ML18022A019

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NRC-2018-000272 - Appeal Response Letter to NRC-2018-000002
ML18022A019
Person / Time
Issue date: 01/18/2018
From: David Nelson
NRC/OCIO
To: Tarver J
- No Known Affiliation
Shared Package
ML18022A013 List:
References
FOIA, NRC-2018-000272
Download: ML18022A019 (38)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 JAN 1 8 2018 Julian Tarver Washington State Penitentiary IMU South H-2 1313 N 13th Ave Walla Walla, WA 99362

Dear Mr. Tarver,

IN RESPONSE REFER TO:

NRC-2018-000272 (NRC-2018-000002)

On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your December 15, 2017, letter, in which you appealed the agency's December 4, 2017, decision related to your Freedom of Information Act (FOIAj request, NRC-2018-000002, which sought a copy of the most current Annual FOIA Report to DO~. You stated that you were "writing to appeal the almost full denial of requested report that :was sent to DOJ from NRC in draft form."

Acting on your appeal, I have reviewed the matter arid have determined that, at the time of your request, the most current Annual FOIA Report that was sent to DOJ was in draft form only, for DOJ's clearance. However, the report has recently been cleared by DOJ, and made publicly available at: https://www.nrc.gov/readinq-rm/foia/annual-reports/. Given this determination, we have enclosed a copy of the final Annual FOIA Report; and therefore, find that your December 15, 2017, appeal regarding the NRC's almost full denial of the requested report of NRC-2018-000002 is granted.

This is the final agency decision. As set forth in the FOIA (5 U.S.C. 552(a)(4)(B)), you can seek

  • judicial review of this decision in a district court of the United States in the district in which you reside or have your principal place of business, in the district where the agency's records are situated, or in the District of Columbia.

As part of the 2007 FOJA amendments, the Office of Government Information Services (OGIS) was created to offer mediation services to resolve disputes between FOIA requesters and Federal agencies as a nonexclusive alternative to litigation. Using OGIS services does not affect your right to pursue litigation. If you are requesting access to your own records (which is considered a Privacy Act request), you should know that OGIS does not have the authority to handle requests made under the Privacy Act of 197 4.

Tarver, J. You may contact OGIS in any of the following ways:

Office of Government Information Services National Archives and Records Administration 732 North Capitol Street, NW Washington, D.C. 20401 Email: ogis@nara.gov Telephone: 202-741-5770 Toll-free: 1-877-684-6448 Fax: 202-7 41-5769 n

£2 David J. Ne~y-/{

Chief lnfor~~ffice~

Office of the Chief Information Officer

United States Nuclear Regulatory Commission Annual Freedom of Information Act (FOIA) Report:

Fiscal Year 2017 I.

Basic Information Regarding Report

1.

Name, title, address, and telephone number of person(s) to be contacted with questions about the report.

Stephanie A. Blaney Freedom of Information Act Officer Mail Stop 0-4H09 United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Telephone: 301-415-7169 Fax: 301-415-5130

2.

Electronic address for the report on the World Wide Web.

http://www.nrc.gov/reading-rm7foia/annual-reports/

3.

How to obtain a copy of the report in paper form.

Contact the U.S. Nuclear Regulatory Commission (NRG) Public Document Room (PDR) located at One White Flint North, 11555 Rockville Pike (first floor}, Rockville, MD 20852-2738, by telephone at 301-415-4737 or 1-800-397-4209, PDR.Resource@nrc.gov or fax at 301-415-3548.

The mailing address is Public Document Room, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

II.

How to Make a FOIA Request

1.

Names, addresses, and telephone numbers of all individual agency components and offices that receive FOIA requests.

Freedom of Information Act Officer Mail Stop 0-4H09 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Telephone: 301-415-7169 Fax: 301-415-5130 E-mail: FOIA.Resource@nrc.gov Electronic submittal http://www.nrc.gov/reading-rm/foia/foia-submittal-form.html

2.

Brief description of why some requests are not granted and an overview of certain general categories of the agency's records to which the FOIA exemptions apply.

