ML20149G773

Review of NRC Draft Renewal Justification to Continue Federally Funded Research & Development Ctr

ML20149G773
Person / Time
Issue date:	07/11/1997
From:	NRC OFFICE OF THE INSPECTOR GENERAL (OIG)
To:
Shared Package
ML20149G766	List: ML20149G763 ML20149G773
References
OIG-97A-07, OIG-97A-7, NUDOCS 9707240058
Download: ML20149G773 (16)

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OFFICE OF i THE INSPECTOR GENERAL L

U.S. NUCLEAR l REGULATORY COMMISSION 4 i

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! REVIEW OF NRC'S DRAFT RENEWAL JUSTIFICATION

! TO CONTINUE THE FEDERALLY FUNDED RESEARCH i

AND DEVELOPMENT CENTER i OlGl97A-07 July 11,1997 4

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1 Review of NRC'S Draft Renewal Justircation to Continue the FFRDC REPORT SYNOPSIS Since October 1987, the U.S. Nuclear Regulatory Commission (NRC) has y sponsored a Federally Funded Research and Development Center (FFRDC), the l Center for Nuclear Waste Regulatory Analyses (the Center). The Center provides the agency with long-term technical assistance and research related to NRC's High-Level Waste (HLW) program under the Nuclear Waste Policy Act of 1982, as I amended. The Federal Acquisition Regulation (FAR) requires that, prior to extending the contract for an FFRDC, sponsors conduct a comprehensive review of the use and need of their FFRDCs. In response to the FAR requirement, the I NRC staff recently drafted its second renewaljustification for extending the Center's contract which expires in September 1997.

I In addressing NRC's first renewaljustification, an Office of the inspector General's (OlG) February 1993 audit report disclosed that the agency was unable to adequately support some statements made in the justification document. OlG -

' recommended that the NRC develop plans and procedures covering justification

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requirements for use in future FFRDC reviews. In our current audit work, we looked I at NRC's second renewal justification process and evaluated (1) whether the agency implemented OlG's previous recommendations on NRC's initial renewal justification and (2) if NRC properly considered all FAR requirements in currently I determining whether to renew sponsorship of the Center.

We found that NRC staff developed an interim plan for performing its FFRDC I renewaljustification, implemented that plan, and drafted a renewaljustification. We believe the draft renewaljustification adequately assesses some, but not all, of the FAR considerations in that (1) the review of the use and resources needed to operate the Center needs to be expanded and (2) the consideration of alternative L sources to meet NRC's needs is not thorough. The draft renewaljustification also does not provide the Commission sufficient information on which to make its

{ judgement because (1) assumptions used by the staff in drawing conclusions are not identified and (2) an Office of the Controller cost comparison referenced by the staff does not reflect the current environment affecting the HLW program. Our

[ report makes one recommendation to address the issues identified.

E Review of NRC s Justification for Renewing its Contract for Federally Fundeti Research and Development Center (FFRDC) Operations. OlGl93A-01, February, 8,1993 olG/97A47 Page1 P**"

Review of NRC'S Draft Renewal Justification to Continue the FFRDC TABLE OF CONTENTS l REPORT SYNOPSIS . . . ....... .... ..... ... . . .. .i l

INTRODUCTION . . . . .. . . . .. . . . 1 I BACKGROUND.

FINDINGS . , . ......

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REVIEW OF THE USE AND RESOURCES NEEDED TO OPERATE THE CENTER NEEDS TO BE EXPANDED ... . . . . .... .... .. 3 CONSIDERATION OF ALTERNATIVE SOURCES IS NOT THOROUGH .. 5 CONCLUSION ... . . .. .. . . . . . . .... .. .7 1

RECOMMENDATION . . .... . . . . ... .. 7 AGENCY COMMENTS . ... ..... . .. .. .. . . .. . .7 l l APPENDICES I 1 Objectives, Scope, And Methodology 1

ll Agency Comments ill Major Contributors To This Report I IV Glossary: Office of the inspector General Products l

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l Review of NRC'S Draft Renewal Justification to Continue the FFRDC INTRODUCTION . .

