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a UNITED STATES NUCLEAR REGULATORY COMMISSION
{ ; ,E REGION V
,4 145o MARIA LANE,sulTE 210 0,% ,e, WALNUT CREEK. cALIFORNI A M50s Region V Policy Statement No. 0109 Revision Responsibility - DRSSP MEMORANDUM TO: All Region V Personnel i FROM: John B. Martin, Regional Administrator
SUBJECT:
PERFORMANCE AND DOCUMENTATION OF TECHNICAL REVIEWS I have collected a few thoughts which should serve as guidelines to the regional staff in conducting their technical work. The following guidance has been my policy for years on licensing work. I thfnk the basic concepts are equally applicable to the technical work we are doics in Regica V to support our licensing activities, technical positions, ana 9ther actions requiring a firm technical basis. These guidelines will probably be supplemented from time to time. Staff members will be expected to adapt these guidelines to nonlicensing work as appropriate. t Each licensing action or technical position we take should be supported by a technical evaluation memorandum. This memorandum will become a part of the official docket file. The technical evaluation memorandum should clearly convey to the reader the nature and extent of the evaluation and the technical basis for,'our actions. These memoranda are a window to the public which provides vis/bility of how we do business. As such, the technical memoranda should bre first class technical documents in every respect.
. The major features of the technical memoranda are as follows:
1 In an introductory statement, the scope and organization of the technical ;
memorandum should be clearly spelled out. Extra time spent on the '
organization of the evaluation will make it much easier to understand and '
should assist the writer in organizing his or her thoughts.
, After the introduction, the overall technical approach to the evaluation j should be outlined. This should include the technical methods used and the rationale for use of those methods. If (in the case of a license review)' the evaluation van a spot check of a licensee's calculations, comparison with established guides and standards, or a completely independent set of staff.
calculations, this should be identified. The basic assumptions, source of data, and reference material must be explicit.
The staff member should clearly and explicitly give his or her conclusions I and the technical basis for the actions or conclusions. This part must be
( siven a lot of thought, and the staff member should be prepared to defend the bases.
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i Technical work should always be handled in a formal and business-like fashion. All references to meetings, reports and correspondence should include ~the report or letter number and the dates. As a general rule, all information or agreements should be documented formally in correspondence that can be referenced. In cases where it is appropriate to reference technical information conveyed by telephone, the person talked to should be l identified and the date given. It is a good practice to document important l calls in a short summary memorandum. More routine calls should be recorded in a personal log book. Log book use is encouraged. Field trips taken, reviews by others should be clearly identified.
Technical evaluations should be reviewed with and checked by the immediate supervisor. The supervisor should sign off in a block called "Approved by Independent calculations, reviews, comments by others and concurrences should be filed along with the technical memorandum in the official docket file.
Issues with other NRC technical personnel (Inspection and Enforcement, NRR, NMSS) or outside reviewers should be resolved if at all possible. Where resolution cannot be achieved by the staff member, the matter should be referred to your Branch Chief, Division Director or the Regional Administrator. In no case should licensing actions be issued without the
! Regional Administrator's approval if any outstanding internal unresolved issues exist.
i Technical issues with licensees should also be resolved if possible. We should try to get licensee agreement to conditions ',e plan to place on the l licensee. This is primarily to make sure the lice.asee understands the condition and the reason for it. Where agreemer, cannot be reached, you should refer the matter to your Branch Chief, Division Director, or the Regional Administrator, to take up with licensee management. Lo not let disagreements fester -- this is why licensees have managers.
All significant licensing actions should be reviewed with the inspection staff. Our actions may depend on how the licensee is actually operating and insight provided by the inspection staff is invaluable.
This Policy Statement is effective immediately
$W B. Martin Regional Administrator' i
Revision 0, July 1 5 , 1983
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Revision Responsibility - ORA i
'9 Region V Instruction No. ,
MANAGEMENT OF ALLEGATIONS A. Purpose To ensure that allegations, complaints and concerns involving NRC licensed activities expressed to, received by or reported to any Region V employee are properly and timely documented, evaluated, handled, controlled, and dispositioned.
