ML20134L789

Forwards Summary of Documentation & Recordkeeping Requirements That Should Be Useful as Clear & Concise Refresher on Requirements

ML20134L789
Person / Time
Issue date:	11/08/1996
From:	Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-3 NUDOCS 9611210227
Download: ML20134L789 (6)

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November 8,1996 NOTE TO: DWM Managers and Supervisors FROM: Michael Weber, DWM/LLDP 1

DOCUMENTATION AND RECORDKEEPING REQUIREMENTS THAT

SUBJECT:

APPLY TO OUR ' JRK Several weeks ago, Margaret aderline asked me to take the lead in summarizing documentation and recordkeeping requirements that apply to work within the Division of Waste Management. The requirements include regulations and procedures imposed by the National Archives and Records Administration, the General i

Accounting Office, NRC Management Directives, and DWM Policy. They apply to both hardcopy and other media, especially electronic mail messages, it is important that we understand and implement these requirements to preserve an auditable

record for our decisions and to comply with the law.

Cecilia Villarreal has prepared the attached summary of the documentation and recordkeeping requirements. Cecilia coordinated development of the summary with NMSS/PMDA and the Office of Administration. It should be useful to you as a clear and concise refresher on documentation and recordkeeping requirements. In addition, it saves you hours of reading through more detailed regulations and l

procedures. For your convenience, it also includes references to the primary regulations and procedures in the event you desire a more thorough review of the requirements.

After reviewing the summary, I suggest that you share this with your staff for their f information and use. If there is sufficient interest, we could arrange one or more staff meetings to review the requirements for documentation and recordkeeping.

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Attachment:

Summary John Hickey Sally Cornell cc: DWM Secretaries Jennifer Davis PUBLIC pc/

Central File _ LLDP r/f NMSS r/f DISTRIBUTION: w/f -

Path and File Name:s:\dwm\lldp\mfw\ record OFC L(DP NAME kMWeber DATE 11/df/96

, ACNW: YES_/ NO _

OFFICIAL RECORD COPY Category: Proprietary _ or CF Only _ y[y, h /

IG : YES Z NO

, LSS : YES _ NO 7 Delete file after distribution: Yes / No 9'd-/f0 9611210227 961108

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.p* *i ', UNITED STATES .

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j NUCLEAR REGULATORY COMMISSION WA8HINGTON, D.C. 20666-0001

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November 8,1996 NOTE TO: DWM Managers and Supervisors '

FROM: Michael Weber, DWM/LLDP

SUBJECT:

DOCUMENTATION AND RECORDKEEPING REQUIREMENTS THAT APPLY TO OUR WORK Several weeks ago, Margaret Federline asked me to take the lead in summarizing documentation and recordkeeping requirements that apply to work within the Division '

of Waste Management. The requirements include regulations and procedures imposed by the National Archives and Records Administration, the General Accounting Office, NRC Management Directives, and DWM Policy. They apply to both hardcopy and other media, especially electronic mail messages. It is important that we understand and implement these requirements to preserve an auditable record for our decisions and to comply with the law.

Cecilia Villarreal has prepared the attached summary of the documentation and recordkeeping requirements. Cecilia coordinated development of the summary with NMSS/PMDA and the Office of Administration. It should be useful to you as a clear and concise refresher on documentation and recordkeeping requirements. In addition, it saves you hours of reading through more detailed regulations and procedures. For your convenience, it also includes references to the primary regulations and procedures in the event you desire a more thorough review of the requirements.

After reviewing the summary, I suggest that you share this with your staff for their information and use. If there is sufficient interest, we could arrange one or more staff meetings to review the requirements for documentation and recordkeeping.

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Attachment:

Summary cc: DWM Secretaries John Hickey Jennifer Davis Sally Cornell CONTACT: Cecilia Villarreal, NMSS/DWM/LLDP 415-7234

SUMMARY

OF NRC RECORDS DISPOSITION ON RETENTION OF DRAFTS AND WORKING PAPERS. E-MAIL COMMUNICATIONS.