Some FOIA requests are not granted because (a) the agency has-no responsive documents, or (b) the responsive documents fall within one or more FOIA exemptions and are not appropriate for discretionary release. The Nuclear Regulatory Commission invokes the FOIA's two privacy exemptions, more than the rest of the other exemptions combined, to prevent unwarranted invasions of the personal privacy of individuals mentioned in law enforcement and non-law enforcement records To protect privacy (47%)

To prevent compromise of a pending investigation or proceeding (6%)

To protect the attorney-client privilege, attorney work products, or the agency's predecisional deliberative process (17%)

To protect proprietary information (8%)

Ill.

Acronyms, Definitions, and Exemptions

1.

Agency-specific acronyms or other terms.

NRG-defined acronyms are available on the NRC Web site at http://www.nrc.gov/readinq-rm/doc-collections/nuregs/staff/sr0544/

2.

Basic terms, expressed in common terminology.

a.

Administrative Appeal - a request to a federal agency asking that it review at a higher administrative level a FOIA determination made by the agency at the initial request level.

b.

Average Number - the number obtained by dividing the sum of a group of numbers by the quantity of numbers in the group. For example, of 3, 7, and 14, the average number is 8.

c.

Backlog - the number of requests or administrative appeals that are pending at an

. agency at the end of the fiscal year that are beyond the statutory time period for a response.

d.

Component - for agencies that process requests on a decentralized basis, a "component" is an entity, also sometimes referred to as an Office, Division, Bureau, Center, or Directorate, within the agency that processes FOIA requests. The FOIA now requires that agencies include in their Annual FOIA Report data for both the agency overall and for each principal component of the agency.

e.

Consultation - the procedure whereby the agency responding to a FOIA request first forwards a record to another agency for its review because that other agency has an interest in the document. Once the agency in receipt of the consultation finishes its review of the record, it responds back to the agency that forwarded it. That agency, in turn, will then respond to the FOIA requester.

f.

Exemption 3 Statute - a federal statute that exempts information from disclosure and which the agency relies on to withhold information under subsection (b)(3) of the FOIA.

g.

FOIA Request - a FOIA request is generally a request to a federal agency for access to records concerning another person (i.e., a "third-party" request), or concerning an organization, or a particular topic of interest. FOIA requests also include requests made by requesters seeking records concerning themselves (i.e., "first-party" requests) when those requesters are not subject to the Privacy Act, such as non-U.S. citizens. Moreover, because all first-party requesters should be afforded the benefit of both the access provisions of the FOIA as well as those of the Privacy Act, FOIA requests also include any first-party requests where an agency determines that it must search beyond its Privacy Act "systems of records" or where a Privacy Act exemption applies, and the agency looks to FOIA to afford the greatest possible access. All requests which require the agency to utilize the FOIA in responding to the requester are included in this Report.

Additionally, a FOIA request includes records referred to the agency for processing and direct response to the requester. It does not, however, include records for which the agency has received a consultation from another agency. (Consultations are reported separately in Section XII of this Report.)

h.

Full Grant - an agency decision to disclose all records in full in response to a FOIA request.

i.

Full Denial - an agency decision not to release any records in response to a FOIA request because the records are exempt in their entireties under one or more of the FOIA exemptions, or because of a procedural reason, such as when no records could be located.

j.

Median Number-the middle, not average, number. For example, of 3, 7, and 14, the median number is 7.

k.

Multi-Track Processing - a system in which simple requests requiring relatively minimal review are placed in one processing track and more voluminous and complex requests are placed in one or more other tracks. Requests granted expedited processing are placed in yet another track. Requests in each track are processed on a first in/first out basis.

i.

Expedited Processing - an agency will process a FOIA request on an expedited basis when a requester satisfies the requirements for expedited processing as set forth in the statute and in agency regulations.

ii.

Simple Request - a FOIA request that an agency using multi-track processing places in its fastest (non-expedited) track based on the low volume and/or simplicity of the records requested.

iii.

Complex Request - a FOIA request that an agency using multi-track processing places in a slower track based on high volume and/or complexity of the records requested.

I.

Partial GranUPartial Denial....:. in response to a FOIA request, an agency decision to disclose portions of the records and to withhold other portions that are exempt under the FOIA, or to otherwise deny a portion of the request for a procedural reason.

m.

Pending Request or Pending Administrative Appeal - a request or administrative appeal for which an agency has not taken final action in all respects.

n.

