. g.,, g, -,.. + ',r.. a w. 7g) c' ~.. ,.',1 . y.,. 7 .,!,, y. ..,s3 s * + : ',E.. . ;. %y - T,[ [. ,g q y, ,l,,& lh__, Lf_ ', 2 _ .... 3',$ 'f' '. - ... *... :. p.: kw ~. ' 3 :. ,F,- . '*+y'I'..

• t-#,

,' - - 1 'g r 3 s., y,,p ,.g t, y g 4 ' 7 , p n , O at * ..4 g.

g. ; *,,,, -

,J. -) .p. .s'....,.. -.. ') i f'- v t, e., j '. ', pg ,.,,4 ,,.p f , e',. _ 4 f. 4 f ; pp. a. . s. Nl ' ' '?

y.

E,.. ^ .-~. , [_ ^ :' ' i. n. :.. . :y.s > ' ? * '.. ^ ..... ~', .5f.- .s .g a l_ i~ ', s- . + 'o .. l.- 9

• +

r 4 * ' .s r g

• i r

e e A 3 '. -...,y,..,. , ~. + s, 4,, Q: - t. a - ,0 i m . en '4 - si ' s... 'p d> t s I + a N, 4, l .M ~, ' .I g, g y. '-w -.,.. f . f,' s ' ( 8 j ~ \\ , '.., ',..,. '.. +. t s .+ _. ~,. - =,.. . ** - '..,. s - --,4 4 ~ ' ~ '. J -y,. '. ' .., f' [ ., > l l _ 6 ...V o. c ] - ~ e , ) ' g- -.,,., ~, ...3 s-y. O.. ' s Q .... '. '.,.. g'.. :,, '.. -1 s g ./, .., '.i', O.i '- ' .1 ' 'l. 5' a' '... '.... _. ' *^ e

l. l

• ' A

'g

- ' =,,.

~

• i *.

s 86.[' o- , :- ;.,~. f . j.- y. i,a ., 1 = .t '8 E- .p....2; i .3 [ ;.. h', 's I- ,,,f - -.,.. -....e....,- '_, '.. '..', t, 3.~. s. ;,.. y. :,, ; -. n _.s f...,

,.,,.....c..

.y ., 4...,:' ' : : , 1.. _..e, .[ ' y' '. ',,',g.,.l.t,.-l,)] y. r,; .g ~, 3.. T*:- i:.. -3 ',3 A f ' '...S['b 6 ',.. y., f '7 ',.,., r,, ..-.. '. [ - 4. :,. 7,,. '., }. [,q'y, 7.. '.l- ' ', ".'- Y -.. k ;' ' '. 'i% t' 3. a - V*p f. s-V. ....c. >.L 3:3 v; . b - ;;z f..

• j ' 7.,

.9,'.:I. /.; .... g,.y.:... n. 7

,,v.. y v :....-u;..

s.. g...., . ~, ... s n

y.. '

'p.y..r. g 7. :w; ;;, y.; . w i no. e.. q,.e. w. :.,.; ;v - c.. n -, v...~4. :s;. 4 y : g. : ,, x. r.v e,..s.e.... w%, g. 2... y.,. v v . v. x,.g : ;,.. ~. n s,..n. g =, t....;

... ~.. w

1.. . ~ > -. ..s . 3 ., p. ;...;..... g t.

c.,

f ..::..W. a ',n. p.. &s,p% a u. .a M.%')h~ w my&y}w

• fMf;W.

c.. l.;,p.Y.M.[. [ . '.T.f Y .y 7. 41 p ),.. :. O, <:.n ". f..w. p.nug.. d u,,t h,a p 6:.p: y..,. m gm . \\. a + = n a.

w c.

