ML20210B955

Office of Investigations Fy 1998 Annual Report, Sanitized Version

ML20210B955
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Issue date:	01/31/1999
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OFFICE OF INVESTIGATIONS P

FY 1998 AXXLAL REPORT January 1999 i

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PDR I.IMITED DIS 1RIBUTION INVESTIGATIVE INFORMATION: MAY NOT BE l'EPRODUCED OR DISTRIBUTED OUTSIDE I NRC WITHOUT CONSULTING THE DIRECTOR, OFFICE OF INVESTIGATIONS

d"22r2 rDr~r. rzD.Dr:H= Tr=:5:MX.2Zd EXECUTIVE

SUMMARY

This report provides the Commission with In FY 98 OI made significant strides te vard the results ofinvestigations completed by the NRC increasing effectiveness, efficiency, and produc-Office of Investigations (OI) (reference SRM tivity in management, organizational, and process-COMJC-89-8, dated June 30,1989). This is the related activities. Many of these achievements tenth OI annual report and addresses fiscal year were the result ofinitiatives first identified through 1998 (FY 98). field office review visits ard other aspects of the OI conducts investigations of alleged wrongdoing by individuals or organizations who The foibwing are significant achievements 4

are licensed by the NRC or applicants for NRC during FY 98:

licenses or who are vendors or contractors of NRC licensees. OI is composed of four region- E The OI goal was to close cases in 11.6 months.

ally based Field Offices reporting to OI Head- OI achieved this goal by rompleting cases in quarters. OI reports to the Deputy Executive an average of 6.3 months.

Director for Regulatory Effectiveness, and is re-sponsible for two NRC programs: Reactor inves- , Another OI goal was to reduce the percer.tage tigations ard.Materir.ls Investigations. In FY 98 f cases m the inventory open longer than there were, on average,33 special agents and 9 12 months to 12%. OI was successful m reach-operational support staff assigned nationwide. ing this goal, with the number of cases m. the The average experience of an OI snecial agent in inventory older than 12 months at 8%.

FY 98 was approximately 17 years in Federal E OI established a goal of 75%, or above, of cases law enforcement within the inventory which are brought to a There were 1,026 allegations regardm.g full conchtsion based on the merits of the case.

potential violations of its rules, regulations, or OI met this goal, acideving 92% for substan-tive cases' requirements received by the NRC during FY 98.

Although the 1,026 allegations represented a 21 %

E In addition to the case inventory, OI processed decrease from the total of 1,305 received in FY 101 FOIA requests, the third largest number 97, there was only a 5% decrease in cases opened of requests processed within offices in NRC bctween FY 97 and FY 98 (206 to 196). Headquarters and the regions. The average The total number ofinvestigations in the OI completion time was within established inventory during FY 98 was 292. OI closed 194 FOIA guidelines.

investigations, or 66% of the total. Approximately G OI completed development of an upgraded 5% of these cases contained multiple suspected management information system and fully wrongdoing violations.

trained its entire staffin the use of the system.

A statistical surnmary of investigations C OI developed and implemented an Opercing opened and closed during FY 98 and a detailed Plan for the Reactor and Materials Investiga-listing of closed cases are contained in the tions Programs, incorporating performance Appendix to this report. goals and metrics for measming their success.

l.! mired DisreistmON investigative inforrnation: May not be reprodecod or distributed outado NRC without consu! ting the Director, Office of Investigations

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_._ .- Ol ANNUAL REPon I

C2cm z R33r rnCZ m z C Z5cc rzTU.11J2.1. T v I~.LJa lNVESTIGATIONS ANALYSIS OF CASE /NVENTOgy; Figure 2 depicts a decreasing trend in the mmm- , , _ ._,---,x:

number of cases opened from FY 96 through Figure 1 shows the OI case inventory from FY 58. Discrimination cases continue to domi- ,

FY 96 to FY 9.8. The total case inventory in FY n te th:othercategories of violations. The num-98 was 292 cases. This is a combination of 96 ber of cases of suspected material false statements cases carried over from FY 97, and an addition.al and the number of cases which mvolve other NRC 196 cases opened in FY 98. Of the 292 cases in regulatory requirements have remained fairly the inventory, OI closed 194. stable since FY 96.

