ML20137Z097
| ML20137Z097 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1997 |
| From: | NRC OFFICE OF THE INSPECTOR GENERAL (OIG) |
| To: | |
| Shared Package | |
| ML20137Z102 | List: |
| References | |
| OIG-96A-10, NUDOCS 9704230357 | |
| Download: ML20137Z097 (16) | |
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OFFICE OF THE INSPECTOR GENERAL U.S. NUCLEAR REGULATORY COMMISSION MANAGEMENT CONTROLS OVER i
NRC PROPERTY AT DOE LABORATORIES SHOULD BE STRENGTHENED OlG/96A-10 March 14,1997 AUDIT REPORT I
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Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened y
-l REPORT SYNOPSIS Since 1992, the Office of the Inspector General (OlG) has issued three audit reports addressing the U.S. Nuclear Regulatory Commission's (NRC) financial and
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administrative accountability for work placed with Department of Energy (DOE) laboratories. The agency recognized the need to strengthen its control over this work and issued Management Directive 11.7, "NRC Procedures for Placement and
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Monitoring of Work With the Department of Energy," (MD 11.7) as the primary means to resolva OlG's reported concerns.
Subsequently, Commissioner Rogers asked OlG to determine if NRC's revised controls over agency funded property at DOE laboratories are adequate. As a result, OlG initi?ted an audit of this area and expanded its review to determine f
whether NRC project managers were effectively implementing other applicable procedures contained in MD 11.7.
We found that NRC project managers have made important progress in administering and controlling individual projects contracted to DOE laboratories.
However, this management should be strengthened by improving the management controls and implementing a streamlined process to aggregately track and oversee NRC funded property at DOE laboratories.
Our report makes three recommendations to NRC management for consideration in providing better accountability for NRC funded property at the DOE laboratories.
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OlG/96A-10 Pagei
l Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened 1
TABLE OF CONTENTS l
REPORT SYNOPSIS..
i INTRODUCTION......
1 Background.......
2 l
FINDINGS.....
3 NRC Does Not Ensure Property Reporting Requirements Are Met... 3 NRC Should Develop a Consolidated, Streamlined Approach to Managing DOE Held Assets....
5 CONCLUSIONS.....
6 RECOMMENDATIONS 7
AGENCY COMMENTS
.7 APPENDICES I
Objectives, Scope And Methodology II Agency Comments I
Ill Major Contributors To This Report IV Glossary: Office of the inspector General Products I
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Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened INTRODUCTION in 1992 and 1093, the Office of the Inspector General (OlG) issued three audit reports addressing the Nuclear Regulatory Commission's (NRC) financial and administrative accountability for work placed with Department of Energy (DOE) m laboratories. The first two reports discussed serious breakdowns in NRC's financial management oversight and identified eight areas for improvementm The third report stated that NRC had initiated corrective actions to address the deficiencies cited in our previous reports.
Because of his concem about whether NRC managers were exercising adequate management oversight, Commissioner Rogers asked OlG to determine the adequacy of NRC's current controls for agency funded property at DOE f
laboratories
- and if NRC had effectively implemented them. We subsequently expanded our review to determine if the agency had effectively implemented other applicable procedures contained in Management Directive 11.7, "NRC Procedures I
(l)
Improvements Needed in NRC's Process for Approving Payments to the Department of Energy, OlG/92A-08, August 31,1992 Improvements Needed in Financial and Administrative Accountability for Offta '. f Nuclear Regulatory Research Funded Work at Department of Energy Laboratories, OlGl92A-20, March 5, 1993 Independent Review of Financial and Administrative Controls for Work Performed by Department of Energy Laboratories, OlG/93A-26, December 14,1993 (2)
The eight areas of NRC financial management previously identified as needing improvement were:
- Project Closing and Deobligation of Funds
- Accounting for NRC Funded Property
- Transfers of Prior-Year Funds
- Final Laboratory Performance Evaluations
- Tracking of Project Status
- Review of Project Costs
- Organization and Retention of Project Files
- Training of Key Personnel (3)
Management Directive 11.7 (MD 11.7), entitled "NRC Procedures for Placement and Monitoring of Work with the Department of Energy " includes NRC's controls for agency funded property at DOE laboratories.
olG/96A 10 Page1
Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened for Placement and Monitoring of Work With the Department of Energy" (MD 11.7).
Appendix I provides greater detail on our objectives, scope, and methodology.
BACKGROUND In 1978, NRC and DOE approved a Memorandum of Understanding (MOU) regarding NRC work placed at DOE laboratories. The MOU established an overall management policy that included guidelines for program planning, implementation, j
control, and funding of the interagency research and related programs.