.. 4 y %. y... s. n &,. : r;..': ..-*.L . m. ...:.:c, . ::,. c w :.,,at y.., n. x,.i.t.w.y, + +y.e . >,.,c.c.-.,. s ... 7, ;.?: ':..'. n,

g m, ;,n l n. w m an

....s yc n, s.c..s-L.1.. '. g :.,,

s t

e :W.: - Tm. w....q....,.< m ~ . a.. s u...,.t,; ', H... :. a.x > ;.. . h.. ':...., ', L;. 4.% ' ~... ' ' ..u .. 4 '...,,.. ' : y j ', o. t ;u, ;:.m. j. W.. : .. Cp= a. ,. t -.* >..- .F. L 4.

h,'. > e e,\\.. ,..? '.I' '/ G. ' 4' 4 , p

• * ' ' 4'. 4, 5

,. 'I t" t . g,, g- ,"p,6.. * ,, A p[ ,,, S,lJ' 's ' gk f*, f', .g l e %,.. $, j,, A

s. g* - ',

', k, e.,-.,. e.;;#. .-1, [ ,,' ' k, e.'.:% s'. .u .r .n . ;- n ' '..,C .?, ,,y ,. y ?,,. ,g 2 - 4 q" c c 1., a,, } . ~.... i ,,g. . g u.

c.,

w- .. i. .a, 3.. .t 44 i;... ,.1., r.. ..A , '...i... 9,.... .,O 4

• i.

.L ., ',. g4l -( g '- - -gq. ic / ..j, .L'\\. ..z ). 3' y e a 8 ... ;1.. 4, 3 - t. ~.......: ., +, ~. 'J 1. . 4 -.,,s P. g -,f..q-qge l'.,5,,',, ,a .,./,' 'J 4 p,,,... '.,. - < < -. l ,e. (,. .. t v.,, e,.,. '3 ., g ,I. ?, e

• [a?.

to. s i, se s .,,,/e..., s s ~ :... t, c-4 ...,c, +, i ,.,.. e .'5L l. ' \\..: .. L -l f ~.',); l' t < ' ' t; ' '.,.. , ' ' l * ','I( '. 1 r.

f

,y ' ' [ I. It. l. ,,,'.i',',*, ,.J. ' ' ,,f' J v. j , l 1' ' ,k ~, - 9 l - ' ' ' X * ' 0 * '[, ' lA f?. .. - %., y '. t, [.' ~ _ fl. y ^ _ ,f. [.. l [,' l v[. b; a j [ } uN Nh,, f,.,}.[,I,

< 4..h.. p '.

,c. ','S,.m, +. .I K~"'. n; : r. g .e. c.. 1 r,. ... ~. c:.... g ,g, 'w$ i, N ', J, . (:1 -.. :.,. a. a"R

.','<-=.

. -y ..,, '. 3 .( *,, '.'

f.,,

4 e., t;. .v..a e. f ef.',- n.-.I - - ....a. .c. v,.: o ., _ f ',. y 'y. ~ ?ns -..,,.. 3 f, j,,..SyY. k}. 1,..h ~' ' iQ < i,.-l, ? '-e, f *;f, g *

• 4' e,
• f ',l %. l..M ' $j -

' 4, " ;[,. g.'., ; -', ' ..gl,.f:'.,tL?,l.q ( ' l, i',l !;i' :'l'y'l, ', '_t* q, ,.l

, l 't

. Mop s * ;.l'. '.

i"**

, le

• U-S

..'s.-.. :l 4;. ' b,7' ,A ,-[s 'r ' c '. x - *,- -  :. n :. r ,, t -

s. w. i a.,., ' +. 4..o.

i& '. ' n,7 .. }.\\ y. e L',,, -.:' ' o v 8. -' ',*. { { a,....p*1-8I t;,, .J 3, N,, , g,Q ',.p 4 3.. .. 9 g', j '. '., '. y S,,' 's.el. :.d.*u 1,. g/ j.- C,h, 4.,., ei ,,c 4,. 'l .'.l,. g.g, *4, f

• e,'.,

4-4, * . ; J,,, s ,'e Oe' b, '. - $-*p',, g, p ,4 6 07 t u,> a' 'j i,, 7,- *, i,, f,,,, y, e. {tW, ' tj- ,.a . r

,'.'. i,,

e, ,,4, .4 s ','.'4 J'. .l .s

.s :

t, 'g ( I I 44 q, J.'.*,,,.,,% g ( '. -,',',i.. : j,1.y a ' y ' y.1 -? i y.59

• '4 g.