Case it.ventory i  ;

investigations Opened (Cases Corried Over From Previous Year (Major Typas of Cases) plus Cases Openeo Current Year)

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l i I Violations of Other NRC Regulatory Requirements Figure 1 M False Statements G Discrimination Figure 2 ANALYSIS OF CASES CPENED:

The 196 investigations opened are categorized Figure 3 indicates the distribution of cases in Figure 2 by majoi types of alleged wrongdoing from FY 96 to FY 98 by percentage and category as follows: of cases opened, as well as a comparison to previ-ous years. The FY 98 distribution shows discrimi-Mar: rial False Statements 47 nation cases representing 41 % of the cases opened, W!ations of Other NRC material false statement cases accounting for 24%,

Regulabry Requirements 69 and violations of other NRC regulatory require-ments representing 35%.

Discrimination 80 llMfTED DisalBUTION Investigative inforrration: May not be reproduced or distributed outside NRC without consulting the Directot Office of Investigations t -- .-

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C k :._C E : " Y X733::: D r X 2 21:;r m r 2 5: r m 2r == m investigations Opened 4 l (Percent by Category)  ;

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, Violations of other Violations of other FY97 NRC Regulatory NRC Regulatory

, Requirements (33%) Requirements (23%)

,llg, Discrimination (42%) A. Discrimination (47%)

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l Figure 3 The graph at Figure 4 depicts the distribu-tion of cases opened from FY 96 through FY 98 Investigations Opened (Reactor / Materials) by the Reactor Investigations and the Materials Investigations Program areas. Reactor-related ( 250 ' ,

cases declined, while materials-related cases re-mained fairly constant. The ratio of reactor t '

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materials cases is approximately 75:25. g 176 W

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ANALYSIS OF CASES QOSED: Ihg

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n Figure 5 depicts the 194 completed investi- lj s1 si gations categorized by major types of alleged 50 -

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wrongdoing as follows:  :

o Material False Statements 53 l FY96 FY97 FY98 i

Violations of Other NRC i i i Total Opened I i Materials Cases Regulatory Requirements 56 l M ReactorCases Discrirnination i Figure 4 85 llMITED DisinistiTION Investigative Information: May not be reproduced or distributed outside NRC without consulting the Director, Office of investigations 4 U.S. NucuAn RrouwoRY CoMMISSloN m m - .wm e~ m . , m .-- rm

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( I Figure 5 indicates a decrease in the number of cases closed from FY 96 to FY 98 (from 240 Investigations Closed

[ cases down to 194), which was also reflected in l

(Major Types of cases) the categories of cases. ,

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E 49 cases were closed after investigation sub-stantiated one or more of the allegations of i i wrongdoing. ' ? so _

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not substantiate wrongdoing. so - / ,

( G 9 were closed where the evidence developed Fy9s h _ _ y -,

Fy97 Fy98 indicated that the safety significance did not  !

[ warrant further expenditure of OI resources. "d O $*yoM*u'irernSnts i M False Statements (Z2) Discrimination E 2 cases were closed after investigation deter-  :

[ mined that there was no NRC regulatory re- l Figure 5 quirement. ,

i G 2 cases were closed as deferred to Department

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of Labor (DOL), in keeping with recent direc- Review Board (ARB) and investigative processes tion from the Conunission (SRM 97-147). in recent years.

[ E 24 cases me closed where OI provided assis- Figure 8 depicts the percentages of cases tance to technical staffinspections. completed as either substantiated /unsubstanti-I L ated, closed due to investigating higher priority E 1 case was a collateral lead development cases, or closed for other reasons. The percent-of one OI field office for another office's investigation. age of substantive cases brought to conclusion

( on the merits as either substantiated or unsub-Figure 6 is a percentage comparison by cat- stantiated increased during this period. At 92%,

egory ofinvestigations closed from FY 96 through this is well within the OI performance goal of

[ FY 98. Discrimination cases accounted for 44% 75%, or above. It is this type of complex and of the closed cases in FY 98, material false state. lengthy investigation upon which the technical, ment cases remained at 27%, the same as in FY 97, legal, and enforcement staffs normally base regu-

[ with cases involving other violations of NRC regu- latory decisions. This high percentage is indica-latory requirements increasing slightly to 29%. tive of efficiencies gained within the investigative programs and the ARB process.