Perfected Request - a request for records which reasonably describes such records and is made in accordance with published rules stating the time, place, fees (if any) and procedures to be followed.

o.

Processed Request or Processed Administrative Appeal - a request or administrative appeal for which an agency has taken final action in all respects.

p.

Range in Number of Days - the lowest and highest number of days to process requests or administrative appeals.

q.

Time Limits - the time period in the statute for an agency to respond to a FOIA request (ordinarily twenty working days from receipt of a perfected FOIA request).

3.

Exemptions

a.

Exemption 1: classified national defense and foreign relations information

b.

Exemption 2: internal agency rules and practices

c.

Exemption 3: information that is prohibited from disclosure by another federal law

d.

Exemption 4: trade secrets and other confidential business information

e.

Exemption 5: inter-agency or intra-agency communications that are protected by legal privileges

f.

Exemption 6: information involving matters of personal privacy

g.

Exemption 7: records or information compiled for law enforcement purposes, to the extent that the production of those records (A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair trial or an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could reasonably be expected to disclose the identity of a confidential source, (E) would disclose techniques and procedures for law enforcement investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions, or (F) could reasonably be expected to endanger the life or physical safety of any individual

h.

Exemption 8: information relating to the supervision of financial institutions

i.

Exemption 9: geological information on wells

4. Agency Component Abbreviation Component Abbreviation Component Name NRG Nuclear Regulatory Commission

IV. EXEMPTION 3 STATUTES Number of Total Number Times of Statute Type of Information Case Citation Agency I Relied upon Times Relied Withheld Component by Agency/

upon Component by Agency Overall 142 U.S.C. 2167 SGI y

NRC 5

5 54 U.S.C 307103 Information about the location, Hornbostel v. U.S. Dep't of the NRC 1

character or ownership of a historic Interior, 305 F. Supp. 2d 21, 32-33 resource (D.D.C. 2003) (dictum}, summary 1

affirmance granted, No. 03-5257, 2004 WL 1900562 (D.C. Cir. Aug.

25, 2004)

Fed. R. Crim. P. 6(e}, enacted Certain records pertaining to grand Sussman v. USMS, 494 F.3d 1106, NRC 1

by Act of July 30, 1977, Pub. jury proceedings 1113 (D.C. Cir. 2007); Fund for L. No. 95~78, 91 Stat. 319 Constitutional Gov't v. Nat'I

~rchives & Records Serv., 656 F.2d 856, 867-68 (D.C. Cir. 1981);

Durham v. U.S. Atty. Gen., No. 06-1 843, 2008 WL 620744, at *2 (E.D.

If ex. Mar. 3, 2008); Cozen O'Connor v. U.S. Dep't of Treasury, 570 F. Supp. 2d 749, 776 (E.D. Pa.

12008).

V.A. FOIA REQUESTS -- RECEIVED, PROCESSED AND PENDING FOIA REQUESTS Number of Number of Number of Number of Requests Requests Requests Requests Agency / Component Pending as of Start Received Processed Pending as of End of Fiscal Year in Fiscal Year in Fiscal Year of Fiscal Year NRC 67 701 687 81 0

AGENCY OVERALL 67 701 687 81 After reviewing its database, NRG updated the number of requests pending as of the start of the fiscal year

V.8.(1). DISPOSITION OF FOIA REQUESTS --ALL PROCESSED REQUESTS Number of Full Denials Based on Reasons Other than Exemptions Number Number of Number of Partial

~II Records Records Improper Other Agency/

of Full Grants/ Full Denials Referred to Fee-FOIA Not Component

  • Based on No Another Request Related not Request Agency Duplicate *Explain TOTAL Grants Partial Records Withdrawn Reason ab I~

Request in Chart Exemptions Component Reason for Other Record Denials Described Below or Agency Reason NRG 195 187 37 127 1

25 30 37 14 14 20 C

687 0

AGENCY 687 OVERALL 195 187 37 127 1

25 30 37 14 14 20 C

V.8.(2). DISPOSITION OF FOIA REQUESTS -- "OTHER" REASONS FOR "FULL DENIALS BASED ON REASONS OTHER THAN EXEMPTIONS" Agency/

Number of Times Description of "Other" Reasons for Denials from Chart 8(1)

