OFFICE OF

THE INSPECTOR GENERAL

U.S. NUCLEAR

REGULATORY COMMISSION

Review of NRC’s Quality Assurance

Process for Official Documents

OIG-01-A-02 February 23, 2001

AUDIT REPORT

All publicly available OIG reports (including this report) are accessible through

NRC’s website at:

http://www.nrc.gov/NRC/OIG/index.html
February 23, 2001

MEMORANDUM TO: William D. Travers

Executive Director for Operations

FROM: Stephen D. Dingbaum/RA/

Assistant Inspector General for Audits

SUBJECT: REVIEW OF NRC’S QUALITY ASSURANCE PROCESS FOR

OFFICIAL DOCUMENTS (OIG-01-A-02)

Attached is the Office of the Inspector General’s (OIG) audit report titled, Review of NRC’s

Quality Assurance Process for Official Documents. The report incorporates comments provided

by your offices, as appropriate, within the body of the report. Agency managers elected not to

provide written comments to the draft report as indicated in Appendix IV.

The provision of inaccurate information by any Government agency can have harmful

consequences on both the decision-making process that relies on such information and the

public’s confidence in the agency. Without exception, the Nuclear Regulatory Commission

(NRC) offices contacted during this review employ quality assurance measures to ensure

accuracy in the documents they generate. However, this report identifies inconsistencies in

NRC’s guidelines and policies which increase the risk of releasing inaccurate information.

This report makes two recommendations to improve NRC’s quality assurance process for

official documents. Please provide information on actions taken or planned on each of the

recommendations directed to your office no later than April 9, 2001. Actions taken or planned

are subject to OIG follow-up.

If you have any questions, please call me at 415-5915.

Attachment: As stated
cc: R. McOsker, OCM/RAM

B. Torres, ACMUI

B. Garrick, ACNW

D. Powers, ACRS

J. Larkins, ACRS/ACNW

P. Bollwerk III, ASLBP

K. Cyr, OGC

J. Cordes, Acting OCAA

S. Reiter, Acting CIO

J. Funches, CFO

P. Rabideau, Deputy CFO

J. Dunn Lee, OIP

D. Rathbun, OCA

W. Beecher, OPA

A. Vietti-Cook, SECY

F. Miraglia, DEDR/OEDO

C. Paperiello, DEDMRS/OEDO

P. Norry, DEDM/OEDO

J. Craig, AO/OEDO

M. Springer, ADM

R. Borchardt, OE

G. Caputo, OI

P. Bird, HR

I. Little, SBCR

W. Kane, NMSS

S. Collins, NRR

A. Thadani, RES

P. Lohaus, OSP

F. Congel, IRO

H. Miller, RI

L. Reyes, RII

J. Dyer, RIII

E. Merschoff, RIV

OPA-RI

OPA-RII

OPA-RIII

OPA-RIV
Review of NRC’s Quality Assurance Process for Official Documents

1

EXECUTIVE SUMMARY

PURPOSE

As part of previous audit and investigative work, the Office of the Inspector General

(OIG) identified instances in which the information prepared by Nuclear Regulatory

Commission (NRC) staff for the Commission, Congress, Office of Management and

Budget, public, and others was of questionable accuracy and reliability. The provision of

inaccurate information by any Government agency can have harmful consequences on

both the decision-making process that relies on such information and the public’s

confidence in the agency. We initiated this review to determine whether NRC has

adequate processes in place to ensure that official NRC documents contain accurate

information.

BACKGROUND

The Commission and Congress base key decisions regarding NRC programs and

operations on the information provided in official NRC documents. The agency has

publicly recognized the importance of providing clear and accurate information by

incorporating it into its Fiscal Year 2000 - 2005 Strategic Plan as a cornerstone of its

goal to increase public confidence.

NRC’s quality assurance process for official documents relies on two primary

components: (1) the ability of document originators to provide accurate information in

the documents they generate, and (2) the concurrence process. Under this process,

staff sign off on a document before passing it up the line for additional concurrences

and, ultimately, final sign off by an NRC official.