.+ - ' I .,3 ', 1.l,.., 7

• . ',., e,
• _ 3, l l. A. '. h, *,. '

[ lJ, L, s , :/pvo,r 3,1 '.w, t t, ,i , c..,. y. s 4 l:d p,.,. f. .. t y., e ' f.,- .9%, .. ".,

• T - ', '.y ' y, _,,9

.e si .,,. y y. p .p e 4 a .e S (.. i

• ',' 4 'I.

sf ,I5 - '5 4. .a p., ,g.. ' -. ' '. ' ' '. -, 5-g 6' Ms, ', *. F.. t. .a a ,1 t '..l- . y 't g. 1, f. e [- - Yd J T', y,.,, 4 .','M,.....d.. (. '. ', l .. a ' [ '.' E A' ,1 Na5',,e,,, i . qi. - e . e

v..

e..41 .,.c ,4, t. ... i l,' 'd,. ,.,y'. ....j. -,. (., .,,,i .iA..- ,1 i. > q ...*-

• 7. !,.

. e. ' y e...w, ' a .. n w', 4,e s. ,.f I 1, .. ,,s, ..f ,1, g r ,.^, ;+ 9 . x. i i r J, ..f.

• .)

, '.l J.,, j f ",.e.# }, -,g

j. y

. 'g...,4 4 .l. 'j (, '. i N.. 3l. ' g '.',,.,,*'~g ,q F'.

• r-e 7, 'g.. ey

. fs..;. P l,,,'..l,w' '..,-* l,

.i

~ .(..

• ,,.. =c.."'w,. >..,.f. f,(.. ' ). j '......,;..., - M.0,4,,

..',9 ..' - ',.., -,,,. : : (, i.'.y n f. N. ~ 4 ;. - - r. c .+. .i. '.,.,,7 . i- ,4 -%,., sA,,, ' i,',-., n,. f yh,n. .,,,..,(*.*'.., 1, ,, yc

• '4.,.

.g, e ,.,f 'n ... g 1 ..'g ),,9 ,h'.. p, y* g. }. 1, ',. '. '.. 7,, -[ T, i.t, f, ' ',,', p.' e, '-( r,,'. 6.,

• -l8.,,8,',

J 4.4*.T ,g', ,g -.,..4 f- .,e g 1 t ,d e, u k g +' .;t 'i _ 'e* .t.' a , i 1 ,,., ' i ' 'p . i e 4,. '$ g

y.i

-.. \\,. ' 'S 3 S, g sj g ".,,e,..* I, ' '6 9' ,t J

• .,'J g.

.,,.'s

t..:

,',.**.I ,,i... ' 4 e . g, 't. 'A,';.',y..-,,.,, g. r e'..,- a '. '[ ',,.7' ' ' lW ' V 9 O' ,'e )' ,f.' 1 '.s. . c, ,,M.l , 7:. ,'s .[,, .Ii , g i ,i. *.,,.*,., y (.( -. {- . ",,,. p if' .'F e ' .i ' /(4, .[, . },,., ?

• • r i O,. j,

})., ' r ';"~ ;,. i,,, $.!- o l-.'... . ' '. '. t a.', ' ] ',. .... l. , s (-

r.. ' ' '. ' - '.

7, '..i. ('. 8e0,R. .. t.. ,, c '..,,,,,.11 [ ' [,3 s g. Id...-,.. ' '.. ' J a* .,,.'g,.i',A,.'f i '* f ,) y -;c O ' ,.,, l ' h * :., , *.,i '. *,. g ;'. ;..., f,  ! ' [. L.. a' 'Yf. ( h,}."'* t ,,' r ' #'be"NL.,<J ','., t /.,. ~, 3 ' l: ' ( "., ' L.' ',. :V O- -.,j,i ~ ' ' ' ? i s -, a ,... }.,. ;.3... m,... : i,,,.,,',';,.'.. - .p'.!.+.v... *.... * ~., ' e/ T.. .t 4.; p...,"f )...w<,,.,y : I,.' t..;. .'.I.. 1.j ' c, 4 (,'i ,.,.... - Q. e

h..'..- >

.y.. .,- 4,':,..',. ' L./ d. i. .'\\.. d f,- i,... p ,

• ts q,

l..

w. r. ..o .-,e (.' h,. ' -, ..,'j'- 4,.- .k ', ' P ..i b.. E.g ['3 */ $.- [ ' 4 i :l.' 1 [ i.. ,l ,a .','0, - ' ' ',, (.,f ' I,b, i# f. l, '. '. i.. g l.j, A. c [ [ h j. (.. 2'" h '. / (4.5.,,h;.,j'[.(,;((..? j J ",Q %. 3 1-s .), 17 p . h,h ~..'Nh ['.,,.' /. /, + + 9. p. ,g +..,.,;.. .? ...

