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_PB,1NC PAI.A T\FF MEMORANDUM FOR: Robert Carlson, Director, EIS, RI DIR v._&Is Carl Alderson, Director, EIS, RII pfp g
- Robert Warnick, Director, EIS, RIII James Gagliardo, Director, EIS, RIV UD blo Allen Johnson, Director, EIS, RV g FROM: Dudley Thompson, Director DE
- Enforcement and Investigations, IE DEP605 File
SUBJECT:
INVESTIGATIVE GUIDANCE MEMORANDA The Chairman has directed that we develop guidelines, standards and procedures regarding investigations on a priority basis. A copy of his memorandum on this subject is attached for your information. We have developed a schedule for accomplishing this and will provide it to the EDO shortly. I will provide a ,
copy to you as soon as it is approved.
As you know, we are not without some guidance concerning investigations. Various tis have been issued on a number of topics such as oaths and affirmations, format for written" statements, handling of potential criminality, and Miranda warnings.
We have attempted to minimize the use of less formal documentation such as memoranda. However, the dynamic nature of the investigative program, the considerable Commission-level interest, and resource constraints have led me to conclude that we need a more responsive mechanism than a II. As a result, I propose to establish a system of Investigative Guidance Memoranda (IGM) anal-ogous to the currently used Enforcement Guidance Memoranda.
The net result of this is as follows: Investigative guidance to be followed during the conduct.or documentation of investigations will be by means of an IGM. Procedures that affect other NRC components such as reporting of potential criminality or contacts with 00J will be by means of tis.
i NOV 2 5198f 2
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. Regional Enforcement Directors * - . - . -
3 Our eventual goal, of course, will be to incorporate as much of this as possible into the Manual Chapter on Investigations, although there will undoubtably be a continuing need for IGMs due to the dynamic nature of the Investigative Program.
',ylf' udley apson, Director Enforctment and Investigations Staff Office of Inspection and Enforcement Encl: Chairman's 11/16/81 memo ec: V. Stello, DED/ROGR ,
R. DeYoung, IE e
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I 254 W DNESDAY, NOVEMBER 18,1981 '
A GANNETT NEWSPAPER i
. , I s It BmigledtZimmer Plant Probe- for Cincinnatt Oas & Electric Co.
l l
- 138 RSMS , pursued his charges through the federal released Tuesday concluded.
, <cO&E3 on timecard cheating at the bii- nureaucracy with the heip of the Gov- The same official summary supports.
i l gg YOH By gy lion dollar power plant in Clermont - ernment Accountability Project (OAP), Applegate's assertion that his origshal
} County. a Washington-based watchdog group. = dismissed by the NRC.
age A-6. ,
lie told the NRC that mistakes on That provoked the NRC into a sec- complaintvoo$n
. "The Re: III invesugative effort i
safety-related systems were being ond look at Applegate's allegations and did not adequately pursue all of the alle- .
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necessary gnternay ,,g .
covered up by contractors and CO&ta ' the way its regional stafI had respond- gations la sufficient depth or breadth i:
j Region III NRC Inspectors from ed. j.
th al uons by rl. and lacked adequate documentation."'
i invesug torThomas Applegate t " " the summarysad '.
{ u tan "Applegate was correct in saying that
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.e.r. defecuve welds in safety-related sys-(See ZIblMER PROBE.:
Applegate worked undercover briefly _ APPLEGATE CRIED cover-up. iip tems had been accepted." one document back of this section)-
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--* Ea,*er t.ebeann eureew smelling salts were to wake her up. he added.
LEllANON-James Besser said p
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- '.,M County motel room last July. ness " Desser also put for himself 2,
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graphsof her. hose.t Iwasgnd a box of con-
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g A-12 THE ONCNNATI ENQUIRERAnlednedar.finarrnher M. Ital . n i .
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.e They "falled to determine the correct e- t ~~y .he commit- e - bl _ s.
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e "The overall invesugauve effort was neither vigorous nor sufficiently broad in CONTNUED FROM PAGE A-1 there was 5% cutMr.
j gi * . CONTINUED FROM PAGE A-1 '
'"The finding 'not substantiated' with the measure, which would allow its sources said i :
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Les hday, Applegate said the full re-port also points to a coverup by CO&E. lie said regard to the allegation that defecuve welds in the government to spend the House had relayed word that the money through the end of the President was likely to veto the 4]. It specifles which pipes and welds were chang- safety-related systems had been accepted is ed Dehind the backs of NRC Inspectors who notconsistent with the facts." fiscal year next Sept 30, or unut measurs unless it rentained a 5%
! l" were examining documentation on supposedly Despite these findings and another, the regular money bills were across-the-tacerd spendmg cut.