In October 1987, the U.S. Nuclear Regulatory Commission (NRC) entered into a five-year contract with Southwest Research Institute (SwRI) to operate a Federally j Funded Research and Development Conter (FFRDC). SwRI established the Center l for Nuclear Waste Regulatory Analyses (the Center) to provide the agency with long-term technical assistance and research reloted to NRC's High-Level Waste (HLW) program under the Nuclear Waste Policy Act of 1982, as amended. On October 15,1992, NRC extended its contract with SwRI for an additional five years.

The current contract is scheduled to expire on September 30,1997. NRC's current FFRDC contract ceiling amount is $134.7 million, which represents one of NRC's largest active contracts. The NRC's Commission must decide whether to renew the contract with SwRI for operation of the Center. Therefore, it is of utmost importance that the Commission have adequate input from the NRC staff on which to make an informed decision.

The Federal Acquisition Regulation (FAR) requires the sponsor, prior to extending the contract for an FFRDC, to conduct a comprehensive review of the use and need of the FFRDC. In a February 1993 report' regarding NRC's first renewal justification for the Center, the Office of the Inspector General (OlG) reported that the agency was unable to adequately support some statements made in its renewal justification. OlG recommended, and NRC agreed, that the agency develop plans and procedures covering justification requiremsnts for use in future FFRDC reviews.

Because of the pending expiration of NRC's contract with SwRI for operation of the Center, we decided to audit NRC's current renewal justification process. We evaluated (1) whether the agency appropriately implemented OlG's previous recommendations and (2) if NRC properly considered all FAR requirements in determining whether to renew the contract with SwRI. Appendix 1 provides more detail about our audit objectives, scope, and methodology.

BACKGROUND FAR Section 35.017, " Federally Funded Research and Development Centers,"

provides the policy and requirements that Federal agencies must satisfy in establishing, using, reviewing, and terminating FFRDCs. When conducting a comprehensive review of the continued use and need of an FFRDC, a sponsoring agency must complete five activities:

' Review of NRC's Justification for Renewing Its Contract for Federally Funded Research (

and Development Center (Fi-RDC) Operations, OlG/93A-01, February 8,1993 OlG/97A-07 Page 1 l -

I Review of NRC'S Draft Renewal Justification to Continue the FFRDC (1) an examination of the sponsor's special technical n9eds and mission requirements that are performed by the FFRDC to deteanine if, and at what level, they continue to exist; .

(2) consideration of alternative sources to meet the sponsc,r's needs; (3) an assessment of the efficiency and effectiveness of the FFRDC in meeting the sponsor's needs; (4) an assessment of the adequacy of the FFRDC management --

in ensuring a cost effective operation; and (5) a determination that the criteria for establisning the FFRDC continue to be satisfied and that the sponsoring agreement is in compliance with the FAR.

FAR also states that the renewaljustification process may be done in parallel to the budget process.

'As indicated above, our earlier report addressed NRC's first renewal justification for I

continued operation of the Center and identified that the NRC did not provide adequa*.e support for some statements made in the renewal justification. We were particularly concemed with NRC's efforts to explore attemative sources to meet the

-l' agency's needs. In that report, we also recognized that the FAR provides no g specific requirements regarding how an FFRDC review is to be conducted or 5 documented. As a result, we. recommended that the NRC develop a plan, or procedures, that covered justification requirements.

We believed this was necessary for NRC to sufficiently plan and document the level of analysis necessary to support conclusions resulting from any future FFRDC review. We also recommended that special emphasis should be placed on ensuring a full consideration of attemative sources to meet the agency's needs. We pointed out that the plan should include steps to ensure that all criteria are compared with .

actual conditions. In response to our report, the then Deputy Executive Director for Nuclear Material Safety, Safeguards and Operations Support agreed with our recomrnendations.