B. Scope l
This instruction provides for the actions to be taken by Region V employees whenever they may be the recipient or otherwise learn of I information that may adversely impact on the NRC or affect NRC licensed activities, including, but not limited to, reactor operation; reactor construction; radiography; control, use, and transportation of radioactive material; safeguards; environment; and discrimination against, intimidation or interference with protected persons for reasons related to protected activities.
C. Definitions i
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, 1. Alleaation is an assertion by an individual in the form of a l statement, complaint, concern or any other manner that indicates an ,
1 impropiety in connection with NRC licensed activities.
- 2. Alleter is an individual who makes an allegation.
- 3. Allegation Panel is a group of Region V esployees selected by a cognizant Division Director to evaluate and recommend actions to resolve an allegation. The Office Allegation Coordinator, and the Enforcement Officer shall serve on all allegation panels, when available.
- 4. Connizant Division Director is the Division Director responsible for the inspection activities affected or otherwise involved in the allegation.
D. Responsibilities and Authorities I
- 1. Regional Administrator is directly responsible to the Executive l 1
Director for Operations to ensure proper and timely execution of NRC {
policies and procedures related to receipt, action and disposition of allegations that fall within the jurisdiction of Region V.
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- 2. Divisica Directors shall ensure that the instructions contained herein are properly and timely executed. In particular, the Cognizant Director shall within two (2) working days, as appropriate:
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- a. Ensure that the Regional Administrator and the Office Allegation Coordinator are aware of allegations that he ber.omes aware of. ,
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- b. Serve as Chairman of Allegation Panel. '
- c. Convene an Allegation Panel, evaluate available information, and formulate an action plan to appropriately dispose of the matter.
- d. Notify the responsible Licensing Office (NRR-NMSS).
- e. Is0ue PN and include in Daily Report only with approval of the Regional Administrator.
- f. Prepare, sign and/or concur in all written communications between Region V and the Alleger.
- g. Establish a file for each allegation which provides current information that is readily retrievable throughout the course of an inquiry / inspection / investigation.
- 3. Office Allegation Coordinator serves as the focal point for the management of information received from allegers and assures that the Regional Administrator and all responsible parties are informed of and kept current on the status of allegations. In particular the Coordinator shall:
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, s. Serve as a member of all Allegation Panels.
- b. Verify that allegations are entered into;NRC Allegation Tracking System within two (2) working days of receipt.
,. c. Verify that written communications have been sent'to alleger as prescribed in Section E.5 of this instruction. Sign and/or concur in the letters sent to an alleger at the discretion of the cognizant Division Director,
- d. Upon disposition and/or closure of an allegation, verify that the file is complete and contains all necessary documentation pertinent to the allegation,
- e. Provide the cognizant Division Director, Enforcement Officer, State Liaison Officer, and Public Information Officer with copies of the Allegation Data Form when the data is entered into the NRC Tracking System. Thereafter, inform the Director and Officers of all significant information subsequently obtained pertaining to the allegation.
- f. Ensure proper Laplementation of Region V Instruction 1302, Allegation Tracking System. ,
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3 Serve as the interface and principal contact person between the i Region V staff and the staff of the Office of Investigations, l
Region V.
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, 4. Enforcement Officer shall: I
- a. Serve as a member of all Allegation Panels.
- b. Provide advise and counsel as to potential violations and
,. possible severity levels that may arise from the allegation.
- c. Alert the Regional Administrator of alleged significant violations of regulatory requirements that potentially will result in escalated enforcement action.
- 5. State Liaison officer shall inform state and local officials of information contained in allegations that fall within the jurisdiction of the state and local governments and provide notice to the appropriate officials of NRC findings and actions if and when appropriate as determined and directed by the cognizant Division Director.
