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NUCLEAR REGULa M COf.*. :SSION -
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SEP 121984 4
MEMORANDUM FOR:
William J. Dircks Executive Director for Operations FROM:
Richard C. DeYoung, Director Office of Inspection and Enforcement
SUBJECT:
PROPOSED NRC MANUAL CHAPTER 0517,
" MANAGEMENT OF ALLEGATIONS"
. Enclosed is the proposed final version of the subject manual chapter. All comments from Office Directors and Regional Administrators have been resolved.
The major comments and their resolution are listed in an enclosure to this memorandum.
Please note that the Labor Relations Branch, ADM, has determined that the NTEU should be given the opportunity to review this manual chapter since it addresses the treatment of allegers, some of whom could be NRC emplofees.
In accordance with Federal policy,'this review should take place subsequent 3
to NRC approval and prior to p'ublication.
As before, the enclosed manual chapter does address "last minute" allegations
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and confidentiality, but final policy decisions remain to be provided separately on these matters by the Commissioners and an EDO Task Group, respectively, sometime in the future.
Please let me know if you need additional assistance in finalizing the manual chapter.
l f _,
Richard C.
- oung, irector Office of pection and Enforcement
Enclosures:
As Stated cc:
Office Directors Regional Administrators S. L. Bachrach, ORM 0512030045 851106 PDR FOIA GARDE 85-59 PDR I
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U.S. NUCLEAR REGULATORY CD P.ISSION NRC MANUAL Volume:
0000 General ^'dministration Part :
0500 Health and Safety IE CHAPTER 0517 MANAGEMENT OF ALLEGATIONS 0517-01 COVERAGE This chapter and its appendices define the policy and procedur.es for the proper receipt, processing, control, and disposition of allegations received by NRC-offices that. concern NRC-regulated activities conducted by HRC licensees and th'eir contractors and the policy and procedures for dealing with individuals who provide. information to the NRC.
0517-02 OBJECTIVES 021 To establish the poiicy for the receipt, processing, control, and disposition of allegations and to define procedures by which the
- receipt, status, and disposition of allegations are tracke:
through the Allegation Management System (AMS), thereby assuring that:
a' allegations are properly assigned for' processing ~and as'sessed for
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safety significance to permit ranking and resolution in a timely manner; b.
timely and accurate information on all allegations is maintained and made available to NRC Offices and Regions on a need-to-know basis; 9
c.
all allegations not resolved by other formal means are processed. in accordance with these procedures and the resolution of all ' allegations is properly documented; E'
022 To assure that individuals making allega' ions to the NRC are properly treated,, provided confidentiality when necessary.
appropriate and possible, and notified of the resolution.
023 To assure that issues raised are promptly and adequately investi-
. gated.
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Approved:
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NRC-?'E-03 M4%GEMENi Or ALLEGATIONI 0517-03 RESPONSIBILITIES AND AUTHORI1IES 031 Executive Director for Operations (EDO)
Set policy and procedures for the receipt, processing, control, and disposition of allegations and establish policy for the treatment ~ and confidentiality of those who provide information to the NRC.
For those matters within the purview of OI and CIA, only set policy and procedures governing their interfaces with other Offices and Regions.
032 All Office Directors / Regional Administrators a.
Establish internal procedures so that all employees are aware of requirements for receipt, processing, control, and disposition of allegations and for the accurate and :..imely upd'ating of the status of.those allegations for which their office is the Action Office.
b.
Appoint an Offi,ce Allegation Coordinator (OAC) who serves as adminis'trative point of contact for employees and other Offices and the Regions.
The OAC will:
1.
Ensure that the ap;iropriate parts of the ' Allegation Data Form (NRC Form 307, Exhibit 1) are completed for all allega-tions received.within the Office or Region an'd that the requested data are accurate and" timely.
2.
Determine the appropriate Action Office and, if applicable, coordinate with the OAC of the affected Office or Region on each allegation received.
3.
Ensure the appropriate paFts of the Allegation Data Form are completed for all allegations for which the Office or Region is the Action Office.
4.
Forward the Allegation Data Form to the respective Action Office OAC when the Office or Region is not the Action Office.
5.
Forward the completed Allegation Data Form to the NRR OAC [and a copy to the Office of Nuclear Materials Safety and Safe-guards (NMSS) OAC', if approp'riate'] within 10 working days of receipt of an allegation when the Office is'the Action Office.
(For power reactors, during the period from 30 days prior to the construction completion date until the Comission meeting on full power acthorizrifikte Receiving Office or Action Office for any allegation will, within 2 w' rking days, tele-o phonically notify the NRR Project Manager of its receipt and the identification of the Action Office in addition to com-pleting the Allegation Data Form.)
Acoroved:
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wAs: EMENT OF ALLEG NRC DE17-032b6 6.
Acquire input jata on new. allegations (including those referred to OI) from the staff within the Of fice or Region and ensure this information is forwarded to the NRR OAC in a timely manner for placement into the AMS.
1 7.
Provide updates (using an AMS printout) on previous allega-
- tions (including those referred to 01) from the staff within the Office or Region and ensure this information is forwarded to the NRR OAC on a monthly basis for placement into the AMS.
)
8.
Provide reports as. described in Appendix 1, Part IX, 4 and 5.
c.
Determine the safety significance and generic implications of those allegations that fall within the programmatic responsibi-lity of that 0ffice or Region and establish schedules for the processing of allegations with the objective of resolving them prior to a licensing decision date, if applicable.
d.
Re, view those allegations for which it is the Action Office for potential board notification and recommend such notification to NRR or NMSS.
Refer all allegations involving wrongdoing, except those involving e.
NRC employees or NRC contractors, to the Office of Investigations and provide technical assistance to OI for investigating allega-tions as requested.
f.
Prior to taking a major action - such as a licensing decision or escalated enforcement, review the. status and resolution.of allegations for that project in the AMS especially those related to the action.
g.
For technical concerns with generic implications, consider the inform other affected Offices for further action (e.g.,
need to AEOD ~ for operational data, RES for concerns affecting research activities,etc.)
h.
For discrimination complaints received concerning possible violation of Section 210(a) of the Energy Reorganization Act, refer the complainant to DOL and promptly notify DOL to ensure their awareness of the complaint and to determine DOL's R-investigative' intent.
Determination of the need for an NRC investigation would rest with 01.
W 033 Director, Office of Investications
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wu Inves.tigate allegations of wrongdoing by other than NRC em-ployees and NRC contractors. - Conduct interface responsiDilities
,with the Offices and Regions as d,escribed herein.
3-Approved:
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7-034 MANAGEMENT OF ALLEGATIONE 034 Director, Off;te of Insoector and Audit::r Investigate allegations of wrongdoing by NRC employees and NRC contractors.
Such allegations do not fall under the purview of this manual chapter and are not entered in the AMS.
035 Director, Office of Insoection and Enforcement Resolve allegitionii affecting matters for which it is the respon-a.
sible office including those that involve vendors or that are generic in nature in coordination with NRR or HMSS.
b.
Monitor the allocation of resources for this activity by the regions.
036 Director, Office of Nuclear Reactor Reculation a.
Propose to the EDO for approval agency-wide policy and dures regarding the processing of allegations.
For~ proce-those alJegations that fall under the purview of OI, propose policy and procedures ' governing their interface with other Offices and Regions.
b.
Review allegations concerning NRR licensees in ecordination with the Action Office for potential board notification and make such notification, if required.
c.
Evaluate implications of allegations relative to licensing deci-sions and plant safety concerning NRR licensees in coordination with IE and the Region (s).
d.
Resolve those allegations pertaining to -reactor licensing issues assigned to NRR.
e.
Maintain the AMS and any necessary improvements to modify its capabilities, in coordination with RM.
037 Director, Office of Nuclear Material Safety and Safecuards Review allegations concerning NMSS licensees in coordination with a.
the Action Office for potential' board notification and make such notification if required.
b.
Evaluate implications of allegations relative to licensing deci-sions concerning HMSS iicensees in coordination with IE and the Region (s).
_. _- h s.
038 Office of Resource Manacement (RM)
Establish the ADP program and. maintain the data base of information a.
in the AMS, b.
Provice monthly (Exhibits 2 and 3) and special reports to Offices and Regions as requested.
Approved:
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W. 3EMEC 0F ALLEMT:3NS NRC 0517-04 0517-04 DEFIh1TIONS 041 Action Office.'
The NRC Office or Region that is responsible for reviewing and taking action, as appropriate, to resolve an allega-tion.
042 Action Office Contact.
The staff member in the Action Office who is assigneo the responsibility for resolving an allegation.
043 Allecation.
A declaration, statement, or assertion of impro-priety or inadequacy associated with NRC-regulated activities, the validity of which has not been established.
This includes all safety concerns identified by sources such as the media, indi-viduals or organizations outside the NRC, and technical audit efforts from Federal, State or local government offices regarding activities at a licensee's site.
Excluded from this definition are matters being handled by more formal processes such as 10 CFR 2.206 petitions, hearing boards, appeal boards, Allegations that may result from these formal processes and etc.
resolved within these processes shall be subject to not are treatment under this manual chapter.
044 A11ecation Management Svstem.(AMS).
A computerized information system that contains a. summary of significant data pertinent to each allegation.
045 Allecer.
An individual or organiration who makes allegat ons.
The individual or organization may be a concerned private citi-zen; a public interest group; a licensee, vendor or. contractor -
employee; a representative of a local, State, or Federal agency.
(NRC employees should be aware of procedures for presenting differing professional opinions, NRC Manual Chapter.4125).
.046 Confidentiality.
The term that refers to the protection of data that airectly, or otherwise, could identify an alleger by name.
