AUDIT REPORT

Audit of NRC’s Process for Revising Management Directives

OIG-14-A-19 September 15, 2014

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

NRC’s Web site at: 

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

OFFICE OF THE

INSPECTOR GENERAL

September 15, 2014

MEMORANDUM TO: Mark A. Satorius

Executive Director for Operations

FROM: Stephen D. Dingbaum /RA/

Assistant Inspector General for Audits

SUBJECT: AUDIT OF NRC’S PROCESS FOR REVISING 

MANAGEMENT DIRECTIVES (OIG-14-A-19)

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

Process for Revising Management Directives.

The report presents the results of the subject audit. Agency comments provided at the 

August 25, 2014, exit conference have been incorporated, as appropriate, into this 

report.

Please provide information on actions taken or planned on each of the 

recommendations within 30 days of the date of this memorandum. Actions taken or 

planned are subject to OIG followup as stated in Management Directive 6.1.

We appreciate the cooperation extended to us by members of your staff during the 

audit. If you have any questions or comments about our report, please contact me at 

415-5915 or Eric Rivera, Team Leader, Financial and Administrative Audit Team, at 

415-7032.

Attachment: As stated 

cc: M. Galloway, OEDO

K. Brock, OEDO

J. Arildsen, OEDO

C. Jaegers, OEDO

RidsEdoMailCenter
Audit of NRC’s Process for Revising Management Directives

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EXECUTIVE SUMMARY

BACKGROUND

Federal regulations1 provide that Federal agencies should strive to 

(1) convey written instructions and document agency policies and 

procedures through effective directives management and (2) provide 

agency personnel with information needed in the right place, at the right 

time, and in a useful format. At NRC, management directives are issued 

to (1) promulgate internal policy and procedures of agencywide interest or 

application that concern a high profile, mission-critical agency function or 

program and (2) impose substantive requirements on more than one NRC 

office. Management directives do not propose new policy; instead, 

directives reflect policy decisions already made and provide the process 

and guidance for implementing that policy. 

NRC Management Directive (MD) 1.1, NRC Management Directives 

System, issued March 18, 2011, describes the process for issuing and 

revising directives. These directives are to be reviewed and reissued or 

certified as relevant at least every 5 years (the 5-Year Plan).

As of November 5, 2013, NRC maintained 164 MDs in its electronic 

catalog on NRC’s Internal Web site (see Appendix C). The average age 

of these 164 MDs is 8.3 years. There are 2.75 full-time equivalents (FTE) 

for the Office of Administration’s (ADM) management of the MD program. 

The 2.75 FTE do not include time spent by other agency offices working 

on the revision of their MDs and supervisory review time.

OBJECTIVES

The audit objectives were to evaluate the adequacy of NRC’s compliance 

with MD 1.1, particularly in the areas of keeping management directives 

accurate and up-to-date, and whether opportunities exist to improve the 

process.

 1 Title 41, Code of Federal Regulations (CFR), Part 102-193, Creation, Maintenance, and Use of Records.
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RESULTS IN BRIEF

Although the agency strives for compliance with MD 1.1, NRC generally is 

not in compliance with keeping MDs accurate and up-to-date. Therefore, 

opportunities exist to improve program efficiency and increase compliance 

with MD 1.1 by (A) issuing MDs timely and (B) centralizing authoritative 

guidance.

MDs Not Issued Timely

The issuance of NRC’s management directives is not always 

timely. Federal regulations require that agencies make every effort to 

document policies and procedures and provide access to them in a timely 

manner. Additionally, agency policy requires MDs to be revised or 

certified as relevant every 5 years (the 5-Year Plan). The revision of NRC 

MDs is not always timely because there are multiple internal control

weaknesses. As a result, agency operations may not be optimally 

performed and knowledge management programs may not be effective. 

Authoritative Guidance Is Fragmented

Federal regulations and agency guidance require NRC to strive to provide 

staff with information needed in the right place, at the right time, and in a 

useful format to conduct agency business. However, NRC’s MD system 

does not always contain up-to-date guidance. This is because the agency 

lacks sufficient internal controls over revisions made to MDs by yellow 

policy announcements.

2 As a result, staff may not have adequate, up-todate guidance to conduct agency operations effectively, and staff could be 

confused or unsure about the correct guidance to follow. 

RECOMMENDATIONS

This report makes recommendations to improve the efficiency of NRC’s 

process for revising MDs. A list of these recommendations appears on 

pages 18-19 of this report.

 2 For the purposes of this report, the term “yellow policy announcement” refers only to NRC’s Policy 

Announcements that inform NRC employees of new or revised policy.
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AGENCY COMMENTS

An exit conference was held with the agency on August 25, 2014. Prior to 

this meeting, after reviewing a discussion draft, agency management 

provided comments that have been incorporated into this report, as 

appropriate. As a result, agency management stated their general 

agreement with the findings and recommendations in this report and opted 

not to provide formal comments for inclusion in this report.
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ABBREVIATIONS AND ACRONYMS

ACRS Advisory Committee on Reactor Safeguards

ADAMS Agencywide Documents Access and Management System

ADM Office of Administration

ASLBP Atomic Safety and Licensing Board Panel

CFR Code of Federal Regulations

CSO Computer Security Office

FSME Office of Federal and State Materials and Environmental 

Management Programs

FTE Full-time Equivalent

MD Management Directive

NMSS Office of Nuclear Material Safety and Safeguards

NRC Nuclear Regulatory Commission

NRR Office of Nuclear Reactor Regulation

NSIR Office of Nuclear Security and Incident Response

OCA Office of Congressional Affairs

OCFO Office of the Chief Financial Officer

OCHCO Office of the Chief Human Capital Officer

OE Office of Enforcement

OEDO Office of the Executive Director for Operations
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OI Office of Investigations

OIG Office of the Inspector General

OIP Office of International Programs

OIS Office of Information Services

OPA Office of Public Affairs

RES Office of Nuclear Regulatory Research

SBCR Office of Small Business and Civil Rights
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TABLE OF CONTENTS

