The lack of a clear and comprehensive report preparation procedure, coupled with inadequate management oversight and the use of inexperienced personnel for report preparation duties, resulted in the preparation and submittal of an inaccurate Annual PCB Report to the Department of Energy. Data inaccuracies identified late in the report preparation and review process were not corrected in time for a complete and accurate report to be transmitted by the required due date. Untimely submittal of the report could have resulted in a fine of $37K per day. Lessons Learned: 1) Procedures used to prepare regulatory documents must provide clear and comprehensive instructions. 2) Management must provide effective oversight to ensure that staff is able to generate an accurate product that meets the requirements. 3) Personnel assigned responsibility for preparation of regulatory reports can more proficiently perform that function if they have a complete understanding of associated data systems and processes.
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