U.S. Department of Energy 

Office of Inspector General 

Office of Inspections and Special Inquires 

Inspection Report 

Internal Controls over Computer Hard 

Drives at the Oak Ridge National 

Laboratory

INS-O-10-03 August 2010 
Department of Energy

Washington, DC 20585

August 16, 2010

MEMORANDUM FOR THE DIRECTOR, OFFICE OF SCIENCE

FROM: Sandra D. Bruce

Assistant Inspector General for Inspections and Special Inquiries

SUBJECT: INFORMATION: Inspection Report on “Internal Controls over 

Computer Hard Drives at the Oak Ridge National Laboratory”

BACKGROUND

The Department of Energy’s (Department) Oak Ridge National Laboratory (ORNL) in Oak 

Ridge, Tennessee, provides unique expertise in support of the Department’s science and national 

security portfolios. UT-Battelle, LLC, manages ORNL for the Department through the Oak 

Ridge Office. ORNL’s mission frequently involves producing and receiving sensitive electronic 

information, data which requires special handling to protect against unauthorized disclosure. Of 

its approximately 16,400 computers, over 6,200 produce, store or transfer sensitive unclassified 

information, such as Official Use Only and Personally Identifiable Information (PII) (e.g. name, 

social security number and medical history). Department guidance requires that storage media 

no longer in use, but previously used to process sensitive unclassified information, be either 

protected by approved encryption or tracked and controlled until purged or destroyed. After 

receiving an allegation that computer hard drives were being removed by unauthorized 

individuals, a practice that could potentially result in the unauthorized release of sensitive 

unclassified information, the Office of Inspector General initiated an inspection to review the 

facts and circumstances of the allegation. 

RESULTS OF INSPECTION 

We concluded that ORNL did not have adequate internal controls to effectively track and control 

hard drives which potentially contain sensitive unclassified information. Specifically, ORNL 

had not implemented controls to encrypt, or track and control, hard drives that may contain 

sensitive unclassified information. Division Computer Security Officers (DCSOs), who are 

responsible for identifying and addressing computer security concerns, informed us that they 

recovered hard drives from unsecure locations, such as unoccupied offices, hallways, and docks. 

Also, after recovering these hard drives, the DCSOs told us that they could not give us an 

accurate count of the number of hard drives in their possession. To clarify the scope of this 

potential vulnerability, we requested that ORNL conduct a survey to account for the total number 

of hard drives secured by the DCSOs. In response to our request, ORNL identified 

approximately 1,500 hard drives that were secured and stored by ORNL DCSOs at the site. In 

reviewing the survey results, we noted significant disparity between the number of hard drives 
2

estimated by the DCSOs and the actual number recovered. Although the DCSOs controlled and 

stored the hard drives, they acknowledged that the hard drives had not been formally tracked, as 

required.

We also reviewed ORNL’s Campus Support and Instrumentation Division’s hard drive database. 

The Division’s instrument technicians are responsible for removing hard drives from excessed 

computers. A review of the database revealed that hard drives were missing from 424 computers 

of which 193 had been used to process information in sensitive program areas, such as the Health 

Services Division and those located in the Limited Security Area. In accordance with ORNL 

policies, fixed (non-removable) computer hard drives are only to be removed from excessed 

computers by Campus Support technicians. Nothing came to our attention to suggest that there 

had been a compromise of system information. However, the concerns raised during the 

inspection suggest that ORNL was not making the maximum use of readily available measures to 

prevent compromise. 

To address these matters, we made recommendations to the Manager, Oak Ridge Office. 

MANAGEMENT REACTION

In comments on a draft of this report, Oak Ridge Office officials concurred with the report 

recommendations, but took exception to some of our analysis regarding the requirement to track 

or encrypt hard drives; the finding of hard drives in unoccupied rooms; and, the unauthorized 

removal of hard drives. We addressed management’s concerns in the report. 