EXECUTIVE SUMMARY....................................................................................... i

ABBREVIATIONS AND ACRONYNMS................................................................iv

I. BACKGROUND.................................................................................... 1

II. OBJECTIVES....................................................................................... 4

III. FINDINGS ........................................................................................... 4

A. MDs Not Issued Timely.......................................................... 5

B. Authoritative Guidance Is Fragmented ................................ 13

IV. CONSOLIDATED LIST OF AGENCY RECOMMENDATIONS .......... 18

V. AGENCY COMMENTS....................................................................... 20

APPENDIXES

A. OBJECTIVES, SCOPE, AND METHODOLODY ..................................... 21

B. GENERAL CATEGORIES FOR HIERARCHY OF NRC POLICY AND 

GUIDANCE.............................................................................................. 24

C. CATALOG OF MANAGEMENT DIRECTIVES AS OF

NOVEMBER 5, 2013 .............................................................................. 25
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I. BACKGROUND

Federal Requirements

Federal regulations3 provide that Federal agencies should strive to

(1) convey written instructions and document agency policies and 

procedures through effective directives management and (2) provide 

agency personnel with information needed in the right place, at the right 

time, and in a useful format. In addition, Nuclear Regulatory Commission 

(NRC) regulations4 provide that “A statement of the NRC’s organization, 

policies, procedures, assignments of responsibility, and delegations of 

authority is in the Nuclear Regulatory Commission Management Directives 

System....” At NRC, management directives (MD) are issued to

(1) promulgate internal policy and procedures of agencywide interest or 

application that concern a high profile, mission-critical agency function or 

program and (2) impose substantive requirements on more than one NRC 

office. MDs do not propose new policy; instead, directives reflect policy 

decisions already made and provide the process and guidance for 

implementing that policy. NRC prepares and issues MDs as well as 

revisions to these documents to meet the requirement that all Federal 

agencies have an internal Management Directives System.

NRC Hierarchy of Internal Policy

The agency maintains general categories for hierarchy of NRC internal 

policy and guidance documents. These documents have been 

categorized into five levels of importance. NRC Commission (Level 1)

(the highest level) includes commission enforcement policy, commission 

documents, and internal commission procedures. NRC Policy 

Implementation (Level 2) (the second highest level) includes management 

directives, yellow policy announcements, and the Collective Bargaining 

Agreement.

5

 The complete detailed hierarchy is shown in Appendix B of 

this report.

 3 Title 41, Code of Federal Regulations (CFR), Part 102-193, Creation, Maintenance, and Use of Records. 4 10 CFR, Part 1.3, Sources of Additional Information. 5 To the extent that the agency’s rules, policies, and regulations are in conflict with the terms of the 

Collective Bargaining Agreement, the Collective Bargaining Agreement terms govern.
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NRC’s Review and Publication Process for Management Directives

NRC MD 1.1, NRC Management Directives System, issued 

March 18, 2011, describes the process for issuing and revising directives. 

These directives are to be reviewed and reissued or certified as relevant 

at least every 5 years (the 5-Year Plan). The agency’s current MD 

revision process is coordinated through several NRC offices, and usually 

involves eight steps (see Figure 1). Appendix C of this report contains the 

catalog of NRC’s management directives as of November 5, 2013.

Logistics

As of November 5, 2013, NRC maintained 164 MDs in its electronic 

catalog on NRC’s Internal Web site (see Appendix C). The average age 

of these 164 MDs was 8.3 years. There are 2.75 full-time equivalents 

(FTE) for the Office of Administration’s (ADM) management of the MD 

program. Included in the 2.75 FTE is 1 FTE responsible for administering 

the NRC announcement program and .25 FTE to update and maintain 

both the MD Signature Status Report and 5-Year Plan, located on NRC’s 

Internal Web site. The remaining 1.5 FTE include the administrative 

staff’s followup to manage each MD through the process, address 

assistance requests from authoring offices, and fulfill ADM’s reviewer 

responsibilities under MD 1.1. The 2.75 FTE do not include time spent by 

other agency offices working on the revision of their MDs and supervisory 

review time.
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Abbreviations and acronyms in Figure 1 are explained as follows: Agencywide Documents Access and 

Management System (ADAMS), Office of Administration (ADM), Chief Financial Officer (CFO), Executive 

Director for Operations (EDO), Office of the General Counsel (OGC), Portable Document Format (PDF), 

Office of the Secretary (SECY).
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II. OBJECTIVES

The audit objectives were to evaluate the adequacy of NRC’s compliance 

with MD 1.1, particularly in the areas of keeping management directives 

accurate and up-to-date, and whether opportunities exist to improve the 

process.

III. FINDINGS

Although the agency strives for compliance with MD 1.1, NRC generally is

not in compliance with keeping MDs accurate and up-to-date. Therefore, 

opportunities exist to improve program efficiency and increase compliance 

with MD 1.1 by

A) Issuing MDs timely.

B) Centralizing authoritative guidance.
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A. MDs Not Issued Timely 

 

The issuance of NRC’s management directives is not always timely. 

Federal regulations require that agencies make every effort to document 

policies and procedures and provide access to them in a timely manner.

Additionally, agency policy requires MDs to be revised or certified as 

relevant every 5 years (the 5-Year Plan). The revision of NRC MDs is not 

always timely because there are multiple internal control weaknesses. As 

a result, agency operations may not be optimally performed and 

knowledge management programs may not be effective. 

 

Timeliness Requirements 

Federal regulations require agencies to document effective policies and 

procedures and provide staff access to them in a timely manner. Further, 

Federal standards provide that information should be communicated to 

management and staff who need it in a useful format and within a 

timeframe that enables them to carry out their internal control and other 

responsibilities.

MD 1.1 requires NRC to review, revise, and reissue MDs or certify them 

as relevant every 5 years in the absence of an extension to the expiration 

date. MD 1.1 also specifically requires the Office of the Executive Director 

for Operations to track MD revision compliance through its electronic 

tracking system.

The Office of the Inspector General (OIG) benchmarked NRC’s MD 

revision process by interviewing staff from four Federal agencies about 

their directives programs. OIG found that all four agencies revise their 

MDs in less than a year, which is significantly shorter than NRC. 

Issuance of NRC’s MDs Is Not Always Timely 

The agency does not revise or certify most MDs as relevant every 5 years. 

As of November 5, 2013,

6 NRC had 164 MDs. More than half (91 of 164) 

of NRC’s MDs had not been revised or certified in 5 or more years (see 

Figure 2). Agency officials explained that their up-to-date performance 

 6 November 5, 2013, was the day after the entrance conference for this audit. 
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calculation was much higher because it did not include 23 Volume 9 (v9) 

MDs, NRC Organization and Functions, or the Volume 10, Office of the 

Chief Human Capital Officer’s 41 MDs (2 are v9 MDs) (see Appendix C).

The Volume 9 MDs were excluded from the original 5-year plan by the 

Office of the Executive Director for Operations because they were going to 

be addressed in a separate initiative.