RESULTS IN BRIEF

Without exception, the NRC offices contacted during this review employ quality

assurance measures to ensure accuracy in the documents they generate; however

inconsistent practices were identified that increase the risk of releasing inaccurate

information. Specifically, the role and responsibilities of NRC’s document originators are

unclear in the agency’s guidance pertaining to correspondence. By providing basic

guidance to document originators on fact checking methods and clarifying existing

guidance concerning their role and the review process, NRC can improve the quality of

its official documents and better achieve its goal of increasing public confidence. In

addition, the Executive Director for Operations (EDO) should issue an announcement

that provides clear expectations for staff to heighten awareness of the importance of

information accuracy.

At the exit conference, NRC managers agreed with the report’s finding and

recommendations. During this discussion, both NRC managers and OIG highlighted the

need for NRC staff to pay close attention to the language they use in written

documents to avoid misinterpretation by the reader. In addition, a senior official stated
Review of NRC’s Quality Assurance Process for Official Documents

2

that initiatives are underway to strengthen the quality assurance process for official

documents in two offices that report to the EDO.

RECOMMENDATIONS

This report makes two recommendations to improve NRC’s quality assurance process

for official documents.
Review of NRC’s Quality Assurance Process for Official Documents

TABLE OF CONTENTS

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

FINDING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

AGENCY COMMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

APPENDICES

I SCOPE AND METHODOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . 9

II AGENCY “GOOD PRACTICES” . . . . . . . . . . . . . . . . . . . . . . . 10

III ABBREVIATIONS AND ACRONYMS . . . . . . . . . . . . . . . . . . . 14

IV AGENCY RESPONSE TO DRAFT REPORT . . . . . . . . . . . . . . 15
Review of NRC’s Quality Assurance Process for Official Documents

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PURPOSE

As part of previous audit and investigative work, the Office of the Inspector General

(OIG) identified instances in which the information prepared by Nuclear Regulatory

Commission (NRC) staff for the Commission, Congress, Office of Management and

Budget (OMB), the public, and others was of questionable accuracy and reliability. OIG

has also received allegations and other feedback in recent years that have called into

question the accuracy of information provided by NRC.

The provision of inaccurate information by any Government agency can have harmful

consequences on both the decision-making process that relies on such information and

the public’s confidence in the agency. The main purpose in conducting this audit was to

evaluate whether NRC has adequate processes in place to ensure that official NRC

documents contain accurate information. It was not to uncover inaccuracies in official

documents or second guess the work of NRC technical staff. Our review focused on

official correspondence.

BACKGROUND

NRC relies on written information to accomplish its regulatory mission. The Commission

and Congress base key decisions regarding NRC programs and operations on the

information provided in official NRC documents. Therefore, it is imperative that NRC’s

information be accurate and fairly reflect the true status of the matter being portrayed.

NRC generates a variety of written documents, including SECY papers; congressional

testimony; responses to correspondence from members of Congress, the public,

licensees, other Government agencies, and other stakeholders; inspection reports;

financial reports; research reports; Federal Register notices; and news releases.

Agency guidance (as described below) related to the preparation of these and other

types of documents recognizes the need for both accuracy and clarity in these products

to ensure that the intended message is conveyed to the recipient. When a reader is

unable to decipher the intended message — even if the document is technically

accurate — a key purpose of issuing the document is not achieved.

NRC strives to ensure that information sent to the public and other stakeholders is

accurate. The agency has recognized the importance of providing clear and accurate

information by incorporating it into its Fiscal Year 2000-2005 Strategic Plan as a

cornerstone of its goal to increase public confidence. The plan states:

NRC views building and maintaining public trust and confidence that the NRC is

carrying out its mission as an important performance goal for the agency. To

reach this goal, the NRC must be viewed as an independent, open, efficient,

clear and reliable regulator. This will be accomplished by providing our

stakeholders with clear and accurate information about, and a meaningful role in,

our regulatory programs.
Review of NRC’s Quality Assurance Process for Official Documents

1 The current version of MD and Handbook 3.57 was approved August 4, 1994.

5

The agency’s guidance concerning accuracy and clarity appears in various publications,

including management directives, NRC’s Principles of Good Regulation, the NRC

Inspection Manual, and specific office and regional instructions. Management Directive

(MD) and Handbook 3.57, “Correspondence Management,”(1) speak directly to the

preparation of NRC’s official correspondence, which is defined in MD 3.57 as “a generic

term for any written communication.” Another key piece of guidance, NRC Inspection

Manual Chapter 0610, “Inspection Reports,” provides instructions concerning content,

format, and style to ensure that inspection reports “clearly communicate significant

inspection results to licensees, NRC staff, and the public.” NRC’s web page also

contains information about the agency’s Plain Language Action Plan, which emphasizes

the need for NRC staff to use “plain, understandable language” in documents and at

public meetings.