- 6. Public Affairs Officer shall respond to requests from members of the media and other members of the public for information concerning allegations. Specific information pertaining to an allegation shall not be released without approval of the cognizant Division Director.
- 7. Region V Employees shall, upon receipt of an allegation, complete an Allegation Report and deliver it to the Office Allegation Coordinator. -
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, E. ACTION:
- 1. Receipt of A11enation
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- a. Region V employees who receive an allegation by U. S. Mail or I
, otherwise in written form shall immediately deliver the document to the Office Allegation Coordinator or in the Coordinator's absence to the Regional Administrator.
- b. Region V employees who receive allegations over the telephone or during discussions with individuals shall obtain, if possible, the following information.
(1) Full name of person.
(2) Telephone number where person can be reached (work -
home).
l (3) Mailing Address. l l
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i (4) Name-of employer.
(5) Place of employment.
(6) Job or pcsition title.
(7) Name of licensee.
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. l (8) Name of facility.
l (9) Nature of Allegation - obtain as many specific details as i possible. In addition to who, what, when, where, why and how, attempt to expand and clarify all information so that issues are well defined and can be readily evaluated as to safety significance.
(10) Regardless of any personal opinions, employees shall communicate with allegers in a professional manner chowing due respect and interest in any and all of the concerns expressed by the alleger. Even in areas where NRC clearly has no jurisdiction, NRC has a duty of notify the appropriate authorities and or otherwise assist the individual in reaching the appropriate authority.
- c. A standard allegation report form is attached as Appendix A to this instruction and should be used to document all allegations. The Office Allegation Coordinator will assist, if needed, with the completion of the report and review all l j
l reports for completeness. At the same time an Allegation Data Form shoold be completed per RV Instruction 1302. Both documents should then be immediately delivered to the Office Allegation Coordinator who shall then immediately notify the cognizant Division Director and provide the Director with copies of the Allegation Report.
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- d. If an employee receiving an allegation believes it would be l l
better for the alleger to discuss the matter with another employee, and if thts alleger consents, transfer the call to or refer the person tc the Office Allegation Coordinator. If that individual is unava ilable then refer the alleger to another
, appropriate employee. However, before referring the alleger, be sure to obtain the alleger's name and phone number or how the individual can be reached in case of a disconnect.
- e. Many persons reporting a particular matter to NRC wish to remain anonymous, If the alleger refuses to give a name inform the person that:
(1) NRC will, if the alleger so requests, treat. the i individual's identify as confidential. (Ste paragraph 7 of this section for additional detail.)
I (3) All matters involving public safety will be examined and evaluated regardless of the possibility of an allegers identity being disclosed by the circumstances.
(3) If the individual is alleging discrimination, refer the person to the Enforcement Officer or to an investigator in the Office of Investigations Region V. If this cannot be done, inform the person that a complaint must be filed with the Departatut of Labor within 30 days of the acts complained of in order to obtain the Department's l
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. assistance. (See paragraph 6 of this section for additional detail.)
(4) NRC Region V policy is to send a letter to the individual to any requested sailing address which documents NRC's
. understanding of the allegation to assure that the NRC has correct information and that the letter will be sent in a plain envelope with a return address shown as follows:
OAC, 1450 Maria Lane, Suite 210, Walnut Creek, CA. 94596.
(See paragraph 5 of this section for additional detail.)
I (5) If the alleger insists on remaining anonymous, obtain as much information as possible and advise the individual to contact the Office Allegation Coordinator, collect, at (415) 943-3700 in about 30 days so that the matter may be further discussed and to ensure that the individual's concernP have been properly addressed.
- 2. Evaluation of Allegation
- a. Except for those allegation that involve conditions that ,
require immediate action such as theft of SNM, sabotage, and immediate threats to the heslth and safety of the public that are governed by other NRC procedures, within two (2) days of receipt of an allegation, the cognizant Division Director shall, as Chairman convene an Allegation Panel, to evaluate the 1
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. information and develop an action plan to resolve the matter.
The Panel shall (1) Ensure that issues raised in the allegation are identified and understood.
