ML20154M291
| ML20154M291 | |
| Person / Time | |
|---|---|
| Issue date: | 08/24/1998 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9810200222 | |
| Download: ML20154M291 (15) | |
Text
.
C itCy Ef UNITED STATES NUCLEAR REGULATORY COMMISSION 'ASED TOTHE POR
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n WASHINGTON. D.C. 2055) RELE
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",,,ggeeeeeeeeeet6e049008 commissioner August 24,1998 MEMORANDUM TO:
John C. Hoyle, Secretary FROM:
Edward McGaffigan, Jr.
SUBJECT:
COMSECY-98-014 - REVISION TO MANAGEMENT DIRECTIVE (MD) 6.1 - RESOLUTION AND FOLLOWUP OF AUDIT RECOMMENDATIONS l approve revision of Management Directive (MD) 6.1 subject to the following comments and attached edits.
First, I concur in the limitation on the Chairman's authonty to unilaterally resolve matters relating to policy formulation, certain types of rulemaking, or orders and adjudications as proposed in the MD. I believe that the phrase "or any other matter within the Commission's authority" also needs to be added to fully capture the collegial functions of the Commission described in Chapter 1 of the Commission's procedures. These collegial functions include " reviewing budget estimates. " " approval of proposals for the reorganization of the major offices. " and appointments to and removals from certain agency positions.
Second, I believe most audits, certainly GAO audits, will in fact raise policy issues or make recommendations that will involve collegial Commission action to resolve, Third, I believe that both the Chairman and each Commissioner needs to be kept informed of the audit process at the draft stage. I have added many edits which are intended to keep the Chairman and each Commissioner informed of audits in progress.
Fourth, I believe that there may be a class of audit reports by other executive branch inspectors General outside the contracting area (dealt with on page 9 of the Handbook) which would require resolution and followuo by the Commission. I have in mind programmatic audits in areas of overlapping responsibilities (such as with DOE, AID, and the Department of State on aid to
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the nuclear safety programs of various East European and former Soviet Union countries, or with EPA and DOE on the various cross-cutting functions identified in our Performance Plan). I presume that such audit recommendations would be referred to the NRC Inspector General (IG) by the inspector General of the executive branch agency. Resolution and followup would then be handled similarly to resolution and followup for a recommendation by the NRC Inspector General. I would appreciate some specificity on how this would work in the next revision of the Management Directive and Handbook, or in this revision if it could be done promptly.
f DI 9810200222 980824 PDR COMMS NRCC
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CORRESPONDENCE PDR 10 X 03
t J. Hoyle 2
Finally, I have restored the references to the Chairman's semiannual report to Congress on audit followup. Unless the law has changed, it is my understanding that the inspector General l
submits a semiannual report to the Chairman by April 30 and October 31 of each year, and that
- within 30 days of receipt, the Chairman must submit agency remarks together with the IG's 4
report to Congress.
4 Attachments: As stated cc:
Chairman Jackson Commissioner Diaz SECY OGC OCA OPA CFO CIO OlG i
i 6
1 V;lume 6, Internal Manrgem:nt Resolution and Followup of Audit Recommendations Directive 6.1
), b r+0 oab Commission
/ "p,gl gg <qe<h (031)(continued) p f t a J h##\\
I Resolves matters raised injntern eports of the Office of the Inspection General (OIG) en they invob poucy formulation, certain types of rulemaking or orders, and adjudications as defined in the Reorganization Plan No.1 of 1980 b)
Chairman m o D ' d "
+9" "'
- C'"""""','
or (032)
- 'd1-
- With regard to audit recommendations addressed to h
,, bbd ef gg,Cna'pfjg c[,'jf,%,,.'!.t 4 Chairman-(a)
- Responds to OIGyn recommendations contained in draft and
,,1 final OIG audit reports and,to GAO,f & Ce ~*aon draftf)AO audit 9,, l bM e reports. (i) o-
- Ensures that recommendations of audit repons are resolved; that corrective actions are assigned, tracked, and completed; and that the Audit Followup Official is advised of actions taken. (ii)
When necessary, resolves differences between OIG and the Commission offices, EDO staff offices, the CFO, and/or the CIO with regard to recommendations contained in OIG internal audit reports.
