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OIG/97A-21 - Review of the Project Manager Position in the Office of Nuclear Reactor Regulation

July 13, 1998

Attached is the Office of the Inspector General's audit report entitled "Review of the Project Manager Position in the Office of Nuclear Reactor Regulation." This report reflects the results of OIG's audit of the significant expansion of duties of the Office of Nuclear Reactor Regulation (NRR) Project Managers.

On April 28, 1998, we provided a draft of this report to the Deputy Executive Director for Regulatory Programs. On June 1, 1998, the Deputy Executive Director for Regulatory Programs responded to our draft report and generally agreed with the objectives of the report's recommendations. NRC staff agreed measures are needed to correct the weaknesses we reported, and stated they plan to initiate several actions to improve the quality of work and productivity of NRR personnel. Given the need for and importance of improving NRR's regulatory processes, we plan to closely monitor the agency's progress in implementing these initiatives.

Please contact me on 415-5915 if we can assist you further in this matter.

• REPORT SYNOPSIS
• INTRODUCTION
• Background
• FINDINGS
• CONCLUSION
• RECOMMENDATIONS
• AGENCY COMMENTS
• OBJECTIVES, SCOPE, AND METHODOLOGY
• ACRONYMS
• MAJOR CONTRIBUTORS TO THIS REPORT
• GLOSSARY: OFFICE OF THE INSPECTOR GENERAL PRODUCTS
• Investigative
• Audit
• Regulatory

REPORT SYNOPSIS

The U.S. Nuclear Regulatory Commission's (NRC) Office of Nuclear Reactor Regulation (NRR) established a Headquarters-based Project Manager (PM) position to assist in licensing and monitoring the nation's commercial nuclear power plants. The PM role has expanded significantly into a multi-purpose position which has resulted in PMs being responsible for a wide range of duties, such as performing licensing actions and inspection and assessment of licensee performance. Due to the significant expansion of duties, we reviewed the role of PMs, factors that affect their work, and the management processes used to oversee this important agency function.

As initially established, PMs were segregated by functional areas. For example, there were Licensing PMs, Operating Reactor PMs, and Research Reactor PMs. However, when the need to license commercial nuclear power plants decreased, NRR shifted its focus to the operational oversight of the plants and moved the Licensing PM position into the same project organizations as the Operating Reactor PMs. According to NRC's Operating Reactor Project Manager's Handbook, PMs are responsible for approximately nine main functions, such as performing licensing actions and activities, serving as the Headquarters contact point for licensees and NRC Regional Office staff counterparts, coordinating preparation of safety evaluation reports and environmental impact statements, participating in special assignments, and coordinating and presenting information to the Commission and other groups on specific projects and subjects.

As a result of our work, we found there is a lack of consensus between Headquarters and Regional Office staff, as well as between individual NRR offices, regarding management's expectations of the PM role. We analyzed information regarding the amount of time PMs charge to various activities and found a wide variance among PMs in time charged to activities considered most important by senior agency managers. In addition, NRC staff, including PMs, noted they are responsible for too many activities, which may be inhibiting their overall effectiveness.

We also found that NRC has not provided adequate management oversight to ensure PMs are sufficiently trained to perform their jobs. For example, in 1989, NRR established its current guidance which identified the types of training needed by PMs to perform their various assignments, but this guidance has not been followed. This has resulted in a disparity of training among PMs. In addition, PMs are expected to perform certain job tasks without receiving formal training in how to accomplish those tasks. Ineffectual training oversight, combined with the lack of clear PM expectations and competing job demands, may prevent PMs from achieving their maximum effectiveness.

We also examined the timeliness of processing certain types of technical reviews and found that the primary impediment to improving the process is the recurrent need for additional information from licensees and Regional Office staff.