Attachment

cc: Deputy Secretary

Under Secretary for Science

Chief of Staff

Director, Office of Risk Management, CF-80

Manager, Oak Ridge Office

Team Leader, Office of Risk Management, CF-80

Audit Resolution Specialist, Office of Risk Management, CF-80
REPORT ON INTERNAL CONTROLS OVER COMPUTER HARD 

DRIVES AT THE OAK RIDGE NATIONAL LABORATORY 

TABLE OF 

CONTENTS 

 OVERVIEW

Introduction and Objective 1 

Summary 1 

DETAILS OF FINDINGS 

Inadequate Controls Over Hard Drives 4 

Other Matters 8 

RECOMMENDATIONS 8 

MANAGEMENT AND INSPECTOR COMMENTS 9 

APPENDICES

A. Scope and Methodology 11 

B. Prior Reports 12 

C. Management Comments 13 
Overview 

Page 1 Introduction and Objective 

INTRODUCTION The Department of Energy’s (Department) Oak Ridge National 

AND OBJECTIVE Laboratory (ORNL) in Oak Ridge, Tennessee, provides technology 

and expertise in support of the Department’s science and national 

security portfolios. UT-Battelle, LLC, manages ORNL for the 

Department through the Oak Ridge Office. ORNL’s mission 

frequently involves producing and receiving sensitive electronic 

information data, which requires special handling to protect against 

unauthorized disclosure. Of its approximately 16,400 computers, 

over 6,200 produce, store or transfer information, including 

sensitive unclassified information, such as Official Use Only and 

Personally Identifiable Information (PII) (e.g. name, social security 

number and medical history). As part of its normal procedures, 

ORNL excesses approximately 2,000 computers annually, many of 

which may have processed sensitive unclassified information. 

To help protect sensitive unclassified information, the Department 

has issued specific tracking, controlling, purging and destruction 

guidance. In addition to Department regulations, ORNL has issued 

internal guidance and cyber security requirements which focus on 

protecting such information from inappropriate release. 

After receiving an allegation that computer hard drives were being 

removed by unauthorized individuals, a practice that could 

potentially result in the unauthorized release of sensitive 

unclassified information, the Office of Inspector General initiated 

an inspection. The inspection was initiated to determine whether: 

• ORNL had adequate internal controls to track and control 

excessed computer hard drives; 

• Internal computer hard drives at ORNL were being 

removed contrary to ORNL’s cyber security policies and 

procedures; and, 

• The circumstances surrounding the removal and disposal of 

hard drives at ORNL were consistent with requirements in 

place at the time of our review. 

SUMMARY We concluded that ORNL’s controls over the tracking of hard 

drives, which may contain sensitive unclassified information, were 

inadequate to prevent the unauthorized dissemination of sensitive 

unclassified information. Specifically, ORNL had not 

implemented controls to encrypt or track and control hard drives. 

Department guidance requires that storage media no longer in use, 
Page 2 Summary 

 but previously used to process sensitive unclassified information, 

be either protected by approved encryption or tracked and 

controlled until purged or destroyed. 

During our review, Division Computer Security Officers (DCSOs), 

who are responsible for identifying and addressing computer 

security concerns, informed us that hard drives were removed from 

computers without authorization, and had been abandoned in 

unoccupied offices, hallways, and other locations. This was an 

apparent disregard for established procedures. These hard drives 

were subsequently collected and secured by the DCSOs. We 

requested that ORNL conduct a survey to determine the number of 

hard drives stored and secured by the DCSOs. 1 As a result of our 

request, ORNL identified approximately 1,500 hard drives (which 

were no longer in use) that were secured and stored by the DCSOs 

at the site. 

 In January 2007, the Department issued Cyber Security Program 

Chief Information Officer Guidance CS-11, “Media Clearing, 

Purging, and Destruction Guidance,” which notes that storage 

media no longer in use, which was previously used to process 

sensitive unclassified information, must be tracked and controlled 

until purged or destroyed.2

 These protective measures for sensitive 

unclassified information are intended to minimize the potential of 

the inadvertent disclosure of information while increasing the 

difficulty of unlawfully obtaining such information. 

 We noted that ORNL policy requires full disc encryption for all 

laptop computers. However, for desktop computers, ORNL had 

not implemented existing Department guidance to encrypt or track 

and control hard drives associated with sensitive unclassified 

systems. ORNL internal policy prohibits individuals other than 

Campus Support and Instrumentation Division instrument 

technicians (Campus Support technicians) from removing hard 

drives from computers. However, our review of the Campus 

Support technicians’ database revealed that hard drives were 

removed by someone other than the authorized technicians. 

Specifically, hard drives were missing from 424 computers 

 (11 were laptop computers) of which 193 had been used to process

 

1

 The total number of hard drives stored and secured included abandoned hard drives and hard drives turned in to the 

DCSOs. The survey would be beneficial in determining the accountability of hard drives which may contain 

sensitive unclassified data. 