(2) Evaluate the safety significance of all issues.
(3) Identify potential violations of regulatory requirements and potential enforcement action.
(4) Determine what additional information must be obtained.
(5) Consider time sensitivity.
(6) Determine how allegation should bn handled, i.e., Inquiry, routine inspection, special inspection or investigation.
Allegations concerning technical matter, such as inadequacies in procedures, qualifications or training; inadequate implementation of procedures; inadequate corrective actionst radiation overexposures; etc. should be handled via the inspection program. Allegations involving wrongdoing such as record falsification; willful or deliberate violation of a regulatory requirement; bitprjalfalsestatement,orimproperconductwhich affects ikcensed activities should be referred to OI for inyestigation.
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. (7) Recommend referrals to other NRC Offices, or to other l
Federal, State or Local governmental agencies. ;
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4 (8) Identify the need for additional expert technical or investigative skills.
l (9) Determine what information should be maintained confidential.
- b. After evaluating the available information, the Allegation Panel shall provide the cognizant Division Director recommendations in the form of an action plan as to what actions should be taken to appropriately resolve the matter.
- c. If inquiry or inspection activities are conducted to verify or obtain additional information about an allegation, the strategy
- should be very clear and the following shall be included in the action plan.
(1) If the inspection strategy involve interviews of people, predetermine and include in action plan the minimum number of persons that will be interviewed; develop a series of questions to ask each individual. and record on a separate document at the time of an interview, the date, time, location, name of person, and the answers obtained plus !
1 any additional relevant information obtained during the l interview. Offer the document to the interviewee to read t__ - ;
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, upon completion of the interview and request the individual to sign and date the document. If the individual refuses, the inspector should so note on the document. All interview documents shall be signed and dated by the inspector. These original interview ,
l documents must be maintained as part of the official agency file.
(2) Information obtained from records to support or refute an allegation should specifically identify the source documents. If possible obtain a copy of the documents.
When the records are numerous such as "weld rod issue data forms" or "daily radiation survey forms," obtain only copies of selected samples.
For documents believed to contain vital information to support or refute an allegation, and if a copy cannot be obtained at the time, request permission to date and initial or otherwise mark the document for future identification and then hand copy or otherwise record all information contained on the document.
(3) If the inspection strategy involves sampling, make sure the technical basis of the sample size is clearly stated.
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- 3. Notifications As Chairman of an Allegation Panel, the cognizant Division Director shall assign individuals, as appropriate, to:
- s. Notify Licensing Office (s) and transmit appropriate documents,
- b. Notify State and Local authorities and refer issues to them that fall with their jurisdiction, e.g. , OSHA violations.
- c. Notify news media.
- d. Issue PN or include in Daily Report (Must have Regional Administrator's approval).
- e. Notify Department of Labor or other Federal Agencies,
- f. Notify Director OI Region V of any potential wrongdoing by individuals that may require referral to the Department of Justice.
- 4. Documentation a .' Each allegation received shall be documented on an allegation report form, attached as Appendix A to this instruction.
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- b. Results of evaluations of allegation yenel shall be documented in a memorandum to files signed by the cognizant Division Director. ,
- c. Action plans to resolve allegations shall be documented and
, approved by the cognizant Division Director.
'd. Details and results of inquiries and inspections shall be documented in the standard IE formats except that all documents obtained during follow-up activities including original interview documents should be filed with the reports.
- e. All documants includia; letters to and from an alleger relating to an allegatits shall be fi.e4 In an appropriate facility docket file. Confidential and .. sensitive material should be i
so marked.
- f. The purpose of all reports and other documents is to set forth sufficient facts and information in a manner such that a reasonable person will read and understand the allegation and the facts and circumstances that were found to exist or had existed concerning the matter. All reporting shall be factual and written in a style such that the NRC does not discouras,e i
persons from bringing matters to its attention. Under no circumstances is the report to be written such that it attacks or discredits the alleger. Pejorative language is to be avoided.