7

 Office of the Chief Human Capital 

Officer MDs were excluded from the calculation because, after 

implementing the 5-year plan, the office’s MD revision schedule was 

extended from 5 to 8 or more years.

The timeliness problem is highlighted even more when reviewing the 

number of MDs that are still pending revision and issuance since 

implementation of the 5-year plan. Figure 3 illustrates that as of 

 7 A May 19, 2014, memorandum from the Director of the Office of Administration to the Executive Director 

for Operations, “U.S. Nuclear Regulatory Commission Plan to Update the Management Directives in 

Volume 9,” provided a schedule for Volume 9 MDs to be completed (ADAMS Accession 

No.# ML14115A020).
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Source: OIG Analysis

68

84

12

Figure 3: Initial 5-Year Plan

Status of 164 MDs as of 11/2013

Revised

Not Revised

Due Date After 11/2013

November 5, 2013, there were 84 MDs that had not been revised and 

issued.

8

 There were also 68 MDs that had been revised and issued;

however, 68 percent of those were issued after the 5-year plan due date. 

Further, 11 of 12 MDs with due dates after November 2013 were more 

than 5 years past their last revision date. 

Weak Internal Control and Low Management Priority 

NRC MDs are not issued9 in a timely manner because internal controls for 

revising MDs are ineffective and NRC senior management does not 

consider keeping MDs up-to-date a priority.

 8 The 84 MDs were all past their due dates. They relate indirectly to the 91 MDs in Figure 2 because 7 of 

the 91 MDs had either been issued and not revised or recertified within the 5-year guideline required by 

MD 1.1, or had a due date after November 2013. 

9 An MDs “issue date” is the date it is signed and becomes effective.
Audit of NRC’s Process for Revising Management Directives

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Weaknesses in Internal Control

NRC management has the fundamental responsibility to develop and 

maintain effective internal control over the MD revision process. OIG 

identified several internal control weaknesses in the following areas:

• Excessive use of extensions.

• Inadequate extension guidance.

• Inadequate reporting.

• Ineffective corporate measure.

Excessive Use of Extensions

The internal controls over extension requests are weak and oversight of 

granting extension requests is ineffective. OIG analysis of agency data 

revealed an excessive granting of extensions to MD expiration dates

pursuant to extension requests by MD owners. For example, the agency 

published 30 MDs between January 1, 2012, and November 5, 2013; 20

of those 30 MDs had at least 1 extension granted, and some had multiple 

extensions granted. In spite of the liberal use of extensions, the agency

published only 4 of those 20 MDs on or before the last extension date. 

The other 16 were published after the last extension date (see Figure 4). 

ADM officials stated that originating offices frequently request extensions 

just prior to the expiration date even though ADM’s existing practice

provides MD owners up to a year’s advance notice before the MDs 5-year

anniversary.
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Inadequate Extension Guidance

MD 1.1 has inadequate guidance for the extension process. MD 1.1 does 

provide that ADM has the administrative authority to grant an initial

1-year extension of the MD expiration date. Additional extensions require 

higher-level approval by the Chairman, Commission, Executive Director 

for Operations, or Chief Financial Officer, as appropriate. OIG requested 

guidelines for the process from ADM and there were none with clear 

criteria documenting a basis to approve or deny any request for an 

extension. In addition, no agency official interviewed by OIG with the 

authority to grant extensions could recall or provide any documentation of 

an extension request denial. 

MD 1.1 further provides, “If an MD has not been revised or certified prior 

to its expiration date, then the MD remains effective after its expiration 
Audit of NRC’s Process for Revising Management Directives

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date.” This statement presents no incentive for agency staff to revise MDs 

timely.

Inadequate Reporting

Internal controls for reporting actionable data to management are also 

weak. ADM routinely collects data and information for NRC’s MD revision 

process and posts it to NRC’s “Policy” Web page as the “Management 

Directives Signature Status Report.” The purpose of the report is to assist 

MD owners by tracking the last action taken on an MD under revision. 

When OIG asked MD owners and other agency staff if they were familiar 

with the ADM report, no one outside ADM (the office responsible for 

creating and maintaining the report) knew of the report’s existence. A 

significant weakness is that ADM does not send this or any regular report 

of actionable information to management for review.

Ineffective Corporate Measure

The agency developed a corporate measure10 to track and monitor 

performance in completing the 5-year plan on a timely basis. NRC 

maintains MD data to track milestones completed in the plan over its 

5-year life. This corporate measure marks office performance “red” for out 

of compliance and “green” for full compliance with the measure. This 

audit revealed that MDs are not issued timely; yet, OIG noted that all 

offices are “green.” This is because when an extension of the expiration 

date is granted, ADM resets the original due date to the extended date 

and still considers the office “green.” Therefore, OIG concludes that the 

corporate measure is weak and ineffective in holding offices accountable 

for their performance. 

A further weakness of this measure involves how the agency compiles

data. NRC does not know when agency offices actually initiate the 

revision process; subsequently, there is no valid start date to measure 

performance accurately. ADM ends the revision period on the date ADM 

accepts NRC Form 521, “Request for Publication or Elimination of an NRC 

Management Directive,” rather than a more representative date such as 

when the MD is published.

 10 The agencywide corporate measure is “Percent of fiscal year 2014 milestones completed in the office’s 

plan to bring management directives up-to-date over a 5-year period.”
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Low Management Priority 

OIG interviewed several program managers and staff assigned 

responsibility for the MD revision process and found that, in general, NRC 

management does not consider it a priority to keep MDs current and upto-date. ADM offers to hold “kickoff” meetings up to a year in advance of 

the revision due dates to provide expertise and assistance to make the 

process more efficient. However, because it is a low priority, offices often 

delegate attendance to inexperienced or new staff or they decline 

attendance.

 

Another indicator of low priority is that compliance with MD 1.1 is not

monitored by senior management. The Office of the Executive Director for 

Operations does not track compliance through its tracking system. This is 

because ADM submits MD packages to the Office of the Executive 

Director for Operations for concurrence and approval without providing a 

proposed due date for completion. Information OIG obtained shows that 

Office of the Executive Director for Operations review and approval was 

required for most MDs. However, on average, MDs remained in that office

for more than 3 months before being approved. 

In addition, it appears that MD revision is not given proper priority in the 

Chairman’s office. Of the 30 MDs issued in calendar years 2012-2013,

6 required approval by the Chairman. Those six took, on average, more 

than 14 months to be approved.