NRC’s process to ensure accuracy in official documents relies on two primary

components. The first component is the ability of document originators to provide

accurate information. The second is the concurrence process wherein staff sign off on a

document before passing it up the line for additional concurrences and, ultimately, final

sign off by an NRC official. According to Handbook 3.57, “The purpose of obtaining

concurrence is to ensure that appropriate managers with collateral responsibility are

aware of and agree to what is written. Although it is important that our documents be of

the highest possible quality, those concurring should focus on the accuracy and clarity

of the information rather than on nonsubstantive editorial changes.”

In 1992 and 1995, a former Executive Director for Operations (EDO) issued memoranda

concerning document accuracy and the concurrence process. The first memo, which

referred to criticism NRC had received concerning “the accuracy of information

contained in some of the staff-generated documents,” conveyed “guiding principles” that

the EDO wanted NRC to follow in the process of originating and concurring on

documents. These principles are still contained in MD and Handbook 3.57. In the 1995

memo, the EDO expressed concern about “excessive concurrences and the resultant

delays” and issued office-specific goals for limiting the concurrence chain to a specific

number of reviewers. These goals are no longer followed, and concurrence chain

lengths vary among offices and for different product types.

FINDING

NRC offices contacted during this review employ quality assurance practices to ensure

accuracy in the documents they generate; however, inconsistencies in Handbook 3.57

and in quality assurance practices increase the risk of releasing inaccurate information.

Specifically, the role and responsibilities of NRC’s document originators are unclear in

Handbook 3.57, and document originators employ inconsistent approaches to quality

assurance. As a result, inaccurate information has been released to Congress or the

public and NRC’s credibility is adversely affected.

Document Originator’s Role and Responsibility Are Unclear in Handbook 3.57
Review of NRC’s Quality Assurance Process for Official Documents

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The primary source of guidance for ensuring accuracy in SECY papers and official

correspondence is MD and Handbook 3.57. This guidance:

 emphasizes the responsibility of document originators for ensuring technical

accuracy in the documents they generate, and

 stresses the importance of the concurrence process as a quality assurance

measure.

Document Originators

Accurate information is the responsibility of the document originator. The document

originators interviewed conveyed an understanding of their responsibility to produce an

accurate draft; however, they described a wide variety of measures they undertake to

make sure their work is accurate. All strategies were based on the individual’s judgment

about what is appropriate, rather than on an NRC-imposed standard. Other factors that

influenced the originator’s approach to quality assurance included deadlines and

availability of staff with the expertise to provide input. One method used by document

originators to check accuracy was a point-by-point verification of a report’s facts and

figures by a co-worker who was not involved in the original draft. Another approach was

taken when the author was so familiar with his subject that he was confident he included

the correct information in his document, without any additional verification. In between

these two extremes were staff who (1) kept highlighted source files of information used

to draft a document, (2) did not keep source files, but knew where they could locate the

source documents if necessary, (3) asked cold readers to review documents, and (4)

went to specific subject matter experts to verify certain aspects of a report. The

variations described above are not necessarily problematic, but reflect the fact that MD

and Handbook 3.57 fail to establish a minimum threshold concerning fact-checking

methods to be employed by document originators.

As currently written, Handbook 3.57 is inconsistent in addressing where the originator’s

responsibility ends with regard to the draft document. Part II (J)(2)(b) of Handbook 3.57

states, “The primary author is responsible for the accuracy of all statements of fact and

all statement[s] of technical opinion contained in the original [emphasis added]

document.” Yet, according to Part I (H)(5), the originator is responsible for “Verifying

that all aspects of the communications are correct.” These two statements are

inconsistent. The first implies the document originator must verify the accuracy of the

original document only, while the latter suggests that originator responsibility carries

through until the document is finalized.