• e 85 o.

n.,.:,....

.t+ i s. ,,- 4 + -. n. ~^(. p .* =.,,c, ,'(',9h

• ,a '4-3.,,.
• I,

3 ,e a =,.. ,,s.,,',.. /q -, .g

• g

.9 3 -t+ f.,

• .i h.4 1.',l :p.,: ' ',

,4 .,g. y r, ,s i- - 6., i t, '\\.-!g,,>'.<.t gi i g 3.., 'e.- g .,' -,, ;r. -,.,, ,,,e g.... *..

• ,?.

.g ,tr ,,i,.*. y T ',,c 4.. p . 4. :e. +. .a. i i.". a 1:.. .?...., 3 '-. ;.. g s

5. l g

a., y

.-, > -..,,; i a,- g ' J,"

• . f,. ' e.
• - - c t' ',

I -. l' .'. Y ' '.', l' ' - ~ 4 .!... p,,,. s, ',,. ;te 'y' a, f.

q. $ '., '.

• y 'f;.

3 ., ", ' ' l' 3 -w...' t','...S.-- i.- f

q. q'.

.2. s s* - W 2'. -4 v t - .s.,. '54 y. .....aVi , c 4,.','c , y y s -{... + [. '.'7 {;,.

> Ig,'

'a .', kJ idif ' i[f ,'l.- .at i f,. l q ',g,o.;.' (,l h' .g \\;l [,. ',',,, ".

4.... -'. d. i '.

.d'+ i 8.- .,. ( r.,f., 4 .g e ., : 3.; , 0.,, . l % Jt r ' i s '. '., y'. j* '(. e, '..../. 8, d ,.... jp. ,d. .. / ', o-i -( l, e, g:- . - pg 4,. p ' - ,g., ..i.. . t g,.n,k. 4. g.. J '.'. g

• e. ' ' ' !p-1,'. ' '

(

• • .l'.

, j ..,v r '. h *,. ;,. t..,/,.N,, & 4' ',' . '.,7. (',8,'.ei'.'A.,

a. '. ? ',..

,e t ', "... --.' i. t. o - ~

• "g

/f:. n*, f 4, '. l 'a [' ' '. ', :. e %, f', ,s.' ' h'g, ' '..p' J 'I . 4,. ' f c, b,5 '- .U

r ',- 1. -,. -,

. :' ' r ?,ljl?,l,..,. ' e c 4, ~e s. i .g, i.wQ. .,s.,v z.. l ? '. *.v %.'l ,i..,..,.' - ,,.,3,*."!',

.h,,. - '. ? ';.', s h t. '..'%'.,..:.3..,...,.,

,','....g.. - s j 1..

• r 1

l,,'I r ..../..:,..p','..,; i. g r, 4gp. -j, 6 4 .rp.- g,,$ - ;-. :. l .,..m# A. 33., $. ' g ? '...y9.,'.. .p. . [,g ' ', ,.p A., -. s- . + "p., f.f ,s, - y .-p - < F *i,p g j, ', f,, ' ' g .,,,M.t. i. - +.. r.. f, y M, ka ..v -o t,,3 ? '[ 'r, 1 h +p. .a. ..+,)'.,,.,..g,g,j;. ;,... :.... ,ys ,/'.,.'\\,;.,,

• ?

h 8 .. 1 - ',. ; t,,,' ;r 5 :., % * '.. ' s. ., ('g.., - l gl gs - ) 1...,p.,...'.,.t ,! N, ,,:i 9 ,d,,.o,',,. t ..,.'"s,-...+ = p y,t,.., 7-' . ',f4 >) 7. 7,. q* n, L f. ,s s r. s .f i ,, p,,.., y-c '. ;; 1 g 7, ..,. 7, ?.@.. 'y. -, ',.. rf. 9 g.a, ..:,i'., .i 1 ,s,*;. <g,,n ; - w g' W ..,.4 L s.. } ? O.. c i : ' n i,.b5 '., - d ; N< )..,. }W .. i, Y sd,, G ' ;. ;.. .l ' n '....