Agency Operations and Knowledge Transfer May Be Affected 

Because NRC’s management assigns a low priority to MD revision 

activities, staff are not adequately focused on the process. As a result, 

agency operations may not be optimally performed because staff may not 

have the most current and up-to-date guidance. Moreover, knowledge 

transfer may be disrupted because of the lack of current and up-to-date 

directives.
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Recommendations: 

OIG recommends that the Executive Director for Operations

1. Revise MD 1.1 to

a. Elevate authority required for approving extensions. 

Extensions can only be granted by the Chairman, the 

Executive Director for Operations, the Chief Financial 

Officer, or their designees (no lower than Deputy Executive 

Directors for Operations, Assistant for Operations, or Deputy 

Chief Financial Officer), as appropriate. 

b. Include guidelines for resetting MD initial due dates. Require 

Executive Director for Operations, or designee, approval to 

reset initial due dates. Clearly state the parameters for 

resetting due dates.

c. Clearly state the parameters and guidelines for granting 

extensions, and provide that even if an extension is granted, 

the authoring office will receive a “red” on the corporate 

measure scorecard unless they also meet the new MD 1.1 

guidelines (recommendation 1.b) for having the initial due 

date reset. 

2. Require a suspense due date for final concurrence/approval by the 

Executive Director for Operations and Chairman when submitting 

MD concurrence packages to those offices, so that the MD can be 

tracked in Office of the Executive Director for Operations’ tracking

system. 

3. Require MD author participation in ADM’s MD revision “kickoff” 

meetings. 

4. Develop and implement a performance measure that effectively 

evaluates MD revision timeliness for MDs that begins with the 

kickoff meeting and ends with the issuance date of the MD. In 

addition, provide the reported results quarterly to the Office of the 

Executive Director for Operations and office directors. 
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B. Authoritative Guidance Is Fragmented 

 

Federal regulations and agency guidance require NRC to strive to provide 

staff with information needed in the right place, at the right time, and in a 

useful format to conduct agency business. However, NRC’s MD system 

does not always contain up-to-date guidance. This is because the agency 

lacks sufficient internal controls over revisions made to MDs by yellow 

policy announcements.

11 As a result, staff may not have adequate, 

up-to-date guidance to conduct agency operations effectively, and staff 

could be confused or unsure about the correct guidance to follow. 

 

Guidance Documentation and Availability Requirements

The Federal Management Regulation (41 CFR § 102-193.25) requires

Federal agencies to strive to provide staff with information needed in the 

right place, at the right time, and in a useful format. It further requires 

agencies to identify and retain permanent records, dispose of temporary 

records promptly, and organize agency files in a logical order so that 

records can be found rapidly to conduct agency business. This also 

ensures that records are complete and facilitates the identification of 

permanent records. 

Agency guidance in MD 3.16, NRC Announcement Program, requires

owners to notify ADM when a yellow policy announcement has been 

superseded. This action eliminates confusion as to what represents

current policy, particularly when revising MDs. Likewise, Article 54.7 of 

the National Treasury Employees Union’s Collective Bargaining 

Agreement requires NRC to establish direct links on the agency’s intranet 

between updated MDs and any related yellow policy announcements. 

Fragmented Guidance

NRC does not consolidate its authoritative guidance in the MD system;

rather, the agency documents this guidance in MDs, yellow policy 

announcements, and other interim policies. NRC’s frequent use of yellow 

 11 For the purposes of this report, the term “yellow policy announcement” refers only to NRC’s Policy 

Announcements that inform NRC employees of new or revised policy.
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policy announcements is a disincentive to efforts to keep the agency’s 

MDs up-to-date. In lieu of revising an MD on a timely basis, the agency

routinely issues yellow policy announcements to convey new or revised 

policy. This practice has become generally accepted, resulting in the 

issuance of many yellow policy announcements and making revision of 

MDs a lower priority. For example, MD 10.62 has not been revised since 

2001, and four yellow policy announcements provide general12 links to this 

MD since then. 

Between January 11, 2010, and November 25, 2013, NRC issued a total 

of 94 yellow policy announcements, revisions to policy, or policy reminder 

announcements. Of the 94, 50 were yellow policy announcements or 

revisions to policy (an average of 12.5 per calendar year) or 53 percent

(50/94) of all released yellow announcements related to policy for the 

period. Staff expressed frustration about how difficult it is to locate current 

and up-to-date policies to conduct agency business effectively. 

Lack of Agency Action To Comply With Guidance Requirements

These conditions exist because the agency has not developed

• A process to link MDs to yellow policy announcements.

• An adequate tracking mechanism for yellow policy announcements.

• Controls to assure that staff does not use yellow policy 

announcements to avoid revising MDs.

No Process To Link MDs To Yellow Policy Announcements 

While there is a process for NRC yellow policy announcements to provide 

general links to the affected MDs, there is no process to provide specific13

links in the MD to associated yellow policy announcements. OIG’s 

analysis found that while yellow policy announcements generally specify

 12 General links within yellow policy announcements, when selected, open NRC’s Internal Web page 

listing for NRC’s current MDs.

13 Specific links from MDs to yellow policy announcements would be embedded within the section or 

paragraph on the pages of the MD updated and, when selected, would open the yellow policy 

announcement. 
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the MDs that contain policies they revise, the majority do not include 

references to the specific sections of the MD they revise. Placing a 

specific link within the MD reduces the chances that the yellow policy 

announcement will cause confusion or be misinterpreted. 

Inadequate Tracking Mechanism for Yellow Policy Announcements 

NRC does not have an adequate mechanism to track yellow policy 

announcements. The agency maintains a comprehensive list of all yellow 

policy announcements since the inception of the yellow policy 

announcement process. ADM explained the purpose of the list was to 

maintain an “Index” of all yellow policy announcements as a historical 

reference for staff who may wish to know how a particular policy or 

procedure developed over time. However, tracking yellow policy 

announcements in this way makes it difficult to determine current policy. 

Yellow policy announcements are intended as temporary measures until 

offices revise their MDs and should be superseded after they are 

incorporated into MDs. OIG interviewed MD authors and learned that they 

routinely incorporate yellow policy announcements into MDs, often at the 

insistence of ADM staff. However, it is rare to find yellow policy 

announcements marked "Superseded" because staff are not aware of the 

required formal notification requirements. As a result, most yellow policy 

announcements are included on NRC’s Internal Web page indefinitely. 