In December 1992, the Executive Director for Operations (EDO) delegated i
oversight authority for the contract management of NRC projects at DOE E l laboratories to NRC's Office of Administration (ADM). This EDO action followed gI criticism by OlG and other intemal agency review groups of NRC's project management practices. The EDO also released the draft of a new management directive (MD 11.7) to provide guidance for contract management at DOE laboratories. One primary objective of MD 11.7 is "to ensure that a framework exists for program management control, administration, monitoring, and closeout of projects placed with POE." The EDO directed ADM to initiate a 6-month pilot study within the Office of Nuclear Regulatory Research (RES) that would serve as a practical basis for evaluating the use of MD 11.7. The EDO's goal was to develop and implement an agency-wide standard for managing work placed at DOE laboratories. ADM completed its pilot study within RES in July 1993 and NRC sought DOE's endorsement of MD 11.7 in December 1993. Following consideration i
of DOE and various NRC program office comments, NRC issued MD 11.7 in May 1994.
1 in June 1994, NRC conducted a seminar on implementing MD 11.7 for DOE and laboratory personnel. This seminar served as a vehicle to clarify directive provisions and as a forum to discuss DOE and laboratory issues and suggestions raised about implementing the directive. In August 1994, DOE agreed to follow MD 11.7 procedures beginning with proposals involving Fiscal Year (FY) 1995 funds. DOE Headquarters provided its own guidance to DOE Operations Offices to clarify MD 11.7 provisions and to address issues raised by DOE and its laboratories.
One process identified in MD 11.7 pertaining to the control of NRC funded property at the DOE laboratories requires that DOE prepare by November 15 of each year OlG/96A-10 Page 2 I
Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened a 2-section comprehensive property report. DOE is to send Section 1 of the report to NRC's Division of Contracts and Property Management, ADM.W This section is to include a listing of all NRC funded property at the laboratories which is either sens'tive* or had an acquisition cost of $5,000 or more (general property). Section 2 o'the report is to contain NRC titled software maintained at the laboratories with a useful life of two or more years and an initial development or acquisition cost of
$25,000 or greater (NRC titled software). More specifically, Section 2 is to include software purchased during the current fiscal year, in the process of being developed, or operational for less than four years and delivered or intended for delivery to the NRC. DOE is to consider all scientific codes as NRC titled software regardless of where the codes currently run. DOE is to send this section 1o NRC's Office of Information Resources Management (IRM).
FINDINGS Overall, we found that NRC project managers have made irr.portant progress in managing individual projects contracted to DOE laboratories. However, we believe NRC continues to lack adequate management controls for NRC funded property at l
DOE laboratories in the aggregate. The agency is currently revising MD 11.7, and therefore, the timing is opportune to strengthen and recons ider tht; management processes and controls over NRC funded property at the DOE labocatories to address this shortcoming.
f NRC Does Not Ensure Property Reporting Requirements Are Met f
Although DOE provided NRC with a general property listing, we focad that DOE has not provided an annuallisting of NRC titled software. As previourly noted, MD 11.7 requires DOE to provide NRC with an annuallisting of NRC funded general property
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(4)
The current revision of MD 11.7 identifies the Division of Contracts and Property Management.
Based on a recent reorganization within ADM, a proposed revision to MD 11.7 identifies that this section should be sent to the Division of Facilities and Property Management.
(5)
Sensitive property consists of items, regardless of value, that are considered to be susceptible to being appropriated for personal use or that can be readily converted to cash. Sensitive property could include such items as personal computers, printers, and cameras.
olG/96A 10 Page 3
Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened and titled software at DOE laboratories. We also found that neither IRM'nor ADM staff were aware that the agency did not receive the required DOE report.
Moreover, a senior IRM official told us that MD 11.7 is an ADM directive and, therefore, he did not believe IRM had any responsibility regarding the DOE inventory of NRC titled software at the DOE laboratories. As a result, NRC lacks adequate controls over NRC titled software in the aggregate, including expensive software developed by DOE laboratories, for scientific and analytical applications.
DOE laborWries currently maintain NRC funded general property with an acquisition cost of over $10 million. This property includes such items as personal computers and computer work stations, tape drive units, oscilloscopes, systems g
digital controls, and spectrometess ranging in acquisition costs from about $2,500 g
to about $57,000 each. Previous OlG audit reports
- also identified that, between FY90 and FY95, NRC planned to spend over $45 million in active and planned g
research projects dealing with computer simulation studies of nuclear reactor E
operations and accidents. This data represents only a partial amount of NRC expenditures for equipment and software that should be tracked.