However, when the resolution involves matters relating to policy formulation, cenain types of rulemaking or orders, and adjudications (as defined in the Reorgamzation Plan No.1 of 1980), refers such A
d issues to the Commission. (b) er
- ay u m
,,s l cc.,,~ >>.e '> a a6 Submits a report to the Congress on management decisions and r
final actions taken with regard to audit recommendations from the OIG. (c)
Executive Director for Operations (EDO)
(033)
Provides policy guidance to ensure that management officials e
throughout t;ie agency understand the value of the audit process and are responsive to audit recommendations. (a)
With regar<.1 to audit recommendatinm addQo the EDO-(b)
Responds to OIG,hommendations contained in draft and 7 l
final O1G reports and GAO,on draft GAO repons. (i)
,,4 L
" f'
- Ensures that recommendations of audit reports are resolved w
and that corrective actions are assigned, tracked, and G a.re-completed. '(ii) jj c,,,,, a '
Approved: January 13.1993 3
(Revised: DRAFT 2/19/98)
l Vtlume 6, Internal Manag:m'ent Resolution and Followup of Audit Recommendations Directive 6.1 l
l Executive Director for Operations (EDO)
(033)(continued)
Serves as Audit Followup Official (AFO). (c) a
- Provides oversight an'd - direction to ensure that recommendations of audit reports are resolved in a timely l
manner and that corrective action is assigned and I
completed. (i) l
- Facilitates resolution of any disagreements between l
Commissior, offices and the Inspector General regarding l
internal audit findings and recommendations. (ii)
- Resolves a.'y disagreements between the Dep'uty Executive Directors for Operations and the Inspector General (IG) regarding internal audit findings and recommendations. (iii)
Provides a system to maintain accurate records and track the status of audit reports and recommendations through the entire process of resolution and corrective action. (iv)
Provides a program to ensure continuing effective corrective action in response to audit recommendations. (v)
Provides for an annual review of implementation of selected audit recommendations. (vi)
Ensures that periodic analyses are conducted of audit recommendations, resolution, and corrective action activities to determine trends and problems and to recommend solutions. (vii) u~ li Reports :yJ in=2 on the status of GAO assignments to the
/
Commission for information. (viii)
Fonvards to the Commission for approval and transmittal the required statements to congressional committees on recommendations contained in final GAO audit reports. (d) somuni Prepares -the NRC Chairman's. report to the Congress on e
management decisions and final actions on OIG audit recommendations. (e)
Chief Financial Officer (CFO)
(034)
Ensures that timely action is taken to pursue collection of funds that e
result from management determinations on audit findings and recommendations. (a)
Approved: Januaiy 13,1993 (Revised: DRAFT 2/19/98) 1
L' V;lume 6, Intern:1 Management Resolution and Followup of Audit Recommendations Directive 6.1 Chief Financial Officer (CFO)
(034)(continued) l Establishes accounts receivable and pursues collection action under Management Directive 4.1, " Accounting Policy and Practices"; " Debt Collection Procedures," 10 CFR Part 15; the
" Salary Offset Procedures for Collecting Debts Owed by Federal Employees to the Federal Government," 10 CFR Part 16; and the Federal Claims Collection. Standards, 4 CFR Parts 101-104, for funds owed NRC as a result of audits. (b)
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Notifies the Deputy Inspector General when accounts receivable are established for funds owed NRC as a result of NRC contract audits. (c)
Informs the AFO of significant audit findings and of any disagreements with OIG on audit findings and recommendation,. (d) u,,,,,,,~ t Provides information on collection of pisallowed costs to the AFO for inclusion in the Chairman's/ report to Congress on management decisions and final actions regarding OIG audit recommendations. (e)
With regard to an audit of the office-(f)
- Responds directly to OIG[on recommendations contained in s.4 A draft OIG and final audit reports, and to GAOfon the accuracy a
of facts and conclusions contained in draft GAO audit
- f ' g reports. (i)
Ensures that recommendations of audit reports are resolved; uJ that corrective actions are assigned, tracked, and completed; Q,,
and that the AFO and OIG are advised of actions taken. (ii)
.Fonvards to the Commission for approval and transmittal the required statements t-congressional committees on recommendations contained in final GAO audit reports. (g)
Develops a remediation plan in consukation with the Director, l
OMB, if there is a sustained audit finding that NRC financial i
management systems are not in compliance with the requirements of the Federal Financial Management Improvement Act of 1996.(h)
Approved: January 13,1993 j
4 (Revised: DRAFT 2/19/98)
Vclume 6, Internal Manag ment Resolution and Followup of Audit Recommendations Directive 6.1 ChiefInformation Officer (CIO) 4 (035)
With regard to an audit of the office--(a) e
- Responds directly to OIGhecommendations contained in,_.