ADM stated that marking yellow policy announcements as superseded is a 

“rare” occurrence and that the issued MD does not automatically 

supersede the announcements. OIG analysis of NRC’s MDs with several

linked yellow policy 

announcements or 

revisions to policy (see 

Table 1) found that ADM 

had not marked any of the 

announcements 

“Superseded.” 

Conversely, MD authors 

indicated they had 

incorporated yellow policy 

announcements 

associated with their 

revised MDs. As an 
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example, one MD author acknowledged an awareness of the potential 

confusion with multiple yellow policy announcements listed for an 

unrevised MD. The MD author had taken the extra precaution of including 

language in one of the yellow policy announcements to supersede the 

previous one. In spite of this extra effort, the author did not provide the 

required “formal” notice to ADM. Therefore, ADM took no action and both 

yellow policy announcements remained posted on the Web page.

The agency maintains yellow policy announcements related to specific 

MDs in the “Related Policy Documents” section of the MD summary page 

posted on the agency’s Internal Web site, which reflects similar 

information found in the comprehensive list. For staff to determine current 

policy, they must compare each yellow policy announcement from both 

lists to determine the most recent version of the policy. This results in an 

unnecessary, time-consuming process.

Inadequate Controls for Using Yellow Policy Announcements To Avoid 

Revising MDs

The agency has not developed controls to ensure that NRC staff do not 

routinely use yellow policy announcements as a means to avoid the MD 

revision process. As an example, Table 1 on page 15 illustrates that NRC 

has provided general links in two yellow policy announcements to MD 3.11

and has not revised the MD since 1997. The agency also provided 

general links in five yellow policy announcements to MD 14.1 and has not 

revised that MD since 2005. Additionally, MD 3.16 does not require an 

expiration date for yellow policy announcements so there is no incentive to 

incorporate them into MDs in a timely fashion.

NRC staff and management agreed that it is much easier to develop

yellow policy announcements than to revise an MD. In addition, ADM staff 

acknowledged the popularity of using yellow policy announcements has 

much to do with the longer process to revise NRC’s management 

directives. 
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Staff May Waste Resources and Not Know What Is Current Policy

If NRC does not track yellow policy announcements and adequately link 

their respective MDs to associated yellow policy announcements, staff 

may waste valuable resources and effort searching files to determine 

current policies. Moreover, staff may become confused about what 

guidance to follow in a particular situation, which could result in conducting

agency business based on incomplete or outdated policies. 

Recommendations: 

OIG recommends that the Executive Director for Operations

 

5. Develop and implement an effective process to link MDs to yellow 

policy announcements at the time offices issue the yellow policy 

announcements. 

6. Develop and implement an adequate mechanism to track yellow 

policy announcements. 

7. Require yellow policy announcement owners to detail in the yellow 

policy announcement the MDs affected and the specific sections 

affected within these MDs. 

8. Revise the list of “Related Policy Documents” for each MD to 

include only yellow policy announcements issued after the current 

MD version date. 

9. Revise MD 3.16 to require an expiration date for yellow policy 

announcements. 
Audit of NRC’s Process for Revising Management Directives

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IV. CONSOLIDATED LIST OF RECOMMENDATIONS 

OIG recommends that the Executive Director for Operations

1. Revise MD 1.1 to

a. Elevate authority required for approving extensions. 

Extensions can only be granted by the Chairman, the 

Executive Director for Operations, the Chief Financial 

Officer, or their designees (no lower than Deputy Executive 

Directors for Operations, Assistant for Operations, or Deputy 

Chief Financial Officer), as appropriate. 

b. Include guidelines for resetting MD initial due dates. Require 

Executive Director for Operations, or designee, approval to 

reset initial due dates. Clearly state the parameters for 

resetting due dates.

c. Clearly state the parameters and guidelines for granting 

extensions, and provide that even if an extension is granted, 

the authoring office will receive a “red” on the corporate 

measure scorecard unless they also meet the new MD 1.1 

guidelines (recommendation 1.b) for having the initial due 

date reset. 

2. Require a suspense due date for final concurrence/approval by the 

Executive Director for Operations and Chairman when submitting 

MD concurrence packages to those offices, so that the MD can be 

tracked in Office of the Executive Director for Operations’ tracking

system. 

3. Require MD author participation in ADM’s MD revision “kickoff” 

meetings. 

4. Develop and implement a performance measure that effectively 

evaluates MD revision timeliness for MDs that begins with the 

kickoff meeting and ends with the issuance date of the MD. In 

addition, provide the reported results quarterly to the Office of the 

Executive Director for Operations and office directors. 
Audit of NRC’s Process for Revising Management Directives

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5. Develop and implement an effective process to link MDs to yellow 

policy announcements at the time offices issue the yellow policy 

announcements. 

6. Develop and implement an adequate mechanism to track yellow 

policy announcements. 

7. Require yellow policy announcement owners to detail in the yellow 

policy announcement the MDs affected and the specific sections 

affected within these MDs. 

8. Revise the list of “Related Policy Documents” for each MD to 

include only yellow policy announcements issued after the current 

MD version date. 

9. Revise MD 3.16 to require an expiration date for yellow policy 

announcements. 
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V. AGENCY COMMENTS 

An exit conference was held with the agency on August 25, 2014. Prior to 

this meeting, after reviewing a discussion draft, agency management 

provided comments that have been incorporated into this report, as 

appropriate. As a result, agency management stated their general 

agreement with the findings and recommendations in this report and opted 

not to provide formal comments for inclusion in this report.
Audit of NRC’s Process for Revising Management Directives

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APPENDIX A

OBJECTIVES, SCOPE, AND METHODOLOGY

OBJECTIVES

The audit objectives were to evaluate the adequacy of NRC’s compliance 

with MD 1.1, particularly in the areas of keeping management directives 

accurate and up-to-date, and whether opportunities exist to improve the 

process.

SCOPE

This audit focused on reviewing internal controls over the NRC 

Management Directives System, which is the official vehicle used by the 

agency to communicate agency policy, objectives, responsibilities, 

authorities, requirements, and guidance to NRC employees. OIG 

analyzed information and developed a universe based on a snapshot

picture of the agency’s electronic management directives catalog as of 

November 5, 2013. OIG requested information from the agency on all 

MDs issued between January 1, 2012, and November 5, 2013. OIG 

auditors performed various tests of compliance with the agency’s 5-Year

Plan to keep management directives accurate and up-to-date. As part of 

this audit, OIG reviewed the extent and use of extensions and NRC yellow 

announcements, but only those that convey new or revised policies.