Additionally, the agency is currently involved with several activities that demonstrate the need for accurate reporting and tracking of NRC titled software systems maintained at DOE laboratories. For example, the agency capitalizes certain NRC titled software for financial reporting purposes and, therefore, accurate and reliable information pertaining to this NRC titled software at the DOE laboratories is essential. Also, the Office of Management and Budget is spearheading the evaluation of a government-wide Year 2000 computer issue which may affect the agency's systems. Without a complete and accurate software inventory, NRC cannot ensure that all agency systems affected by this or a similar type of issue will be evaluated appropriately. Finally, the Information Technology Management Reform Act of 1996 requires that NRC establish and maintain a detailed process to controlits software inventory.
A RES official told us that DOE's Energy Science and Tech ology Software Center (ESTSC) maintains an inventory of NRC titled software systems at the DOE laboratories. We found, however, that NRC cannot rely on the ESTSC listing of software to be representative of all NRC titled software, including that maintained (6)
Performance Criteria and Better Management Oversight Needed to Enhance NRC's Research Program Contnbutions, OlG/92A-11, March 8,1993 Review of NRC's Research Program Management, OlGl94A-29, March 1,1995 OlG/96A 10 Page 4
Mena@ ment Controls Over NRC Property at DOE Laboratories Should Be Strengthened at the DOE laboratories, because the latest ESTSC listing identifies 147 software systems by acronym name only. We also were told that the systems identified in the ESTSC index may include software syt.tems other than those maintained at the DOE laboratories and software systems that have been jointly sponsored by NRC and another entity which may not be NRC titled software.
As discussed in the foDowing section, we believe NRC needs to consider ways to improve the agency's ability to collect and use timely, accurate data on NRC property and software held by DOE laboratories.
NRC Should Develop a Consolidated, Streamlined Approach to Managing DOE Held Assets We found that the current processes and controls to manage and track NRC funded property at the DOE laboratories should be strengthened. As previously noted, NRC did not receive the required inventory of.NRC titled software at the DOE laboratories, and no one in NRC recognized that the agency did not receive the report. Additionally, there is no current guidance for using the inventory and, as a result, staff did not use the DOE general property listing as intended. Although DOE laboratories send Monthly Letter Status Reports (MLSR) to NRC project managers detailing property purchased, the data is not entered into a centralized agency inventory record. As a result, NRC currently cannot ensure that existing property is considered before approving purchases for new laboratory projects.
In response to our previous audit findings in this area, ADM issued procedures in June 1993 regarding NRC use of the DOE property listing. However, NRC did not carry these procedural requirements forward when MD 11.7 was developed.
Additionally, we found a more recent ADM office memorandum of January 1996 which indicates that the section of the DOE inventory listing general property should be sent to the NRC program offices. However, this memorandum does not provide guidance on how the listing should be used.
We believe the intended controls outlined in ADM's June 1993 property control procedures and in the January 1996 memorandum would be quite time consuming and would require extensive coordination and significant agency resources to implement. Under the intended controls, once NRC received the annual DOE property reports, ADM and IRM staff would need to reconcile the listings with the previous year's reports, make copies for each program office, and ensure their olG/96A 10 Page6
Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened delivery. Program support staff in the program offices would have to either duplicate salient portions of the property listings for each program manager or distribute the total property listings among the over 100 project managers for their review. In addition, each project manager would need adequate time to reconcile the DOE property listings with the information contained in their individual project files.
Therefore, we believe NRC needs to develop a consolidated, streamlined approach for establishing and maintaining controls over the property maintained at the DOE laboratories. We were told by an ADM official that, in addition to NRC project managers receiving MLSRs, ADM receives a copy of all MLSRs. This official told 1
us that, by using the MLSRs, ADM has the capability to establish a centralized inventory for NRC funded property at the DOE laboratories and could update such an inventory on a timely basis. ADM officials also concurred with our observation El that utilizing a personal computer and inexpensive "off-the-shelf" software to g
develop such a data base would require a minimal level of effort and agency resources. Although ADM currently maintains an inventory to track, control, and dispose all NRC funded property purchased for commercial contracts, the agency has not developed such a centralized process for NRC assets at DOE laboratories.
Il CONCLUSIONS Generally, we believe NRC project managers have made important progress in administering and controlling individual projects contracted to DOE laboratories.
However, NRC should strengthen management controls and implement.a streamlined, automated process to aggregately track and oversee NRC funded property and software at DOE laboratories. NRC could model this system after the centralized inventory kept for property acquired under commercial contracts.
Because NRC is in the process of revising MD 11.7, it is also timely for the agency to strengthen the management controls over NRC property at DOE laboratories.