It is not intended to deny staff members access to the identity of the a11eger when such identification is required by staff members to evaluate and resolve allegations.
047 Inouirv.
An activity involving minimal effort to - determine the appropriate response to information reported to the NRC.
Typi-cally, an ' inquiry entails,the ' use of tne telephone or written correspondence rather than formal interviews or other investi-L; -
gative measures; however, formal interviews will be conducted if required.
speciaY activity that may be used to 048 Inspection.
A routine or
- examine and subsequently resolve an allegation.
5 Aporoved:
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$ 0". 7- 04 9 MANAGEMENT Of AI.LE W I..
049 Investication.
Formal activities nonnally conducted by the Of fice-of Investigations on its own volition, or at the request of the Commission,
- EDO, or Regional Administrators, with or without technical assistance.
The Office of Investigations is the lead Action Office for all investigations involving wrong-doing, excluding wrongdoing by NRC employees and NRC contractors which is handled by OIA.
050 Office A11ecation Coordinator (OAC).
A designated staff member in each Office or Region wno serves as the administrative point of contact for that Office or Region regarding the processing of allegations.
051 Receivine Office.
The Office or Region that initially receives an allegation.
In some cases, the Action Office and Receiving Office will be the same if the allegation falls within the functional responsibility of the Receiving Office.
052 Safety Sionificance.
A measure of the importance of 'an' allega-tion relative tp its potential impact on the public health and safety.'
053 Wronodoinc For the purposes of this manual chapter, it includes the alleged deliberate, ' purposeful, or willful violation of NRC regulations, license technical specifications, licensee commitments to the NRC, or other laws or statutes of interest to NRC.
0517-05 BASIC REQUIREMENTS 051 Aeolicability.
The provisions of this chapter and appendices are applicable to, and shall be followed by, a Q NRC employees.
052 Wronodoinc.
Allegations of wrongdoing at NRC-regulated facili-ties, as opposed to those involving technical issues, fall within the purview of the Office of Investigations (allegations of wrongdoing by NRC employees or NRC contractors fall within the purview of OIA and are not entered into the AMS).
The Office or Region will enter allegations of wrongdoing into the AMS using information provided by OI (see Appendix 1, Part IX.2 of this manual chapter).
OI will investigate allegations involving wrongdoing, and provide either. a report ori a summary of its findings to the " requesting O'ffi'ce' or Region.
Allegations involving wrongdoing received by a Region will be coordinated by N
the Region OAC with the 01 Field Office Director in that Region and those received by Offices at NRC Headquarters will be coor-
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053 Action Office Assignments Allegations submitted by any source concerning NRC-regulatec activities should be transmitted by the Receiving Office OAC to the OAC in the appropriate Office or Region for processing.
i Accroved:
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i4ANAGEMEC OF ARE3ATIONS NPC 0517-054 054 Confidentialitv.
The identity of individuals making allegations shoulo not be revealed by the NRC unless it is clear that the individual concerned has no objection.
A confidentiality agreement (Exhibit 4) should be executed for those allegers who specifically request it, and should be offered for execution to those allegers who by their actions convey the inference that their identity will be protected by the NRC but who are apparently unaware that such an agreement is available.
The offer of a confidentiality agreement should be contingent upon an assessment of 'the usefulness of the information provided, if such a determination can be made in a timely manner.
For other individuals, confidentiality need not be provided.
As a general rule, however, the "need to know" principle should be implemented for all allegers.
For those allegers with a confidential.ity agreeraent, this means that the identity of the source ' must be protected by not referring to the name or other identifying information in discussions unless absolutely necessary and by expurgating the name and other identifying information from documents before disseminating these to the staff.
For those allegers without a confidentiality agreement, this means avoidance of ' unnecessary use of the identity of the source and other identifying information in discussions and in documents.
It must be made clear to. all concerned if and on what tenns the anonymity of a person making an allegation is to be protected.
A clear record should be maintained for the files to preclude later misunderstandings.
The confidentiality agreement may be signed by Office Directors and Regional Administrators only and may be transmitted to the alleger for signature by mail or in person as convenience dictates.
If at any time for any reason confidentiality is, breached or jeopardized,
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Office or Regional management. should be informed and the. person should be advised, the reason explained and remedial measures taken, if possible, to reduce the impact of disclosure.
Since OI has established policie; and practices for the protection of conficentiality for its activities, the above are not I
necessarily applicable to 01.
1 055 Resoondino to A11egers.
Those who provide allegations to NRC staff must be treated with respect, consiceration, and tact.
Under no 1:ircumstances should they be dealt with brusquely or
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abusively.
When allegations are received in writing, a prompt
.;;r.
attempt to make personal contact must ordinarily be made in each
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case either by a letter, telephone caii or even a personal meeting.
f Contact should be.. earnest _.anqL.pr_o.fes sional.
The alleger should be promptly advised of the results of followup action and, in instances of unusual delay in providing the. results, should be advised of the status periodicgily so that there is an awareness that the allegation is not being ignored.
7 Approved:
'GC-0517-04C MANAGEMENT OF ALLEGATIONS 056 Screenino of Allecations.
Allegations should be screened for significance to safety and the more serious ones should be addres-sed first.
All allegations should be addressed as promptly as resources will allow and as the need is identified.
Screening of allegations should be considered diligently to the point where some may be dismissed early in the process for logical reasons (i.e.,
lack of specificity after reasonable followup, lack of safety significance, etc.) to conserve staff resources.
Followup
- on allegations, whether they are general or specific, should focus
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not only on"the specific allegation but on the overall area of concern, including the potential for generic implicati.ons as well as criminal activities.. In this regard, note that an allegation.
directed toward a non-safety item or activity may, through generic considerations, affect a safety item or activity.
When a number of allegations point to or reinforce indications of a broader problem, prompt action to broaden the scope of the inquiry should then be taken to determine whether or not such is the case.
While the safety significance of an allegatio'n is an important factor in determining the extent and promptness of staff resourc'es commitment, it should net affect the staff treatment of the alleger as discussed in section 055, above.
057 Timeliness of Resolvino AFlecations.
The Action Office should resolve all -allegations in a manner which is timely under _the circumstances and professional in scope and depth.
Allegations having relatively high safety significance should be addressed expeditiously. Less significant= llegations should be addressed as priorities and resources permit, but usually within 6 months of receipt. If-it is appropriate, an inspection should be made.
A plant visit with the person making the allegation should be made if necessary and if the individual is villing to make such a visit to find the exact location of a problem." Access issues-should be addressed on a case-by-case basis.
Travel costs for the individual only can be offered, if necessary, and are borne by the Office or Region extending the offer.
Care should be taken to avoid embarrassment or abuse of the individual, e.g., schedule visit on off-shift / weekend, etc.
058 Involvement of Licensees or Other Affected Orcanization.
For allegations involving a potentially significant and immediate impact on the public health and safety, the affected organization M
should be 'promptly-informed to assure proper and timely action.
For' other allegations, once infomation from allegers is received w
and understood by the Office / Region and if it is deemed appropriate by the Office Director / Regional Administrator, the licensee / vender should be advised specifica4.ly-by. letter of the area of concern and should be reouested to address it, subject to further audit by NRC, in order to minimize the expenditure of NRC resources.
In all instances, however; confidentiality must not be breached and the effectiveness of investigati'ons/ inspections should not be com-promised, such as by prematurely releasing or appearing to release Approved:
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N:I-0517-056 MANAGEMENT OF ALLEGATI0HS an.NRC inspection report (note exceptions discussed below).
The alleger must be informed that this is not handing a matter over to the affected organization, but that NRC will review and evaluate the actions of the affected organization and perform independent activities as necessary.
The affected organization should be informed regarding the resolution of the allegation if appropriate (See Appendix I Part VIII).
tEo exceptions' to the above.
The first exception is There are where the information cannot be released in sufficient detail to be of use to the licensee or vendor without compromising the identity of the confidential source.
In such cases release should normally not be made unless the release is necessary to prevent an imminent threat to the public health and safety.
The EDO shall be consulted in all cases where it appears there is a need to release the identity of a confidential source.
The second exception is where a licensee / vender could compromise an investigation / inspection because of knowledge gained from the release of information, especially if wrongdoing is involved.
The Regional Administrator for inspections and the Director of the Office of Investigations for investigations shall decide whether or not to release the information to avoid compromising NRC action.
Release of. information to a licensee / vendor is expected to be the exception for OI investigations.
Note that 10 CFR 19.16(a), involvin.g radiological working condi-tions, requires that a worker's allegation in writing be made available to the licensee no later than at the time of inspec-
- tion, and that confidentiality be provided at the worker's request.
In addition to expurgating names and other identifying information, protection of confidentiality could also_ involve retyping an alleger's handwrjtten nottee.
In the event the-potential for wrongdoing is involved, OI should be requested to perform an investigation in which case the licensee would not be informed.
059 "Last Minute" Allegations.
When a large number of issues are raised at the same time, as has occurred with several plants as they approach issuance of an OL,.the difficulties in executing the above policy guidelines are compounded.
Consideration should be given to organizing a task force, comprised of both headquarters and regional personnel with a sertior, N,RC manager as the task force
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leader, to resolve these issues within the usual short time frame g
between the date the issues were identified and the proposed date for issuance of an OL.
A high cegree of organization in the g
initial stages will be required in order to deal with these 4
parti ~cular situatio'nP.
Td coTI* ewe NRC resources in resolving these large numbers of issues, the involvement by the licensee except as noted above will be appropriate.
It may also be quite
. appropriate to categorize th'e large -number of issues into two s
MANAGEMEC DF ALLE1ATICNS N C OE17-05E general groups, one group in which the issues are judged to be significant and therefore require resolution prior to OL issuance, and a second group in which the issues are of lesser importance pemitting resolution over a longer time frame, even subsequent to OL issuance.