Finally, NRC has recently taken steps to assess factors affecting the PM function, but the scope and outcomes of these efforts are unclear at this time. While the Office of the Inspector General (OIG) supports the NRC's efforts in this regard, we recommend any initiatives be targeted to ensure the agency:

-- Re-evaluates and clearly defines PM job expectations and communicates the expectations to Headquarters and Regional Office staff; and,

-- Ensures PMs receive the training necessary to meet these expectations.

OIG plans to monitor NRC's progress in correcting the weaknesses identified in this important agency function.

INTRODUCTION

The U.S. Nuclear Regulatory Commission's (NRC) Office of Nuclear Reactor Regulation (NRR) established a Headquarters-based Project Manager (PM) position to assist in licensing and monitoring the nation's commercial nuclear power plants. The PM role has expanded significantly into a multi-purpose position which has resulted in PMs being responsible for a wide range of duties, such as performing licensing actions and inspection and assessment of licensee performance. Due to the significant expansion of duties, we reviewed the role of PMs, factors that affect their work, and the management processes used to oversee this important agency function. This report presents the results of our review. Appendix I contains additional information regarding our objectives, scope, and methodology.

Background

NRR is responsible for ensuring public health and safety through licensing and inspection activities at all commercial nuclear power reactor facilities in the United States. The responsibility for providing overall project management activities related to licensing and inspection of nuclear power reactors resides within the Associate Director for Projects (ADPR) organization. (See the organization chart attached as Appendix II.) ADPR has 11 Project Directorates associated with NRC's four Regional Offices. The Directorates, which are headed by Project Directors (PD), direct the activities of approximately 75 PMs. For the purposes of this report, lead Project Managers (lead PMs) will refer to PMs who have "dedicated" plant assignments. Each operating reactor has, in most cases, a lead PM who is the focal point for all information related to that plant. PMs were originally segregated by functional areas. For example, there were Licensing PMs, Operating Reactor PMs, and Research Reactor PMs. However, when the need to license commercial nuclear power plants decreased, NRR shifted its focus to the operational oversight of the plants and moved the Licensing PM position into the same project organizations as the Operating Reactor PMs.

NRC's Operating Reactor Project Manager's Handbook provides PMs guidance and outlines approximately nine main functions required of a lead PM, such as performing licensing actions⁽¹⁾ and activities,⁽²⁾ serving as the Headquarters contact point for licensees and NRC Regional Office staff counterparts, coordinating preparation of safety evaluation reports and environmental impact statements, participating in special assignments, and coordinating and presenting information to the Commission and other groups on specific projects and subjects.

In July 1997, NRR contracted for a job task and functional analysis (JTA) to examine the tasks performed by ADPR personnel and evaluate how and by which position, specific tasks and functions are best performed. In addition, the JTA will identify associated training requirements. The estimated completion date of the JTA is July 1998. As part of another internal evaluation, NRC may perform a "top down" assessment of all the programs and activities in NRR. The assessment would examine NRR's current programs and activities to determine whether they achieve their desired purpose in an efficient and effective manner, and whether they should be continued, redesigned, or sunset. The extent or actual performance of this assessment is uncertain at this time. The findings contained in this Office of the Inspector General (OIG) report should assist NRC management in improving the effectiveness of the PM function, as well as for making decisions on the scope and focus of future assessments.

FINDINGS

We found there is a lack of consensus between Headquarters and Regional Office staff, as well as between individual NRR offices, regarding management's expectations of the PM role and the activities PMs currently perform. The expectations vary considerably, as do the functions agency managers consider most important for PMs to perform. For example, 75 percent of the senior NRR managers we interviewed believe licensing work is the PM's most valuable function, while Regional Office officials generally said that PMs add the most value as focal points of information regarding the status of plant activities, including licensing actions. Our analysis confirmed this lack of role clarity. We analyzed information regarding the amount of time PMs charge and found that PMs charge differing amounts of time to a wide variety of activities. In addition, NRC staff, including PMs, noted they are responsible for too many activities, which may be inhibiting their overall effectiveness.

