ML25239B546
| ML25239B546 | |
| Person / Time | |
|---|---|
| Issue date: | 08/27/2025 |
| From: | Virkar H NRC/OIG/AIGA |
| To: | Buhler M NRC/EDO |
| References | |
| DNFSB-24-A-04 | |
| Download: ML25239B546 (1) | |
Text
NRC Headquarters l 11555 Rockville Pike l Rockville, Maryland 20852 l 301.415.5930 nrcoig.oversight.gov MEMORANDUM DATE:
August 27, 2025 TO:
Mary J. Buhler Executive Director of Operations FROM:
Hruta Virkar, CPA /RA/
Assistant Inspector General for Audits & Evaluations
SUBJECT:
STATUS OF RECOMMENDATIONS: AUDIT OF THE DEFENSE NUCLEAR FACILITIES SAFETY BOARDS FREEDOM OF INFORMATION ACT PROGRAM (DNFSB-24-A-04)
REFERENCE:
SENIOR PROGRAM ADVISOR, MEMORANDUM DATED JULY 24, 2025 Attached is the Office of the Inspector Generals (OIG) analysis and status of recommendation as discussed in the agencys response dated July 24, 2025. Based on this response, recommendations 1.3, 1.4, 2.1, 2.2, and 3.2 are now closed.
Recommendation 3.1 was previously closed. Recommendations 1.1 and 1.2 remain open and resolved. Please provide an updated status of the open, resolved recommendations by February 25, 2026.
If you have any questions or concerns, please call me at 301.415.1982 or Connor McCune, Senior Auditor, at 301.415.3943.
Attachment:
As stated cc: K. Herrera, DEDO J. Biggins, DEDRS G. Garvin, DEDRS
Audit Report AUDIT OF THE DEFENSE NUCLEAR FACILITIES SAFETY BOARDS FREEDOM OF INFORMATION ACT PROGRAM Status of Recommendations (DNFSB-24-A-04) 2 Recommendation 1.1:
Revise its Freedom of Information Act (FOIA) regulations to capture substantive changes from the FOIA Improvement Act of 2016.
Agency Response Dated July 24, 2025:
The Defense Nuclear Facilities Safety Board (DNFSB) is currently revising the FOIA regulation and operating procedure to capture all the detailed comprehensive procedures and federal guidelines. This regulation and operating procedure will be finalized by the end of the third quarter. However, the fee scheduled was updated in October 2024. Agency FOIA Representatives were identified, and training was conducted in June 2025 that outlined a comprehensive overview of the FOIA and its practical application within a government agency.
OIG Analysis:
Upon receipt and review of the DNFSBs updated FOIA regulation, the OIG will close this recommendation.
Status:
Open: Resolved
Audit Report AUDIT OF THE DEFENSE NUCLEAR FACILITIES SAFETY BOARDS FREEDOM OF INFORMATION ACT PROGRAM Status of Recommendations (DNFSB-24-A-04) 3 Recommendation 1.2:
Update its internal FOIA guidance for statutory timelines, extension conditions, fee waivers, perfection policy, referrals, and consultations.
Agency Response Dated July 24, 2025:
DNFSB is currently revising the FOIA regulation and operating procedure to capture all the detailed comprehensive procedures and federal guidelines. This regulation and operating procedure will be finalized by the end of the third quarter. However, the fee schedule was updated in October 2024.
OIG Analysis:
Upon receipt and review of the DNFSBs updated FOIA operating procedure, the OIG will close this recommendation.
Status:
Open: Resolved
Audit Report AUDIT OF THE DEFENSE NUCLEAR FACILITIES SAFETY BOARDS FREEDOM OF INFORMATION ACT PROGRAM Status of Recommendations (DNFSB-24-A-04) 4 Recommendation 1.3:
Require annual FOIA-specific training for key officials involved in its FOIA program oversight.
Agency Response Dated July 24, 2025:
Agency FOIA Representatives were identified, and training was conducted in June 2025 that outlined a comprehensive overview of FOIA and its practical application within a government agency.
OIG Analysis:
The OIG reviewed the FOIA training records for the key officials in the FOIA program and training materials. This recommendation is now closed.
Status:
Closed
Audit Report AUDIT OF THE DEFENSE NUCLEAR FACILITIES SAFETY BOARDS FREEDOM OF INFORMATION ACT PROGRAM Status of Recommendations (DNFSB-24-A-04) 5 Recommendation 1.4:
Develop a quality assurance process to review FOIA responses for completeness.