TIME AND ATTENDANCE FILES. AND TELEPHONE CALLS e Records Status of Drafts and Workina Paoers National Archives

• and Records Administration (NARA) regulations recuire that working files, such as preliminary drafts.and rough notes usec to develop or support an' official record must be retained for adequate and -

proper documentation if both of the following 2 conditions are met:

1) Theyw$re'circulatedormadeavailable-toemployees,otherthanthe creator, for official purpose such as approval, comment. action.

etc.; and

2) They contain unicue information, such as substantive annotations or comments that adc to a proper understanding of the agency's formulation and execution of basic policies. decisions, actions, or responsibilities.

The goal' is to properly document the actions and decisions of the agency, Retain those drafts with comments or ideas that are vital to the understanding of the final document but were not included in the final.

Drafts are to be filed with the final record that they support. 00 NOT SET UP A SPECIAL FILE FOR ALL DRAFTS. See Management Directive 3.53 Part-I. Page 8.

e Record Status of Electronic Mail The NARA regulations require that:

a. NRC staff review each incoming and outgoing e-mail message to determine if it is a Federal record by using the same criteria used for information created or received on any other media. If he/she conducts business using e-mail, he/she generally creates e-mail records.

b. E-mail messages and attachments that are records must be maintained in a recordkeeping system that groups related records together.

Recordkeeping systems that include e-mail messages must have the following:

a, capability to grou) related records into classifications according to the nature of t1e business;

b. capability to permit easy and timely retrieval of records:

! c. capability to store in a usable format for their required retention

. period: and Attachment

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d. . accessibility by individuals who have a business need for information contained in the. system.

E-mail communications are Federal records when they meet both of the following conditions: .

a. They are created or received by an NRC employee to transact official agency business: and

b. They are preserved, or, are appropriate for preservation, as evidence of the agency's organization and activities, or because of the value of the information they contain.

Communication types that are considered Federal records and require

. preservation:

e communications that relate to programs, policies, organizations, decisions, decision making, minutes, or agendas:

e. messages that contain unique information that explains why the agency made a decision or took. action:

I e messages that direct one to take action or that one uses to direct another to act: '

e drafts ~of records (e.g...SECY papers) circulated via e-mail for a) proval, action 'etc. or action that are sianificantly changed in tie final version; e information generated or acquired by.the NRC via e-mail pertaining a tolan: inspection of. a licensee's facility that contains unique l ' information;such as the. rationale for an NRC decision, or guidance  ;

that is not documented in the official record.

l The communications types that are not considered Federal records and do 1 l not require preservation:

l i a. communications that provide little or no evidence of agency activities:

l b. communications that have no documentary value; and

c. insignificant communications that are facilitative in nature; e.g. 4 casual inquiries about the status of an activity, requests for l routine information, transmittals that forward documented  ;

information but do not require action: realies to an e-mail inquiry I about information that is documented in t1e official files.

For additional guidance on electronic records and examples of record and nonrecord electronic material, including e-mail communications and

j. Preserving E-Mail Records. consult NRC Management Directive 3.53. NRC I

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Records Management Program. Part IX. Procedures for Creating. l Maintaining. Using, and Disposing of Electronic-Records.

E-mail messages that are not official records should be deleted when no I

longer needed. These may be subject to requests under the Freedom of l i

i information Act and litigation and court orders. When this occurs the '

messages must be preserved until no longer needed for such purposes.

i e Time and Attendance Files

! T&A clerks are responsible for retaining the Time and Attendance source ,

, information: e.g.. T&A electronic reports: time or sign-in sheets:  !

flexitime records

leave applications for jury duty and military duty and

other types of leave; authorized premium pay or overtime, upon which l leave input data is based. The General Records Schedule of the National Archives and Records Service requires that these records be kept for six i vears or until a GA0 audit occurs whichever is sooner. To ensure that 4

proper retirement and retention of these records occurs, each Primary T&A clerk must prepare NRC-306 (Files Maintenance and Disposition Plan) for j

these records. The records do not' have to be kept in the office space for the entire six years. They can be boxed and sent to records holding

! in two-year increments. If the records become too voluminous for you to

' retain, contact Sally Cornell at 415-8045.