We also found that NRC has not provided adequate management oversight to ensure PMs are sufficiently trained to perform their jobs. In 1989, NRR established its current guidance which identifies the types of training needed by PMs to perform their various assignments, but this guidance has not been followed. This has resulted in a disparity in the knowledge, skills, and abilities among PMs, which may also impact their effectiveness. In addition, PMs are expected to perform certain job tasks without receiving formal training in how to accomplish those tasks. For example, PMs are responsible for providing input to various sections of the Systematic Assessment of Licensee Performance (SALP) reports, including the Maintenance module, even though PMs may not be trained in maintenance engineering skills.

We examined the processing of certain types of technical reviews and found that the recurrent need for NRR staff to request additional information (RAI) from licensees and Regional Office staff tends to impede the timely completion of licensing actions. The agency might reduce lengthy processing times by focusing on ways to reduce the quantity of RAI requests. As a result, PMs may be more effective in completing licensing actions and activities in a timely manner, and more responsive to licensees and Regional Office staff needs.

The role of the project manager needs better focus

The PM role has expanded significantly into a multi-purpose position which has resulted in PMs being responsible for a wide range of activities. We examined whether NRR management's expectations of PMs, as well as the views and expectations of other NRC staff, are clear. Although PM expectations are defined in the NRC Operating Reactor Project Manager's Handbook, we found that management's expectations of PMs vary widely, and the PM role needs better focus.

Expectations are Widely Varied

In meeting with agency officials at Headquarters and two Regional Offices, we found considerable differences regarding management's expectations of the PM's role, including which PM functions managers consider most important. We augmented the information gained from these interviews by analyzing data obtained from two agency information systems.⁽³⁾ That data comprised time charged to NRR activities during fiscal year (FY) 1997 and was restricted to lead PMs.

We found a lack of consensus between Headquarters and Regional Office staff, as well as between individual NRR offices, regarding expectations of what the PM role should be and the relative importance of functions currently performed by PMs. For example, NRR senior managers agreed that the activities conducted by PMs fit into three broad functional areas: (1) coordination or performance of plant-related licensing actions and licensing activities, such as safety evaluations; (2) acting as a focal point for information related to activities for a particular plant; and (3) participation in plant safety assessments. In general, NRR senior managers considered licensing work as the most important PM function. In contrast, Regional Office staff generally stated that the most important PM function is to be a focal point for information on activities related to a specific plant in support of Region-based oversight of operating reactors.

Headquarters staff also stated that while processing licensing actions and activities is the most important function of the PM position, other activities assigned to PMs may be reducing PM effectiveness and resulting in increases in the licensing action backlog. For example, the licensing action inventory increased 10 percent in FY 1996 and 15 percent in FY 1997. In addition, both managers and staff expressed concerns that PMs are being asked to give priority to processing non-safety-related controlled correspondence, petitions from the public,⁽⁴⁾ and recent increased emphasis on PMs updating technical documents such as Final Safety Analysis Reports (FSAR).

We analyzed PM time charges during FY 1997 and found wide ranges in the amount of time charged to various functions performed by lead PMs. As illustrated in Table 1, we found an uneven distribution of time that PMs spent on activities senior managers deem important, such as licensing, where the actual amount of time PMs charged varied from 12.1 percent to 84.3 percent.

Table 1: Variation in Lead PM Time Charges (excluding absence)

We believe that the PM function will continue to absorb various unrelated duties until a clear role is identified and a focus is given to this position. In our opinion, NRC management needs to: (1) reach a consensus on the expectations of the PM position, including determining how the position fits into the overall picture of licensee safety assessment, and (2) communicate the unified expectations to the staff.

Some PM Activities Need Better Alignment

NRC staff, including PMs, expressed concerns that being responsible for so many competing tasks may inhibit PMs from performing expected activities to the best of their abilities. We found inconsistent performances in two activities PMs are currently responsible for: (1) performance of safety evaluations (SE), and (2) participation in various functional areas of the SALP process. Better alignment of the responsibilities in these two areas might enhance PM effectiveness.