[ Figure 7 demonstrates that there was a high number of substantive (substantiated and unsub- High priority substantiated and unsubstanti-stantiated) cases closed in FY 98. This trend con- ated cases are the most time consuming and rou-

{ tinues to be reflective ofimproved resource usage tinely the most complex cases in Ol's inventory.

through efficiencies gained in both the Allega'. ion Figure 9 depicts the time cases were in process 1.lMITED DISTRIBUTION Investigative Informotion: May not be reproduced or distriouted r outside NRC without consulting the Director, Office of Investigations m m~.n-.-w. ;m . - - - , m, -

01 ANNUAL REPon 5

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Investigations Closed (Percent by Category)

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NRC Regulatory NRC Regulatory i Requirements (31%) Requirements (27 Discrimination (46%)

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Investigations Closed from FY 96 through FY 98, by results and by l (Category of Closure) Priority of the m.vestigation. As can be seen in l g_, Figure 9, OI continually reduced the time in pro-280 _ cess in all case categories. The o .erall number l 2so - '" of months to complete cases decreased 16% from l 240 - FY 96 to FY 98. Figure 9 also confirms a more l 220 - significant decrease of 22% in the completion l73200- time for substantiated or unsubstantiated high

? 180 - priority cases.

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6 140 -

i3 Figure 10 shows the percentage of monthly

3 120 - j inventory of cases open longer than 12 months 5 from FY 96 through FY 98. In FY 96, these older

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cases represented 13% of the inventory, while in FY 97 they were down to 8%. Between FY 96 l l 20 - and FY 98, there was a decrease (38%) in the num-o

/ ber of cases in the monthly inventory over 12 l FY96 FY97 FY98 months (16 down to 10 cases). This is an indica-ll l Total Closed I l Closed Due to Higher tion of Continued success in OI's initiatives toward f Substantiated or improving effectiveness and efficiency in the in-

! Unsubstantiated Cases OtherAdministrative Vestigative process and specifically in eXpedi-j tiously closing cases.

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llMITED DISTRitsVTION Investigative Information: Moy not be reproduced or distributed outside NRC without consulting the Director. Office of investigations 6 U.S. NUCLEAR REGULATORY Commission Pr '" M m ? -

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i investigations Closed (Percentage Substantiated j and Unsubstantiated) i l FY96 FY97 Substantiated and Substantiated and Other (10%) Other(12%)

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Closed Due to Ck4ed Due to Unsubstantiated (82%)

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i l Unsubstantiated (92%)

Closed Due to Working Higher Prionties (5%)

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( l.lMITED DISTRIBUTION Investigative Inforrnation: May not be reproduced or distributed E outside NRC without consulting the Director, Office of Investigations I

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.E gmgg ngg gg- 3,n.gg=;gwg y,3; E Figure 11 depicts the number of cases re-  ;

ferred to DOJ from FY 96 through FY 98.  ; case-specific staff Hours j 60 '  ;

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Inves:igative Activities (73%)

FY96 FY97 FY98 Cese Administration (27%)

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! i Case-specific staff hours are shown in requests processed within offices in NRC Head-Figure 12, indicating a 7% increase over FY 97. quarters and the regions in FY 98. These actions Overall, however, staff hours have remained rela- were completed within the established FOIA time- E tively constant from FY 96 through FY 98. The liness guidelines. E FY 98 ratio ofinvestigative activities (field work, investigative travel, etc.) to administrative activi. The distribution of work and the already dis-ties (allegation review process, writing the final cussed reduction in case completion time and per-report ofinvestigation, management review of the centage of older cases in the inventory, coupled case, etc.) is approximately 73:27, which is well with the significant increase in the number of sub- g within OI's standard of 60:40. stantive cases completed, are all indicative of the g fact that OI is using its resources effectively and In addition to cases closed, OI processed ef5ciently to assist the NRC regulatory process in 101 FOIA requests, the tidrd largest number of a timely manner.

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I llMITED DISTRIBUTION Investigative 5 formation: May not be reproduced or distributed outside NRC without consulting the Directot Office of Investigations 8 U.S. NucuAn REGuWoRY CoMMIS$loN & ~ - rNw CT"ta me4 -7 w - -- -q

4 m a z r n m . n r - = m .:u r c r z u z r 2 nr z z z E 1 Z Z SIGNIFICANT ACTIONS NRC ENFORCEMENT Acrions: sat resung company, unc. and m,_.m. - .

m J&L Engineering, Inc.