As another example of inconsistency in the guidance, Part II (C)(4)(b) of Handbook 3.57

states that the primary author is responsible for, “Ensuring that contributions from others

are accurate and [emphasis added] that the contributor is an appropriate source for the

information.” Yet, according to Part II (J)(2)(ii), the primary author must, “Ensure that

contributions from others are accurate or [emphasis added] that the contributor is a

proper source for accurate information.” These two statements are inconsistent

because the first suggests that the primary author must undertake two distinct quality

assurance measures with regard to contributions from others, while the latter suggests

that either measure will suffice.
Review of NRC’s Quality Assurance Process for Official Documents

2 This requirement also appears in Part IV (R)(5) of Handbook 3.57.

3 The more stringent requirement (i.e., if changes are made to a document that affect specific facts

or substance, the document must be returned to the primary author for “verification and/or

documentation of the change and new concurrences”) appears in Parts III and IV of MD 3.57,

which address letters and memoranda. The less stringent requirement (i.e., return the document

to the primary author for verification and/or documentation of the change) appears in Part II, which

addresses principal and general correspondence. The requirement is unclear because letters and

memoranda will, by definition, fall into either the principal or general correspondence category.

Principal correspondence, as defined in MD 3.57, is executive correspondence that on the basis of

its source, subject matter, sensitivity, or possible impact on NRC programs requires priority control,

response, and management awareness. General correspondence, according to MD 3.57, refers to

the correspondence that does not fit under the principal correspondence category.

7

Concurrence Process

A lack of clarity in Handbook 3.57 pertaining to the meaning of concurrence exists.

According to Part II (J)(3), “the purpose of obtaining concurrence is to ensure that

appropriate managers with collateral responsibility are aware of and agree to [emphasis

added] what is written.” Yet, two paragraphs later, the guidance states, “An individual’s

concurrence does not mean that he or she agrees [emphasis added] with the structure

or every detail of the document.” Although concurrence chain reviewers were not

unclear on their responsibilities in that role, this contradictory explanation in Handbook

3.57 constitutes another example where the agency’s expectations and guidance need

to be clarified.

Another relevant inconsistency in Handbook 3.57 pertains to whether documents are

sent back to the originator to review and concur on changes that arise through the

concurrence process. Handbook 3.57 makes two different statements concerning this

issue. Part III (S)(3)(2) requires that if changes are made to a document that affect

specific facts or substance, the document must be returned to the primary author for

“verification and/or documentation of the change and new concurrences.” However,

Part II (J)(3)(e) requires return of the document to the primary author for verification

and/or documentation of the change but omits the requirement for “new

concurrences.”(3) The return of documents to the originator for review and/or

concurrence is a prudent measure for ensuring that inaccuracies are not inadvertently

introduced to a document during the review process. However, it is an essential

requirement if document originators are being held responsible for “verifying that all

aspects of the communications are correct.” If NRC’s intent is that responsibility for

accuracy shifts once changes are introduced through the concurrence process, the

Handbook needs to state this clearly so that accountability can be established for later

and final versions of the product.
Review of NRC’s Quality Assurance Process for Official Documents

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Specific practices that enhance the concurrence/quality assurance process are included

in Appendix III of this report.

Conclusion

The failure to employ appropriate quality assurance measures can interfere with the

decision-making process and diminish public confidence. NRC at times finds itself in

the media spotlight for perceived inaccuracies and lack of candor in its communication.

It is inevitable that some mistakes will occur due to the varying perceptions of and

resources available to staff. However, the agency needs to provide consistent guidance

and clear expectations to staff concerning fundamental information verification

approaches. This will help ensure that the information it disseminates is accurate and

that staff clearly understand their responsibilities with regard to the quality assurance

process.

At the exit conference covering the topics in the report, NRC managers agreed with the

finding and recommendations. During this discussion, both NRC managers and OIG

highlighted the need for NRC staff to pay close attention to the language they use in

written documents to avoid misinterpretation by the reader. In addition, a senior official

stated that initiatives are underway to strengthen the quality assurance process for

official documents in two offices that report to the EDO.

RECOMMENDATIONS

OIG recommends that the Executive Director for Operations:

1) Revise MD 3.57 to clearly establish the responsibilities of the document originator and

concurrence chain reviewers with regard to accuracy in the final product, and set clear

expectations for document originators concerning fact-checking methods.