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Review of NRC'S Draft Renewal Justification to Continue the FFRDC l

s FINDINGS I

E We found that NRC staff developed an interim plan for performing its FFRDC renewaljustification, implemented that plan, and drafted a renewaljustification. We

{. believe the draft renewal justification adequately assesses some, but not all, of the FAR considerations, in that, (1) the review of the use and resources needed to I operate the Center needs to be expanded and (2) the consideration of alternative j i sources to meet NRC's needs is not thorough. We believe the draft renewal justification also does not provide the Commission sufficient information on wnich to render its judgement, because assumptions used by the staff in drawing l

conclusions are not identified and an Office of the Controller (OC) cost comparison

I referenced by the staff does not reflect the cwrent environment affecting the HLW program.

I The fdbwing two sections of our report describe more specifically our concerns with the agency's draft renewal justification document.

I Review of the Use and Resources Needed to Operate the Center Needs to be i

"*P""d'd E

.5 l The draft renewal justification adequately addressed the agency's special technical i needs for an FFRDC; however, the mission requirement leve!s identified in the draft i do not adequately portray the current and potential future use of the Center The draft renewal justification states that the Center needs 61 full time equivalent (FTE) positions to fully support the HLW program, and 54 FTE to minimally support the  !

" breadth and depth of skills required over the long term." However, neither the actual number of staff at the Center (currently at 42 FTE) nor the implications of the present staffing level are identified in the draft renewal justification. More specifically, the draft does not fully discuss whether, at the current staffing level, the Conter presently has the breadth and depth needed to minimally support the HLW I program or whether it will be able to maintain / acquire this capability over the years.

I The NRC staff considered nine assumptions in drafting the renewal justification.

E Although some information on the assumptions is contained in the justification package for the Commission's consideratica, the nine assumptions themselves are I not. We believe a review of these assumptions is important to the Commission in making an informed decision on renewing the contract with SwRI. Five of these assumptions address issues involving implementation of both the Department of Energy (DOE) and NRC HLW programs in the near term, while the four remaining assumptions deal with other programmatic considerations and future work areas.

olGI97A-07 pad 83

Review of NRC'S Dsaft Renewal Justification to Continue the FFRDC Moreover, reductions in NRC's budget have impacted NRC's HLW program and tho assumptions for assessing whether to renew the Center's contract. We believe I these budget reductions should have signaled the NRC staff to re-visit the original  !

assumptions and revise the draft renewal justification accordingly.  !

The HLW appropriation funds the Center and other HLW program activities within NRC. In Fiscal Years (FY) 1996 and 1997, NRC's HLW program appropriation fell from the $22 million received in FY 1995 to $11 million for each year. NRC supplemented the $11 million appropriation with $6 million and $3 million in carryover funds in FYs 1996 and 1997, respectively. NRC requested $17 million for l,

its HLW program for FY 1998 and NRC staff said that it was not anticipated that g sufficient carrycver funds will be available to supplement the appropriation. This 3j

.@est consisty of about $12.5 million for the Center and about $4.5'million for other activities not associated with the Center. However, the NRC staff'e draft g' renewaljustification is written based on funding of $17 million solely for support of 5 the Center in FY 1998. Therefore, the renewaljustification draft does not align witn NRC's HLW budget request for FY 1998. Moreover, even if the full HLW appropriation req Jested for FY 1998 is received, it will not fully support the Center's activities described in the current draft justification because $4.5 million of the $17 .

million requested will be used to support other activities outside of the Centor.

Consequently, in November 1996, the Director, Nuclear Material Safety and Safeguards (NMSS), identified that insufficient funding in FYs 1996 and 1997, and l

further cuts in FY 1998, would result in a potential significant weakness. The HLW  ;

program would be unable to achieve legislatively mandated directives. The Director I described some of the programmatic effects of the FYs 1996 and 1997 budget cuts I and further stated that, if NRC's FY 1998 appropriation for the HLW program remained at $11 million (the same appropriations received in the previous two years), (1) the program will have further reductions in scope, (2) NRC's review of DOE's viability assessment and license application would be limited to the current knowledge base, and (3) the three-year time period for licensing specified in the Nuclear Waste Policy Act, as amended, would not be possible.