draft OIG and final audit repons, and to GAOfon the accuracy
]
of facts and conclusions contained in draft GAO audit 4
repons. (i) cu,e
- Ensures that recommendations of audit repdns are resolved; j
that corrective actions are assigned, tracked, and completed; cg,,3,,,a and that the AFO and OIG are advised of actions taken. (ii)
Informs the AFO of significant audit findings and of any disagreements with OIG on audit findings and recommendations. (b)
Forwards to the Commission for approval and transmittal the e
required statements to congressional committees on recommendations contained in final GAO audit repons. (c)
Concurs in responses and target dates for recommendations e
affecting NRC's information technology infrastructure or applications systems. (d)
Inspector General, Office of the Inspector General (OIG)
Ncp (036) d y
- s.. >
Provides copies of allinternal audit repons to the AFO (a)
. cd'* ** e Provides copies of all contract audit repons issued by OlO to the Division of Contracts and Property Management, Office of Administration. (b)
- Informs the AFO about disagreements on internal audit recommendations and provides information copies of matters referred to the Commission for resolution.' (c)
Provides information copies of all internal audit repons to the CFO. (d)
Periodically evaluates audit recommendations, management decisions, and resulting corrective actions to identify trends and systemic problems. (e)
Evaluates the adequacy of NRC's audit followup system. (f)
Approved: hanuary 13,1993 (Revised: DRAFT 2/19/98) 5
V: lum] 6, Internal Managem:nt Resolution and Followup of Audit Recommendations Directive 6.1 Inspector General, Office of the Inspector General (OIG)
(036)(continued)
Reviews implementation actions by NRC management to e
determine whether these actions were consistent with the management decision. (g)
With regard to GAO audits of OIG--(h) e
- Responds directly to draft and final GAO audit reports; (i)
- Transmits the required statements to congressional committees on recommendations contained in final GAO audit reports. (ii) l Directors of Commission Offices, Panels, and Advisory Committees
@f,,,#
(037)
,o p1
- 3..y,c.
- w With regard to audits of their offices-I Respond directly to OIG with a py to the Chairman and/*
e l
Commissioneri on recommendatio contained in draft OIG and final audit reports, and to GAO on the accuracy of facts and conclusions contained in draft GAO audit reports. (a)
Provide to the Commission for approval and transmittal the e
required statements to congressional committees on recommendations contained in final GAO audit reports. (b)
Ensure that recommendations of audit reports are resolved; that e
corrective actions are assigned, tracked, and completed; and that l
l the' AFO, OIG, and the Chairman and,Commissionert are advised i
E of actions taken. (c)
-A Deputy Executive Directors for Operations (038)
I Review and respond directly to O1G to draft internal audit reports e
for their respective areas of responsibility.(a)
Coordinate resolution and corrective action on internal audit e
recommendations involving more than one program or agency. (b)
Inform the AFO of significant audit findings and of anydisagreements with OIG on audit findings and recommendations. (c)
Approved: January 13,1993 6
(Revised: DRAFT 2/19/981
Wlume 6, Internal Managem:nt Resolution and Followup of Audit Recommendations Directive 6.1 Deputy Chief Financial Officer (039)
Reviews and responds to draft internal audit reports. (a) e Coordinates resolution and corrective action on internal audit recommendations involving more than one program or agency. (b) d nts d
Office Directors Reporting to the 6"
EDO and Regional Administrators (0310)
Submit responses to audit reports to'the appropriate Deputy Executive Director for Operations. (a)
Take corrective action in response to audit recommendations in a timely manner and advise the AFO and the OIG of the action taken. (b)
Notify the CFO when corrective actions in response to audit recommendations result in significant changes to existing i
management controls or in the development of new management controls. (c)