- j. incomplete Investigation of quality assurance passed.
There appeared little chance i
, sound workmanshtn at Zimmer,'Palladino said nothing "to date" Senate officials atid the ~ Congress would meet those I AppIerate said he felt vindicated by the indicates that the " unsatisfactory" N RC re- measure approved by the com- terms,efficials egreed.
i i report and predicted more bad news for CO&E sponse to Applegate's charges created a dan- mittee calls for spending of H15.3 "I would urge you and your f
{
j next week in another NRC report -
ger to public health. - , blillon-a level ther insisted was colleajuee in Lhe Senate to only $100 million above Mr. Rea- adopt a Mt across.the. board !
Some NitC staff members said Tuesday CO&E agreed.
9J "It's pretty hard to quarrel with his post. gan's request. Administrauon reductlen, Mr. Reagan told I
that conditions may be worse than the report l Y. tion," spokesman David Allemuchle said. of ficials disputed that figure, al- Baker, adeng.*lt is crucial that
-We've always expressed our confidence in the though they could not immedt- fiscal year 1982 spending and l A indicated.
safety and lategrity of Zimmer." ,ately provide their own esumate defielt levels be constralned to ON E OFFICI AL close to the investiga- of spending in the bill. .the maahames degree feasible."
4 tions, who asked that his name not be used, THOSE ASSURANCES anucipated the I said the crlucal report "was watered down."I first major emergency preparedness drill at j e lie said bureaucraue cauuon kept the lan- Limmer and in Clermont and Campbell coun- 7. g ,.Qg- "z". g^., , 'g "u'7" y' g' '.ct ,"g.; -
p j guage from being stronger. - -
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j 4 Palladino's chler investigator, James J. '
cu mmings, supported that contention. Today, while the NRC judges CO&E's abil- ,
i l Q@ In ms ice . . .- . -=F. Lum =msa lty to cope with a mock accident at the reac- g a
1 p said NRC regional inspectors didn't even re- tor,other federal of ficials wl!! review how well
.vlew data on "spect!!c welds alleged to be county and state agencies would have been- p ,"
.4p defecuve" although there was a history of able to protect the public. N 6 ~
Letters by Palladino, Cummings and sup-g, - ' ,
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'Y such problems at Zimmer.
- h I . porting documents were released after The ,
4 Ly Moreover, other NRC investigations are Enquirer filed a request for the documents suspect, Cummings indicated in his memo. under the Freedom of Information Act GAP.
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f'f/ randum to Palladino and the four other com. also filed a request ,
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Cummings said his staf f "made a con- Despite Pa!!adino's conclusions, disagree- -
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7/ scious effort to temper our evaluation process ment exists within the NRC, i e ,
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with the very obvious f act that few Investiga - William J. Dircks, executive director for l" -
t t 2 tions can successfully withstand the crluctsm NRC operations, accused Cummings of falling g 4 .
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-' 4 of aMondaymorningquarterback." to understand "the NRC mission or priorttles, 1 A" .
L Cummings said blame "must be shared
- no't only by the Individuals who were specift. orstruction processes 4 of aand controls involved planL" in the con- f i nucicar power l k . cally assigned to the case but also by regional L
. . officials who faued to properly supervise the . None of Applegate's charges are substan-j ,
, tial, Dircks said. Moreover, NRC inspectors are l l . . Case.
catching construction problems, including "
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PALLADINO RELIED on data from Cum- welds, and CO&E or its contractors are solving' lh
'.mings* Of flee of Inspector and Auditor. It them' *
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. of Inspection and Enforcement,saying* "I am unable to conclude Lhat the Office e They "falled to properly document the of Inspection as Enforcement Investigation of j p h m
g results of investigation both as to Interviews Applegate's allegations was unsausfactory," ;
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- s. s UNITED s7ATES
, NUCLEAR REGULATORY COMMISSION
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..,;, . . . .. November 16. 1981 . . -
'Imiamn ,
MEMORANDUM FOR: William J. Dircks
. Executive Director for Operations 7
Nunzio J. Palladino i/
FROM:
SUBJECT:
CIA REPORT ON THF. ADEQUACY OF THE DIE INVESTIGATION AT THE WILLIAM H. ZDNER NUCLEAR POWER STATION -
I agree with OIA's finding that 01E's original investigation should have been more comprehensive. I believe we need criteria to detemine the instances which require full-scale investigations. The NRC does not have the resources to conduct in-depth investigations in all instances, and such in-depth investigations are 'not called for by the circumstances of every case. However, when a full investigation is called for, as for example in the case of possible criminal conduct, NRC needs' to conduct that investigation consistent with fundamental standards that govern investigations by any agency. .