We discussed NRC's reduced appropriations and current budget request for the HLW program with the Office of Management and Budget (OMB) officials and staff l members of the Housa Subcommittee on Energy and Water Development, Committee on Appropriat ons. Given the current budget climate, they indicated that NRC needs to re-evaluate its needs and resources for the HLW program. l Additionally, the Subcommittee staff with whom we spoke said they had begun to gl question NRC's credibility regarding the agency's HLW budgets, because for two gl consecutive years NRC said tnat the Center would be closed if the HLW program olG/97A-07 Page 4

Review of NRC'S Draft Renewal Justification to Continue the FFRDC )

received an $11 million appropriation. However, despite receiving this appropriation f ' level for both years, the Center has remained open.

Based on these comments, we believe the NRC draft renewal justification must l-_ provide the Commission with sufficient analysis and detail to clearly identify the funding level at which the agency would not be able to~ meet its HLW program p ' mandates or sustain the Center. NRC and the Center performed an analysis of.

)! s different funding levels and the impact each level would have on the HLW program and support to the Center, but the details of this analysis are not included in the-draft renewal justification package. We believe ."a line in the sand,*'.or minimal

. support level for the HLW program and the Center, must be provided by the NRC staff to the Commission. .It is critical to the Commission's ability to make an g informad decision on whether to renew the Center's contract.:

a Fina' lly, NRC's current Strategic Assessment and Rebaseltning initiative resulted in f', the development'of a series of direction setting issues (DSI) for the agency to form

, the basis of the new NRC Strategic Plan.- One of the DSI's options states that NRC

- will maintain NRC's HLW program; The Commission's preliminary view on this DSI is that NRC should continue to support the national HLW program at whatever level <

is appropriate to keep pace with the national programa in addition, the Commission .

desires to explore taking a more active role in resolving ist,ues in the national HLW -

program, consistent with NRC's mission, We believe that, if the recent downward trend in appropriated funding levels continues for the HLW program,' NRC will not i be able to accomplish this DS1 as intended.

We believe an analysis of these three conditions (reduction of NRC's HLW program funding, the potentialLsignificant weakness in the HLW program, and the NRC o strategic assessment DSI addressing the HLW program) is needed. The analysis should emphasize use of the Center End the NRC staffs assumptions in developing  ;

[ the draft renewaljustification. ' Such an analysis would provide the Commission with -

the necessary detail to make an informed decision regarding renewal of the e agency's FFRDC.

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Consideration of Alternative Sources is Not Thorough -

h As previously identified, when conducting a comprehensive revHm of the continued

o. use and need of an FFRDC, a sponsoring agency must consider attemativa sources to meet the sponsor's needs. In response to a fin' ding in our previous audit report, the then Deputy Executive Director for Nuclear Materia'l Safety, Safeguards and Operations Support committed to seeking OMB guidance regarding consideration OlG/97A-07 'Page5

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' Review of NRC'S Draft Renewal Justification to Continue the FFRDC of attemative sources. NMSS staff said that they contacted OMB and were told that a poll of alternative sources considered from technical staff would satisfy this requirement.

Although the draft renewaljustification cites there are some alternative sources to meet NRC's HLW program needs, the methodology used to generate the list was not thorough. The NMSS poll of technical staff resulted in responses from some project managers not being aware of any alternative sources to several other staff providing specific altemative considerations that would provide some, if not all, of the technical support needed by NRC.

Based on the listing generated by the technical staff, NRC determined that none of the identified sources were adequate in meeting either continuity of technical support or conflict of interest concems. We found that the analysis of atternatives was not fully documented in the draft renewal justification. The draft justification also did not consider the enhanced expertise acquired by NRC staff in their 10 years of overseeing the Center or the possibility of further enhancing NRC's staff capabilities as an additional alternative consideration. In addition, the draft justification's discussion only addressed re-competing the contract as an FFRDC.

We do not believe NRC adequately analyzed the use of individual contracts to different entities for providing an attemative method of support.