The ADPR organization is responsible for coordinating licensing and technical review activities, and NRC's Operating Reactor Project Manager's Handbook indicates that a PM is expected to be able to prepare SE reports. However, we found management's expectations regarding a PM's performance of SE reviews are mixed. For example, one senior NRR manager stated that PMs do not perform the licensing work, rather they "broker the work and lead the team doing the work." However, another senior manager said the PM function was created to manage the completion of licensing actions and "personally do about 50 percent of the actions." PMs said they are not aware of any management expectations on this subject, so they independently decide whether to perform SEs. Accordingly, we found inconsistencies among PMs related to this activity. In addition, we believe there are inherent weaknesses in performing SE reviews in ADPR which are outlined below:

• ADPR has responsibility for coordinating the completion of SEs, but PMs have no delegated authority to ensure the timeliness of SEs being performed in the Associate Director for Technical Review (ADTR) organization, where most SE review time is actually accrued. We identified about 200,000 hours charged to licensing actions and activities by NRR employees in FY 1997 of which only about 14,000 hours were charged by lead PMs for actually performing a review (not including hours we estimated as needed for a PM to manage the review process).⁽⁵⁾ Technical reviewers charged more than 120,000 hours for performing reviews in ADTR, which is already tasked to perform such reviews.

• According to the staff we interviewed, the technical capability of PMs to perform SEs is widely varied. On the other hand, technical reviewers in ADTR have specific functional expertise that can be maintained through daily on-the-job learning or easily identified training.

In our opinion, the performance of fairly specific SEs detracts from a PM's ability and time to focus on the broader issues of a plant's licensing performance and status, and safety performance. Also, NRR should ensure that management responsibilities are restricted to as few reporting lines as possible to best exercise quality control. Performing SEs within a single office would increase the effectiveness of this important quality control and assure isolation of responsibility. However, because of the role PMs play in plant assessment and their need to maintain an overall awareness of plant activities and plant license conditions, it is important that PMs are involved in setting the priority and completion date goals for licensing actions and activities. As such, we believe PMs are currently the appropriate focal point for the flow of such requests into and out of NRR.

Another PM activity that we found may be performed more efficiently with better alignment is the PM's role in the SALP process. NRC is currently reviewing the licensee performance assessment area, including SALP. However, at this time, the SALP process remains in effect and any changes to this or other agency assessment methods are undetermined.

NRC uses the SALP process to articulate its observations and insights on a licensee's safety performance to licensee management and to the public. The PM's role in the process is primarily to support the NRR SALP Board⁽⁶⁾ members as a coordinator for the functional areas assigned to NRR.

SALP reports generally consist of the assessment of four functional areas for operating reactors: (1) Plant Operations, (2) Maintenance, (3) Engineering, and (4) Plant Support. Regional Office officials determine which of these functional areas NRR will coordinate. However, we found the area designations to NRR are not consistent across Regions, and we found no documented rationale for the functional assignments. For example, NRR PDs monitoring plants in the four Regions have four different SALP responsibilities and the assignments from any Region can change from SALP to SALP. NRC staff, including PMs, told us that unless PMs had prior work experience in the designated SALP area, for instance as a resident inspector, they would typically have to contact resident inspectors and/or Regional Office staff to obtain the additional information needed to provide input. Senior NRC officials and PMs indicated that this additional effort would essentially be duplicating information that already exists in each Region.

We believe the role and responsibilities of the PMs should be used to identify the most appropriate input area to a SALP, or any other performance assessment report, and that area should be consistent for all Project Directorates and Regions. Based on the current role of PMs, we agree with NRC staff who told us PMs would most appropriately participate in the SALP, or other safety assessments, by commenting on a licensee's performance in licensing.⁽⁷⁾ The SALP location designated for commenting on a licensee's licensing performance is the Engineering module. NRR officials told us that they are currently making an effort to increase the amount of information that PMs place on the docket in regard to license activity, which will allow such material to be included in future SALP reports. We encourage NRR to continue this effort.