~
Please develop ' guidelines for determining when to conduct investigations, and establish more femal investigative standards and procedures for such investigations. I believe it could be helpful to consult with OIA, and perhaps with investigative agencies outside the NRC in connection
' with this effort. I would like you to provide SECY a schedule indicating
- when you think the new guidelines, standaras, and procedures can be completed.. .
cc: Comissioner Gilinsky l Comissioner Bradford - '
! Comissioner Ahearne .
l Comissi6ner Roberts SECY - -
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institute for Pchey Studies 1
1901 Ove Street. N.W.. Washington. D.C. 20009 (202)234 0382
. November 23, 1981 Dixector office of A6rinistration FREEDOM OF INFORMAT10t{
Nuclear Regulatory Ccmnission ACT REQUEST Washirgton, D.C. 20555 -
fCY] A- @ h Q P Ts kh::m it May cancern: Gox. Q \ \ -3 0 - 2 I On behalf of our client, Mr. Thomas Applegate, and pursuant to 1:eth the Freedom of Infornution Act (5 U.S.C. 5552) and tha Privacy Act (5 U.S.C.
- 5552a), se request copies of all notes, rre.oranda, telephone logs, tapes, diaries and/or other records prepared by U.S. goverr.ent e ployees in connection with an August 7,1981 Nuclear Pegulatory Ccmrission ("NRC")
Office of Inspector ard Auditor ("oIA") report entitled "Seecial Irruirv re:
Maquacy of IE Investigation 50-358/80-9 at the Willia:n H. Zi:nrer Nuclear P w- station " ("Zirrner CIA Peport"), as well as the investigation the Zirrner CIA ;tsport is based upon. In particular, dr. Applegate requests all earlier full er partial drafts and/or proposed supple:nents t6 the Zinnur CIA Ps;crt, as well as all records related to any deletions fran its final versien. If any rr.aterial covered by this repast has been destroyed .
and/or reeved, please provide all surrounding dec. nentation including bt not li:nited to a description of the action (s) taken, relevant date(s),
and justL'ication for the actien(s) .
i.
ft. Applegate regt.ests that fees be waived, because " finding the inferrration can be censidered as prirrarily benefitting the general public. " 5 U.S.C. S 552 (a) (4) (A) . The fee waiver should he granted for three' reasons. First, he schnits this reqbest to further the goals of his C h h 10, 1980 whistleblcwing disc 1csure to the Cffice of the Special Counsel of the Merit syste.s Protection Beard. 'ihe Special Counsel required an N;C investigation only after finding a reasonable b211ef that Ft. Apple-gate's disclosure evidenced illegality, r-ismanage:nznt, gross waste and a substantial and specific dnager to public health or safety. Unques- -
tionably, the Special Counssi finding and tre ensuing OIA Papert.- which fundmentally challenges the generic nature of NRC investigations -
prcves that it. Islegate's ccncems serve "the public interest." He seeks these doeurents in order to nonitor the adequacy. of the NFC respcnse.
Second, the findings of the Zirnmer CIA report totally ignered two vital issues in Mr. Applegate's whistlebicwing disclosu:n -
- 1) the failure to adequately review his criminal allegatiers of widesp ad black: arkets, s ruggling, and theft, and ,,
- 2) the fnilure to ecntact witnesses in 79:11 1980 who sculd hevo exposed a series of issues six nenths b2 fore gip raised then with the ccm-ission and the special Councol.
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R office of Mministration Nuclear Regulatory camission .
Noveber 23, 1981 Page Bo -
me special counsel had ordered the comission to respond to both allegations.
Se docmants Mr. Applegate roguests nay help to explain why the comission chose to defy a legal requi....at of the Civil Service Reform Act. We subnit that it inherently serves the public interest to further undarstand the process that leads to governnent illegality.
Third, press accounts have contained charges that the report was " watered
&wn. " Although deleted portions would not represent tha Camission's findigs, it is in the public interest to fully air the facts and conpeting policies '
in the debate that produced this controversial doctrnant. De issue is of the utnest inportarce to the Anarican people - the adequacy of NRC efforts to protect public health and safety.