We conducted this performance audit at NRC headquarters in Rockville, 

Maryland, from November 2013 through May 2014. Internal controls 

related to the audit objectives were reviewed and analyzed. Throughout 

the audit, auditors were aware of the possibility of fraud, waste, or abuse 

in the program under review.

METHODOLOGY

To accomplish the audit objectives, OIG reviewed relevant laws, 

regulations, and guidance, including 41 Code of Federal Regulations 

(CFR) 102-193, Creation, Maintenance, and Use of Records; 10 CFR 1.3, 

Sources of Additional Information; and Public Law 90-620, Public Printing 

and Documents. We also reviewed Office of Management and Budget 
Audit of NRC’s Process for Revising Management Directives

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Circular A-123, Management’s Responsibility for Internal Control; the 

Government Accountability Office Standards for Internal Control in the 

Federal Government; Management Directives; Article 54.7 in the 

Collective Bargaining Agreement between NRC and the National Treasury 

Employees Union; and a July 2008 OIG report titled Audit of NRC's 

Controls Over the Process for Eliminating Management Directives, for 

relevance to this audit.

OIG also reviewed agency guidance and documents, including the Final 

Report of the Management Directives Working Group Program Review 

Findings and Recommendations, July 2006. We also reviewed the 

following ADM documents and system: (1) master schedule for updating 

all agency management directives over the 5-year period FY 2009-2013, 

(2) Management Directives Work Flow Core Review Process for All 

New/Revised Management Directives, and (3) electronic file system for 

capturing NRC management directive documentation. We also reviewed 

required agency forms to issue, publish, eliminate, or request an extension 

for management directives. OIG reviewed NRC’s policy announcements 

on the Internal Web site and the electronic catalog of management 

directives including the following for specific review purposes:

Management

Directive Title

1.1 NRC Management Directives System

3.16 NRC Announcement Program

Volume 9 NRC Organization and Functions

OIG interviewed NRC staff at headquarters to obtain insights on the 

agency’s process for revising management directives. OIG interviewed 

staff from all four NRC regions to determine the usefulness of 

management directives and to determine the amount of input received by 

regions in the process. Finally, OIG interviewed staff from four Federal 

agencies to review best practices.

We conducted this performance audit in accordance with generally 

accepted government auditing standards. Those standards require that 

we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a 
Audit of NRC’s Process for Revising Management Directives

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reasonable basis for our findings and conclusions based on our audit 

objectives.

This audit work was conducted by Eric Rivera, Team Leader; Terri 

Cooper, Audit Manager; Gail Butler, Senior Auditor; and Michael 

Steinberg, Senior Auditor.
Audit of NRC’s Process for Revising Management Directives

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 Source: NRC Intranet

APPENDIX B

GENERAL CATEGORIES FOR HIERARCHY OF NRC POLICY AND GUIDANCE
Audit of NRC’s Process for Revising Management Directives

Source: OIG Generated

25

CATALOG OF MANAGEMENT DIRECTIVES APPENDIX C

AS OF NOVEMBER 5, 2013

MD 

Number MD Title

MD 

Effective 

Date Office

Years 

Since 

Current 

Version

NOTE: MDs dated more than 5 years past their last revision date as of November 5, 2013, are designated by cells 

highlighted in pink.

1. 1.1 NRC Management Directives System 03/18/2011 ADM 2

2. 2.3 Telecommunications 10/13/2011 OIS 2

3. 2.6 Information Technology Infrastructure 03/07/2005 OIS 8

4. 2.7 Personal Use of Information Technology 07/28/2006 OIS 7

5. 2.8 Project Management Methods 06/19/2007 OIS 6

6. 3.1 Freedom of Information Act 06/08/2011 OIS 2

7. 3.2 Privacy Act 06/27/2007 OIS 6

8. 3.4 Release of Information to the Public 02/06/2009 OIS 4

9. 3.5 Attendance at NRC Staff-Sponsored Meetings 12/23/2011 OEDO 1

10. 3.7 NUREG-Series Publications 08/17/2004 ADM 9

11. 3.9

NRC Staff and Contractor Speeches, Presentations, 

Papers, and Journal Articles on Regulatory and Technical 

Subjects 11/01/2011

ADM

2

12. 3.11 Conferences and Conference Proceedings 11/04/1997 ADM 16

13. 3.12

Handling and Disposition of Foreign Documents and 

Translations 07/12/2001 ADM 12

14. 3.13 Reproduction and Distribution 08/09/2011 ADM 2

15. 3.14 U.S. Nuclear Regulatory Commission Public Web Site 08/06/2008 OIS 5

16. 3.15 Multimedia Services 11/25/2011 ADM 1

17. 3.16 NRC Announcement Program 10/02/2013 ADM 0

18. 3.17 NRC Information Quality Programs 04/09/2009 OIS 4

19. 3.23 Mail Management 10/03/2002 ADM 11

20. 3.25 Graphic Design and Production Services 06/03/2010 ADM 3

21. 3.51 Library Services 02/25/2013 OIS 0

22. 3.52 Availability and Retention of Codes and Standards 10/19/2012 OIS 1

23. 3.53 NRC Records and Document Management Program 03/15/2007 OIS 6

24. 3.54 NRC Collections of Information and Report Management 05/22/2006 OIS 7

25. 3.55 Forms Management Program 03/30/2011 OIS 2

26. 3.57 Correspondence Management 11/08/2011 OEDO 1

27. 4.1 Accounting Policy and Practices 09/09/2005 OCFO 8

28. 4.2 Administrative Control of Funds 04/11/2008 OCFO 5

29. 4.3 Financial Management Systems 07/07/2005 OCFO 8
Audit of NRC’s Process for Revising Management Directives

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MD 

Number MD Title

MD 

Effective 

Date Office

Years 

Since 

Current 

Version

NOTE: MDs dated more than 5 years past their last revision date as of November 5, 2013, are designated by cells 

highlighted in pink.