Improvements needed in training oversight

We reviewed NRR's current training requirements for PMs and discussed the training program with senior NRC officials and PMs. Although NRR has established training requirements, we found that management views on PM training differ and oversight of PMs' training is lacking and needs improvement.

NRR's training requirements for PMs are detailed in a May 1989 memorandum to NRR staff. The memorandum states that supervisors are to identify courses each PM should take to meet the job requirements and those courses become the formal training plan for that employee. Furthermore, NRC Management Directive 10.77, Employee Development and Training, dated August 27, 1996, directs supervisors to meet at least semi-annually with staff members to ensure that all have completed the training specified in formal training and qualification programs. However, PMs told us that their supervisors had not established training plans as required in the 1989 memorandum, nor had any PMs been requested to develop their own plans. We also learned that most of the PDs do not conduct the required semi-annual meetings with their PMs to discuss training needs and that they rely on the PMs to request desired training classes.

The 1989 memo mandates that PMs receive a minimum amount of technical training for each type of plant they are assigned to. A senior NRR official we spoke with emphasized that job assignments should still be matched to the type of plants for which PMs have received training; for example, a Pressurized Water Reactor-trained PM should not be assigned to a Boiling Water Reactor plant. However, in February 1997, an ADPR Division reviewed the training records for its PMs to determine if PMs were meeting the technical training requirements of the position. The review found that about 80 percent of the PMs needed additional training to comply with NRR's 1989 guidance. The review also found that 15 percent of the PMs had no technical training related to the type of plant for which they were the lead PM. In addition, our review found that other ADPR PMs have not received formal training on the type of plants to which they are assigned. Furthermore, NRR managers stated, and the 1989 memorandum provides, that PMs should periodically receive refresher training on their assigned plant types. However, none of the PMs we interviewed had taken refresher courses of any type.

The NRC's Operating Reactor Project Manager's Handbook indicates that a PM must have a high level of technical knowledge to perform and manage quality technical reviews. PMs participate in and lead technical discussions, formulate overall technical judgments, and write technical reports. PMs must be able to correlate the many facets of nuclear and conventional technology that may influence the operation and design of a nuclear facility.

Senior NRR officials told us that training is an important component of PMs' ability to perform their jobs and that they are committed to the development of a technical training program to ensure that all PMs receive the training necessary to meet established requirements. In fact, a formal PM qualifications system, similar to the NRC Inspector Qualification program, is under consideration and favored by many of the staff we spoke with. However, although PMs and PDs we interviewed generally agreed that technical training is important, several said PMs cannot afford the time away from the office because the work backlogs during their absence. On occasion, PMs have rescheduled or canceled training due to more pressing work assignments. Conversely, a few PMs and PDs told us that formal training may not even be necessary, as PMs have gained technical knowledge and expertise through years of on-the-job training (OJT).

While we acknowledge that PMs benefit from OJT, we agree with NRC staff who told us that formal training is needed in addition to OJT, and we do not believe NRC has assured itself that OJT is a sufficient substitute for formal training. We also recognize that the outcomes of the JTA and other initiatives may be used to revise existing training requirements and add newly identified areas to a formal training program. However, regardless of any changes to the program that may result from the JTA or other initiatives, management needs to provide the time and staff support necessary to ensure PMs are adequately trained in areas identified as critical to the PM's job function.

Recurrent requests add to processing time

NRC staff, including PMs, told us that NRR needs to be more responsive to licensees and Regional Office staff needs by improving the timeliness of completing licensing actions and activities. We examined the processing of certain types of licensing actions as part of our review of factors that impact the effectiveness of PMs. We found that the recurrent requests for additional information (RAIs) appear to be the primary impediment to shortening the amount of time it takes to complete licensing actions and activities.