Fca any doctments or portions of docrants that y:n: de .y d..e to a specific e .yi. ion, please provide an index,itamizing and describing docunants or portions of docments withheld'. D e index should provide a detailed justification of your grounds for claiming each exemption, wh%ing why each exemption is relevant to the dceujent or portion withheld. 1his index is required under Vaughn V. Rosen (I), 484 F.2d 820 (D.C. Cir.1973) , cart. denied, 415 U.S. 977 (1974) .
We icok forverd to your response within tan wrking days.
Sincerely, gg b-,1 . ,.,.
Associate Director
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i 31t 3acIn t Cridque BY BEN L.K AUMAN Whatever their differences q sawwswew about the CI A probe. Chatrman 'O r Ud P Nuctest Regut. tory Commission h*I ag, odu".n gon Il ro e
- l. * %. .. , (NRC) employees responsible for Inspections and enforcement at uon meets !;RC requirements. '# - .
( The OI A report is so riawed i
1' g * .T Zimmer power stauon say they .*
3 1 that it does not alter that tonclu.
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kU-Chicago-based Regton 1D staff . Poster.said the CIA report at members blamed a recent repors Zimmer *coes not deal with att
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spector & Auditor (01Ak questioned stess, significanuy mischaracterises statements .-J
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'd- 3 ' the regional staff botched its teso does not document mterviews probe of complaints about dan. conducted, contains statements i.
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serously shoddy workmansfup not supported b fact and renches i p *i and cover-ups at tammer. Inaccurate co ustona y. ,a,* -- A %e, gg *'*g s
/ .' But Regton III investigator . * *11 also appears that the%ves.
Rf ' % 'J l James E. Foster said OIA was .tigauve e!! art neither included Kf K . ? ** ,f M'k g M [h Q I guuty of everything it unjusur ac. Interviews of pertinent licensee j L cused regional personnel of doing, (CO&E) sad contractor raonnel.
fg- . QQ-be saki. reviews of appropftate g -p*/ '_
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. Dgulter, he characterised 01A veloped crucialtaformauon?
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- Innsugator.O.A. Phlulp. said 01A that the NRC probe was not to m ,d
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- errors raised doubts about that . vindicate or discredit a crtue or to brancW: understandings of new make an accounting to Abe r, .~ D'* v '
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Comments by Poster and Pht!. The Reston III pr'obe's prtdiary " -#d 9* fM lip were part of the Region 11I objectins were to see if Zimmer
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- g. , in september, whether they were requirements, whether zimmer A 3 i
persuasive was not elear, consututed a hasard to pubite ,.
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,' . e .j8 /gqi y(a NRC Chairman Nunslo Pal. healt.*n and safety, "and to take (
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- . s et another w- war = am. legedly ha$ Deen accepted as g . etal in WWetnn told The KH. good. Region III staff checked to u
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mrar taa6 raundmo was only . see if bad welds had a11pped past FIRE GUTS HOME: Fire Cast. s
,Iducting n no-wto* fight with Imat tazpecuana. Eurytning was by a ttree eierm fire Tuesday rsgNt. 7 r*
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-v.s. Rep. Morris Udall, D-Arts, fine. "No noncompuance regard
- Florence, Ala,where Na wife Lo he
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N .Iwho chairs a key House subcom eing these welds has been idenua neegreers whe nenfed Brewer Tuesda n- .mtuee on energy and the envi- fled? rh111tp wrote.
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. whaient Palladino's mouws, . specuens.gnored Theyi Poulupe preuminary prior to final in.
Thwe wwe ne us. ' ~.
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wrong. '
- OIA stood truth on its head, wassaid;"The history of the welds 4 (OyedrrQM *. W.
not viewed as signifncanL*. . ,
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- Repp er. O!A conclusions are, O!A crtuctse of examinauon of PEILLIP ALSO *rondemned Fli s OnI-75r i *
.31 unsupported "but de (Foster's five pipes maahandled during i fT *1 *
' t*v {emphasas) apply to the O!A re. dettwry.
%O The sector invesugator sent 1U1HJUl*CQ*
. i-e ttew? Ther were: .
- c' e *"I'be invesugauon failed to the restonal director a 38.ltem A 33-passenger Ford statbus
- 5 H Cyroperty document the results of
- criuque of 01A'S toport carrying the Thomas More Col. *
- antesussuon as to latervlees and ,' Complaints about sloppy work lese varsity and jtintor varstly .