"Other" Reason Component Was Relied Upon NRC N/A AGENCY OVERALL TOTAL 0

0

V.B.(3). DISPOSITION OF FOIA REQUESTS -- NUMBER OF TIMES EXEMPTIONS APPLIED Agency/

Ex. 1 Ex.2 Ex. 3 Ex.4 Ex. 5 Ex.6 Ex. 7(A) Ex. 7(8) Ex. 7(C) Ex. 7(0) Ex. 7(E) Ex. 7(F)

Ex.8 Ex.9 Component NRC 3

7 3

29 59 88 20 0

74 0

28 35 0

a AGENCY OVERALL 3

7 3

29 59 88 20 0

74 0

28 35 0

a

VI.A. ADMINISTRATIVE APPEALS OF INITIAL DETERMINATIONS OF FOIA REQUESTS-- RECEIVED, PROCESSED, AND PENDING ADMINISTRATIVE APPEALS Number of Appeals Number of Number of Number of Appeals Agency I Component Pending as of Start Appeals Received Appeals Processed Pending as of End of Fiscal Year in Fiscal Year in Fiscal Year of Fiscal Year NRC 16 194 205 AGENCY OVERALL 16 194 205 5

0 5

VI.B. DISPOSITION OF ADMINISTRATIVE APPEALS --ALL PROCESSED APPEALS Number Partially Number Completely Number of Appeals Number Affirmed on Affirmed & Partially Agency/ Component Appeal Reversed/Remanded on Reversed/Remanded on Closed for Other TOTAL Appeal Appeal Reasons NRC 158 5

3 39 205 0

AGENCY OVERALL 158 5

3 39 205 i

VI.C.(1). REASON~ FOR DENIAL ON APPEAL-- NUMBER OF TIMES EXEMPTIONS APPLIED Agency/

Ex.1 Ex.2 Ex.3 Ex.4 Ex'. 5 Ex. 6 Ex. 7(A) Ex. 7(8) Ex. 7(C) Ex. 7(D) Ex. 7(E) Ex. 7(F)

Ex. 8 Ex.9 Component NRC 2

4 4

17 22 4

a 15 C

9 7

C C

AGENCY OVERALL 2

4 4

17 22 4

C 15 a

9 7

C C

VI.C.(2). REASONS FOR DENIAL ON APPEAL -- REASONS OTHER THAN EXEMPTIONS Appeal Records Based Referred at Fee-Records Improper Not Duplicate Solely on Other

  • Agency/

No Initial Request Related not Request Agency Request or Request in Denial of *Explain in Component Records Withdrawn Reasonably for Other Litigation Request chart Request Reason Described Reasons Record Appeal for below Level Expedited Processing NRC 3

0 0

5 3

13 1

13 0

C 1

AGENCY OVERALL 3

0 0

5 3

13 1

13 0

C 1

VI.C.(3). REASONS FOR DENIAL ON APPEAL -- "OTHER" REASONS Agency/

Component NRC AGENCY OVERALL Description of "Other" Reasons for Denial on Appeal from Chart C(2)

Untimely umber of Times N

w "Other" Reason as Relied Upon 1

TOTAL 1

1

VI.C.(4). RESPONSE TIME FOR ADMINISTRATIVE APPEALS Agency/ Component Median Number of Days Average Number of Lowest Number of Days Highest Number of Days Days AGENCY OVERALL 15.00 23.99

<1 213.00

VI.C.(5). TEN OLDEST PENDING ADMINISTRATIVE APPEALS Agency I 10th Oldes' 9th 8th 7th 6th 5th 4th 3rd 2nd Oldest Component Appeal Appeal Date of Appeal Number of Days Pending Date of Appeal N/A N/A N/A N/A NIP. 12017-09-08 12017 08 12017-05-26 2017-04-19 12016-01-11 AGENCY OVERALL Number of Days Pending 15 15 87 114 227

VII.A. FOIA REQUESTS -- RESPONSE TIME FOR ALL PROCESSED PERFECTED REQUESTS SIMPLE COMPLEX EXPEDITED PROCESSING Agency/

Median Average Lowest Highest Median Average Lowest Highest Median Average Lowest Highest Component Number Number Number Number Number Number Number Number Number Number Number Number of Days of Days of Days of Days of Days of Days of Days of Days of Days of Days of Days of Days AGENCY OVERALL 8