2) Issue an announcement that provides clear expectations for staff to heighten

awareness of the importance of information accuracy.

AGENCY COMMENTS

OIG provided this report in draft form to agency officials and discussed its content at an

exit conference on January 11, 2001. The views of attending officials have been

incorporated in this report as appropriate. Agency managers elected not to provide

written comments to the draft report. (See Appendix IV)
Appendix I

Review of NRC’s Quality Assurance Process for Official Documents

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SCOPE AND METHODOLOGY

This audit focused on the Nuclear Regulatory Commission’s (NRC) quality assurance

processes for ensuring that official documents contain accurate information. It included a

review of agency, regional, and office guidance pertaining to quality assurance of documents.

Interviews were conducted with senior management officials, managers, and staff responsible

for originating, tracking, reviewing, concurring on, and signing official documents in 16

headquarters offices and 2 regional offices (Regions I and II). During these interviews, Office

of the Inspector General (OIG) staff sought information about (1) the types of documents each

office produces and the quality assurance measures employed for each type, (2) the

concurrence process, (3) ways to improve quality assurance activities, and (4) specific “good

practices” that offices follow with regard to these activities. OIG also contacted several other

Federal agencies to learn about their quality assurance processes for official documents,

reviewed recommendations issued by the Department of Health and Human Services pertaining

to rulemaking, and interviewed staff from the Union of Concerned Scientists and Public Citizen.

At the start of this review, OIG determined it would be problematic to quantify the number of

errors in NRC documents due to the large volume, variety, and technical complexity of material

the agency prepares. Instead, OIG maintained a focus on processes employed by NRC for

ensuring the accuracy of information in official documents. OIG did, however, explore

examples of inaccuracies that the OIG had identified during previous audit and investigative

work and other examples where accuracy of information had been called into question. This

audit was performed in accordance with generally accepted Government auditing standards

and included a review of management controls related to the objective of the audit.

The work was conducted from August 2000 to November 2000. The following OIG staff

members were major contributors to this report: Corenthis Kelley, Team Leader; Judy Gordon,

Senior Management Analyst; and Vicki Foster, Management Analyst.
Appendix II

Review of NRC’s Quality Assurance Process for Official Documents

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AGENCY “GOOD PRACTICES”

Many offices and individuals involved in producing official NRC documents employ their own

specific procedures that supplement the agency’s overall guidance concerning quality

assurance processes for such documents. During the audit, a collection of some of these

agency “good practices” was compiled. This appendix was prepared to offer options for

managers and staff to consider. Some of these “good practices” are not required by NRC

guidance and others, while required, are employed in a manner that seems particularly helpful

to the quality assurance process. The chart below provides an overview of these practices;

further elaboration is provided in the numbered paragraphs that follow the chart.

Good Practices To Facilitate the Document Review Process

1 Hold up-front planning meetings among concurring individuals.

2 Share changes with document originator.

3 Hold staff accountable for inaccuracies.

4 Share “lessons learned.”

5 Use parallel concurrence.

6 Use informal parallel reviews prior to concurrence process.

7 Have court reporters transcribe public meetings.

8 Involve public affairs staff in “Plain English” reviews.

9 Send press releases back to originator to review Commission changes.

10 Establish communication team for high profile events.

11 Keep source files of reference materials.

12 Use primary or reliable secondary source materials.

13 Have technical editor proofread documents.

14 Ask “cold reader” to review the document.

15 Allow concurrence option to agree with facts, but disagree with

conclusion.

16 Provide product-specific concurrence guidance.

17 Modify concurrence chains to avoid redundancy, yet include necessary

reviewers.

18 Conduct “peer reviews” of written products.
Appendix II

Review of NRC’s Quality Assurance Process for Official Documents

Good Practices To Facilitate the Document Review Process

11

19 Alternate people who write about the same subject.

20 Use WordPerfect compare feature.

21 Conduct independent referencing on written products.

22 Hold off-site draft reviews prior to concurrence process.

1. Hold up-front planning meetings among individuals (including the originator) who will be

concurring on a document to discuss the desired approach to preparing a written

product and appropriate content.

2. Share all changes made to the original draft with the document originator. This not only

helps to ensure accuracy, but also serves as a coaching strategy.