To augment our review, we extracted FY 1997 data from RITS and WISP to analyze how Priority 1 and Priority 2 licensing actions and activities moved between ADPR and ADTR personnel. We also reviewed the pattern of time charges occurring over the period these actions were in process and found that personnel in both organizations charged small amounts of time per week over the course of each review. This resulted in actions taking long periods of time to complete in comparison with the relatively few hours actually spent performing the reviews, as illustrated in Table 2 below.

Table 2: Time to Complete Technical Review Requests^a

To gain a better understanding of the licensing process, we selected a judgmental sample of nine Priority 1 license amendment requests and TIAs⁽⁸⁾. We discussed the processing of each of these actions with the technical review staff and the PM(s) involved and found that the recurrent need to request additional information impacted the timely processing of each of these actions. That is, in the reviewer's professional judgment, the original submittal did not contain sufficient information for the reviewer to perform the evaluation. To obtain the additional information deemed necessary by the applicable reviewer, a request, such as an RAI, was issued to the appropriate licensee or Regional Office staff. The PMs and technical reviewers told us that work virtually stops on actions pending receipt of each RAI response, which can take a week to several months, impacting the PMs' effectiveness in scheduling and performing the licensing portion of their jobs.

PMs told us that they generally perform reviews having historical precedents; however, they stated that approximately 50 percent or more of even those reviews required RAIs. On the other hand, technical reviewers said that one or more RAIs are required for nearly every request they receive in ADTR. Staff felt that NRC's more conservative approach over the past few years has resulted in an increase in formal RAIs that previously might have been requested verbally. Staff also provided these additional reasons for RAIs:

• The quality of submittals varies among licensees; some licensees submit very complete requests and others frequently submit insufficient requests. For example, some concern was expressed that licensees may submit "skeleton" requests because they want NRC, in an RAI, to provide them with specific information needed to complete the review;

• Licensees are being conservative in submitting information to NRC that may be docketed and become accessible to Public Utility Commissions and/or subject to additional NRC regulation;

• Licensees may not have the necessary level of technical expertise in a specific area; and,

• Two parties dealing with complex issues have difficulty anticipating what the other needs for such a review without seeing the request in written form.

PMs and ADTR staff generally stated that RAIs did not take any significant amount of time to prepare; therefore, gains in this area would primarily be in shortening the length of processing time rather than in significant reductions in staff hours consumed. Senior managers told us that NRR may shortly conduct its own review of this area, either internally or through the contracted assessment.

We believe that identifying ways to alleviate the need for recurrent RAIs will improve the timeliness of processing licensing actions and activities, thereby creating an environment where PMs can more effectively perform their licensing role and NRR can be more responsive to the needs of licensees and Regional Office staff.

CONCLUSION

From our discussions with NRC senior officials and other staff, we found that the expectations of the PM position vary considerably. We also found wide variance among PMs in the amounts of time charged to those activities that management considered most important. The diverse expectations of agency officials indicate a lack of clarity in PM position priorities and imply that there are unclear responsibilities for performing activities.

As a result of our review of factors affecting the PM workload, we believe that a lack of clearly defined expectations has led to inconsistencies in the performance of two current PM activities: performing safety evaluations, and providing input to various sections of the SALP reports. In our opinion, the responsibility for performing all SEs should reside within the ADTR organization. We also believe that the PM's role in the SALP process lacks focus and consistency. For any position in NRC that has a role in the safety assessment of a nuclear power plant, the need for clear identification and justification of that position's input is critical to its value. We believe PMs would most appropriately participate in the SALP, or other safety assessments, by commenting on a licensee's performance in licensing.

In addition, although NRC has identified the types of training needed by PMs and issued related guidance, we found that this guidance is not being followed and that management support and attention to PM training is lacking.