30. 4.4 Internal Control 10/02/2012 OCFO 1

31. 4.5 Contingency Plan for Periods of Lapsed Appropriations 01/03/2012 OCFO 1

32. 4.6 License Fee Management Program 07/17/2010 OCFO 3

33. 4.7

Policies and Practices Governing NRC Long-Range 

Planning, Budget Formulation, and Resource Management 10/01/1989 OCFO 24

34. 5.1 Intergovernmental Consultation 04/05/1993 FSME 20

35. 5.2

Cooperation With States at Commercial Nuclear Power 

Plants and Other Nuclear Production or Utilization Facilities 10/29/2010 FSME 3

36. 5.3 Agreement State Participation in Working Groups 08/22/2007 FSME 6

37. 5.4 Official Representation Expenses 09/25/2007 OIP 6

38. 5.5 Public Affairs Program 04/26/2013 OPA 0

39. 5.6

Integrated Materials Performance Evaluation Program 

(IMPEP) 02/26/2004 FSME 9

40. 5.7 Technical Assistance to Agreement States 03/28/2013 FSME 0

41. 5.8 Proposed Section 274b Agreements with States 06/25/2013 FSME 0

42. 5.9 Adequacy and Compatibility of Agreement State Programs 02/27/1998 FSME 15

43. 5.10

Formal Qualifications for Integrated Materials Performance 

Evaluation Program (IMPEP) Team Members 01/05/1999 FSME 14

44. 5.12

International Nuclear and Radiological Event Scale (INES) 

Participation 01/30/2012 NSIR 1

45. 5.13 NRC International Activities Practices and Procedures 06/06/2008 OIP 5

46. 6.1 Resolution and Follow-up of Audit Recommendations 02/20/2006 OEDO 7

47. 6.2 Continuity of Operations Program 02/20/2013 NSIR 0

48. 6.3 The Rulemaking Process 07/22/2013 ADM 0

49. 6.4 Generic Issues Program 11/17/2009 RES 3

50. 6.5

NRC Participation in the Development and Use of 

Consensus Standards 12/20/2011 RES 1

51. 6.6 Regulatory Guides 04/12/2011 RES 2

52. 6.8 Lessons Learned Program 08/01/2006 RES 7

53. 7.1 Tort Claims Against the United States 05/21/2010 OGC 3

54. 7.2 Claims for Personal Property Loss or Damage 06/02/2010 OGC 3

55. 7.3 Participation in Professional Organizations 09/29/2009 OGC 4

56. 7.4

Reporting Suspected Wrongdoing and Processing OIG 

Referrals 04/28/2006 OIG 7

57. 7.5 Ethics Counseling and Training 07/01/2010 OGC 3

58. 7.6 Public and Confidential Financial Disclosure Reports 01/18/2010 OGC 3
Audit of NRC’s Process for Revising Management Directives

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MD 

Number MD Title

MD 

Effective 

Date Office

Years 

Since 

Current 

Version

NOTE: MDs dated more than 5 years past their last revision date as of November 5, 2013, are designated by cells 

highlighted in pink.

59. 7.7 Secutiry Ownership 09/29/2009 OGC 4

60. 7.8 Outside Employment 12/20/2010 OGC 2

61. 7.9 Ethics Approvals and Waivers 09/29/2009 OGC 4

62. 7.10 Political Activity 09/27/2010 OGC 3

63. 7.12 Enforcement of Post-Employment Restrictions 09/01/2009 OGC 4

64. 8.1 Abnormal Occurrence Reporting Procedure 09/09/2011 RES 2

65. 8.2 NRC Incident Response Program 06/16/2006 NSIR 7

66. 8.3 NRC Incident Investigation Program 03/27/2001 NSIR 12

67. 8.4

Management of Facility-specific Backfitting and Information 

Collection 10/09/2013 RES 0

68. 8.5 Operational Safety Data Review 07/08/2013 NMSS 0

69. 8.7 Reactor Operating Experience Program 09/27/2012 NRR 1

70. 8.8 Management of Allegations 11/15/2010 OE 2

71. 8.9 Accident Investigation 08/26/2005 NSIR 8

72. 8.10 NRC Medical Event Assessment Program 07/06/1994 FSME 19

73. 8.11 Review Process for 10 CFR 2.206 Petitions 10/25/2000 NRR 13

74. 8.12

Decommissioning Financial Assurance Instrument Security 

Program 04/03/1998 FSME 15

75. 8.13 Reactor Oversight Process 10/03/2010 NRR 3

76. 8.14 Agency Action Review Meeting 02/01/2013 NRR 0

77. 8.17 Licensee Complaints Against NRC Employees 05/05/2005 NRR 8

78. 8.18 NRC Generic Communications Program 03/05/2009 NRR 4

79. 9.1 Organizational Management 06/12/1987 OCHCO 26

80. 9.2

Organization and Functions, Office of the Inspector 

General 11/06/2013 OIG 0

81. 9.3

Organization and Functions, Advisory Committee on 

Reactor Safeguards 10/06/1985 ACRS 28

82. 9.5

Organization and Functions, Atomic Safety and Licensing 

Board Panel 05/10/1984 ASLBP 29

83. 9.6

Organization and Functions, Office of Commission 

Appellate Adjudication 07/30/1991 OCAA 22

84. 9.7 Organization and Functions, Office of the General Counsel 10/04/2010 OGC 3

85. 9.8 Organization and Functions, Office of Investigations 04/05/2010 OI 3

86. 9.10 Organization and Functions, Office of the Secretary 04/20/2009 SECY 4

87. 9.11 Organization and Functions, Office of Public Affairs 07/09/1993 OPA 20

88. 9.13 Organization and Functions, Office of Congressional Affairs 07/08/1993 OCA 20

89. 9.14

Organization and Functions, Office of International 

Programs 07/30/2001 OIP 12
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MD 

Number MD Title

MD 

Effective 

Date Office

Years 

Since 

Current 

Version

NOTE: MDs dated more than 5 years past their last revision date as of November 5, 2013, are designated by cells 

highlighted in pink.

90. 9.15

Organization and Functions, Office of State and Tribal 

Programs 08/24/2004 FSME 9

91. 9.17

Organization and Functions, Office of the Executive 

Director for Operations 09/12/1991 OEDO 22

92. 9.19 Organization and Functions, Office of Enforcement 05/09/1989 OE 24

93. 9.20

Organization and Functions, Office of the Chief Financial 

Officer 03/07/2002 OCFO 11

94. 9.21 Organization and Functions, Office of Administration 05/26/1993 ADM 20

95. 9.22

Organization and Functions, Office of Administration and 

Resources Management 04/15/1987 OIS 26

96. 9.24

Organization and Functions, Office of Small and 

Disadvantaged Business Utilization/Civil Rights 11/05/1990 SBCR 23

97. 9.25 Organization and Functions, Office of Human Resources 07/13/2004 OCHCO 9