I matertai refleved? . . and quality easurance oogged basketball teams and three
- r! *,g lpesar*mine the cornet status ange trien.The invesugauon faued to *coaches construction overturned through on Interstate much -of th q .ntstory of several welds? Witnessee at fleensing hear. 'fs afternoon, near Oeorgetown,causing attnor xy. Tuesday injurta,*f y e *The overallinvestigauve of. , Ings tried repeatedly to se& the
- l e fort was neither vigorous nor NRC to pay stianuen to their no te and totany wrecting tne van, j 3 3, cono,,, gl,, ,es,.ea esufficienur breed in acope? . eastges of sneputude and dis.
ar. . And, Foster noted, CIA apper. honesty at the construcuen ette. . head coach of the TMC Rebela j i
ennut recorded laterviews witn in. Was in f atr condigon la JehB The NRC saad criminal mat
- epecuon and enforcement staff, ters are not its primary concern Oraves Memorial
.a Ho. spital 18 1*
- tecreuyl and assured crtues that the qual.
3 ; Regional offletals vere in Cin. Ity maeurance program would + e-
' etnnau Tuescar, etscumstng their catch f aulty work before the Tn[4 E n 6 1
Invesugauons with of fletals of hulton-dollar plant in Clermont 1 Q1 L LJG 3**"
11f a sp.
octncinnas! Oss & Electine Co. County was licensed for ep(ta. . * .+'
(CObsk -
tions. Ohio needs more' money for edee f '
. Neppler would not say whether Sut recency, the NRC ordered more incenures for new Joon, as CO&F. faced hefty fines for als. CO&E to assume all gus11ty assur. maintain its present level er supr*8 3.
tases at Damer, but he indicated ance responsibutues sad to bring services. Republican tuberna.'cns-
, that questions about contractors its staff up to demands of the lot. Seth Taft said Tuesday, hiding sloppy work would be on Contractors lust weren1doing the And. Taft said. tne state . shou!C
, thesdenda, job. Region !T1 Inspectors said. de all this witnin the present le*
.* None of the Then NRC ordered CO&E to uon?
squire shutung boblems en construe. would recheck all safety related spo. ** *t, a retar
- 4ttorrisy and
,lon, he added. Elmser le to tems. That's gotng on now, of the Cuyahoga County CommW l
lenerate electricity commercia!!r If NRC off1ctals are cornct. EnguJter that tae maJos campaign
.wlthin two years, accordlag to that problems involve sloppy be jobs, schools sad federal cutone'
,CO&E;alatset schedule. ' documentauen. net careless wort he La runntag because he gets "as and systemaue cowr ups-then sausfacuen frem selving ethers
- pft NRC AND CO&E epotesmen NRC precedures f.or finding,
- have scheduled separate preas tracting and correcung construe. EE S AID the htgh unemploye,
,,,,,,,., tenterences today, uen mista.kts are suspert. the state shows the need for st*8
, - -y ,a n w:. mrusanw ee -
e.
, _ . _ . _ _ . . , , _ . . _ _ - . _ - - - - - , . . - - , - - - --. - - - - - - - ' - - - - ' - - ^ - - - ~ ~ - " ~~
m: .1 ouannan o umcc macu wunco vupcquengwsp p. . . .
. f Congress should consider establishing an . lines legcommenbne . !.'OlA reports,on\ par...Y t Nlt ama and lie.n, etencene e_ K A Ut ..v e4
,,, 9 Of flee of Inspector General at NRC. ' s. Ucularly if a disagreement or,~snisunder- . tratayl fis standing exists.
ve resoure (4 Such a move would be desirable "In . . .. - .. . : i alm ed at eli naung.f raud 4
4; e' . cous.t em- (e rice esi AO) report view of the crlucalimporLance of etrecuve .~. "Further, we found certain Instances 4ritha N .
.'t.
- t -
l
- ' - I .a el- .' et. : ..latory and efficient regulation to the future of where OI A reviewed and apparenUy sp');;. , O A that Of a dI
- % pros. .. Inse,et Lions commercial nuclear activities
- OAO said. 8 proved prograsp offices
- comments before.Pinvesuget reports lack at ll
-eu. ne t Lhe Zunener power An independent Inspector Oeneral ' accepting the n and including (hem on its that inves uve teports lesued l
- could better evaluate NRC's performance; e reports. , ,( f , .'"e*A :4K.i m g.dnoconclus recommendationdt <- e' e is.. t * :.s NflC's Of fice of In- combat fraud, waste, abuse and mismanq .*;. *. 's" r -
- el 6 . ** * . t. s. It '.a.m e inspart on ORA's fallere beerst..r .oI Al. whicle enumines agement; anel assure that both Congressu : ,*I.ASTIJ, WE noted certain.InstancesJto produceA tung forth pelectes,
. in tia .mc !or lucptitude and .and the NRC commissioners receive objec. . were OI A undertook joint lawestigauens.e. proceglures and gu " evert though l$-
.*.4 . : L saltl. In 1F85. tha$ its, snedsate plans inr.