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Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened RECOMMENDATIONS To ensure that NRC management processes and controls regarding NRC property at DOE laboratories are adequate, we believe the Director, ADM, should further l
improve the existing property control and tracking systems associated with MD 11.7 procedures. To that end, we recommend that the Director, ADM, strengthen NRC's controls over NRC funded property at DOE laboratories by:
(1)
Taking steps to encourage DOE to provide the annual listing of NRC titled soft' ware as required by MD 11.7; (2)
Reassessing the procedures identified :n the currently proposed revisions to MD 11.7 and other agency documents to more clearly define the expectations and internal processes for tracking and overseeir NRC funded property maintained at DOE laboratories; l
and (3)
Developing and maintaining a centralized inventory for tracking and
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overseeing NRC funded property maintained at DOE laboratories.
AGENCY COMMENTS On March 5,1997, the Deputy Executive Director for Management Services (DEDO) responded to our draft report and stated, "I agree that the management of
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agency-funded property at DOE should be strengthened by improving management controls and implementing a streamlined process to aggregately track and oversee NRC-funded property at DOE laboratories." The DEDO agreed with all of our l
recommendations and provided completion dates for each. Appendix ll contains a copy of the DEDO's comments.
olG/96A 10 Page 7
f Appendix l l
Management Controls Over NRC Property at DOji L boratorios Should Be Strengthened OBJECTIVES, SCOPE, AND METHODOLOGY The objective of our review was to evaluate the effectiveness of U.S. Nuclear Regulatory Commission (NRC) project managers' implementation of NRC's l
Management Directive 11.7, entitled, "NRC Procedures for Placement and Monitoring of Work With the Department of Energy"(MD 11.7). We wanted to determine if NRC had improved its management of work placed with Department of Energy (DOE) laboratories. Based on a request from Commissioner Rogers, we initially limited our scope of work to reviewing NRC project managers' control over NRC funded property at the DOE laboratories. However, after performing initial survey work in this area and meeting with the Commissioner's staff, we expanded our review to determine if the agency had effectively implemented other procedures contained in MD 11.7.
Our review included an in-depth analysis of MD 11.7 and selected project files to address: (1) project needs and priorities, (ii) bases for selecting the particular procurement method and use of the DOE laboratory, (iii) NRC's evaluation of laboratory proposals and negotiation results, (iv) management of the projects' technical performance and financial accountability, and (v) controls for tracking and overseeing NRC funded property at DOE laboratories. We did not evaluate the closecut of NRC projects at DOE laboratories, as projects NRC initiated beginning with Fiscal Year 1995 funds had not concluded by the time we finished our audit field work.
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in performing our work, we: (1) selected a sample of job codes from NRC program offices; (2) reviewed the associated files to determine adherence to MD 11.7 requirements; (3) interviewed NRC project managers and key personnel; and, (4) l interviewed DOE / laboratory management and staff associated with implementing MD 11.7 requirements.
f We did not review MD 11.7 proposed revisions regarding conflict of interest provisions or other legislative requirements, as the Counsel to the Inspector General undertakes this activity. Additionally, we did not review Office of the Controller f
activities related to implementing MD 11.7 because our review of the Chief Financial Officer's Act provisions takes into account those actions.
We performed our review from February through December 1996 in accordance with generally accepted Government auditing standards.
olG/96A-10 Page 1 of 1
r Appendix 11 Manag: ment Controls Ov:r NRC Property et DOE Laboratori:s Should Be Str ngthened P
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t UNITED STATES l
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E NUCLEAR REGULATORY COMMISSION 5
WASHINGTON, D.C. 2055f4001 March 5, 1997 MEMORANDUM TO:
Thomas J. Barchi Assistant Inspector General for Audits 1
FROM:
Patricia G. Norry Deputy Executive Director
,f/
for Management Services
SUBJECT:
DRAFT REPORT - MANAGEMENT CONTROLS OVER NRC PROPERTY AT DOE LABORATORIES SHOULD BE STRENGTHENED I
This responds to your January 31, 1997, memorandum transmitting the subject audit report.
I am pleased to note your conclusion that agency project I
managers have made important progress in administering and controlling projects placed with DOE laboratories.
I agree that the management of agency-funded property at DOE should be strengthened by improving management controls and implementing a streamlined process to aggregately track and I
oversee NRC-funded property at DOE laboratories.
We have reviewed your specific recommendations and provide the following I
responses:
RECOMMENDATION 1 Take steps to encourage DOE to provide the annual listing of NRC-titled software' as required by Management Directive (MD) 11.7.