Within the fomer group, subdivisions may be appropriate consistent with the planned stages of licensing for the facility (i.e., criticality, 5% power, full power).
060 Accendix 1.
-This appendix provides procedures for receipt, control, processing, and ' isposition of allegations assigned to d
NRC Offices or Regions and the procedures and guidelines used to record the receipt, status, and disposition of allegations in the AMS.
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I wANAGEWENT OF ALLEGATIONS APPENCIX 1, N:iC 05L' PROCEDURES FOR SCREENING, ASSESSING, AND CONTROLLIHG ALLEGATIONS AND FOR ALLEGATION MANAGEMENT SYST Part I: General This part establishes procedural guidance for screening, assessing, and controlling allegations that come to the attention of the NRC staff.
These functions are to be established within each Region and Office under the control of an individual Office Allegation Coordinator (OAC), or a panel cf staff personnel or other appropriate staff technical persons.
The Regions and Offices will establish procedures consistent with this guidance and where appropriate provide the required training to ensure that their staffs are fully informed regarding the proper management of allegations.
Allegations pertaining.to NRC-licensed facilities anti activities may come to the attention of the NRC staff by telephone, letter, news inedia reports, or by direct verbal contact at. sites, in offices, at. meetings,- and even at social functions.
All allegations, no matter how originated, atre. subject to processing in accordance with this manual chapter.
It is imperative allegations be recognized as such by staff members and processed pro-that fessionally, prom,ptly, and with consistent treatment.
It is, very important to note that where safety is involved, the NRC does recognize the term "off-the r'ecord."
Allegers who wish to provide not off-the-record information must be clearly advised that infonnation impor-tant to safety cannot be treated off the record, but that the 'information I
will be ace'epted officially and acted upon a necessary.
The name of the alleger and other identifying information will be protected, however, under the confidentiality guideliner presented herein.
J Any employee who receives an allegation must be aware that it is essential to protect the identity of the alleger if such anonymity,,is requested or.
implied by his/her actions (i.e., an al' leger who employs circuitous means to contact the NRC or makes several phone calls anonymously and then subse-quently identifies himself as the one who has been making the anonymous
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calls).
To this end, coordination with the appropriate Office or Region Allegation Coordinator must comply with the.:onfidentiality guidelines discussed separately (Basic Requirement 054).
If necessary, the identity of an alleger ' may be revealed, but only if a confidentiality agreement has not been executed.
As a general rule, the "need to know" principle should be used when dealing with the protection of a person's identity.
NRC employees, particularl'y resident and r'egional inspectors, regional supervisors, and DACs who are expected to receive the majority of allega-tions, should become fully familfar with the prescribed policies and proce-dures to ensure that the required actions are performed.
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It is the responsibility of 'all employees who receive allegations to take whatever steps are necessary to ensure that an appropriate OAC is promptly informed.
Whenever possible, the per. son making the allegation should be j
referred to either the OAC, other individuals as designated by the Region or
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Office, or arrangements should be made for the OAC or designated staff member to recontact the individual.
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i Al-1 Acoroved:
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4 URC %1' M MAMGEMENT OF ALLEGATIONS Part II:
The Office A11ecation Coordinator (OAC) i The initial responsibility of the OAC is to identify the proper Action 1.
Office to which the allegation should be assigned for evaluation and resolution in coordination with other OAC's (either in the Offices or Regions).
The OAC serves as, a focal point for administrative processing and con-2.
trol of all allegations assigned to the Regions and Offices.
The OAC is responsible for tracking allegations from initial receipt to final resolution.
The OAC assures establishment and maintenance of files that clearly identify allegations assigned to the Region or Office
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and documents actions initiated to resolve such matters.-
The OAC ensures that management and cognizant staff are informed of allega-tions under their purview, kept current on the status,'of such alle-gations by provid'ng accurate and timely information to the AP.5, and briefed on the pr.) posed final resolution of allegations.
The OAC also ensures that the final resolution is properly documented.
The OAC assists technical staff members who are reviewing allegation 3.
information, primarily in the form of coordinating activities neces-sary to resolve issues.
In addition, the OAC may assist in the formulation of a course of actjon to resolve issues.
4 A panel, which includes the OAC as a member, may be designated with the primary responsibility to ensure that all allegations are promptly assigned and properly evaluated, and that the actions taken to resolve the allegation, as well as the resolution, are properly documented and transmitted to the alleger and the affected organization as appro-priate.
5.
The OAC will serve as the point of contact with 00L on matters
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'involving discrimination under Section 210(a) of t'he Energy Reorganization Act and will coordinate as necessary with OI and the Enforcement Staffs.
Part III:
Receiot of an A11ecation 1.
A11ecations Received by Telechone or Personal Visit Any NRC employee who receives a telephone call from someone who wishes to make an allegatico should have the caller transferred to the OAC or appropriate. technical staff member 'n the Office or Region.
i Likewise, if an individual appears in person at an NRC Office, the individual should be referred to the OAC or other technical staff member.
Technical
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employees, when unable to refer the telephone call or the v1sitor as de's'cri bed',- ~5ii5Tl'dbtai n as much information as i
possible from the individual (see item 3, below).
When unable to locate the OAC or other technical staff member, administrative em-playees should refer 'an individual to a technical staff supervisor.
4 Annenved-al-7
wANAGEu.ENT OF AL.EGAT:0NS APDENDIX 1. NRC 05'7 2.
Allegations Received bv Mail Personnel responsible for distribution of mail will forward cor-respondence that appears to contain an allegation to the OAC.
Both letters and envelopes will be forwarded and no copies will be made.
An employee who receives direct correspondence, including internal NRC memoranda, that contains allegations shall forward the correspondence to the OAC.
All,, personnel who may come into possession of this type of correspondence also should' be made aware that correspondence con-taining confidential source information should be transmitted in a sealed envelope marked "To Be Opened by Addressee Only;" for expedited transmittals (e.g.,
electronically), confidential source information should be deleted from correspondence.
4 3.
Discussions with Allecer i
Any employee receiving a telephone call or visit, as discussed in i
item 1, shall attempt to obtain as much information as possible from the individual.
It is crucial to identify:
a.
full na'me b.
complete mailing address telephone number where the individual may be contacted,
c.
d.
position or relationship-t'o facility or activity involved L
e.
nature of allegation If the alleger declines to provide the above information, attempt to establish the reason (s) using the following guidance:
Inform the individual that if so requested, his/her identity will be kept confidential.
Explain further, if necessary, that Public Law 95-601 ' affords protection to the a11eger by-pychibiting an employer.
from discriminating against an empl6yee for contacting the NRC, Bacic Requirement 054 provides further information regarding protection of confidentiality.
S The alleger may be informed that the NRC erployee with whom he/she is in contact does not have the capability to evaluate the infomation, to determine follow up action, or to establish NRC jurisdiction;
-therefore, it may be necessary that someone else contact the a11eger for additional information.
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'The alleger sh'oul'd be informed also~, thit--unless an objection is registered--he/she will be recontacted as soon as possible regarding W
the allegation.
This may bie dona by telephone, personal visit, or by a letter to the alleger, at an address designated, which will also e
acknowledge the receiot *'ef' the 1rlTegation.
This prccess will permit the alleger to review the information with the NRC to provide maximum assurance that the information has been correctly interpreted and understood.
Al-3 Approved:
F.
,4?C CSD AP"EM l( l HANAGEMENT OF ALLEGATIONS If the alleger persists in not offering identification after the above explanations, document the allegation in as much detail as possible and advise the alleger that he/she may contact the OAC or designated staff in 30 days or any other agreed upon period, for infomation on me nbe r the status of any actions being taken on the infomation supplied.
For allegations of-discrimination that fall under Section 210(a) of the Energy Reorganization Act, inform the allegers that NRC will look into the complaint and any safety concerns identified ty the alleger, and that appropriate enforcement actions will be taken against the employer if the allegation is substantiated.
To assure personal employee rights are protected, advise the alleger that the complaint must be filed with 00L within 30 days of the occurrence of the discrimination event.
Part IV:
Action by the Receivino Emolovee and the Of fice Allecation Coorcinator (OAC)
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1.
When an allegation concerning a NRC-regulated activity is received, the employee receiving.the allegation will provide the information obtained i
to the Receiving Office OAC who will complete an NRC Form 307, Alle-gation Data Form.
The Action Office is then identified and the completed form is forwarded to ' the Action Office OAC.
Until ' direct input / update capability is provided to the Regions and Offices, a copy of the completed form will be forwarded to the NRR OAC, and.one copy to the NMSS OAC, if appropriate for the issue.
NRC Form 307 serves a~s notification to NP.SS and NRR 'that an allegation has been received that may affect their licensing activity; NRR will enter the pertinent information in the AMS in accordance 'with these procedures.
All allegations must be entered into the AMS.
In this way an " audit trail" will be established so that NRC actions can be properly monitored and completed.
~
2.
The Action Office OAC or 'other designated staff member 'will itnsure that the alleger is properly contacted to acknowledge receipt of the allegation and to confirm the specifics of the allegation.
Depending 4
on the nature of an allegation, the OAC will provide copies of the allegation documentation and the letter sent to the. alleger (with the alleger's identity and identifying information concealed) to the cognizant technical staff supervisor for evaluation and initiation of action.
Such copies also will be forwarded to O! Headquarters or to the cognizant 01. Field 0ffice for information.
'When responsibility
~
for the handling _of an allegation is transferred from one organizational unit m-to another, the alleger should be notified of the new point of (name and telephone number) by the individual who is relieved contact in order to assure cont.inugy.
A single point of contact 2
as contact should be "the rule.