2

 CS-11 has been replaced by the Department’s issued Cyber Security Technical and Management Requirements, 

“Media Clearing, Purging, and Destruction (TMR-10)”. 
Page 3 Summary 

 information in sensitive program areas, such as the Health Services 

Division and those located in the Limited Security Area (LSA). 

While we are not aware of any resulting compromise, these types 

of weaknesses expose the Department to the risk that sensitive 

mission and PII information may be compromised. We

coordinated with Oak Ridge Office and ORNL officials during our 

fieldwork. In response to our findings, ORNL officials initiated a 

number of corrective actions to track hard drives used to process 

such information. These actions included: 

• Notifying ORNL employees of ORNL’s policy that fixed 

(non-removable) computer hard drives are only to be

removed from excessed computers by Campus Support 

technicians. ORNL is currently working on addressing 

employee awareness and also anticipates revising its cyber 

security training on this topic; 

• Removing and destroying approximately 1,500 hard drives; 

and, 

• Taking action to implement the Department’s most current 

guidance and requirements on tracking hard drives used in 

processing sensitive unclassified information. 

 

 The Office of Inspector General has completed several reviews 

related to information security, expressing concerns regarding the 

ability of Department sites to protect sensitive unclassified 

information. An August 2009 OIG report identified the concern 

that various Department sites were not encrypting sensitive 

information contained on desktops. A list of the associated reports 

is found at Appendix B.
Details of Findings 

Page 4 Details of Findings 

INADEQUATE We concluded that ORNL did not have adequate internal 

CONTROLS controls to effectively encrypt or track and control hard drives that 

OVER potentially contain sensitive unclassified information. Computer 

HARD DRIVES Support technicians and DCSO informed us that hard drives were 

removed from computers by unauthorized personnel and, in some 

instances, abandoned in various locations. This situation occurred 

because some ORNL employees were not aware of the 

requirement that only technicians were authorized to remove hard 

drives; and ORNL had not implemented effective control 

measures. In this regard, officials had not ensured that responsible 

employees complied with ORNL internal guidelines or the 

Department’s guidance and requirement to encrypt or track and 

control, hard drives containing sensitive unclassified information. 

This situation increased the potential for the compromise of 

sensitive unclassified information. 

Recovered The DCSOs informed us that numerous hard drives had been 

Hard Drives recovered from unoccupied ORNL offices, hallways, docks and 

other locations. These hard drives, some from computers used in 

sensitive areas, were removed without authorization, abandoned in 

various locations and subsequently found by DCSOs and secured. 

The identity of the individuals abandoning those hard drives was 

unknown to the DCSOs. Although the DCSOs subsequently 

controlled and stored the hard drives, none of the DCSOs provided 

evidence that the hard drives were formally tracked. To emphasize 

this lack of tracking, one DCSO we interviewed estimated 

approximately 100 recovered hard drives were in storage, but when 

he took us to an adjacent building, we counted only 55 recovered 

hard drives. These hard drives have been stored in two locked 

rooms for years since being secured from various offices and 

laboratories. 

In order to determine the number of untracked hard drives residing 

with the DCSOs, we requested that Laboratory officials conduct a 

survey to identify hard drives secured and stored by ORNL which 

were no longer in use. As a result of our request, the DCSOs 

identified approximately 1,500 hard drives, including the 55 

originally identified in our review. After conducting this 

assessment, ORNL management took immediate action and 

destroyed the 1,500 hard drives in accordance with Department 

regulations. 

The survey results also identified 66 recovered hard drives that 

were identified and collected by the DCSO we mentioned 

previously. No explanation was ever provided to account for the 

additional 11 hard drives. In fact, the survey identified several 
Page 5 Details of Findings 

other DCSOs with a significant disparity between the estimated 

number of hard drives in storage and those actually recovered, the 

largest discrepancy of which was 159 fewer hard drives collected 

than was originally estimated by the DCSO. The lack of controls 

identified in our report and the disparity noted above raised 

additional concerns regarding the potential for compromised 

information.