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- 5. Letters to Alleters Acknowledning Receipt of A11eastions i
All allegations received from concerned citiz, ens will be {
acknowledged by letter back to the individual who presented the allegation. This letter, in addition to stating an acknowledgement 1
of the contact, will also contain a "Statement of Concerns" as an enclosure to the letter. The statement will detail the allegation av understood by the individual who received the allegation. The purpose of the letter is to assure the alleger that his concern will be examined as appropriate, and that the examination will address all of the specific concerns expressed by the alleger.
The Office Allegation Coordiantor (OAC) is responsible for preparing acknowledgement letters to allegers. No members of the Region V staff will prepare and forward any correspondence to allegers without first coordinating such action with the OAC, to ensure that a single point of contact can be maintained for the alleger.
Generally there are six types of letters which could be sent to allegers. These are as follows:
- 1. Normal first letter
- 2. Restatement of Concerns
- 3. Request for Additional Information
- 4. Close-out for Lack of Response
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. 5. Close-out for Action Completed
- 6. Referral of Allegation to Ancther Agency Samples of the above letters are attached to this instruction as
,. Appendix B. '
- 6. Employee Discrimination Complaints
- a. Backaround A Memorandum of Understanding (MOU) signed by NRC and the Department of Labor (DOL) facilitates coordination and cooperation between the agencies in the processing of violations of the employee protection provisions of Section 210(a) of the Energy Reorganization Act. Subsequently, working arrangements were developed and points of contact established at regional and headquarters levels for each agency.
- b. Workina Arranaements l
The working arrangements between NRC and DOL establish cert,ain commitments that must be carried out by the regional contacts for the NRC. The working arrangements provide that NRC will refer complaints to DOL, advise DOL of complaints received concerning employee discrimination, inform DOL of
, investigations that NRC is conducting into these matters, facilitate DOL investigations by assisting in gaining access to 1
NRC-licensed facilities, and decide whether NRC should conduct-i 1
an independent investigation. j l
Section 410 of the Energy Reorganization Act prohibits any evjloyer, including an NRC-licensee, applicant or a contractor or subcontractor from discriminating against any employee with respect to their compensation, terms, conditions or privileges of employment because the employee, assisted or participated, or is about to assist or participate in any manner in any action to carry out the purpos.2 of' either the Energy Reorganization Act of the Atoalc Energy Act of 1954.
NRC and DOL agreed to cooperate with each other to the fullest extent possible in every case of alleged discrimination involving employees of NRC licenses, applicants, or contractors j 1
and sub-contractors. NRC will take all reasonable steps to assist DOL in obtaining access to licensed facilities and necessary security clearances. Each agency agreed to share and promote access to all information it obtains concerning a particular allegation and, to the extent permitted by law, will protect the confidantiality of information identified as ,
- sensitive that was supplied to it by the ether agency.
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- c. Processina of Complaints If a coaplaint is received concerning a possible violation of Section 210(a), the OAC will refer the complainant to the Enforcement Coordinator, the Region V point of contact t responsible for the regional implementation of the NRC-DOL MOU.
Region V will not normally initiate any action on such a cocplaint if DOL is conducting, or has completed, an investigation and found no violations; however, the matter will be documented on an Allegation Report and entered into the Region V Allegation Tracking System.
- 7. Confidentiality
- a. Bacharound The ability of the NRC to obtain information, particularly adverse information, depends on the subsequent handling of such information within NRC and the ability to protect the identity 1
of individuals providing the information from retaliatory actions by their employers and co-workers. While Public Law 95-601 makes it unlawful for employers to take retaliatory actions against employees reporting information to the NRC ,and provides the means for the employee to obtain legal remedies, the legal process can be very lengthy, so much so, that employees are still reluctant to provide information for fear
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of being out of work for an extended period of tian i through the legal process. ;
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Confidentiality is a means by which the NRC protects ana withholds the identity of an individual who provides.