Finally, our review of how licensing actions are processed identified RAIs as the primary impediment to the completion of licensing actions.

RECOMMENDATIONS

We recognize that NRC may, as a result of its current agency-wide initiative to implement a performance management process, conduct a "top down" assessment of all the programs and activities in NRR. That assessment would examine NRR's current programs and activities to determine whether they achieve their desired purpose in an efficient and effective manner and whether they should be continued, redesigned, or sunset. However, the performance of that assessment is uncertain at this date. Therefore, to ensure that NRR's Project Manager position has a clear role and focus, we recommend that the agency:

(1) Re-evaluate and clearly define expectations and responsibilities, including participation in the licensee assessment process, for Project Managers based on how such a position fits into NRR's mission to ensure public health and safety through licensing and inspection activities, and communicate the expectations to Headquarters and Regional Office staff.

(2) Follow training guidance and ensure Project Managers are adequately trained in critical job functions. Take appropriate action to assure adequate management support and oversight of the current training requirements for Project Managers, or the requirements as modified by the JTA and other on-going initiatives.

(3) Relocate responsibility for the performance of all technical reviews to ADTR and establish Project Managers as the focal point for movement of those reviews into and out of NRR.

Additionally, NRC might identify ways to improve the effectiveness of PMs in their licensing role by examining factors causing recurrent Requests for Additional Information.

AGENCY COMMENTS

The Deputy Executive Director for Regulatory Programs stated that NRC staff generally agree with the findings and recommendations of this report, but disagreed with our recommendation to relocate responsibility for the performance of all technical reviews to ADTR and establish PMs as the focal point for the movement of those reviews into and out of NRR. His comments are contained in Appendix IV. We have incorporated editorial changes in our final report where appropriate.

Subsequent to receiving NRC's comments, we met with senior agency staff, including the Deputy Executive Director for Regulatory Programs. Staff agreed that measures are needed to correct the weaknesses we reported, and stated they plan to initiate several actions to improve the quality of work and productivity by examining ways to reduce inefficiencies in work flow between ADPR and ADTR. NRC staff agreed to provide OIG with schedules for implementing these actions. Given the need for and importance of improving NRR's regulatory processes, we plan to closely monitor the agency's progress in implementing these initiatives.

OBJECTIVES, SCOPE, AND METHODOLOGY

The objectives of our review were to (1) identify and examine the role of Project Managers in the Office of Nuclear Reactor Regulation (NRR), and (2) examine factors affecting the workload of Project Managers.

To accomplish our objectives, we interviewed senior U.S. Nuclear Regulatory Commission (NRC) officials and staff in NRR, including Project Managers and technical reviewers, as well as two NRC Deputy Executive Directors for Operations. We also interviewed Regional and Deputy Regional Administrators, Division and Deputy Division Directors, Resident Inspectors, and other staff members in Regions I and IV. In addition, we met with representatives of the Nuclear Energy Institute, the nuclear industry's Washington-based policy institute.

We conducted data analysis on information from the agency's Workload Information and Scheduling Program (WISP) and Regulatory Information Tracking System (RITS). This information encompassed the time charged by NRR staff, including Project Managers, to various activities during fiscal year 1997 (weekending October 5, 1996, through weekending September 27, 1997). We performed a quality review of WISP data on a statistical sample.⁽⁹⁾ Based on work performed in an earlier Office of the Inspector General report,⁽¹⁰⁾ we determined that data from RITS was reliable.

We reviewed relevant management controls, including various policies and procedures, NRC Management Directives, the NRC's Operating Reactor Project Manager's Handbook, and other guidance documents in addition to discussing controls with NRC management officials.

We conducted our audit from July 1997 through April 1998 in accordance with generally accepted Government auditing standards.