T The OAC will follow up on the allegation with the cognizant technical staff supervisor at periodic intervals until the matter has been satisfactorily resolved.
When the case is closed, an update should be made to that effect in the AMS.
i Annenved-al-a
WANAGEW.ENT OF ALLEGATIONS APPENDIX 1. O ;.. 7 3.
The OAC will coordinate allegation info mation with the technical staff and may assist in determining whether the information is suf fi-cient to identify the issues.
If the information is determined to be insufficient, the OAC or designated staff member will assist in i
further contact with the alleger.
A single point of contact with an alleger provides a means of better controlling communications, aids in developing rapport, establishes continuity in the flow of information between the Regions and other, NRC Offices, and aids in protection of the alleger's identity.
4.
The OAC assists the cognizant technical staff in identifying and separating the issues involved in an allegation into one of the follow-ing categories:
a.
Allegations that involve purely technical
- matters, such as:*
inadequacies in procedures, qualifications, or training; inade-quate implementation. of actions; or overexposure (s) procedures; or inadequate corrective to radiation.
b.
Allegat. ions that involve wrongdoing sucn as:
record falsifi-cation; willful or deliberate violations; material false state-ments; discrimination under Section
- 210(a) of the Energy Reorganization Act; or oth,er improper condJct.
~
c.
Allegations that involve matters outside the jurisdict, ion of MRC.
l 5.
Technical issues in category 4a involving failure to meet requirements have the potential for being willful or deliberate violations.
- However, in the absence of specific allegations of wi11 fulness or deliberateness, such issues will normally be tracked separately as technical issues and resolved using program resources.
If an allegation covers issues that affect other Regions or Offices, fo,11ow-up activities.will be coordin-ated with the affected Offices and a toad Office will be designated. The OAC will contact the affected Offices which should result in a mutual agreement as to which Office or Region should have the lead.
If agree-ment cannot be reached at the OAC level, then the Regional Adminis-trators or Office Directors will resolve which Office or Region should take the lead.
6.
Allegations in category 4b, should be referred to OI Field or Head quarters personnel except for those involving NRC employees or NRC contractors.
7.
When applicable and after coordination, the Action Office should notify other agencies such
.n the Occupational Safety and Health Administration, DOE, etc.
in dealing with allegations in category 4c.
Notification to 'oth'er FfderIT'- l aw enforcement agencies and State and local jurisdictions of possible criminality involved in allegations should be handled by the appropriate OI Office or the Office of Inspector -and Auditor (for matters falling within its purview only.)
Al-5 ar.nenve+
b
E DE" ADDENDfX 1
_ ANAGEMENT OF ALLEGCN The OAC ensures that a discrimination complainant under Section 210(a) 8.
of the Energy Reorganization Act is properly referred to DOL (tne complaint must be filed with DOL within 30 days of its occurrence),
and that DOL is promptly notified of the complaint.
Complaints shouic be filed with the Office of the Administrator, Wage and Hour Division, Employment Standards Administration, U.
S.
Department of Labor, Room 53502, 200 Constitution Aven'ue, N.
W., Washingt_on, D.
C.
20210.
The.
'tegional Administrator or Office Director should be promptly informed.
The ' OAC also ma-intains awareness of DOL's investigative intent, and ensures NRC consideration of the need for its own investigation by timely referral to DI.
The OAC will take reasonable steps to facilitate DOL's investigation by assisting DOL in obtaining access to licensed facilities and any necessary security clearances.
This type of allegation should also be entered into the AMS.
9.
If an allegation is determined to have generic implications, other Offices and/or Regions with responsibilities that may be affected will be appropriately notified by the Action Office (e.g., AEOD for opera-tional data, RES for concerns affecting research acti viti e's, etc.)
10.
Inforniation regarding suspected improper conduct by NRC employees and NRC contractors will be brought to the attention of appropriate management for possible referral to the Office of Inspector and Auditor (OIA).
Part V:
Documentino A11ecations 1.
When an allegation is received and the action office identified, a-working file should be established to contain all related documentation.
concerning the allegation, including all correspondence, memorandum to files, interviews, and summaries of telephone conversations, discus-sions, and meetings.
This file shall be maintained in the official files of the Action Office-in itn officia1Ty designated-location.
To ensure proper evaluation, full and complete information should be documented about each allegation.
In addition to obtaining basic information, attempts should be made to expand and clarify the information so that the issue is well defined.
All allegations, regardless of source or how received, must be documented.
Records or files containing the name of a confidential source or other identifying information (i.e. a confidentiality agreement has been executed) should be stamped "This material contains confidential source information."
- /.
2.
There will be ' occasions when the al-legations obviously have no sub-stance and appear to represent a distortion of facts.
However, even in these cases, documentation is necessary that identifies the con-tact, the general content of any communications, and 'the basis for a conclusion that the matter need. act..be pursued.
Instances such as
+
these will be coordinated with the appropriate technical staff by the OAC to ensure proper dispos'ition.
3.
The importance of obtaining and ' documenting all pertinent information about an allegation cannot be overemphasized.
Evaluation and screen-ing of the allegation, as well as the proposed course of action that will be adopted to resolve the issue will be based primarily on this information.
In some cases', a person,al interview with the Approved:
Al-6 F
..e
KA W E W OF ALLEGATION!
ADDENC:X 1. NRC 0517 4
alleger may be warranted.
In 4these cases, the OAC will consult with NRC management to determine thel best way to obtain the details re-quired.
Depending on the nature of the allegation and the ~ time sensi-tivity, assistence from the Office, of Investigations (OI) or other resources may be requested.
s 1
4.
As soorg 'as, possible after receiving an allegation or becoming aware of information that indicates inadequate or improper activities, the person receiving "the allegation shall notify the OAC.
Normally, no action will be taken-to verify the validity of the allegations, nor shall such matters be discussed with licensees, if necessary, until after the OAC or. designated staff member has briefed appropriate NRC management.
5.
The OAC or other designated staff member is responsible,for reviewing all information received in, conjunction with an allegation and for ensuring that management and cognizant technical staff members are fully informed.
~ '
6.
Allegations normally should not be ' addressed in Preliminary Notifica-tions ~(PNs) or Daily Reports (DRs); however, if it is determined that PN or DR entries are appropriate, the approval of an Office Director or a Regional Administrator should be obtained.
7.
If allegation documents' must be sent to other NRC personnel, they should be appropriately handled to protect the identity of the confide'ntial alleger.
The confidential alleger'.s identity or other identifying information should not be released unless there is a "need to know" (See Basic Requirement 054).
Part VI:
Evaluation by Cconizant Technical Staff 1.
When an allegation package is received, the tachnical ~ staff within the' Office or. Region will review the documentation to determine if there is a safety concern that requires immediate action.
The technical staff is responsible for development, initiation, and follow-through on corrective actions.
Allegations
- or documents containing a sub-stantial number of allegations once entered in the AMS can be screened using the following criteria:
a.
Is there an issnediate safety concern which must' be quickly addressed?
3.-
Is the allegation a specific safety or' quality issue or a gener-b.
LG.
alized concern?
e.
c.
Has the staff previoias.ly addressad..this issue?
d.
Determine whether the. allegation package contains sufficient information for a thorough evaluation.
If it does not, identify
'the additional info'rmation tha't is needed.
f Al-7 Approved:
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N R C.
JENDIX 1 HANAGEMENT OF ALLEGATION!
e.
Determine whett.e r all aspects 'of the allegation are adequate _ly defined and described to pemit or require a meaningful and exten-sive evaluation.
This is a screening process that may result in a decision not to consider the allegation further.
If the latter is the decided course of action, the alleger should be so informed in
~
a courteous and diplomatic manner along with the rationale for not -
considering it further.
The potential for adverse publicity must be recognized when taking this action.
f.
Determine whether the identity of the. alleger is necessary for a thorough evaluation.
Determine what' specific issues are involved in the allegation and g.
whether the issues can be adequately addressed by a technical inspection.
h.
Determine if the allegation can be examined and resolved during a routine, scheduled inspection.
If this is not possible, deter-mine the best way to address the issues.
~
i.
Determihe whether licensee / vendor resources can reasonably be used in resolving the allegation to conserve staff resources.
Consider potential problems associated with " turning the issue over to the licensee."
j.
Detemine whether the allegation has the potential ~ to require escalated enforcement action.
k.
Determine the time sensitivity of the allegation, and what immed-inte actions are necessary.
1.
Detemine whether investigative assistance will be needed.
Identify peripheral issues that could develop.
m.
Consider if any licensing actions or board proceedings are pending n.
which could be influenced or affected by the allegation.
When an allegation involves a case pending before a licensing or ' appeal board or the Commission, information concerning it should be provided ~to NRR or NMSS as soon as possible to assist in the detemination of whether or not a board notification should be made.
Thi,s decision must be made promptly 'by NRR or NMSS in
" 1.
accordance with offite Troceduras.' -
M Determine if other NRC-Offices that may have an interest should o.
be notified.
p.
As soon as possible af ter the receipt of an allegation and the relevant infomation has been reviewed end evaluated, the Action Office will make a preliminary determination of the safety signi-ficance of the item and the need for immediate regulatory action.
This determination will be reported in the next AMS update.
Approved:
Al-B g
h 1
r.
~~
MANAGEME C OF ALLEG.ATIONS APPENM X 1. NRC 0517 q.
Establish a schedule for the resolution of each allegation which is consi:; tent with the licensing schedule, if applicable.
Notify the OAC or designated staff member when the status changes r.
er action (s) is complete.
2.
It is the responsibility of the technical staff within the Office or Region to resolve each allegation that falls under its jurisdiction,
.and subsequently,,to notify the OAC or designated staff member of the action taken so that the status of each allegation can be tracked to closecut.