.)

Q...,.' : J . n L l. s' ' L

i... c x$. n,W.. v.

.su

,y.

. ;,q. s. ;~c., v. a.w~.

w v.~

x c.;,... ~:n. 8 ' c... n w : v., :~.,~. m ,..c

lQ-\\. %

w* f v. p. y'% '.v,,.

... v.'

.,., <f 4 _, ly:.. ; [.y.m.,yg 3.. ,t ., u.,,,:.: '. w* i

i. 3 =.;...

?,.. =..,..,.. ~Q:., o ....,$'a -.'.4 q:l,,i',. n. .e ;; '*~ *[. ,G..' ~.. e,'.. q- '... .y.,,e,..' 't. .,,'.[. s., ,,,.. ;. ff. ;.',4, 1. '. ~,..,; :. ; m, ' f j,,,'.},c. %.. k ?,9, .' cl 3...,1 " -, .. -.. c ).,. .f.. -.,,. -1.. } : s .i .g?.g., %p:%g;. % 4.u%.',. V;: s . ' ' 'G.1 ,.1 .,s l,. ,s ,.I'; 3 y V-y t y'. > W.,...W.v;i .'q'f ' M ; :{S ' X q f W h Q. '& W,,'n '}~g,' }N. c ,L ,.</. b.: r Vv :' y. T R-. 'r ( v. yQ..jQ.._, h,l.f: ).. l %l. [. 9 ' a..f.. i ; f ).;i l J R: s: e ,,k\\ f y.b : 'f.,.y;2 % Q.z..Q:";i f. f., v j '.,,, -..,...f. _N.h %.' m.. m . m. ... -'.4,...',..'.. g { _-. ~,,. I y ..s :, ' '.. '. ** v. '.,. ;. gq.'.': C .2,, , >. y) : " 4 y z -(, T +" g g

r. w.. w, s.f4 8 3:

L L v." m,, 3,,9.q,...'.#,4., n.. J..u;,. (. - ..u, c. x,. c.. m. '. c, .-t q:i.,<,'./ ..;,js,.. , y,, t >d y y .;it -*,,7 y ; %y"g8Qp d. p.g'4.,; M !.=; Q. Q,; W(.w.} M_.r:x:,;.c..;u ?.'

.. )[% l A.

ya;y . , 3 r.j &,.(%.t ,a m, ,.y v. ,./.., p. g ,y y g, n?,?' h ;.s isf;M.A :, _ s, .;.g.,.,. ..,. :.g i v. ~;..%., g., w;,s.L. m. ? 7. l; +.%.,:W, . y N t,.?; w.., m.' ;;.; Q.. :r.. J. ? N.N. J. - n.,..a...m.'y r,:p :,:...! w *.,; V Q ;; 4 a - .g .~ t?; M.). :;; in 6 j i l. .c!:p. Q ~.n.,a. [,. l

?.... m Gu

.. y <.. h....k.,,...M. h...... m, n..m.tc.A j, bhhh,...w u.hMh.;.. i r.. .m n w;.<. ~.. .:.w n.. u .h' 11$ k k N. * :.3.-h> :hg.h, n...

1.: e a

kN.hfN v.,. a4.:.<.. .y, y. 7 9 2. k..... s 3 '. A. : a d o

s.-

o

..'..',1.

f'.;.en.. 'I '. <.,...,,.... +. k..., r.. . p; ' 3.;( v. ',.,.... Yc r y; *, f.;..., s e .i.u.e.y...,:.. ...vu. .3 , 9 7.. i,.. - s.,., 's, :.m,s,.a ;;,, s.;.,y,. s.m, y, y '! a. ..;,c.t.,\\ ;.c w + tb,q:s(,.:: 4 , p :p, e,;.'.5,;. ;~..., '.,;; L w. .J . m, '. .. - m:* ..y ,p 1.. , 4,e,.; A s : ry; u.:a -. ;., 4 ,,9 ;.o ', a,,. :,.. ...",..t*.,,.. ;;. sy'v ' *,,'..,g, ; s, /. \\ g. y e. '.,y',. <,.. a.. ;.>.(.,. o z..:.._, :,,, s,

l. ~L 9 e 3

1 ~ ..,.y :. .; a-: o, %,s j..~ 4 y ,o. a;. ..}}