ACRONYMS

MAJOR CONTRIBUTORS TO THIS REPORT

William D. McDowell
Team Leader

Robert W. Moody
Senior Auditor

Catherine M. Colleli
Management Analyst

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 warranted. The agency is expected to advise the OIG within 90 days of receiving the investigative report as to what disciplinary or other action has been taken in response to investigative report findings.

2. EVENT INQUIRY - 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 OIG of managerial initiatives taken in response to issues identified in these reports but tracking its recommendations is not required.

3. MANAGEMENT IMPLICATIONS REPORT (MIR) - MEMORANDUM

MIRs provide a "ROOT CAUSE" analysis sufficient for managers to facilitate correction of problems and to avoid similar issues in the future. Agency tracking of recommendations is not required.

Audit

4. AUDIT REPORT - BLUE COVER

An Audit Report is the documentation of the review, recommendations, and findings resulting from an objective assessment of a program, function, or activity. Audits follow a defined procedure that allows for agency review and comment on draft audit reports. The audit results are also reported in the OIG'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 provides an initial, quick response to a question or issue, and data to determine whether an in-depth independent audit should be planned. Agency tracking of recommendations is not required.

Regulatory

6. REGULATORY COMMENTARY - BROWN COVER

Regulatory Commentary is the review of existing and proposed legislation, regulations, and policies so as to assist the agency in preventing and detecting fraud, waste, and abuse in programs and operations. Commentaries cite the IG Act as authority for the review, state the specific law, regulation or policy examined, pertinent background information considered and identifies OIG concerns, observations, and objections. Significant observations regarding action or inaction by the agency are reported in the OIG Semiannual Report to Congress. Each report indicates whether a response is required.

1. "Licensing actions" are those licensee requests, such as license amendments, reliefs, or exemptions, that require review and approval by NRC staff before they may be implemented by the licensee. Nearly every such action involves consideration of the effect of that action on public health and safety and the environment. In most cases, this consideration involves preparation of a documented evaluation of those effects known as a safety evaluation.

2. "Licensing activities" are reviews or other tasks that NRC performs for itself, such as answering Technical Information Assistance requests from Regional Offices and reviewing the responses to Generic Letters and Bulletins.

3. NRR's Workload Information and Scheduling Program (WISP) and NRC's Regulatory Information Tracking System (RITS), which is the agency's main system for tracking employee time charges for billing purposes. Employees enter time charges in RITS on a weekly basis for hours worked on various tasks. These tasks are assigned specific Technical Assignment Control numbers for tracking purposes.

4. The amount of time PMs spent in FY 1997 on controlled correspondence and petitions filed by members of the public under Section 2.206 of NRC's regulations, was directly related to the plant a PM was assigned and varies considerably. Some PMs had no such activities.

5. We identified a review as being performed by a PM if a PM charged more than 90 percent of the hours related to that review. Of about 3,400 OIG-identified licensing actions and activities worked on during FY 1997, PMs charged more than 90 percent of the time on about 1,200, requiring an average of about 21 hours or less each to complete. The balance of the reviews were done in ADTR and required an average of about 60-100 hours to complete depending on priority level.

6. The SALP Board includes SES-level representatives from the responsible Region and an NRR SES-level manager from ADPR. Regional Administrators have responsibility for developing and issuing SALP reports.

7. Particularly, the quality, timeliness, and adequacy of a licensee's requests for and actions taken related, for example, to license amendment requests, requests for relief, and requests for exemptions.

8. Task Interface Agreements (TIA) are Regional Office requests for Headquarters technical expertise and assistance.

9. We reviewed a total of 78 records using (1) expected error rate of 5 percent, (2) confidence level of 90 percent, and (3) upper error limit of 10 percent. We checked a total of 13 data fields. Those results indicated that we would have to avoid use of certain WISP data fields and exercise caution with the use of other fields. We made those adjustments in our work and informed NRR officials of the results of our quality review.

10. OIG/96A-09, September 13, 1996, Review of NRC's Part 170 License Fee Billing System.