Agency Response Dated July 24, 2025:
DNFSB has established the Government Information Systems Program Manager (GIPSM) that plays a vital role in supporting the quality assurance and review of the FOIA requests, primarily by ensuring the technical integrity, completeness, and efficient handling of electronic information. While the final legal determination rests with the agency's FOIA Office and legal counsel, the Information Technology Program Manager's expertise is crucial the robust and compliant process.
DNFSB utilizes the ServiceNow Portal that significantly helps with FOIA requests by providing a centralized, automated, and transparent platform for managing the entire FOIA lifecycle. It leverages core capabilities, often seen in IT Service Management (ITSM) or Customer Service Management (CSM). ServiceNow Portal has improved the FOIA efficiency, reduced backlogs, and enhanced compliance for DNFSB.
OIG Analysis:
The OIG reviewed the documented job duties for the new GIPSM role and determined that they meet the intent of the recommendation. This recommendation is now closed.
Status:
Closed
Audit Report AUDIT OF THE DEFENSE NUCLEAR FACILITIES SAFETY BOARDS FREEDOM OF INFORMATION ACT PROGRAM Status of Recommendations (DNFSB-24-A-04) 6 Recommendation 2.1:
Develop and implement systematic quality assurance procedures for FOIA request tracking and management.
Agency Response Dated July 24, 2025:
DNFSB has completed full integration of FOIA requests into the ServiceNow platform. ServiceNow provides robust capabilities that significantly enhance quality assurance (QA) for FOIA (Freedom of Information Act) tracking and management. It moves beyond simple tracking to embed QA directly into the workflow, ensuring accuracy, completeness, and compliance. The leveraging these integrated features, ServiceNow transforms FOIA management from a manual, error-prone process into a structured, auditable, and continuously improving operation, significantly enhancing the quality assurance of DNFSBs FOIA responses.
OIG Analysis:
DNFSB staff performed a demonstration of the FOIA request tracking, processing, and quality assurance measures within the ServiceNow Portal for the OIG. Based on this demonstration, this recommendation is now closed.
Status:
Closed
Audit Report AUDIT OF THE DEFENSE NUCLEAR FACILITIES SAFETY BOARDS FREEDOM OF INFORMATION ACT PROGRAM Status of Recommendations (DNFSB-24-A-04) 7 Recommendation 2.2:
Complete compliance with and implement the National Archive and Records Administrations (NARA) electronic records management requirements as they pertain to FOIA records.
Agency Response Dated July 24, 2025:
DNFSB has completed full integration of FOIA requests into the ServiceNow platform. ServiceNow provides robust capabilities that significantly enhance quality assurance (QA) for FOIA (Freedom of Information Act) tracking and management. It moves beyond simple tracking to embed QA directly into the workflow, ensuring accuracy, completeness, and compliance. The leveraging these integrated features, ServiceNow transforms FOIA management from a manual, error-prone process into a structured, auditable, and continuously improving operation, significantly enhancing the quality assurance of DNFSBs FOIA responses.
OIG Analysis:
DNFSB staff performed a demonstration of the FOIA request tracking function within the ServiceNow Portal for the OIG.
Based on this demonstration, this recommendation is now closed.
Status:
Closed
Audit Report AUDIT OF THE DEFENSE NUCLEAR FACILITIES SAFETY BOARDS FREEDOM OF INFORMATION ACT PROGRAM Status of Recommendations (DNFSB-24-A-04) 8 Recommendation 3.2:
Establish procedures to ensure transparent communication with the Contracting Officers Representative (COR) on developments in the FOIA program and facilitate adequate monitoring of the FOIA-specific sections of the contract in accordance with its terms.
Agency Response Dated July 24, 2025:
All FOIA request processing, status updates, and relevant communications are now managed within ServiceNow. This platform provides the COR with direct, real-time access to dashboards and reports detailing key FOIA program developments, including request volumes, processing times, and backlog status. Automated notifications alert the COR to critical milestones or significant events within the FOIA program, ensuring they are consistently informed.
OIG Analysis:
After receipt and review of the examples of direct communication with the COR regarding important FOIA matters, and confirmation of COR involvement in the ServiceNow portal for FOIA requests during the ServiceNow demonstration, this recommendation is now closed.
Status:
Closed