17

<1 179 35 63

<1 245 297 297 297 297

VII.B. PROCESSED REQUESTS -- RESPONSE TIME FOR PERFECTED REQUESTS IN WHICH INFORMATION WAS GRANTED SIMPLE COMPLEX EXPEDITED PROCESSING Agency I Median Average Lowest Highest Median Average Lowest Highest Median Average Lowest Highest Component Number Number Number Number Number Number Number Number Number Number Number Number of Days of Days - of Days of Days of Days of Days of Days of Days of Days of Days of Days of Days AGENCY OVERALL 11 21

<1 179 52 80 4

245 297 297 297 297

VII.C. PROCESSED SIMPLE REQUESTS -- RESPONSE TIME IN DAY INCREMENTS Agency/

<1-20 21-40 41-60 61-80 81-100 101-120 121-140 141-160 161-180 181-200 201-300 301-400 401+

TOTAL Component Days Days Days Days Days Days Days Days Days Days Days Days Days NRC 394 80 16 9

7 9

2 2

1 0

0 0

0 520 C

AGENCY 520 OVERALL 394 80 16

~

7 9

2 2

1 0

0 0

0

VII.C. PROCESSED COMPLEX REQUESTS-- RESPONSE TIME IN DAY INCREMENTS Agency/

<1-20 21-40 41-60 61-80 81-100 101-120 121-140 141-160 161-180 181-200 201-300 301-400 401+

TOTAL Component Days Days Days Days Days Days Days Days Days Days Days Days Days NRC 42 20 9

1C 10 3

4 3

1 1

12 C

0 115 C

AGENCY 115 OVERALL 42 20 9

1C 10 3

4 3

1 1

12 C

C

VII.C. PROCESSED REQUESTS GRANTED EXPEDITED PROCESSING -- RESPONSE TIME IN DAY INCREMENTS Agency/

<1-20 21-40 41-60 61-80 81-100 101-120 121-140 141-160 161-180 181-200 201-300 301-400 401+

TOTAL Component Days Days Days Days Days Days Days Days Days Days Days Days Days NRC 0

0 0

C 0

0 0

0 0

0 1

0 0

1 C

AGENCY 0

C 0

C 0

0 0

0 0

0 1

0 0

1 OVERALL

VII.D. PENDING REQUESTS -- ALL PENDING PERFECTED REQUESTS SIMPLE COMPLEX EXPEDITED PROCESSING Agency / Component Number Median Average Number Median Average Number Median Average Pending Number of Number of Pending Number of Number of Pending Number of Number of Days Days Days Days Days Days AGENCY OVERALL 28 71 81 51 109 127 C

N/A NIA

VILE. PENDING REQUESTS -- TEN OLDEST PENDING PERFECTED REQUESTS Agency/

10th Oldes1 9th 8th 7th 6th 5th 4th 3rd 2nd Oldest Component Request Request Date of Receipt Number of Days Pending Date of Receipt 2016-10-13 2016-09-16 2016-09-14 2016-08-24 2016-07-01 12016-07-01 12016-06-21 12016-06-20 12016-05-23 2016-05-11 AGENCY OVERALL Number of Days Pending 240 258 260 274 311 311 319 320 339 347

VIII.A. REQUESTS FOR EXPEDITED PROCESSING Median Number of Average Number Number Agency/

Number Granted Number Denied Days to of Days to Adjudicated Component Adjudicate Adjudicate Within Ten Calendar Days AGENCY OVERALL 0

15 NIA 2

13

VIII.B. REQUESTS FOR FEE WAIVER Agency I Median Number o1 Average Number Number Granted Number Denied Days to of Days to Component Adjudicate Adjudicate AGENCY OVERALL 11 125 NIA N/A

IX. FOIA PERSONNEL AND COSTS PERSONNEL COSTS Agency I Number of "Full-Number of Total Number of Component Time FOIA "Equivalent Full-

"Full-Time FOIA Processing Costs Litigation-Related Total Costs Employees" Time FOIA Staff