- incriminating and/or adverse information to the NRC. It is NRC policy not to divulge to others the identity of individuals granted confidentiality, either during or subsequent to an inquiry based on the information provided *
- 3 NRC.
- b. Use of Confidentiality
, Confidentiality should not be routinely offered to individuals making allegations or otherwise providing information during the course of an NRC inquiry, inspection or investigation.
However, if a Region V staff member is of the opinion that he would not receive the information, or if the individual providing the information requests anonymity, then a grant of confidentiality will be proffered. Before confidentiality has l been granted, the individual should be informed that, although the pledge is not absolute, it is NRC policy not to divulge the identity of people granted confidentiality. Also, the individual should be told that their name will not normally, appear in the publicly released reports. The individual's identity may, however, be revealed where required by law, when necessary to insure public health and safety, pursuant to Congressional directives, or where the nature of the l
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. allegations or the ILuited number of people with access to the reported information may provide a basis for guessing their identity. In these cases, NRC will neither confirm or deny .
requests to verify the identity of a source of information.
Should a Region V staff membec grant confideatiality, all facts !
- and circumstances surrounding the pledge must be documented in a memorandum to the OAC who will coordinate the information with the cognizant Division Director.
- c. Restrictions Within Region V, the identity of any individual making allegations, expressing concerns, or registering complaints shall be treated as "0FFICIAL USE ONLY" information. Their names shall not appear in any report (except as noted above regarding the preparation of Allegation Reports or related memorandum) or any internal memorandum or other document placed in normal mail distribution, nor will it be divulged to any NRC employee or outside individual who does not have a need for such information. If it is necessary to p. ovide the name of an individual reporting information (alleger) to an inspector assigned to followup an allegation, or to other NRC offices, l the OAC will coordinate the request for release with the j cognizant Division Director. Every effort stall be made to preclude the inadvertent or premature disclosure of the l l
identity of an individual providing information in connection with an allegation, complaint or concern. I i
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, In no case will the identity of such an individual be made known to a licensee employee without the specific approval of the cognizant Division Director. If the licensee correctly
., guesses the identity of the individual, the Region V staff members will respond that the NRU position is to neither
, confirm nor deny the validity of such guesses and refuse to discuss the matter further.
One point regarding promises of confidentiality should be -
clearly understood by all Region V staff members and explained to the individual providing information, if appropriate. A pledge of confidentiality shall not be made (or may not be t honored if previously granted) if the individual provides ,
information indicating that he intends to or has personally committed, or participated in criminal acts which may include a deliberate (knowing and willfull) violation of NRC rcquirements.
Approved:
John 3. Martin Regional Administrator ,
Dates l
- Revision 0, October , 1963 G
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t APPENDIX A l PREPARATION OF ALLEGATION REPORT t
A. Purpose l :
Allegation Reports (AR) serve as the basic document for initiating an allegation file within Region V. All allegations should be documented on the Allegation Report form in accordance with the following instructions:
B. Documentation Region V personnel shall document information regarding an allegation, complaint or concern on Form as follows:
- a. Name -
Enter the full name of the individual providing the information.
- b. Address -
Enter the mailing address of the individual providing the information.
- c. Phone -
Enter the residential and/or business phone number of the individual providing the ,
information.
- d. Allegation -
Enter a concise statement describing the
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, allegrtion, concern or complaint (e.g., improper s
welding procedures used in containment).
- e. Facility -
Enter the name of the facility involved in the allegation, complaint or concern (e.g'~, Trojan). .
- f. Docket No. -
Enter the docket number of the facility if known.
3 File No. -
Leave blank. The Office Allegation Coordinator (AOC) will assign an NRC tracking number.
- h. Date -
Enter the time of initial contact with the individual who provided the information.
- i. Confidenti- -
If the individual who provi6es the information 2
ality Requested specifically asks for confidentiality, circle yes. (If confidentiality was requested details of the request must be explained in the Susunary of Information Section).
J. Summary of -
Enter the details of the information provided Information by the individual.