, RESPONSE:
Agree. We are sending a letter to DOE to remind them of the MD 11.7 l
requirement to provide information on NRC-titled software in their annual property reports. We will also direct DOE to send this information to the Office of Administration (ADM) instead of the Office of Information Resources Management (IRM), as currently required. This will provide a central focus for review and reconciliation of all NRC-funded property at DOE labs (see response to Recomendation 3). We will amend MD 11.7 to reflect this change.
Completion: May 30, 1997.
RECOMMENDATION 2 Reassess the procedures identified in the currently proposed revisions to MD 11.7 and other agency documents to more clearly define the expectations and I
internal processes for tracking and overseeing NRC-funded property maintained at DOE laboratories.
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3 App:ndix 11 Management Controls Over NRC Property at DOE Laboratories Should Be Strengthened Thomas J. Barchi,
I
RESPONSE
Agree. 7e plan to revise MD 11.7 to clearly state the process, controls and office responsibilities necessary to ensure effective management and tracking of property acquired under DOE agreements.
Completion:
May 30, 1997.
RECOMMENDATION 3 Develop and maintain a centralized inventory for tracking and overseeing g
NRC-funded property maintained at DOE laboratories.
3
RESPONSE
Agree. ADM will be responsible for developing and maintaining a centralized database of NRC-funded DOE-held property, including NRC-titled software, acquired under DOE agreements. We will compare this information against the information provided by DOE in its annual report and will resolve any discrepancies. ADM will also coordinate data regarding NRC-titled software 6;ith IRM to ensure that accurate and complete inventory information is provided to the Office of the Controller for capitalization purposes as required for agency financial statements. Con;pletion: July 31, 1997.
Please contact me at 415-7443 or Edward L. Halman at 415-6222 should you have any questions regardirg our response.
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Appendix 111 Management Controls Over NRO Property at DOE Laboratories Should Be Strengthened MAJOR CONTRIBUTORS TO THIS REPORT Corenthis B. Kelley, Team Leader 1
RussellIrish, Audit Manager l
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OlG/96A 10 Page 1 of 1 W
Appendix IV M:nagement Controls Ovir NRC Property et DOE Laboratori;s Should De StrIngthened GLOSSARY: OFFICE OF THE INSPECTOR GENERAL PRODUCTS INVESTIGATIVE 1.
INVESTIGATIVE REPORT-WHITE COVER An Investigative Report documents pertinent facts of a case and describes available evidence relevant to allegations against individuals, including aspects of an allegation not substantiated.
Investigative reports do not recommend disciplinary action against individual employees.
Investigative reports are sensitive documents and contain information subject to the Privacy Act restrictions. Reports are given to officials and managers who have a need to know in order to property determine whether administrative action is warranted. The agency is expected to advise the OlG within 90 days of receiving the investigative report as to what disciplinary or other action has been taken in response to investigative report findings.
2.
EVENTINQUIRY-GREEN COVER The Event inquiry is an investigative product that documents the examination of events or agency actions that do not focus specifically on individual misconduct. These reports identify institutional weaknesses that led to or allowed a problem to occur. The agency is requested to advise the OlG of managerial initiatives taken in response to issues identified in these reports but tracking its recommendations is not required.
3.
MANAGEMENT IMPLICA TIONS REPORT (MIR) - MEMORANDUM MIRs provide a " ROOT CAUSE" analysis sufficient for managers to facilitate correction of problems and to avoid similar issues in the future. Agency tracking of recommendations is not required.
Avoir 4.
AUDITREPORT-BLUE COVER An Audit Report is the documentation of the review, recommendations, and findings resulting from an objective assessment of a program, function, or activity. Audits follow a defined procedure that allows for agency revwie and comment on draft audit reports. The audit results are also reported in the OlG's " Semiannual Report" to tne Congress. Tracking of audit report recommendations and agency response is required.
5.
SPECIAL EVALUATION REPORT-BURGUNDY COVER A Special Evaluation Report documents the results of short-term, limited assessments. It provides an initial, quick response to a question or issue, and data to determine whether an in-depth independent audit should be planned Agency tracking of recommendations is not required.
REGULATORY 6.
REGULATORY COMMENTARY-BROWN COVER Regulatory Commentary is the review of existing and proposed legislation, regulations, and policies so as to assist the agency in preventing and detecting fraud, waste, and abuse in programs and operations. Commentaries cite the IG Act as authority for the review, state the specific law, regulation or policy examined, pertinent background information considered and identifies OlG concems, observations, and objections. Significant observations regarding action or inaction by the agency are reported in the OlG Semiannual Report to Congress. Each report indicates whether a response is required.
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