,) For information on Records and Authorized. Disposition, consult.

j NUREG-0910.

f e Use and Documentation of Phone Calls The p rpose of ths documentation ofl phone calls is to register i signi icant information obtained or provided, and to communicate it  ;

i promptly.

i Telephone calls can.be used to enhance the efficiency of the regulatory

process by acquiring information from, or providing information to. l

licensees. States, members of the public, or other interested parties. '

However, if information collected or provided during telephone calls is I

to be used to resolve substantive matters related.to protection of the  ;

public or the environment, proper documentation is essential to preserve J

and communicate the information and establish a defensible record for NRC's decisions.

Telephone calls should not be used to resolve licensing or other

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regulatory issues that can best be discussed and resolved in open meetings or via correspondence. NRC licensees are required to report by telephone certain events and emergencies to NRC through the NRC Operations Center (cf. 10 CFR 20.2201).

For more information on Use and Documentation of Phone Calls, see Interim Policy On Use And Documentation Of Telephone Calls (DWM POLICY 3).

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Memorandum to DWM staff from M. Federline dtd 3/29/96.

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l PRNACY ACT STATEMENT i

Pursuant TO 5 U.S.C. 552a(e)(3), enacted into law by Section 3 of the Privacy Act of 1974 (Public Law  ;93-579), the following statement is fumished to individuals who supply information to the U.S. Nuclear Regulatory Commission on NRC Forms 64,64A, and 648. This information is maintained in a system of

! records designated as NRC-20 and described at 58 Federal Register 36468 (July 7,1993), or the most recent Federa/ Register publication of the Nuclear Regulatory Commission's " Republication of Systems of i

! Records Notices" that is available at the NRC Public Document Room, Gelman Building, Lower Level, i 2120 L Street NW, Washington, DC.

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1. AUTHORITY: 5 U.S.C 5701; 31 U.S.C. 716,1104,1108,3511,3512,3701,3711,3717,3718

(1988); Federal Travel Regulations,41 CFR Parts 301-304; and Federal Property Management i Regulations,41 CFR Part 101-71. The authority for soliciting the social security number is Executive Order 9397, dated November 22,1943.

, 2. PRINCIPAL PURPOSE (S): The information is used to make reimbursement claims for approved and authorized travel expenses, per diem, and other change of station expenses.

< 3. ROUTINE USE(S): The information is used for transmittal to the U.S. Treasury to secure payment.

l The information may also be disclosed to an appropriate Federal, State, local, or Foreign agency in j the event the information indicates a violation or potential violation of law and in the course of an 1

administrative orjudicial proceeding. In addition, this information may be transferred to an appropriate Federal, State, local, or Foreign agency to the extent relevant and necessary for an NRC decision l

about you or to the extent relevant and necessary for that agency's decision about you. Information

from this form may also be disclosed, in the course of discovery under a protective order issued by a l court of competent jurisdiction, and in presenting evidence, to a Congressional office to respond to I l

their inquiry made at your request, or to NRC-paid experts, consultants, and others under contract with the NRC, on a need-to-know basis. i l

! 4. WHETHER DISCLOSURE IS MANDATORY OR VOLUNTARY AND EFFECT ON INDIVIDUAL OF "

4 NOT PROVIDING INFORMATION: Disclosure is mandatory, if the requested information is not 4

provided, reimbursement may be denied. Failure to provide the social security number may result in 2

delayed processing. The use of the security numberis made necessary because of the large number j of present and former Federal employees and applicants who have identical names and birth dates, and whose identitles can only be distinguished by use of a social security number, j 5. SYSTEM MANAGER (S) AND ADDRESS:

Chief, Travel Management Branch Division of Accounting and Finance Office of the Controller U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 l