Director, Division of Contracts and Property Management, Office of Administration (0311)
Resolves any disagreements on contract audit recommendations e
between contracting officers and OIG. (a)
Informs the AFO of any disagreements on contract audit recommendations before taking final action. (b)
Establishes target dates for corrective action in response to contract e
audit recommendations. (c)
Ensures there is written documentation that demonstrates the e
adequacy and appropriateness of actions taken in respons-to contract audit recommendations. (d)
>o m ~,,,I l
Providesinform on on contract audits to the AFO for inclusion in e
the Chairman's eport to Congress on management decisions and final actions on OIG audit recommendations. (e)
Approved: January 13,1993 (Revised: DRAFT 2/19/98) 7
V: lum 2 6, Internal Manigement Resalutian and EcIlswup cf Audit Rec:mmendati:ns Handhonk 6.1 Part I i
Distribution ofInternal Audit Reports (C)(continued)
Audited Organization Receiving Official Commission Chairman Chief Financial Officer (CFO)
CFO Chief Information Officer (CIO)
CIO i
Commission offices (including Office Director Commission panels and advisory committees)
Executive Director for Operations (EDO) EDO EDO staff offices and regional offices Cognizant Deputy EDO Final OIG Internal Audit Reports (2)
The Inspector General (IG) will issue fmal audit reports to NRC receiving officials as the IG deems appropriate. The IG also will provide copies of final reports to the appropriate receiving officials I
shown in the above tablgand to the Audit Followup Official (EDO), 6")
4 W C hir m *aJ %, A c.,, r.mw Contract Audit Reports (3)
The -IG will issue final audit reports to the cognizant contract negotiator or administrator.
Resolution of Audit Recommendations (D).
OIG Internal Audit Recommendations (1) '
Audit recommendations should be resolved within 6 months after issuance of a fmal report. Corrective action must proceed as rapidly as possible. (a) l l
Approved: January 13,1993 (Revised: LRAFT 2/19/98) 3
\\
V:lume 6, Internal Management Restluti:n and Fellowup of Audit Recommendations Handbook 6.1 Part I Resolution of Audit Recommendations ~(D)(continued) l OIG Internal Audit Recommendations (1)(continued)'
When a draft or final internal audit report is provided to agency 4
management, management will evaluate the audit findings and recommendations contained in the report and issue a management decision with respect to these findings and recommendations.
Internal audits are considered resolved. when' the audit organization and agency. management agree on the a.ction to be taken on reported findings and. recommendations and the dollar savings resulting from a management decision. (i)
OIG generally provides the audited organization with an e
opportunity, usually of 30 days, to formally comment on a draft OIG audit report before the final report is issued. OIG staff will meet with appropriate officials, as necessary, to discuss facts contained in the draft report and the actions needed to resolve the findings and recommendations of the report. (ii)
The formal response to each draft audit report willindicate whether or not the audited organization agrees with each recommendation.
If the audited organization agrees with a recommendation, the response will give the planned corrective action, the title of the management official responsible for ensuring action is taken, and the date each action will be completed. (iii)
If the audited organization ' disagrees with a recommendation in an e
audit report, the response will explain fully the reason for the disagreement, as well as any alternative action the audited organization believes is necessary. Where disagreement is based on interpretation oflaw, regulation, or the authority of officials to take or not take action, the response will be coordinated with the. Office of the General Counsel (OGC) and will state the legal basis for the disagreement. (iv) 4 g w q,.,,,,mog The Chainnan[esponds to OIG on recommendations directed to the I
Commission that are contained in draft and final OIG audit reports.