In a previous audit report 2, we addressed how the NRC manages its contract for operation of the Center. We recommended that NRC staff complete a cost comparison of performing the Center's work within the agency versus at the Center, g' Although OC performed a cost comparison for completing all of the Center's work g within the agency versus at the Center, the cost comparisnn is not comprehensive.

This comparison was completed in 1994, when there was no indication of a long gj term budget reduction. Further, OC used data fM only one year, instead of Bl assuming and'using data covering the full 5 years of the contract. In areas where l the comparison found insufficient data, no cost difference was assumed. As such, the OC cost comparison does not provide a thorough and realistic basis on which to evaluate the merits of performing HLW program work at the Center or within the 4 agency.

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2 NRC Effectively Manages Its Contract With Southwest Research Institute For Operating The Center For Nuclear Waste Regulatory Analyses, OlG)93A-11, December 14,1993 olG/97A-07 Page 6

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Review of NRC'S Draft Renewal Justification to Continue the FFRDC CONCLUSION

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We believe the NRC staffs draft renewaljustification does not provide sufficient information by which the Commission can render its judgement regarding whether b to renew the SwRI contract. This is caused, in part, because assumptions suppnrting the current draft justification are not provided in the paper and should be re-assessed given the current budget climate and NRC's strategic assessment.

[ Further, NRC's analysis of alternative sources to support the HLW program is not adequately documented and does not consider the enhanced expertise acquired by NRC staff. Additionally, the cost comparison performed by OC is not comprehensive and does not reflect the current environment affecting the HLW program. We believe NRC needs to re-evaluate the data on which the current draft justification is based and revise the justification to provide the Commission sufficient information to make an informed business decision.

[ RECOMMENDATION To ensure that the Center's renewal justificatiun provides the best possible

{ information to support the Commission in making an informed decision regarding continuation of the Center, we recommend that the Executive Director for

{ Operations revise the draft renewaljustification to include:

(1) Details regarding the assumptions on which the justification

( is based; (2) An analysis of the minimum budget level needed to support

[ the contract as well as contingencies based on varying budget levels; (3) An analysis of the minimum staffing levels needed at the Center to sustain viable support for NRC's HLW program; and

[- A detailed discussion of alternative sources.

(4)

[ AGENCY COMMENTS On July 3,1997, the Deputy Executive Director for Regulatory Programs (DEDR) responded to our draft report and agreed with our recommendation. The DEDR informed us that "the initial Commission paper has been revised to address the four items in your recommendation and to provide additional information which was not

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available at the time of the initial draft." Appendix ll contains a copy of the DEDR's comments. ,

OlG/97A-07 Page 7

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Appendix l

{ , Review of NRC'S Draft Ranewal Just.rcation to Continue the FFRDC

{ OBJECTIVES, SCOPE, AND METHODOLOGY j h Fisca! Year 1988, the U.S. Nuclear Regulatory Commission (NRC) established L

the Center for Nuclear Waste Regulatory Analyses (the Center) as a Federally Funded Research and Development Center (FFRDC). The purpose was to provide

[ sustained technical assistance and research free from conflict of interest for NRC's portion of the High-Level Waste Program.

{ FFRDC contracts are intended to be long-term in nature. However, the Office of Federal Procurement Policy (OFPP), Office of Management and Budget (OMB),

requires that agencies conduct analyses prior to renewing FFRDCs to determine f whether the unique FFRDC relationship is still needed. The analyses should address whether the market place has changed to the point where competition should be sought, and should evaluate past performance and any future changes f to the FFRDC's mission.

( Responding to a September 1992 request from OFPP, the Office of the inspector i

General (OlG) audited the nature and adequacy of NRC's first justification for renewing its FFRDC. OlG found that, although the NRC addressed all requirements

{ for an FFRDC review, the NRC staff was unable to adequately support some statements it made in its renewaljustification. OlG recommended that the NRC develop plans and procedures covering justification requirements for use in future

{ FFRDC reviews and the agency agreed. NRC's contract for the Center is scheduled to expire in September 1997 and the agency's justification for this renewal will have to be completed prior to this expiration.