3. Hold staff accountable for inaccuracies in their written work by documenting the

problems in this area during performance appraisals.

4. Regularly heighten staff awareness about accuracy issues. In one region, this is

accomplished by the sharing of “lessons learned” experiences pertaining to specific

examples of inaccuracies or lack of clarity during training, in memoranda, and verbally,

as appropriate. In the same region, signs are posted throughout the regional office

reminding staff to be sensitive to audience perceptions.

5. Send documents around for parallel, or simultaneous, concurrence. This practice

requires some extra effort in terms of coordinating feedback, but can draw the process

to a close more quickly than the sequential concurrence approach.

6. Send documents around for simultaneous informal review prior to the formal

concurrence process. This review may include a combination of people who will not be

on the formal concurrence chain as well as people on the chain.

7. Utilize court reporters to transcribe the verbal exchanges that occur during public

meetings. This allows NRC to respond better to attendees who have requested that

NRC provide them with certain information at a later date. This “good practice” has

limited applicability with regard to ensuring accuracy in written documents, but is useful

with regard to the issue of accuracy in verbal exchanges with the public.

8. Involve public affairs staff in reviewing documents for “Plain English.” This practice

occurs routinely in one region, and sporadically in headquarters.

9. Send press releases back to the document originator for review after the Commission

has made changes to the document.
Appendix II

Review of NRC’s Quality Assurance Process for Official Documents

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10. Establish a communication team to ensure consistency and accuracy of responses with

regard to specific high profile events. One such team was created in Region I, following

the recent steam generator tube leak at Indian Point Unit 2 Power Plant, and included

multidisciplinary team members from both headquarters and the region. The team was

created to assist NRC management in the coordination of agency communications with

the public and other external stakeholders. One of its responsibilities was to coordinate

written responses to congressional correspondence and inquiries.

11. Keep source files of reference materials used to compose an item of correspondence.

Highlight specific information that was used in the product provided for concurrence.

12. Use only primary or reliable secondary source materials in preparing written documents.

13. Have documents proofread by a technical editor.

14. Have documents reviewed by a “cold reader” who was not involved in the preparation of

the document, but who has expertise in the subject area.

15. Allow a concurrence option whereby the person concurring can document that he or she

concurs with the facts and information presented in a document, but disagrees with the

conclusion.

16. Provide specific written guidance concerning concurrence chain requirements for

specific products.

17. Modify concurrence chains to avoid redundancy yet include the necessary reviewers. In

one region where an addition was made to the concurrence chain for a particular

product, a pilot test was first conducted to see if the time needed to obtain the additional

review resulted in improved accuracy. In one headquarters office, the concurrence

chain was shortened by deleting duplicate reviews at the same management level.

18. Conduct “peer reviews” of written products. In one region that employs this practice,

peer review participants review inspection reports issued during the preceding quarter.

All participants read and critically assess the reports (or report sections) to determine

whether they are consistent with agency guidance, and then openly discuss their

findings.

19. Alternate people who write about the same subject. In one region where this practice is

employed, two different inspectors alternate monthly visits to a particular site. This

gives them an opportunity to discuss their observations, which are ultimately combined

into one quarterly inspection report.
Appendix II

Review of NRC’s Quality Assurance Process for Official Documents

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20. Use the WordPerfect compare feature to compare different versions of a document and

determine where changes have been made.

21. Independently reference written products by having an individual, who has not worked

on a product, review that product and check factual statements against the source

documents. This review is more rigorous than the “cold reader” approach described in

number 14.

22. Hold off-site reviews of draft products prior to the concurrence process. Participants are

those who will be on the concurrence chain for the product. This practice encourages

reviewers to focus on the subject and to discuss issues prior to the concurrence

process.
Appendix III

Review of NRC’s Quality Assurance Process for Official Documents

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ABBREVIATIONS AND ACRONYMS

EC Executive Council

EDO Executive Director for Operations

FY Fiscal Year

MD Management Directive

NRC Nuclear Regulatory Commission

OIG Office of the Inspector General

OMB Office of Management and Budget
Appendix IV

Review of NRC’s Quality Assurance Process for Official Documents

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AGENCY RESPONSE TO DRAFT REPORT