The CFO, CIO, and directors of Commission offices, panels, and independent advisory committees respond to draft and final OIG a
- ' g reports containing recommendations for their office e
eputy Executive Directors for Operations (Deputy EDOs) respond to t
eg, and final OIG audit reports containing recommenM or their 4
respective areas of responsibilitysample responses to OIG reports are cs, included in Exhibit 1 to this handbook. (b) w h emsLA Approved: January 13,1993 4
(Revised: DRAFT 2/19/98)
Vclums 6, Internal Mana'gement Restlutinn and F:ll wup cf Audit Recommendati:ns Rnndbook 6.1 Part I Resolution of Audit Recommendations (D)(continued)
OIG Internal Audit Recommendations (1)(continued)
The Chairman has the final authority for audit resolution except for matters relating to policy formulation, cenain types of rulemaking or er W,%
rders, ami adjudications as defined in the Reorganization Plan No.1 of
- 9 w,h 19
,,The Chairman will refer matters in these latter areas for R
Cornmission consideration and will subsequently communicate the h,,,o,_kyJ cg decision to OIG. (f recommendation is con g 9 na.,
,c ~
u An intern udi resolved when the Chainn es a management decision on the recommendation. OIG disagreements with responses to audit recommendations from audited l
e M " "'"_'
- nrganizations other than the Commission may be submitted to the p
l Chairhmor resolution in accordance with the procedures set fonh
" Mt " t4, ' below. (d)
Disagreements on responses to audit recommendations from the CFO, I
CIO, or directors of Commission offices, panels, and committees may be submitted by the IG or the diccior directly to the Chairman;for resolunon. Disagreements on responses to audit recommendations from the Deputy EDOs may be submitted by the IG or the Deputy 8' w EDOs to the Audit Followup Official (AFO) for resolution. If the AFO and the IG cannot reach an agreement on the disputed issue, either
" p,
l @%gr N ) Nparty may submit the matter to the Chairman,for resolu es The resolution process may take place before or after OIG issues a final report. If a draft report has been issued to the audited orgamzation for comment and there still are unresolved recommendations at the time the final report is issued, OIG will indicate in the final report which recommendations remain unresolved. OIG will include the positions of both OIG and the audited organization on these recommendations. (i)
If the IG disagrees with NRC management's position on an audit e
recommendation in a final audit report, the AFO will nevertheless sider the remmmendation resolved unless the IG refers the l
matter to the ChairrMfor resolution within 30 days after the final report is issued. The IG and the AFO will work together to accomplish resolution within 6 months of the final report date. (ii)
In some instances, the IG may decide not to request the Cham 7na l
0 e
resolve the disagreement but will hold an issue open for further review or other OIG action. OIG will note this course of action in their final report and the AFO will consider the recommendation resolved. (iii)
Approved: January 13,1993 (Revised: DRAFT 2/19/98) 5
(
Vclume 6, Internal Management Resoluti:n end F:llowup cf Audit Recommendati:ns Handhook 6.1 Part I Resolution of Audit Recommendations (D)(continued)
GAO Audit Recommendations (3)
GAO may provide draft reports to NRC for review and comment so that final repons may incorporate agency views. Under 31 U.S.C.
718(b)(1), NRC must provide comments on draft GAO reports within l
30 days of issuance. An extension of the comment period may be requested if it is not possible to respond within 30 days and if GAO decides that a longer period is necessary and likely to result in a more accurate repon. Typically, comments on GAO draft reports address the accuracy of facts and conclusions, but not the recommendations. (a) 4 p i 6, The Commission, the CFO, CIO, and directors of Commission offices, pc panels, and boards, and the IG respond to draft GAO audit reports
- b(,
involving their offices. The EDO responds to draft GAO audit reports p,11 concerning agency programs and operations within the EDO's area of i
dp N' responsibility.,(b) be
' " Il f*hs.
4 p
GAO issues final reports to the Congress or to the Chairman. If the N
h report is issued to the Congress, a copy is provided to the Chairman.
f""J A ead "'t Additional copies are provided to the Audit Followup Official and to l
r CWCo#,p.
the Director, OMB. (c)
GAO final reports require, by statute, a response to Congress within 60 days on the recommendations presented by GAO. The response will discuss the action taken, or to be taken, by the agency.
The Commission reviews and approves the NRC response and requires 14 to 21 days for review, Commission approval constitutes l
a management decision and resolution. (i)
If NRC staff disagrees with a recommendation contained in a final l
audit report, the response will state the reason for the disagreement, as well as any alternative action the staff believes necessary. Where disagreement is based on interpretation oflaw, j
regulation, or the authority of officials to take or not take action, the l
response will be coordinated with OGC and will state the legal basis l
for the disagreement. (ii)
Sample responses to GAO reports are included in Exhibits 2 and 3 of this handbook. (d)
Statements to the Office of Management and Budget (OMB) are processed as follows--(e) t Approved: January 13,1993 (Revised: DRAFT 2/19/98) 7 l
V:lume 6, Internal Manag: ment Resolutiott and Followup of Audit Recommendations Handbook 6.1 Part III j.f,,
j c s "'s # e"' ;
+
N'& s y s f +,.a* \\u' ',
t A3.%,,,,~c,,,#c.