OBJECTIVES The objectives of this audit were to (1) evaluate NRC's corrective action for implementing OlG's previous recommendation and (2) determine if NRC properly considered all of the requirements for an FFRDC review prior to renewing its FFRDC contract. This audit is considered a review ofintemal management controls related to renewal of an FFRDC, based upon the Federal Acquisition Regulation requirements.

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We directed our audit work at the draft renewaljustification developed for extending the Southwest Research Institute contract, set to expire in September 1997.

Follow-up with OFPP took place to determine if any changes had occurred in the criteria for renewing FFRDC contracts.

O)G/97A47 Page 1 of 2

Review of NRC'S Draft Renewal Justification to Continue the FFRDC Our ai u 1

., e: view of current Federal regulations and guidance, NRC ,

polir - nd contract provisions for the FFRDC; (2) discussions wV , ' the Offices of Administration and the Office of Nuclear Liateriali irds; (3) review of NRC's draft renewal justification and supporting u . "fying an additional period for FFRDC support, and (4) discussions with .J4: s and staff members of the House Subcommittee on Energy and Water Developinent, Committee on Appropriations.

We conducted our audit work between January and March 1997 in accordance with generally accepted government auditing standards.

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l Appendix ll I

Review of NRC'S Draft Renewal Justification to Continue the FFRDC g ea aro uq g k UNITED STATES j

g NUCLEAR REGULATORY COMMISSION

• WASHINGTON D.C. 20656 0001 0

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• 4 July 3, 1997 MEMORANDUM T0: Thomas J. Barchi Assistant Inspector General for Audits Office of the Inspector General FROM: Hugh L. Thompson, Jr. l 4 M.

i De)uty Executive Director for legulatory Programs (

SUBJECT:

DRAFT REPORT - REVIEW 0F NRC'S DRAFT RENEWAL JUSTIFICATION l TO CONTINUE THE FEDERALLY FUNDED RESEARCH AND DEVELOPMENT CENTER (FFRDC)

This responds to your June 5. 1997, memorandum transmitting the subject draft audit report. Your recommendation and our response follows:

i Recommendation To ensure that the Center renewal justification provides the best F possible information to support the Commission in making an informed decision regarding continuation of the Center, we recommend that the Executive Director for Operations revise the draft renewal justification I to include:

1 Details regarding the assumptions on which the justification is 1 based; y 2. An analysis df the minimum budget level needed to support the contract as well as contingencies based on varying budget levels:

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3. An analysis of the minimum staffing levels needed at the Center to sustain viable support for NRC's HLW program; and l

} 4. A detailed discussion of alternative sources.

Resoonse l Agree. The initial Commission paper has been revised to address the four items in your recommendation and to provide additional information I which was not available at the time of the initial draft.

CONTACT: Shirley L. Fortuna. NMSS/PMDA '

(301) 415-7804 OlG/97A47 Page 1 of i e

Appendix 111 Review of NRC'S Draft Renewal Justification to Continue the FFRDC MAJOR CONTRIBUTORS TO THIS REPORT Corenthis B. Kelley Team Leader Russell Irish Audit Manager i Judith L. Leonhardt Senior Auditor i

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l Appendix IV i R:: view of NRC*S Draft Renewal Justification to Continue the FFRDC l l

l 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 properly determine whether administrative action is wananted. 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 investigativo 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 I OlG of managerial initiatives taken in response to isr ues identified in these reports but tracking its recommendations is not required.

3. MANAGEMENT IMPLICA TIONS REPOPT ,'MIF) - 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 I required.

AUDIT

4. AUDIT REPORT- BLUE COVER An Audit Report is the documentation of the review, recommendations, and findings resulting from I an obiective assessment of a program, function, or activity. Audits follow a defined procedure that allows for agency review and comment on draft audit reports. The audit results are also reported in the OlG's " Semiannual Report" to the 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 l 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 t

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 OIG 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.

olG/97A-07 Page 1 of 1

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