There were 182 escalated enforcement ac-lP tions taken by the NRC in FY 98, which included civil penalties, orders, and notices of violation at An investigation determined that the presi-dent / owner of J&L Testing Company, Inc. (JLT),

and the president / owner of J&L Engineering, Inc.

or above Severity Level III. In 39, or 21%, of (JLE), co-located corporations that at different I these actions, the OI investigative findings were factored into the decision to take escalated enforce-times held byprouuct nuclear material licenses, de-liberately violated various NRC regulations and ment action. requirements concerning the use and transfer of I The following are examples of significant nuclear gauges, and knowingly provided false,in-accurate, and incomplete information to the NRC cases, the results of which were factored into en-about such use and transfer. Further, the investi-forcement action taken by the NRC in FY 98:

gation disclosed that both presidents / owners, and others at their direction, including the then-Nine Mile Point Radiation Safety Officer, destroyed, altered, sani-tized, or otherwise disposed of business records An investigation determined that two com-in order to conceal the unauthorized use and trans-puter programmers intentionally altered the Nine fer of the nuclear gauges. Based on the investiga-Mile Point Fitness-for-Duty computerprogram to tive findings, the NRC revoked JLT's Materials ensure that certain individuals would be excluded License and issued orders to both presidents /own-a from random drug testing. Enforcement action ers prohibiting their involvement in NRC- licensed g resulted in orders to the programmers prohibiting activities for a period of 5 years.

them from involvement in NRC-licensed activi-ties for 5 years.

NDT Services, Inc.

Indian Point 2 An extensive investigation by OI determined I An investigation determined that two nuclear that NDT Services, Inc., failed to report a discon-nect event at a job site in Puerto Rico. Several production technicians (NPT) assigned to the Test- allegers came forward indicating a lack of train-ing and Performance Division deliberately falsi- ing and potential falsification of records. The NRC 1 fied an Appendix "R" Emergency Light issued an immediate order prohibiting NDT from surveillance test record, and that one of the NPTs engaging in radiographic activities.

at Indian Point falsified an Emergency Diesel Gen-erator surveillance test record. Enforcement ac-tion resulted m the licensee being assessed a Ohio State University

$55,000 civil penalty. An investigation determined that Ohio State University (OSU) deliberately failed to conduct required inventories and disposed of licensed LIMITED DISTRIBUTION Investigative Information: May not be reproduced or distributed outside NRC without consu! ting the Director, Office of Investigations p 3_ mmy m- ..

_m

] Ol ANNUAL REPORT 9

CUTJ..a.2m u m X X L 2 2:2=~D2 DEW M materials improperly. The investigation disclosed concerns. A Confirmatory Order was issued to that the RSO had willfully failed to perform these STP confirming its agreement to improve the han-requirements. The investigation also concluded dling of safety concerns brought to management that senior management at OSU and/or the radia-g by employees.

E tion safety committee personnel shared culpabil-ity due to their lack ofinvolvement and guidance Wood R:ver Niemorial Hospital E to the radiation safety program. The NRC issued 3

a Severity Level II violation, two Severity Level An investigation disclosed that a nuclear III violations and assessed a combined civil pen- medicine technologist deliberately falsified re- g alty of $13,000 to OSU. In addition, a Demand quired radiation surveys. A Notice of Violation, E for Information was issued because the licensee Severity Level III, and Proposed Imposition of failed to prevent recurrent willful violations. Civil Penalty in the amount of $2,750, was issued to the licensee. Additionally, a Notice of Viola-Terracon Companies, Inc. tion, Severity Level IV, was issued to the nuclear medicine technologist.

An investigation disclosed that Terracon Companies, Inc., deliberately violated procedures regarding the transportation of nuclear moisture density gauges and were allowed to use nuclear moisture density gauges prior to completing re-FroseAt Count Acrious:

" " " " l Of the194 investigations closed in FY 98,53 quired training. An Order Imposing Civil Mon- cases were referred to DOJ for prosecutorial re-etary Penalty in the amount of $5,000 was issued view. During FY 98, OI supported two Federal to Terracon Companies, Inc. grandjuries. In addition, OIinvestigations resulted g in four guilty pleas in Federal court.