Part III Reporting Requirements b,, - ~. I l The Chairman's,Jteport to the Congress on Management Decisions and Final Action on OIG Recommendations (A) p,,sa e l l
The Audit Followup Official (AFO) will rep re, for the Chairman's approval and submission to the Congre, a report on management decisions and final actions with regard t recommendation:; from the Office of the Inspector General (OIG). (1) so, +~' i The Chairman's report will contain any comments the Chairman p
believes appropnate and willinclude the following--(2)
Statistical tables showing the total number of audit reports and the e
dollar value of disallowed costs for audit reports-(a)
- For which final action had not been taken by the commencement of the reporting period (i)
- On which management decisions were made during the reporting period (ii)
- For which final action was taken during the reporting period, including--(iii)
The dollar value of disallowed costs that were recovered by management through collection,' offset, property in lieu of cash, or otherwise (a)
The dollar value of disallowed costs that were written off by management (b)
- For which no final action has been taken by the end of the reporting period (iv)
I Approved: January 13,1993 16 (Revised: DRAFT 2/19/98) l
Wluma 6, Internal Management Res::lutten and F:llswup cf Audit Rec:mmendatisns Handhook 6.1 Part HI l The Chairman's Report to the Congress on Management Decisions and Final Action on OIG Recommendations (A)(continued)
Statistical tables showing the total number of audit reports and the dollar value of recommendations that funds be put to better use by management agreed to in a management decision for audit reports-(b)
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- For which final action had not been taken by the -
commencement of' the reponing period (i)
- On which management decisions 'were made during the reporting period (ii)
- For which final action was taken during the reporting period, including, the dollar value of recommendations that---(iii)
Were actually completed (a)
Management has subsequently concluded should not or could not be implemented or completed (b)'
A statement with regard to audit reports on which management decisions have been made but final action has not been taken, other than audit reports on which a management decision was made within the preceding year, containing-(c)
- A list of such audit reports and the date each such report was issued (i)
- The dollar value of disallowed costs for each report (ii)
- The dollar value of recommendations that funds be put to better use agreed to by management for each report (iii)
- An explanation of the reason final action has not been taken with regard to each such audit' report. (Such statement may exclude audit reports that are under formal administrative or judicial appeal or upon which management of an establishment has agreed to pursue a legislative solution, but shall identify the number of reports in each category sc excluded.) (iv) sm, ~.1 l
Thegeport will be annotated to identify the number of audit reports issued by the Defense Contract Audit Agency and the related dollars that are included in the statistics reported by the agency. (d)
Approved: January 13,1993 (Revised: DRAFT 2/19/98) 17
V lume 6, Int:rn:1 M:nrg: ment -
2 Res:luti:n and Followup of Audit Recommendations Handbook 6.1 Exhibits Exhibit 3 (continued)
The Honorable [Name), Jr., Chairman Committee on Government -Reform and Oversight United States House of Representatives Washington, DC 20515 Representative [Name]*
cc:
The Honorable [Name], Chairman.
Subcommittee on Clean Air, Wetlands, Private Property and Nuclear Safety Committee on Environment and Public Works United States Senate zWashington, DC 20510 Senator (Name]
cc:
thexHopotable (Name-], Chai
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an Subch mit e on Epr a
th ir hr L,N Com 'ttee o r/.... [.. h. A ^
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C Uni d ates se of ep s tati s Washington C 2b515' ov "
r4 C cc: Representative (Name]
lh5 gv The Honorable [Na e],
n Subcommittee on ergy nd er Committee on merce United Stat ouse o epr e ive Washingt
,D 0515 cc: Repres nta '
[
e]
notabl [Nller Ge eral o] h e
nited States omp
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G unt ice s 'ngton, 54 bl'e[Name], Director The H o
- ment and Budget Was gton 20503
- The cc is the Ranking Minority Individual on the Committee.
J T
l Approved January 13,1993
~
98 (Revised: DRAFT 2/19/98)
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