Hard drive storage 

 During interviews, several DCSOs acknowledged that certain of 

the hard drives contained PII or opined the likelihood of such. To 

determine whether any of the hard drives contained PII, we 

requested that the Office of Inspector General’s Office of 

Investigations conduct a forensic examination of a hard drive that 

another DCSO indicated was found unsecured. In this case, the 

owner was never known to the DCSO. The forensic examination 

of the hard drive revealed that the hard drive contained sensitive 

unclassified information. Specifically, the examination of the hard 

drive revealed 21 pages of PII, including the name, date of birth, 

and medical information pertaining to an ORNL employee.

3

 The 

hard drive also contained the individual’s salary/deduction wage 

allocations, which ORNL treats as sensitive unclassified 

information, and assorted scientific research data.

 

The inspection did not determine whether the personal information 

was generated by the individual on his or her work computer for 

personal use or by ORNL’s Health Services Division, Human 

Resources Directorate, or otherwise maintained by UT-Battelle or 

 

3

 In accordance with Department policy, we notified the Office of Cyber Security regarding this issue. 
Page 6 Details of Findings 

 the Department. In accordance with the Department’s Chief 

Information Officer Guidance CS-38A, “Protection of Sensitive 

Unclassified Information, Including Personally Identifiable 

Information,” UT-Battelle does not consider personal information 

stored by individuals about themselves on their assigned 

workstations or laptops at ORNL to be PII. Therefore, such 

information is not subject to Department protection requirements 

for sensitive unclassified information, unless it contains a social 

security number. ORNL’s policy, “Requirements for Protected 

Personally Identifiable Information,” defines PII as “An 

individual’s first name or first initial and last name in combination 

with any one or more of the following types of information 

including, but not limited to, medical, and financial records, etc.” 

 Senior ORNL officials indicated that “encryption and tracking are 

not currently required by the ORNL contract.” The officials 

further stated that ORNL is in compliance with the current Office 

of Science’s Program Cyber Security Plan (PCSP), which has not 

been updated since 2007. However, the Department requires that 

Departmental elements, including the Office of Science, which 

manages ORNL, develop cyber security requirements through a 

Program Cyber Security Plan (PCSP) using a risk-based approach. 

Specifically, the Office of Science’s PCSP requirement is to 

implement Department Manual 205.1-2, “Clearing, Sanitization, 

and Destruction of Information System Storage Media, Memory 

Devices, and Related Hardware Manual.” Senior ORNL officials 

stated that 205.1-2 does not require encryption or tracking of hard 

drives. However, we noted that Department Manual 205.1-6, 

“Media Sanitization Manual,” issued in December 2008, requires 

that storage media no longer in use, previously used to process 

sensitive unclassified information, must either be protected by 

approved encryption or tracked and controlled until purged or 

destroyed. 

 According to a senior Headquarters official responsible for 

maintaining and developing the PCSP for the Office of Science, 

ORNL is required to implement Department Manual 205.1-2 with 

consideration of Departmental Guidance CS-11, “Media Clearing, 

Purging, and Destruction Guidance.” CS-11, issued in January 

2007, as a part of the Department’s Cyber Security Revitalization 

Plan, identifies specific guidance concerning the tracking or 

control of storage media used to process sensitive unclassified 

information. The senior official stated that if ORNL officials did 

not implement CS-11, they should have documented that a risk 

assessment was conducted and formally identified the individual 

who assumed the risk to not implement the guidance. Oak Ridge
Page 7 Details of Findings 

 Office and ORNL officials were unable to provide documentation 

of the risk assessment conducted, nor could they provide the name 

or title of the individual accepting responsibility for not 

implementing Department guidance. The guidance noted in CS-11 

is similar to the requirements in Department Manual 205.1-6, 

“Media Sanitization Manual,” in that both require that sensitive 

information must be tracked and controlled until purged or 

destroyed. ORNL incorporated the requirements of Department 

Manual 205.1-6 in its contract in March 2009, but had not included 

the Manual requirements in its current ORNL Cyber Security Plan. 

A senior ORNL official from the Office of the Chief Information 

Officer informed us that, prior to our inspection there had been 

discussions of possibly encrypting hard drives for sensitive 

unclassified systems, or identifying systems that may contain such 

information and tracking the associated hard drives as part of 

ORNL’s Cyber Security Plan. In September 2009, ORNL officials 

informed us that they had initiated actions to evaluate the 

implementation of tracking hard drives used to process sensitive 

unclassified information. 