. e.t.1 k.w. J Pai(C rol cagues in Live Informatioh neulcar activiues? N on problems involving,
- .e .*. wth other program
.? * .48/These molnts, collect offices.:ively', Indica 44 dc2nde the development of ouch amanuaL" at lx .4 sung as. luvest gation of ~ When GAO looked four years ago. NRC kthaR .DI A*l Indpendence, deeds to be..?* ' OIA found fault,with the lege llegion.
.s .:'c,III invesuga
. . of . ..: errously shoidy work seemed too small to warrant the inspectoce' strengthened."
ut.5 a vs.unser general operauon subsequenUy ordered .., Another problem is that. DI L 't A reports.. canissions. ... . gion . e. 34 .y.lsamer
. .t ** . e .: fpr* singlarj
.. Ill e.asa tals re.por ded that for 12 federat agencies. ,
'are " Internal management documents J;r .In addluon to.its recomsnendatlesi'of*
- e. 4:e r n g tent umi that OIA . that are not generally released outside of f an Inspector General, OAO suggested the
..: cr .~, at unjustly < harged to NRC'S FOUI,UPS at Three Mlle Island g .NRC.*0 AO said.- . .~~
- OIA: "t J g. .
and elsewhere changed that judgment,1 P That was how OIA handledits review of;. < e Develop a pryotem for pla. -nning d
. v-r; :I e.astles .lanwwhich do G AO ncknowledged. e- 4 Region III's leso invesugauon kt Elmmer. 'su 1 setting priorttles for audit and in a4
.n t ree ne. u.e r 1 rtet.e e.perifically NRC commissioners disagreed, saying v. OIA completed its review of the invesu- .* Live work that compiles'with Of of s t.: tho..e of Rei;tess: Ill than Hist OI A is being upgraded and will be . gauon in August bdt refused to release the. . Management and'Besdget criteria a,nd y damning findings to TheEnquirerdespitoV OAOguidance. '
to adequate. ~'*****4.
wie 01 % managensent, lack of A key G AO crluctsm concerned ,OI A A Freedom ofIn*ormauon Act reguest.
e.e an.: . unfilets of Interest are independence and conflicts of Interest. . . That repot) was released in mid f e o onConcentrate' internal fraud and investigative' waste.. resoutpps d8 Nt : It's fine that DIA reports direcuy to the November because NRC Chairman Nunzio*b e Avoid assigning auditors to insdstigEA Palladino presented.it, approvingly to a.'.tivework.
N RC commissioners and la "thus organisa-
- es e. s.a.' 'lut s f i elke-J on tionally Independent." G AO said, but
..: ut t i..: :am;-al.preneet prac- operauons are too vulnerable to internal;', environment. '. " '
'Ilouse' 'subcommitteq**"d "on energy and the . , ' e co-ordinat xmg scures of employees to take agency pressures. ' OAO said spanagespent weaknesses also e efforts te ldentify
. e Develop thatpossible long-promised assignments'ds-ope
.t. . . *:- ... **:**
- r.ms u s.ers of Thrre Allie is- "We founti several instances where * 'tontribute to work which can beless thast,f ons h manual. - -
mvestas:atmg what went wrong findings, conclusions and/or recosamen. th o Begin to snonitor assignseents se IIhat Aer plan'. dations were revised or deleted primarily pact. [ ssatisfactoryin
.t
. e- eguality[q.agliness
. lateilleent decisions and im-f can be: erade whether
.I employees aIso charged NRC because NRC programs officials disagreed," W' .^~3. - f to increase. snalntain or reduce W
. ima turalt O Ao said. "*! . '*0!A HAS foclased toe'sadeh of itsI.'icoenmitted toajoh.
G AO said.
.is the Lind of problem in OIA's "We also discovered that OIA rouunely' i attendon on administrative and personnel 8t ' o Establish and enforce'requiresngnis e that led GAO to conclude that allows program officials to exceed dead. matters rather than en the sporejugpor '.. forfollow-upotaudits anginvesugationa..
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