3 Arizona Public Service Company . .

The following are examples of sigmficant j An investigation disclosed that two reactor Federal court cases in FY 98:

operators and two senior reactor operators at Palo Verde Nuclear Plant failed to perform the required Dresden Nuclear Plant E surveillance test on the emergency diesel genera-E tors within the time requirements, and deliberately An investigation was conducted in conjunc-

"back timed" documentation to reflect that the test tion with the DOJ and the U.S. Attorney's Office g was conducted. A Notice 6f Violation and Pro- in Chicago, Illinois, which determined that a se- 3 posed Imposition of Civil Penalty in the amount nior reactor operator candidate and a reactor op- .

of $50,000 was issued to the Arizona Public Ser- erator candidate had wrongfully searched an vice Company. Additionally, Notices of Wlations instructor's desk, removed a copy of the senior E!

W were issued to the four individual operators. reactor operator and reactor operator examination being administered at Dresden and made copies, South Texas Project thus compromising the examination. The investi-4 gation resulted in the senior reactor operator can- 1 An investigation determined that four em- didate pleading guilty to a misdemeanor and the ployees at South Texas Project (STP) were sub- reactor operator candidate pleading guilty to 1 jected to a hostile work environment created by a a felony in U.S. District Court. The senior reac-former manager after the employees raised safety tor operator candidate was sentenced to one year I.lMITED DISTRIBUTION Investigative informa1 ion: May not be reproduced or distributed g

g outside NRC without consulting the Directot Office of Investigations M U.S. NucuAR REGUWoW COMMISSION i:M WCW "" ~E" '~'"t""PP~

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probation, fined $2,000 and ordered to serve 100 Federal court. He was sentenced to one year pro-hours of community service. He was also given bation, fined $5,000, and debarred from any NRC

( by the court a lifetime ban from employment in activities for one year.

the nuclear industry regulated by the NRC. The reactor operator candidate was sentenced to tw years probation and fined $1,000. The NRC is- Brandon Supply Company sued a fiva year ban from nuclear activities to this OI was asked to assist the Department of reactor operator candidate. In addition, Common- Energy's (DOE) Office ofInspector General (OIG) wealth Edison, the licensee, was issued a Severity in determining whether Brandon Supply, Inc.,

Level III violation and fined $50,000. (Brandon ), a materials vendor, sold used, surplus

{ and/or remanufactured piping, and valves to A. B. Gamma, Inc. S uthem California Edison's San Onofre Nuclear Generating Station (SONGS). The DOE /OIG, in An investigation was conducted involving a conjunction with the U.S. Attorney's Office, Los storage site in Hammond, Indiana, used for the Angeles, California, served a Grand Jury Sub-storage of truck trailers, which was determined to poena on Brandon for records relating to be contaminated with cesium-137. Twelve con- Brandon's sales to government installations. A taminated recovery dmms with evidence of pos- review of subpoenaed documents disclosed that sible repackaging and processing were discovered during the mid-1992 timeframe, Brandon sold at the site. The investigation disclosed that a surplus used and/or remanufactured piping / valves nuclear consultant was the actual operator of the to SONGS as new materials. With the assistance site. This consultant had previously sought NRC of OI, it was determined that the requisite materi-( interpretation of a common carrier exemption in als were purchased for non-nuclear /non-safety regard to the transport and storage of byproduct related applications and were not upgraded to material and had been advised that an NRC license nuclear safety-related applications. Brandon

[ was required before performing such services. The pleaded guilty to one count of mail fraud. Bran-investigation determined that A. B. Gamma had don was sentenced to one year probation, ordered f deliberately violated NRC regulations. The in- to pay a fine of $32,000, and to pay restitution in

t. vestigation was referred to the U.S. Attorney's the amount of $19,754, to the DOE, the Navy De-Office for the Northern District ofIllinois. The partment, and SONGS. SONGS was awarded consultant pleaded guilty to a misdemeanor in $11,102 of the restitution tota'.

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lNITIATIVES In FY 97, OI commenced an initiative to iden- were operating satisfactorily within OI require-tify and formally report programmatic issues ments, and, more importantly, that OI's clients in which are developed during investigations, but are senior staff management at the regions were well-not directly related to specific wrongdoing, such satisfied with the effectivener afficiency and pro-as weaknesses in management oversight, training ductivity of OI.

s deficiencies, workplace culture / climate, and po-tential areas for improving or clarifying NRC regu_ For the past several years 01 has been work-latory requirements. In FY 98, through close ing with the Office of the Chief Information Of-coordination with the technical, legal, and enforce _ ficer (OCIO) and its contractors to upgrada the ment staffs, OI continued this initiative to enhance OI Management Information System (OIMIS).