98. 9.26

Organization and Functions, Office of Nuclear Material 

Safety and Safeguards 10/27/1989 NMSS 24

99. 9.27

Organization and Functions, Office of Nuclear Reactor 

Regulation 07/13/1989 NRR 24

100. 9.28

Organization and Functions, Office of Nuclear Regulatory 

Research 05/26/1989 RES 24

101. 9.29 Organization and Functions, Regional Offices 04/15/2010 OEDO 3

102. 10.1

Appointments, General Employment Issues, Details, and 

Position Changes 10/10/1995 OCHCO 18

103. 10.2 Staffing Assistance for International Organizations 04/16/1999 OCHCO 14

104. 10.6 Use of Consultants and Experts 05/10/2002 OCHCO 11

105. 10.8 Clearances Before Separation or Reassignment 09/10/2002 OCHCO 11

106. 10.10 Recruitment 07/13/1992 OCHCO 21

107. 10.11 Visiting Fellows Program 08/12/2011 OCHCO 2

108. 10.12 Use of Advisory Committee Members 02/06/2013 OCHCO 0

109. 10.13 Special Employment Programs 04/14/2000 OCHCO 13

110. 10.14 Employee Trial Period 03/16/1998 OCHCO 15

111. 10.15 Merit Staffing Program 02/21/1996 OCHCO 17

112. 10.36 Position Evaluation and Pay Administration 06/05/1987 OCHCO 26

113. 10.37 Position Evaluation and Benchmarks 09/11/2007 OCHCO 6

114. 10.38 Position Management 07/19/2010 OCHCO 3

115. 10.41 Pay Administration 02/28/2013 OCHCO 0

116. 10.42 Work Schedules and Premium Pay 11/23/2012 OCHCO 0

117. 10.43 Time and Labor Reporting 09/29/2009 OCHCO 4

118. 10.45 Advances in Pay 03/25/2003 OCHCO 10
Audit of NRC’s Process for Revising Management Directives

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MD 

Number MD Title

MD 

Effective 

Date Office

Years 

Since 

Current 

Version

NOTE: MDs dated more than 5 years past their last revision date as of November 5, 2013, are designated by cells 

highlighted in pink.

119. 10.49 Student Loan Repayment Program 07/29/2004 OCHCO 9

120. 10.50 Pension Offset Waiver 07/08/2013 OCHCO 0

121. 10.51 Recruitment, Relocation and Retention Incentives 11/01/2011 OCHCO 2

122. 10.62 Leave Administration 11/19/2001 OCHCO 11

123. 10.67 General Grade Performance Management System 08/17/2012 OCHCO 1

124. 10.72 Awards and Recognition 09/03/2013 OCHCO 0

125. 10.77 Employee Training and Development 02/08/2005 OCHCO 8

126. 10.78 NRC Intern Program 11/15/1991 OCHCO 21

127. 10.99 Discipline, Adverse Actions, and Separations 06/05/1987 OCHCO 26

128. 10.100 Appeals from Adverse Actions 06/05/1987 OCHCO 26

129. 10.101 Employee Grievances 06/05/1987 OCHCO 26

130. 10.102

Labor-Management Relations Program for Federal 

Employees 06/15/2010 OCHCO 3

131. 10.103 Reduction in Force for non-SES Employees 11/04/2002 OCHCO 11

132. 10.122 Employee Assistance and Wellness Services Program 12/13/2002 OCHCO 10

133. 10.130

Safety and Health Program Under the Occupational Safety 

and Health Act 03/04/2002 ADM 11

134. 10.131 Protection of NRC Employees Against Ionizing Radiation 01/17/2003 FSME 10

135. 10.135

Senior Executive Service (SES) Employment and Staffing 

Programs 02/20/1996 OCHCO 17

136. 10.137

Senior Executive Service Performance Management 

System 02/15/2006 OCHCO 7

137. 10.138 Reduction in Force in the Senior Executive Service 06/07/2005 OCHCO 8

138. 10.145 Senior Level System 06/12/1996 OCHCO 17

139. 10.146 Distinguished Engineers and Scientists Program 02/04/1999 OCHCO 14

140. 10.148 Senior Level Performance Appraisal System 10/04/1993 OCHCO 20

141. 10.153 Administrative Judges - Compensation and Staffing 04/26/2013 OCHCO 0

142. 10.158

NRC Non-Concurrence Process - DRAFT - Interim

Guidance 11/29/2006 OE 6

143. 10.159 The NRC Differing Professional Opinions Program 05/16/2004 OE 9

144. 10.160 Open Door Policy 08/28/1997 OE 16

145. 10.161

Civil Rights Program and Affirmative Employment and 

Diversity Management Program 04/19/2011 SBCR 2

146. 10.162 Disability Programs and Reasonable Accommodation 07/29/2005 OCHCO 8

147. 11.1 NRC Acquisition of Supplies and Services 03/29/2006 ADM 7

148. 11.4 NRC Small and Disadvantaged Business Program 07/07/1994 SBCR 19

149. 11.6 Financial Assistance Program 09/16/2011 ADM 2
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MD 

Number MD Title

MD 

Effective 

Date Office

Years 

Since 

Current 

Version

NOTE: MDs dated more than 5 years past their last revision date as of November 5, 2013, are designated by cells 

highlighted in pink.

150. 11.7

NRC Procedures for Placement and Monitoring of Work 

With the U.S. Department of Energy (DOE) 01/19/2012 ADM 1

151. 11.8

NRC Procedures for Placement and Monitoring of Work 

With Federal Agencies Other Than the U.S. Department of 

Energy Laboratory Work 09/05/2012 ADM 1

152. 12.0 Glossary 07/15/1994 ADM 19

153. 12.1 NRC Facility Security Program 09/14/2011 ADM 2

154. 12.2 NRC Classified Information Security Program 08/02/2007 NSIR 6

155. 12.3 NRC Personnel Security Program 10/08/2013 ADM 0

156. 12.4 NRC Telecommunications Systems Security Program 12/08/1999 NSIR 13

157. 12.5 Cyber Security Program 08/15/2013 CSO 0

158. 12.6 NRC Sensitive Unclassified Information Security Program 12/20/1999 OIS 13

159. 12.7 NRC Safeguards Information Security Program 06/25/2008 NSIR 5

160. 13.1 Property Management 02/16/2011 ADM 2

161. 13.2 Facility Management 09/25/2012 ADM 1

162. 13.4 Transportation Management 02/19/2013 ADM 0

163. 14.1 Official Temporary Duty Travel 06/07/2005 OCFO 8

164. 14.2 Relocation Allowances 08/15/2006 OCFO 7