Final resolution of an allegation shall be documented and placed in the working file along with all supporting documentation.
The final report should state the facts clearly, in a style that does not belittle or disparage the alleger.
3.
For those allegations resulting in the need for corrective action, the
~
affected organization (s) shall be properly informed.
Part VII:
A11ecation Resolution Documentation
- ~
~
1.
A11egation resolution documentation officially closes the file for that case and shall be placed in the working file which new becomes a closed case file.
Closed case files shall be retired to inactive storage through the Document
- Management Branch, TIDC, and destroyed y
according to the Comprehensive Records Disposition Schedule (HUREG-0910).
Appropriate documents, including those necessary for an individual to understand the incoming-allegation and its resolution, shall be placed in the NRC records system (PDR, LPDR, Docket File, Subject File, DCS) and must be treated to protect the -identity of the alleger.
2.
A final report should be prepared that sets forth the facts about the allegation and its resolution clearly and conclusively.~ The final re-port can be a memorandum for a relatively minor matter, an investiga-tion / inspection report, or a technical paper for a complex or major generic matter.
It can be an SER supplement for multiple allegations proximate to OL issuance.
It should not contain the name of, or material that could be used to identify, the alleger (See Basic Requirement 054).
3.
The final report should include a summary of the concern, a 'descrip-tion of the evaluation. performed and the conclusions drawn.
It should be written in a style that 'does not bilittTe or disparage the alleger.
4.
Appropriate entries should be made in the AMS to close cut the allega-tion.
5.
When the final report has been approved (i.e., the case is closed), all allegation documentation is subject to release under the FOIA with appropriate precautions.to protect confidentiality.
Until that time,
'all allegation documentation is exempt from release under the FOIA in
^
accordance with 10 CFR 9.5 Exemption (7) due to actual, or the potential for, law enforcement action.
File documents, however, are frozen by the FOIA request for release when the case is closed should a subsequent FOIA request be received.
Al-9 Approved:
G.
N 1 ZU ANENOD 1 KANAGEMEVT OF ALLEGATIONE Part VIII:
Dissemination of Final Report 1.
A copy of the final report shall be sent to the alleger and, if appro-priate, to the affected outside organization (s).
A transmittal letter may be needed to summarize the matter.
in Part VII.1 above, copies of the final report shall be placed in 2.
As the NRC records system, and should be treated so as not to reveal the identity of the alleger.
3.
The foregoing does not apply to 01 investigative reports.
PART IX:
ALLEGATION MANAGEMENT SYSTEM 1.
General
~
For purposes of the Allegation Management System (AMS) the defini-a.
tion provided for an allegation is very general and broad.
The i
significance or,'nonsignificance of an allegation will be judged during the Action Office review and follow-up activities.
There is to be no screening of a,llegations for possible deletion prior to entering them into the. system (except of course for duplication
.of entries).
The AMS should provide a vehicle' for collecting, storing and retrieving all key information regarding.all alltga-tions.
The Action Office determines the necessary action to be taken based upon the specifics of tTie case.
Some allegations may be received and closed out the same day.
b.
The AMS. provides ' basic descriptive and status information and serves as a referral system.
It identifies the office and staff I
to contact for more specifics..on an allegation..Additi,onally, it keeps the staff informed as to how the allegation was resolved and provides reference to the close out documentation.
c.
When an allegation is received, ' it is not necessary to identify by separate entry into the AMS every component or. subset of the allegation.
For example, if an allegation is received that con-sists of 15 separate concerns of wrongdoing and technical defi-ciencies, the allegation may be entered as one allegation. However, the description of the allegation should include the number of separate concerns. and.their subject.ar.ea.
In'some cases there may be a distinct grouping of concerns, for example, in two areas such-as training and quali.ty assurance.
In such a case it may be j
appropriate to enter two allegations.
A main objective is to ensure that the receipt of an. allegation is entered and tracked in
~
i the system.
An alTegation '~is7Et" completed and closed until an Action Office supervisor determines that appropriate action has been taken.
I i
Accreved:
Al-10
HANAGP.ENT OF ALLEGATIONS AP M C IX 1. NRC 05'7 d.
Sensitive infomation such as the names of persons making allega-tions shall not be entered in the system.
All information entere::
t on the form shall be unclassified and shall not contain any safe-guards information or any proprietary or commercial (2.790) infor-nation.
Some allegations may require action by two or more offices.
For l
e.
purposes of entering the. allegation into the AMS either separate entries should be made for each Action Office for their assigned action or one entry may be made with the involved DACs agreeing on the lead Action Office for followup of. the allegation.
If another Office is involved in responding to an allegation, it
~
should be so indicated in the " remarks" section.
2.
Interfaces with the Office of Investications The Office of Investigations has jurisdication over all allegations a.
of wrongdoing except those involving NRC employees or NRC contractors and.will forward all allegations of a technical nature
]
ta the. appropriate Office or Region.
The Office or Region will be responsible for entering all allegations-even those unoer tN purview of 01--into the AMS using a Region or Office AMS number.
b.
For those allegations o'f wrongdoing, except those involving NRC employees or NRC ' contractors, assigned to the Region. or. 0ffice:
~
(1) The Region or Office OAC will coordinate with the OI Field Director or 01 Headquarters representative to determine if sensitive information is included which should not be placed into the AMS.
All sensitive information is to be deleted and the word " sensitive" put in its place.
However an attempt should be made to provide. descriptih-material to assist the AMS user to the maximum extent possible.
(2) The Region or Office OAC will assign a Region or Office AMS number.
The OI assigned number should be entered. in the AMS as a cross reference.
(3) The name and phone number of the OI Field Director or OI Headquarters representative will be placed in the appropriate section of the form as the Action Office contact.
u (4) The OI Field Director will keep the Region or Office OAC L
apprised of the status of the allegation investigation and provide timely information necessary to determine the safety significance.o.f.,the. _alJe_ga, tion to appropriate Regional or.
Office management and for use in updating the AMS.
64 i<
e e
o c." 0517, APPEF.I7 1 6%NAGEMENT 3 A LEGATIONS 1
(5)
The allegation will be considered closed when the. investiga-tion report has been issued and as long as no technical issues.
remain.
If technical issues or an investigation remain, the allegation remains-open, reference is made to the technical report or OI investigation report if either is complete, and a schedule for resolution of the allegation is placed in the Allegation Data Form or in the AMS update.
For allegations of' wrongdoing received by DI, the OI Headquarters c.
or Field Director will coordinate with the respective Office or Region DAC to complete the items 2.b(1) through (5), above.
. d.
For allegations of a t'echnical nature received by 01, the OI Head-quarters or Field Director will contact the respective Office or Region and follow the procedures as indicated in item 3 below for the Receiving Office.
3.
Receiving Office
~
Upon receipt of an allegation involving an NRC-regulated activity, the person receiving the allegation will provide the information rela-tive to the allegation (see Exhibit 1) to the OAC who will initiate steps required to identify the Action Office and to enter the alle-gation into the AMS.
The Receiving Office OAC should, in addition to determining' the appro-priate Action Office, coordinate with the Action Office, and receive concurrence from the Action Office before transfer of responsibility.
4.
Action Office.
The Action Office shall :
Complete that portion of the Allegation -Data Form marked " Action a.
Office," assign an allegation riumber to it7 and f6tward a copy of
~
the form to the NRR DAC for entry into the AMS, and to the NMSS OAC, if appropriate, within 10 working days of the date of receipt of the allegation for information.
b.
Provide AMS updates to the NRR OAC on a monthly basis by indicating updates on the previous month's status report.
Updates are due to NRR by the 25th of each month.
All input to NRR for the AMS should be sent in " addressee only" envelopes to, " Allegation Management System, Mail Stop 528.
Completior. of the follow up action for 'an' allegation will be recorded 'by updating the monthly status report.
Name and telephone of Office or Regional' Allega-
~M tion Coordinators will-be indicated at the top of the update sheets; any changes in the designation of OACs will be made here.
As soon as possible af ter the receipt of an allegation and relevant c.
information has been reviewed and evaluated, make a preliminary detemination of safety significance and the need for any regu-latory action.
This determination will be reported in the next AMS update.
Approved:
Al-12 b
i
MJ M GEMEN'T OF AL. _.
APDENDIX 1. NRC 0517 3
d.
Schedule the resolution of each allegation to be consistent with the licensing schedule and the safety significance of. the alle-gation.
e.
Make a determination regarding the need for a board notification to'HRR or HMSS.
If the initial board notification is preliminary in nature, a follow up notification is sent to boards when evaluation is completed, or whenever significant relevant informa-tion is identified ~during the course.of evaluating the allegation.
This detennination should be made as soon as possible in accordance with the Action Office board notification procedures.
. f.
Develop and maintain a working file for each allegation, which will
~
contain all related documentation.
For those allegations comprised of multiple concerns, separate working files may need, to be estab-lished for each concern.
Provide status information to the NRR OAC for the AMS regarding g.
items c-f, above.
h.
Thirty days prior to the construction completion date (appli-cant's estimate) for each pending OL, each Action Office will forward to the Division of. Licensing /NRR, an evaluation of the.
safety significance of. 'all allegations not scheduled to be resolved before the construction completion date, 'with a raram-mendation as to whether any or all of them constitute grounds for delaying issuance of (or otherwise restricting) an operating
~
license.
i Thirty days -prior to a Commission decision on' authorizing full-power operation, a
report similar to item h above, will be prepared.
~
f.
Ensure protection of the identity of all allegers when confiden-tiality is requested or implied by their actions.
5.
NRR OAC Upon receipt of. an Allegation Data Fom and updates, the NRR OAC a.
will perform a quality check and will transmit the information to the Office of Resource Management (RM) for input. into the AMS.