In a related Office of Inspector General report issued in 

 August 2009, concerning the protection of sensitive unclassified 

information, we noted that sites reviewed were not encrypting 

sensitive information contained on desktops. Additionally, the 

National Institute of Standards and Technology (NIST) Special 

Publication 800-111, “Guide to Storage Encryption Technologies 

for End User Devices,” had identified such an encryption practice 

as a “best practice” and part of an effective risk-based management 

approach to information protection. 

Unauthorized We reviewed the hard drive database operated by the ORNL 

Removal of Campus Support technicians. Our review revealed that 424 hard

Hard Drives drives were removed by someone other than the authorized 

technicians during the period of January 2008 to January 2009. Of 

the 424 hard drives, 193 were from sensitive program areas 

involved in national security, export control and medical 

information processing. The review also revealed that many 

computers had multiple hard drives installed, some up to 18. The 

removal of hard drives by unauthorized individuals as recognized 

by Department policy represents a vulnerability. 

 During our interviews, three property custodians and one DCSO 

acknowledged removing the hard drives for use as a storage device 

or for reuse in other computers. One DCSO informed us of 

instances in which computers waiting to be excessed were being 

taken by ORNL employees from unoccupied rooms or hallways.
Page 8 Recommendations 

 In addition, 2 network administrators informed us that they had 

removed 10 hard drives from computers waiting to be excessed 

that were once used in sensitive program areas. This was done in 

order to reuse them in an internal networking device. When asked 

why they removed the hard drives, the administrators indicated 

they were unaware of ORNL’s procedures which limits hard drive 

removal to Campus Support technicians. ORNL procedure entitled 

“Procedure for Disposition of Computers and Other Items with 

Media,” specifies only ORNL’s Campus Support technicians are 

authorized to remove internal hard drives. 

 Senior ORNL officials informed us that many of the hard drives 

were removed by non-Campus Support technicians prior to the 

issuance of its current policy. They further stated that hard drives 

for unclassified computers located in the Limited Security Area 

(LSA) must be removed prior to being excessed from the LSA, but 

the technicians were incorrectly completing the forms. The 

officials also indicated that improvements were made to the 

internal procedures, issued between January 2008 and December

2008, clarifying the Campus Support technicians’ roles and 

responsibilities in hard drive disposition. 

 

OTHER MATTERS Although outside the scope of our inspection, a DCSO informed us 

of computers being taken by some ORNL employees or 

disappearing while waiting to be excessed. During Fiscal Years 

2007 and 2008, ORNL’s Property Management Organization listed 

11 computers stolen and 39 computers/servers lost (3 of those 

reported as lost were subsequently found). The computers were 

likely at the end of their useful life and were not of great value, but 

their disappearance and the lack of controls raised additional 

concerns regarding the potential for compromised information. 

RECOMMENDATIONS Significant and timely corrective actions have been taken by 

ORNL to improve security controls for most of the vulnerabilities 

we identified; however, additional actions are warranted. 

 We recommend that the Manager, Oak Ridge Office: 

1. Implement the Department’s requirements concerning 

storage media no longer in use and previously used to 

process sensitive unclassified information, to protect the 

media by approved encryption, or tracking and control until 

purged or destroyed. 

2. Ensure ORNL trains employees on its policy and 

procedures regarding removal of computer hard drives. 
Page 9 Management and Inspector Comments 

MANAGEMENT AND In comments on a draft of this report, the Department’s Oak Ridge 

INSPECTOR Office concurred with the recommendations. Although 

COMMENTS management concurred with our recommendation, they took 

exception to some of our analysis regarding the requirement to 

track or encrypt hard drives; the finding of hard drives in 

unoccupied rooms, and the unauthorized removal of hard drives. 

Management’s comments are included in their entirety in 

Appendix C of this report. 

We consider management’s comments and corrective actions 

planned and/or taken responsive to our recommendations. We 

have addressed management’s comments below and made

technical changes to the report, as appropriate. 

Management said that the ORNL sanitization policies are in 

compliance with the current Office of Science (SC) Program Cyber 

Security Plan (PCSP). The PCSP states, “SC policy is to 

implement DOE M 205.1-2 with consideration of CS-11.” 

Management observed that tracking or encryption of hard drives is 

not required. We acknowledge that DOE M 205.1-2 does not 

require tracking or encryption of hard drives; however, CS-11 does 

require storage media no longer in use, previously used to process 

sensitive unclassified information, be tracked and controlled until 

purged or destroyed. Furthermore, if ORNL officials considered 

but did not implement CS-11, they should have documented the 

risk assessment conducted and formally identified the individual 

who assumed the risk to not implement the guidance. The Oak 

Ridge Office and ORNL officials were unable to provide us that 

documentation. 