Costs Employees" NRC 11 4

15

$2,168,781.00

$0.00

$2,168,781.00 0

$0.00 AGENCY OVERALL 11 4

15

$2,168,781.00

$0.00

$2,168,781.00

X. FEES COLLECTED FOR PROCESSING REQUESTS Agency / Component Total Amount of Fees Percentage of Total Collected Costs NRG

$17,891.00 0.82%

AGENCY OVERALL

$17,891.00 0.82%

XI.A. NUMBER OF TIMES SUBSECTION (C) USED Agency / Component Number of Times Subsection (C) Used NRC 0

AGENCY OVERALL 0

XI.B. NUMBER OF SUBSECTION (A)(2) POSTINGS Agency / Component Number of (a)(2) Records Posted by the Number of (a)(2) Records Posted by FOIAOffice Program Offices NRC 411 241 AGENCY OVERALL 411 241

XII.A. BACKLOGS OF FOIA REQUESTS AND ADMINISTRATIVE APPEALS Number of Backlogged Number of Backlogged Agency I Component Requests as of End of Appeals as of End of

  • Fiscal Year Fiscal Year NRC 60 3

AGENCY OVERALL 60 3

XII.B. CONSULTATIONS ON FOIA REQUESTS ~-RECEIVED, PROCESSED, AND PEN.DING CONSULTATIONS Number of Number of Consultations Received Number of Consultations Received Agency / Component from Other Agencies Consultations Received from Other Agencies

~hat were Pending at the from Other Agencies that were Processed by Agency as of Start During the Fiscal Year the Agency During the of the Fiscal Year Fiscal Year NRC a

5 5

AGENCY OVERALL a

5 5

Number of Consultations Received from Other Agencies that were Pending at the Agency as of End of the Fiscal Year 0

0 0

XII.C. CONSULTATIONS ON FOIA REQUESTS--TEN OLDEST CONSULTATIONS RECEIVED FROM OTHER AGENCIES AND PENDING AT THE AGENCY Agency I 1oth Oldest 9th 8th 7th 6th 5th 4th 3rd 2nd Oldest Component Consultation Consultation Date Number of Days AGENCY Date NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA OVERALL Number of Days C

0 0

a 0

0 a

0 0

C

XII.D.(1). COMPARISON OF NUMBERS OF REQUESTS FROM PREVIOUS AND CURRENT ANNUAL REPORT-- REQUESTS RECEIVED AND PROCESSED NUMBER OF REQUESTS RECEIVED NUMBER OF REQUESTS PROCESSED Number Received Number Received Number Processed Number Processed Agency / Component During Fiscal Year from During Fiscal Year from Last Year's Annual During Fiscal Year from Last Year's Annual During Fiscal Year from Report Current Annual Report Report Current Annual Report NRG 785 701 753 687 AGENCY OVERALL 785 701 753 687

XII.D.(2). COMPARISON OF NUMBERS OF REQUESTS FROM PREVIOUS AND CURRENT ANINUAL REPORT -- BACKLOGGED REQUESTS Agency / Component NRC AGENCY OVERALL Number of Backlogged Number of Backlogged Requests as of End of the Requests as of End of the Fiscal Year from Previous Fiscal Year from Current Annual Report Annual Report 20 60 20 60 After reviewing its database, NRG adjusted the number of backlogged requests from the previous annual report

XII.E.(1). COMPARISON OF NUMBERS OF ADMINISTRATIVE APPEALS FROM PREVIOUS AND CURRENT ANNUAL REPORT --APPEALS RECEIVED AND PROCESSED NUMBER OF APPEALS RECEIVED NUMBER OF APPEALS PROCESSED Number Received Number Received Number Processed Number Processed Agency/ Component During Fiscal Year from During Fiscal Year from During Fiscal Year from During Fiscal Year from Last Year's Annual Last Year's Annual Report Current Annual Report Report Current Annual Report NRC 176 194 166 205 AGENCY OVERALL 176 194 166 205

XII.E.(2). COMPARISON OF NUMBERS OF ADMINIST RATIVE APPEALS FROM PREVIOUS AND CURRENT ANNUAL REPORT -- BACKLOGGED APPEALS Number of Backlogged Agency I Component Appeals as of End of the Fiscal Year from Previous Annual Report NRC 1

AGENCY OVERALL 1

Nu mber of Backlogged eals as of End of the al Year from Current App Fisc Annual Report