This procedure will be modified when direct input or update capability "to' the' AMS can be-obtained ' for Offices and Regions.
M b.
NRR will coordinate with RM to provide Offices and Regions monthly
{
status reports curing the first week of each month.
The monthly k--
report will includeda. list.at allsopen allegations and a list of those allegations closed during the last 30 days.
The format for the status report is provided (Exhibit 3).
Al-13 Approved:
i"'
s
.. ~.
~
- INT OF ALLEGAT:; :
EXHIS:
NRC Fom 307 ALLEGATION DATA FORM 1.
ALLEGATION NUMBER:
-A-a 2.
FACILITY:
Name Unit No.
Docket No.
a.
b.
c.
3.
TYPE OF REGULATED ACTIVITY:
C a. Reactor Ob. Vendor O c. Materials O e. Safeguards O e. Other 4.
MATERIALS LICENSE NUMBER:
5.
FUNCTIONAL AREA (s):
O a. Operations-O b. Construction O c. Safeguards
- d. Transportation O e. Energency preparedness 3
- f. Onsite health and safety O g. Offsite health'and safety
- h. Other E
6.
DESCRIPTION:
2 Eg 7.
hUttiER OF CONEtRh5:
8.
SOURCE:-
O a. Contractor employee O b. Licensee employee O c. NRC employee O d. Forner employee O e. News media C f. Private citi.ttn
'O g. Organization O i, Anonymous O h. Other 9.
CONFIDENTIALITY REQuisiLD:
O Yes O he
~
- 10. DATE ALLEGATION RECEIVED:
/ /
~
U
- 11. EMPLOYEE /0FFICE RECEIVING ATCEUATTON:
a
- 12. ACTION OFFICE CONTACT / PHONE:
- 13. SAFETY SIGNIFICANCE:
O High O Macium O Low Q None
- 14. BOARD NOTIFICATION REC 0 MENDED: O Yes O No
- 15. OI NOTIFIED:
O Yes O No
- 16. STATUS:
0 0 pen O Closed Scheduled Completion Date: _/_/_
Date Closed:
/ /
- 17. WAS' ALLEGATION It23T RTIATED:
O Yes O No O Partially
- 18. WAS ENFORCEMENT ACTION TAKEN: O Yes' O No OIn Process 3
SEVERITY LEVEL:
- 19. WAS O! INVESTIGATION PERFORMED: O Yes ~ O No O In Process e
O Yes O No C 50.54(f) Q 30.32(d) 070.22(d ) Q 40.31(b)
'c Disposition:
- 21. ALLEGER NOTIFIED OF LLost.DUT:
0 tes O ho -
- 22. REMARKS:
~
W T
- 23. CRD55 RLriREhCE:
- 24. PROJECT MANAGER /PH T :
,5
- 25. APPLIGANT'S CONSIL%i10N COMPLt..UOh DAit:
/ /
w
~
E
- 26. BOARD NOTIFICATION ISSUED: ' D Yes " O Yo' ~ -
E 1
El-1 Approved:
C f3
, O.kE;7, i[kHISIT 1 W - W OF ALLE W.
INSTRUCT 10N3 1.
Allegation Muncer Action Office fill in the boxes to uniquely iden-tify this allegation OFFICE official NRC office abbreviation for the Office responsible for followup activities.
YEAR last two digits of the calendar year in which the allegation was reported to NRC.
A identifies this numer as an allegation numer.
NWSER sequential numer assigned by the Office or Region responsible for the followup activities.
T.XAMPLE The 24th allegation received by IE in 1982 would be shown as IE-82-A-0024 2.
Facility (ies)
Give the name of the facility (ies) or company ('ies,)
Involved about whom the allegation is made. - Write the docket nueer, if appropriate, in the spaces to
~
the right. If the allegation is made about a specific individual or if the information in this item is otherwise sensitive, write SENSITIVE.. If more than three facilities or companies are in-volved write GENERIC.
6.
Description Briefly describe the allegation (1 or 2 senter.ces).
Be concise. If an allegation includes several in- -
stances of technical deficiencies or wrongdoing.
list the assertions separately or group them by type.
NOTE: If the description of the allegation is i
sensitive, write only SENSITIVE.
7.
Neer of Write the totsi numer of concerns given in the Concerns allegation. Note that each Office or Region may need to establish a working file for each concern.
8.
Source Check the box that sest cl arly describes the 3
affiliation. DO NOT include the name of the indi-vidual making the allegation.
9.
C nfidentiality Indicate whether confidentiality has specifically Requested been requested.
- 13. Safety Provide an estimate of the safety signif.icance of Significance allegation Example (a) Check *high" for ana-11eged deft-ciency in an operating plant that could have an isnedtate and great effect on public health and safety (b) Check " Low" for an alleged deficiency in a plant under construction that would have a minor effect on public health and safety
- 20. Did Disposition Check appropriate box (es) and briefly describe Result in Letter method of disposition (e.g., letter, technical to Modify or report, inspection report, SER, etc.) and identify Revoke License
, document.
- 22. Remarts Include' additional infdrmation as appropriate.
EXAMPLES: list oth>r allegations related to this allegation; list other NRC offices responsible for followup activities on this allegation.
_.I
- 23. Leoss Reference Identif.y.other _re_ lated allegations and investiga-tions ay al::ha-nJter1c 6signation.
- 25. Applie:.nt's
. For plants under construction, enter the appli-l Cor.:tn.ction rant'r estiantec construction completion date; Completion Date tic *r is no need to previde this information until 3 or 2 months prior to the estimated date.
- 26. Board hotification Indicate whether a board nctification was issued.
1 Issued Approved:
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LISI 0F ALL ALLEGATIONS
.~
v FACILITY NAME ALLESA119ti_H18tl.liR COMTACI f_1LfjipHg IIAln ISISCO FIRE SEALSI NRIII-83-A-0029
' W GUL DEMOND 388-5608 OPEN AMfRICAN TESTING LABS OIR4-85-A-0041 RK NfRR 728-8130 OPEN l
AMERICAN ILSIING LASS RIV-83-A-0023 IF WE5fERMAN 728-5100 CLOSED AMER 511AM CORP RII-84-A-0026 B URYC 242-4513 OPEN ARRAM545 IL2 RIV-84-A-0001 IF WESTERMAN 728-8800 GPEN ARKANSAS lE2 RIV-St-A-Stil TF WESTERMAN 728-8800 OPEN.
ARNED FORCES RADISBIOLOGY RES INST
-RI-83-A-0081 JD KINNEMAN 408-1252 OPEN ARN0/DAP CORP. MICNIGAN CITY. IN NRIII-84-A-0083 DJ 5REMIAW5KI 388-5611 CLOSED ATLANTIC CITY MEDICAL CEMIER RI-84-A-0024 JE GLENN 408-1260 CLOSED AILAMIIC NUCLEAR SERVICES
'RII-83-A-0807
.GA 1000 242-4813 CLOSED AUGURN STEEL MILL RII-83-A-0015 GA 1000 242-4893 CLOSED
' O.
8 BANN50M; INC.
RII-84-A-0049 8 URYC 242-4193 CLOSED BARCLAY-INT (RNATIONAL RIV-83-A-0082 IF WESTERMAN 728-0100 OPEN BASIC ENGINEERS NATIONAL VALVE, FA WIE-84-A-0003 EW MER5CNOFF 492-4572 OPEN E3 BAYIDWN-INDU5T X-RAY CONSI CS RII-83-A-002)***)
GA 100D 242-4193 CLOSED e
DEAVER VALLEY 1 RI-83-A-0074l LE 1RIPP 488-1227 Ct05ED BEAVER MALLEY I RI-83-A-0080 LE 1RIPP 484-1227 CLO5ED 4
DEAVER WALLEY l RI-83-A-0084 LE TRIPP 404-1227 Ct0$LD
]
BEAVER ALLEY l*
3 RI-84-A-0006 LE TRIPP 488-1227 CLO5ED t
BEAVER AL L EY l RI-84-A-0007 LE TRIPP 488-1227 OPEN' BE AVER.WAL L EY 2
- RI-83-A-0088 IE 1RIPP 488-1227 OPEN BE AVER W ALLEY 2 RI-84-A-0009 LE IRIPP 488-1227 OPEN BEAVER VALLEY 2:
RI-84-A 0043 LE TRIPP 488-1358 OPEN J
BECNIEL 4
R IV-8 3-A-08 3 N 8 *)
IF WESTERMAN 728-8100 CLO5ED BEttEFONTE I RII-83-A-0039 GA TODD 242-4893 CLO5fD L
BELLETONIE 1 e
RII-83-A-0040 GA 1000 242-4193 Ct05LD i
i SEttEFONTE I RII-83-A-0090 GA TODD 242-4193 CLOSED
]7 BELLEFONTE 1 I
RII-83-A-Ol22 8 URYC 242-4193 OPEN 13 BEttEFONIE I RII-83-A-Sl23 8 URYC 242-4113 OPLN 1
y DEtLEFON1E I Ril-84-A-000I B URYC 242-4193 OrtN BELLEFONtE I RII-84-A-0009 GA 10D0 242-4113 OPEN DEL L EFONIE l RII-84-A-0036 JS LAMRFORD 242-4894 OPEN fI DEttEFONIE I RII-84-A-0052 J5 LANKFORD 242-4194 CLO5ED in l
DEST INDU$iRIES INC. ARLINGTON VA RII-84-A-0027 A TILLMAN 242-5693 CLOSED
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4 BEINE5DA IIOSP. CINCINNATI. Ollie RIII-83-A-0078 DJ SRENIAWSKI 388-5611 CLOSFD l
BIG ROCK POINT RIII-83-A-5067 LR,GREGER 388-5644 C t 0 5 '. D h
l BEK NASTE DUMP. W. COVINA. CA RW-84-A-0048 RD THOMA5 463-3763 Closed i
8086 WARMER RIV-83-A-0029 TF. WESTERMAN 728-8800 OPEN 2
l BORIDE PRODUCIS INC RIV-83-A-0060 RK llERR 728-8830 OPEN.