the overall NRC mission regarding licensee over- This upgrade was completed in FY 98, and all OI sight and regulatory effectiveness. users of the system, nationwide. were trained in its operation. The system will be deployed dur-Guidance provided by the Commission in the ing the first quarter of FY 99, and is anticipated to Staff Requirements Memorandum for SECY be fully operational in the second quarter of FY 147, "Re-Evaluation of SECY-96-199 Issues; Plan 99. This system will enhance OI's ability to track, to Better Focus Resources on High Priority Dis- monitor and manage investigative case invento-crimination Cases," was implemented with Alle- ries at both the individual field office level and gation Guidance Memorandum (AGM) 98-02, nationwide. In addition,it willincrease the over-

" Revising the Criteria for Investigating Discrimi- all accountability and reporting capability, while nation Allegations." This AGM provides revised decreasing administrative requirements.

priorities for such investigations. It additionally provides guidance for ARBS on implementing the OIis participating in the development of an revised priorities and determining when it is ap. interface of the data bases of the Office of En-propriate to defer discrimination investigations to forcement, the Allegation Management System, the DOL when they are conducting an investiga. and others involved in the analysis and evalua-tion based on the same or similar complaints. tion of operational data. The goalis to link these data elements in an effort to improve the agency's The OI self-assessment program continued ability to detect potential safety performance in FY 98 through visits to OI field offices and trends based on such factors as increased fre-meetings with senior regional staff. Thue visits quency and/or significance of allegations,inves-focused on OI performance measures related to tigative findings (programmatic issues identified general operational and administrative matters, as well as specific wrongdoing), and enforcement compliance with policy and procedures, timeli- . matters. The upgraded OIMIS is compatible with ness, and outcomes of our work with regard to this goal and should be linked to the Allegation effectiveness, efficiency, productivity, and client Management System in FY 99. The data base of satisfaction. Each field office was visited by a the Office of Enforcement is being upgraded in team composed of senior OI Headquarters per- FY 99. The OIMIS is partially linked with the sonnel and a Field Office Director from another current enforcement data base, and full linkage office. The visits determined that the field offices should be accomplished by FY 2000, when the I.lMITED DistnistmON Investigative information: May not be reproduced or distributed outside NRC without consulting the Director, Offic e of investigations e ..,,,- - - - - , - - , " a 01 ANNUAL REPon 13 L

r::XXXrrwL:C 2X.: ZK  ::Eri ..- L.a:ir:22 a:i:L enforcement data base upgrade is complete. In FY 99 in the Reactor and Materials Investiga-addition, the upgraded OIMIS is fully Year 2000 tions Programs to completion of cases in 9 compatible. months, or less. OI also reduced its FY 99 Oper-ating Plan goal regarding cases in inventory over In keeping with overall agency efforts toward 12 months to maintaining ar. ?veraFr of such improving efficiency, OI has been an active part- cases at 9%, or below. Additionally, OI estab-ner in the project to implement the new lished a new goal of 75%, or above, of cases Agencywide Documents Access and Management within the inventory which are brought to a full Systems (ADAMS). When ADAMS is imple- conclusion based on the merits of the case. This mented, it will be linked and integrated with the g

goal addresses effectiveness and efficiency, as g new OIMIS. well as quality and productivity.

OI has supported the agency efforts to for- In summary, OI has successfully met its goals mulate a strong NRC Strategic Plan and Perfor- in FY 98, and will strive for additional efficiencies mance Plan. To accomplish this, OI developed in the coming fiscal year. Our newly developed g Operating Plans for the Rextor Investigations management information system will improve our E Program and the Materials Investigations Program ability to accomplish our mission. Review teams which describe the strategies and performance will again visit each field office. The results will 3 measurements OI will use to support the Perfor- be analyzed and addressed with a view toward con- E mance and Strategic Plans and to adjust budget- tinuing to explore methods to increase effective-ary requirements. In FY 98, improved efficiency ness and efficiency by fostering an environment of I

and the resultant reduction in case completion time productive change in support of NRC goals. E enabled OI to reduce its Operating Plan goal for I

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llMITED DISTRIBtlTION g Investigative Information: May not be reproduced or distnbuted outside NRC without consulting the Director, Office of Investigations E 14 U.S. NucuAn REGUWoW CoMMISSloN NM' ~~"~7CI"~7 - Ar i XP"T