 Management commented that our reporting of hard drives found in 

unoccupied offices is misleading because offices used for storage 

were locked. While we agree that several unoccupied offices and 

locations used for storage were locked, we were told by DCSOs 

(who are responsible for accountability of hard drives) of instances 

in which hard drives were collected from unlocked offices and 

locations, which the DCSOs subsequently secured. Also, one 

DCSO informed us of instances in which computers awaiting 

excessing were being taken by ORNL employees from unoccupied 

rooms or hallways. 

 Management noted non-instrument technicians removed many 

hard drives prior to policy revisions and that some systems in the 

LSA had removable hard drives, accounting for some missing hard 

drives. Removable hard drives were not listed in our sample. 
Page 10 Management and Inspector Comments 

 Also, we noted that the policy to restrict the removal of hard drives 

from unclassified systems, including systems in the LSAs, was 

implemented in October 2005. Consequently, it seems unlikely 

that hard drives removed from computers by non-technicians prior 

to October 2005 were part of our data sample. Also, management 

noted that several boxes of hard drives not associated with 

computers were turned in by ORNL personnel, indicating the 

awareness of needed sanitization. The collection of several boxes 

of hard drives not associated with computers raises additional 

concerns regarding the lack of controls and the potential for 

compromised information from other media.
Appendix A 

Page 11 Scope and Methodology 

SCOPE AND Our review included computer excessing policies and procedures 

METHODOLOGY at the Oak Ridge National Laboratory and Department. The 

majority of our fieldwork was conducted from January through 

April 2010. Our research, analysis and fieldwork activities 

included: 

• Interviews with approximately 48 property custodians, 

DCSOs, security officials associated with over 30 ORNL 

program areas; 

• Review of Department and local policies and regulations 

pertaining to internally transferred and excessed computers; 

• Assessment of documents, survey results, and electronic 

spreadsheets regarding computers excessed, unaccounted 

for hard drives, abandoned hard drives, and lost or stolen 

computers; 

• Coordination with the Office of Inspector General’s

Technology Crimes Section to recover information stored 

on a recovered and secured hard drive; and, 

• Review of prior Office of Inspector General and 

Government Accountability Office reports, and other

related reports. 

This inspection was conducted in accordance with the Council of 

the Inspectors General on Integrity and Efficiency, “Quality 

Standards for Inspections,” issued by the President’s Council on 

Integrity and Efficiency. 
Appendix B 

Page 12 Prior Reports 

PRIOR REPORTS The following are prior related DOE Office of Inspector General 

reports: 

 

• “The Federal Energy Regulatory Commission’s 

Unclassified Cyber Security Program – 2009” (DOE/IG0830, October 2009); 

• “The Department’s Unclassified Cyber Security Program – 

2009” (DOE/IG-0828, October 2009); 

• “Protection of the Department of Energy’s Unclassified 

Sensitive Electronic Information” (DOE/IG-0818, August 

2009); 

• “Security Weaknesses in the Handling of Unclassified 

Printers and Copiers at the Oak Ridge National Laboratory” 

(INS-L-09-06, S08IS001, May 2009); 

• “Personal Property Management at Lawrence Livermore

National Laboratory” (INS-O-09-03, May 2009); 

• Special Report: “Management Challenges at the 

Department of Energy” (DOE/IG-0782, December 2007);

• “Security Over Personally Identifiable Information”

(DOE/IG-0771, July 2007); 

• “Internal Controls Over Computer Property at the 

Department’s Counterintelligence Directorate” (DOE/IG0762, March 2007); and, 

• “Excessing of Computers Used for Unclassified Controlled 

Information at Lawrence Livermore National Laboratory” 

(DOE/IG-0759, March 2007).
Appendix C 

______________________________________________________________________________ 

Page 13 Management Comments 
Appendix C (continued) 

______________________________________________________________________________ 

Page 14 Management Comments 
Appendix C (continued) 

______________________________________________________________________________ 

Page 15 Management Comments 
Appendix C (continued) 

______________________________________________________________________________ 

Page 16 Management Comments 
 IG Report No. INS-O-10-03

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