[
30 VARI ELECIRIC INC OIR4-85-A-0077 RK NERR 728-8110 OPEN t
BPS INSTRUMEHIS INC. EVAN5 VILL. IN RIII-84-A-Og30 DJ SRENIAW5KI 388-5688 Clos [D l}
BRAIDWOOD l NRIII A-Os t(**)
WS LIITLE 388-5578 OPEN e-
,",, nut ilPt E F ACIFTTTLEASSOCIAEDWi1NINs5AttEGATIONNUNGER
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TECHNICAL REVIEW TEAM GUIDANCE JUNE 1984 Prepared By: T 4.1 4/5/ge.
R. H. Wessman Approved By:, h s M j
/,4 T. A. fpDolito, Project Director 6
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,i TECHNICAL EEVIEW TEAM GU:DA' E
I.
Introduction Actions, was approved by R. DeYoung, H. Denton egulatory June 5.-1984
-(TRT) has been formed to evaluate and resolv and J. Collins on allegations presently identified.
these charts are included with this guidance as ments 1 and 2).
to the five technical-issue groupings.The TRT will b corres These grou,ps are:ponding Electrical The groups / Instrumentation, Civil / Mechanical, Coatings QA/QC, will be comprised of a group leader and reviewers that specialists in the particular technical area. The staffing of th groups will be drawn from the various NRC offices and se as arranged between the Project Director and line mana/or contractors, may be called together for a specified period of time gement. The TRT in part as needed to complete resolution of like
, dispersed back e
n whole or be under the direct supervision of the Project Director The TRT will The guidance contained herein will address the following:
Method and approach for identification and disposition of allegations
_ Allegations Tracking SystemPreparation of Documentatio Protection of Individuals Initiation of Special NRC actions, such as confinnation of action letters or 50.54(f) letters Manpower accounting for. TRT members II.
Technical Review Team Method and Acoroach The Technical Review Team method and approach to resolutio technical issues and alle to Technical Review Team"gations is described in the detailed " Instructions n closecut of which is provided as Attachment 3.
be mostly concerned with the resolution /closecut of appro i The TRT will allegations that are assigned to the TRT.
x mately 300 expected to understand and implement these instructions.Each member of When possible, the team activities will be pla a at least partial approach should result in the most efficient use of inspection re This For example, in resolving and closing out a specific allegati be possible to also close or partia19 es,-
on, it may a separate (but related) categoryr such as, IEB closecut, room inspection, routine preoperational program inspection mod l this mode of ' peration will contribute to the completion of th o
u e, etc.
While inspection program, it is not envisioned that Region IV's res e routine to complete the routine inspection program will be significa tl ource needs n y reduced.
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!!. Decume-tat en and Records An individual reccrd file (work package) shall be developed and for each open issue or group of like issues.
maintained by Region IV and will be maintained and used by the TRTThe files have be contain or reference pertinent documentation associated with the Each file will issue.
Resolution of each issue shall be supported with a clearly record trail.
Accordingly, the record file shall contain or make referen to all significant records relied upon to reach resolution Records of personnel interviews shall be developed and retained those instances where interviews are relied upon by the NRC st ff decisions of technical adequacy.
a or the date, time, location of the interview; the name of contain:
interviewer and interviewee; and a surunary of questions asked and
' relevant infomation obtained.
Uponissuanceofreports(suchasSSER'sorInspectionReporti close out open issues, those records which are appropriately re which (e.g., meeting transcripts, permanent applicant rec removed from the record file as approved by project management, etc.)
They must be self-explanatory. Files must be maintained in a Upon completion of the TRT effort, the files will be transferred to the appropriate line office for retenti (e.g., allegations files will be transferred to Region IV allegation on es).
IV. Trackino Scheme
~
All Comanche Peak allegations are to be identified and listed sunnary tracking sheets, as shown in Attachment 4.
ons primari'y concerned with allegations, it may. resolve other open tec Although the TRT is issues, which are sunwarized on tracking sheets shown as Attachm Open issues may come from (but are not necessarily limited areas:
allegations hearing items licensing items inspection modules that are incomplete inspection open items (non-compliances, unresolved items, etc )
SER followup items Part 21 or 50.55(e) items investigative issues A fundamental part of the listing development is t'he estimate of resources reqvfred and the schedule for completion of each group of similar items.
The allegations tracking system will be maintained on the 5520 word processer. Status of individual allegations will be updated biweekly b the Project Director's staff.
e t:
t-
r discipline codes are assigned.to each items as
, numbering and XQY - Z X
Corresponds to the Task Code (Allegations, Hearing issues Q
Identifies those particular issues that are QA/QC related
,etc.)
irregardless of the discipline.
Y Corresponds to a sequential number. Corresponds to a Z
,etc.)
The sequence of numbering starts over with code.
ne V,
gotectionofIndividuals The identity of persons providing allegations to the NRC shali disclosed as expressly req.a matter of practice.
uesting confidentiality, all efforts shall be made toIn o
e protect the individual's identity.
an anonymous relationship with segments of the NRC will also considered.
This will i.nclude:
of allegation documentation and correspondence; minimal identifying titles, or position descriptions in written material; enlarged sampling of activities so that is is not evident to perso alleger; and other indirect approaches toward of a' legations.
During the course of NRC.reriews or inspection similar efforts shall be made to protect the identity of license,e or contractor employees who provide infomation which ma being critical of licensee or contractor activities. y be construed as All interviews of allegers will be conducted by the TRT and/or 01 appropriate.
Director) will coordinate alleger interviews involving
, as personnel.
He will assure that technical issues are identified an passed to the TRT for resolution.
VI. Special NRC Actions As part of the allegation review effort, it may be appropriate to initiate a followup. ctions which are not routinely required for technical issue These may include:
issuing requests for information to the licensee under 10 CFR 50.54(f), Confimation of Action letter o or requests' to the Department of Justice to grant ininunity for certain individuals the concurre. Actions such as these, if required, shall be handled with
~
NRC procedures,nce of the Project Director and in accordance with establis u
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V?2. MenDower Accountine Offices shall implement established manpower accounting syst monitor resource expenditures related to this activity for all manpower expenditures, both technical an i
The new and account the Comanche Peak TRT effort.
, expended on management reporting.to all task force members to ensure a meaningful l
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3 TECllNICAL REVIEW TEAll (TRT)
Project Hanager T.A. Ippolito Ass ' tant n er ace s
R. Wessman (HRR)
.J. Gagliardo (IE) (Tentative)
R.C. Tang (NRR) t.lec t rica l/
Ins'trumentation Civil /Hechanical qA/QC Coatings Test Programs
~
I.eader Leader Leader Lead r Leader J. Calvo (NRR)
L. Shao (RES)
T. Con![RII R. Keimig (RI) 1(g i
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- Technical Issues
- Technical Issues
- Programmatic f
, Technical Issues
- Technten:
and Generic
- Allegations
- Allegations technical issues
- Allegations and allegations
- Allegations
- QA/QC Related
- QA/QC Related to E. I&C to Civil /Hech
- QA/QC Related to
- QA/QC IJelated t
- Integrate QA/QC Coatings from other Groups Test Programs
- Interface with other groups on QA/QC
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INSTRUCTIONS TO TECHNICAL REVIEW TEAM The following ihartions are to be used by the Technical Revi the resoluticadttis::::sition of technical issues and allegati ew Team in provide team gu.h and sample document formats ons.
The instructions these instructmns
, as shown in the Annexes to A.
following g,s. m 1 guidelines:Each indivddueE team member s n s the 1.
Preptarn approach / method / rational to individual items 2.
Recznd mIB pertinent discussions or interviews.
3.'
Weipr:t dzzcumented evidence over oral representations 4
of namrgement perfonnance. Sed. the generic implications o ns 5.
Be ac:er.::nve to per' mutations / ancillary issues.
t 6.
Si2r um eBiegations to put into perspective; SALF,, gnavdous reviews, IDVP, LERs, IEBs; fit all pieces r
- nput, in (w w w ensive picture.
7 Respond gmrfessionally, nondefensively, nonagressively nestnmEVy in dealing with licensee and contractor personnel or
, and allegms. Don't be defensive-minded:
the tem w-Do not prejud Don't criticize or talk down to anyone. ge or prejudice 8.
When N=ing issues with allegers, approach from alleger's perspec::se; seek to understand.
Assume alleger credibility, honestby 9.
Assume witure there is smoke, there is fire." attitude."
10.
Do not gruwnnounce the item of concern to the licensee / cont whenever passible.
11.
DeveBay//metain records of all interviews wh technumB/henagerial adequacy decisions.
Maintain record protection.
12.
Pntect. m33egers/ personnel contacted.
{innen neayested).to avoM 1!in:Using attention on individual.Use ind Honor confidentiality 13.
Discus:simn with group leaders is encouraged. Draft 14 Procer:: mB1 information; do not prerelease conclusions prior to sasatjement review.-
Do not discuss cc7clusions with licensee.
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Assse all your notes / records / drafts / materials c ll
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sd ject to FOIA.
i o ected will be i
16.
1 Pake prompt notice to the Project Director of sig ifi n
cant issues.
17.
Irr-progress receipt of a new allegation should be repo t d c::: edinator to get it into the system.
re to site treated separately from the ongoing allegationsNew allegations will be t
(See Section I).
- 18. Be visible.
Wear NRC hard hats, etc.
19.
Istividuals should maintain an orderly, m accroach.
seful amt systematic.
20.
Keep it simple / understandable.
trackgrounds will need to understand what you have doPeople ne. -
21.
Cansider a post effort critique.
Keep track of lessons learned.
22.
Firaject Director or his assistani..A1111 media and " in o the tituir resolution and publishing of the SSERtite rev F
e media prior B.
- hg o= work package (s) and related infonnation.
sheert iis shown in Annex 1.
A work package cover ta iidemtify essentially identical allegationsGroup leaders should review 4
package and documented in the allegation trackin The numbers of -
- 1..
Bewrite (if necessary) general thrust of the allegation in ' lai amplish. -
If necessary, discuss with a11eger.
p n
2.
IBeselop and document approach to resolution.
an approach to resolution plan is. attached as Annex 2.A draft outline of 3.
l Identify material that needs to be reviewed and documented 4
Edustify applicable regulations / requirements.
5.
Idesti.fy the individuals who need to be interviewed 4
6.
Acustre pertinent records.
magion allegation files.
Do not remove rec'ords from site or furr work package. Assure copies of appropriate records a I
satitized to preserve confidentiality.
7.
Tamr.ider generic / management implications.
8.
3dettify related inspection items or technical issues (modules er portions thereof, followup items, noncompliance, etc.) that camId be completed-in conjunction with resolution of allegations want package.
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Tne approach to resolution will be reviewed anc approved by th group leaders.
than allegations (IES followup, room turnover inspection e responsi:.'e dich the allegation resolution effort and findings can be c edit d
, etc.) toward r
e.
I.
Identify manpower needs by specialty (request help where 2.
Develop estimated completion of each allegation.
3.
Group Leader shall specify individuals to do the work and approve the work package by signing the cover sheet.
E.
Conduct inspection in accordance with approach to resolution it.
Document conversations that are used in resolution issues or allegations.
In inspectin make signed statements (if possible)g allegations, have. individuals that* indicate what was said, who was there, where, date and time, and purpose of the interv These statements should be signed by all present.
Record fom, attached as Annex 3, See Conversation 2.
Obtain copies of key documents.
on a few pages of a larger document, obtain copies of and mark the copies with the information that should lead back to the original document (s).
the work packages.
This information should be filed with E.
Group leaders should keep the Project Director or his assistant inf of significant developments.
daily; however, important developments should be reporte omed F.
Evaluate results of technical issue or allegation review.
4 G.
Prepare documentation to disposition the allegation.
writeup format is shown in Annex 4.
The allegation fin mind the following guidance:
In preparing the documentation, keep 1.
Indicate that the allegation is understood.
Briefly, but fairly, restate the allegation If you discussed the allegation with the alleger, then say so..
2.
Respond to the allegation.
merit to the contention?
Is the alleger correct?
Is there some 2.
Do not casually dismiss an allegation.
the wall," someone may see some merit in the allegationEven if the al 4
Recognize and address (if possible) the underlying problem wh raise to the alleged problem; i.e., what management failure allowed 14,000 undersized bolts into.the Class I system?
generic implications and what was do,ne to resolve them.Also address the 5.
If there is no safety significane, say why.
will be reading and evaluating the analysis. Remember, nonengineers
__.m_-
6.
Avoid the suggestion that a sample collected w is a
" statistically valid" sample).
sample, without characterization. Simply state the size of the 7.
If it appears that the problem was caused, even if in part failure to properly implement QA or -inadequate administrat
, by a management contrpls, then address this aspect.
e the overall QA program effectiveness will have to be addressed An assessment of H.
followup to previously identified inspection find r s, documented and closed out in an inspection re
- ons, IE Manual Chapter 0610.
ance of I.
allegations will be treated as follows:New allegations may 3.
Receipient shall report allegation to Project Director via his Group Leader, and fill out allegation tracking forms.
2.
NRR will make board notification, if appropriate.
3.
TRT team member may be requested to provide technical '
assistance to OI in taking statements from allegers.
4 Review alleger's statements and identify additional technical issues.
5.
The Project Director's staff will enter technical issues into tracking system.
appropriate group in TRT.They will assign all technical issues to 6.
questions to applicant, based on technical issues 7
Obtain Project Director approval of proposed correspondence to applicant.
4 8.
The Director, DL, will dispatch questions to applicant.
9.
The TRT will review the applicant response and include it in an evaluation.
- 10. Document results.
e i
7 Annex 1 Comanche Peak Allecation Work Packace x
Allegation Number Numbers of Similar Allegations Statement of Allegation:
Reference Documents:
Source of Allegation _
Date Received The 'above information prepared by _
Name Date Group Leader Name Date Assigned Team Members Date Assigned 1
Date Assignec Date Assigned Date Assigned P
i,-
_ _, _ _ _ _..,. - - ~
1 SAMPLE --
Annex 2 CDMANCHE PEAK OPEN ISSUE ACTION PLAN M: AQ-05, AQ-06, AQ-18, AQ-22 Ref. No.:
4-83-A-48, 4-83-A-81
_Cha racterizations :
Inspectors not properly certified.QC inspector certifica not verified.
Past employment
_ Initial Assessment of Sienificance:
Answers to exams given.
QC inspectors may have performed of the inspections questionable. inspections wnile not properly qua ty
_ Source:
QA allegations; unknown allegation Acoroach to Resolutions?
1.
ANSI N45.2.6 (73/78) Review contractors certification program a Levels I, II, and III.
rements and 2.
Determine whether rec,ords reflect verification of education experience (past employment) - in writing (see C and 3.
exam answers were routinely given to exams (if possible) ne if 4
See QC inspector list for particular records to be reviewed 5.
Refer any examples of wrongdoing to 01.
6.
Evaluate allegations for generic / safety implications
~
7.
Report on results of review /ev,aluation of allegations Related Open Issue Identification 1.
Using system code, pull related allegations, open items inspection findings, etc., from the tracking system open item lis previous 2.
Review activities necessary to close or partially close relat d i either based on inspection conducted above or reasonable additi e
- tems, inspection while the inspector is familiar with the areas 3.
While performing physical inspections above systeem, components, and structures for any, apparent defect orexamin indicator.of faulty workmanship.
4 them for any knowledge of other potential deficienc interview Status:
-Review lead:
, support: 01
_ Estimated Resources:
5 man-days Estimated Completion: July 25, 1984 CLOSURE:
Reviewed by:
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t Annex 3 Conversation Record Allegation Number Time _
Type Date
_ Visit Conference Telephone
_ Inco_ ming
_ Outgoing Name of Person (s) Contacted or in Contact With You Organization Telephone Number
SUBJECT:
SUMMARY
Name of Person Documenting Conversation Signature Date Name(s) of Other Persons Who Were Present During Conversati on below and agree that it accurately represents the ual(s) named on.
Signature of Person Providing Information _
File: Allegation Work Package cc:
Project Director Group Leader Additional pages may be attached as needed.
identified, tigned, and dated.
Additional pages should be
1 Annex 4 Allecation Writeuo (SSER)
Allalfegationreviewsandclosecutwillbedocumentedi SER.
The SSER input will'be submitted in the following format n supplements to the 1.
A11ecation Groue - Title of Work Package 2.
A11ecation numbers 3.
_ Characterization - Statement of the allegation.
enaracterization of allegation.
Plain English If allegation clarified with alleger, then so state.Should b people.
4 Assessment of safety sienificance - Include what was revi size 1f appropriats).
(Attach documentation of interviews.) Persons and titles of individuals in CA, or management controls as appropriate. significanc Sumary of findings. Statement of' 5.
Conclusion and staff oosition - State if the allegation is substa t
,1 in wnole or in part (explain 1f necessary).
~
n ated with. alleger, so state.
If findings we.re discussed 6.
Actions Recuired - Is future action required?
inspect 1on T5/FSAR change?
Specify. Additi,onal 7.
_ Potential Violations - Did this allegation involve a violation of N regulations?
If yes, specify.
be included on an inspection report.Writeup should be specific enough to Recomendations will be reviewed.Violatien' levels will b by team management.
8.
Attachments - Attachments should be clearly identified
,, 9.
Reference documents 10.
This statement prepared by:
Name Date Reviewed by:
Group Leader Date Approved by:
Project Director
~
Date
.f40TE:
This writeup will be prepared in the above format and typed on th 5520 for retention in.the NRC staff files.
e ' IBM for publishing in the SSER.7-10 suppressed, will be printed on t eady I'
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TASK AMD DISCIPLINE CODES I.
_ Task Codes A - Allegations B - IE Bulletins, Circulars Information Notices C - CAT inspection findings 0 - Deficiency Reports 50.55(e), and Part 21 Reports E - Inspection findings,
'G - Generic letter issues (violations, unresolved items, and open items)
H - Hearing open issues I - Investigation Reports issues L - SALP open issues M - Congressional or Commission concerns 0 - Operator Licensing open items P - Inspection Program Status 0 - Final OA Reinspectio R - Room / System Turnover.n issues 5 - SER open items status (those done, those to do) j T - Task force special inspection items
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U - Unfinished punchlist items V - IDVP open issues 2 - Vendor open items II. Discioline Codes 1.
0 - QA/0C (General)
B - Bolts C - Concrete /Rebar E - Electrical W - Welding P - Pipe (Construction)
H - Hangers l
I - Intimidation 0 - Coatings T - Test Program D - Design of pipe M - Miscellaneous / pipe supports l
A - Independant Assessment i
k V - Vendor / Generic 5 - Instrumentation R - Records N - NDE K - Cables / Terminations F - Fire Protection U - Procedures / Instructions Review.
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