- k. Prepared By -
Enter your printed name and signature.-
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- 1. Date -
Enter date document was prepared.
. m. Action -
Leave blank. 0AC will use this space for Required internal administrative actions. i l
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- n. Reviewed By -
Leave blank. l
- o. Date -
' Leave blank.
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. ALLEGATION REPORT l . NAME: , ALLEGATION: FACILITY: l l
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a JRESS: ' FILE NO:
CATE: '
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PHONE: CONFIDENTIALITY REQUESTED YES NO DOC NO:
SUMMARY
'OF INFORMATION:
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p est or l Dntranto or cart .l l
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fWFIPt A t LIEF OWt Y _ Dn mat DIEC1OEF A/8'//d M
/ g UNITED STATES l .
Rf NUCLEAR REGULATORY COMMISSION h
MOONV e, 1450 MARIA LANE.SulTE 210 WALNUT CREEK. CALIFORNIA Mst$ l (DATE) :
(NAME') *
(ADDRESS)
(CITY, STATE, ZIP CODE)
Dear '(Mrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
SUBJECT:
l (ALLEGATION FILE NUMBER) i l
(STANDARD INTRODUCTORY PARAGRAPH) l This refers to (TELEPHONE CALLS, MEETINGS AND/OR LETTERS) in which you expressed concerns related to (GENERAL areas of allegation) practices at (NAME OF UTILITY l AND/OR SITE).
(STANDARD PARAGRAPH - INQUIRY INITIATED)
An enclosure to this letter documents your concerns (S) as I understand (IT/THEM) based on (OUR CONVERSATION)(MY CONVERSATICN WITH )(OUR MEETING) (OUR LETTER). We have in (ated an inquiry regarding this matter, therefore, if the enclosure does not c- etely and accu *ately reflect all of your concerns, please contact me collect as soon as possibie at (415) 943-3700 so that we can assure that they are adequately addressed during our inquiry. If you should call and I am not available, please leave a message so that I can return your call.
(STANDARD PARAGRAPH - INSPECTION RE0 VESTED)
An enclosure to this letter documents your concern (S) as I uncerstano (IT/THEM) eased on (OUR CONVERSATION)(MY CONVERSATION With )(OUR MEETING)(YOUR LETTER).
I have requested that our inspectors loJk into this matter curing one of their 1 upcoming inspections, therefore, if the enclosure does not completely and !
accurately reflect all of your concerns, please contact me cellect as soon as 1 possible at (415) 943-37.00- so that we can assure that they are adequately I addressed during the planned inspection. If you should call and I am not available, please leave a message so that I can return your call.
(STANDARD PARAGRAPH - ACKNOWLEDGE RE0 VEST FOR CONFIDENTIALITY)
Regarding your' request for confidentiality, let me assure you that we will make every attempt to handle this matter in such a way as to maintain your anonymity. 1 In this respect, I would like to point out that licensees sometimes correctly !
guess the identity of the individual providing information to us. In such cases l cur policy is to neither confirm or deny the accuracy of their guesst 1
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i f , g* "2-(STANDARD PARAGRAPH-CLOSING) .
In c1'osing, we appreciate your bringing y9ur concerns to our attention. If you have additional questions, or.If I can be tf further assistance in this matter, please do not hesitate to contact me.
Sincerely, (NAME)
(TITLE)
Enclosure (s):
Statement of Concerns e
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/ \^ umrto sTATas NUCLEAR REGULATORY COMMISSION l s naoxm v ;
- 1490 MARIA LANE Buff E 210
- J WALNUT CREEK. CALIFORNIA 94506
- !!** l (DATE)
(NAME) h l (ADDRESS)
(CITY, STATE, IIP CODE)
Dear (Hrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
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SUBJECT:
(ALLEGATION FILE NUMBER)
(STANDARD INTRODUCTORY PARAGRAPH) i This refers to our letter to you dated (DATE), the enclosure to which documented our understanding of your concerns relative to (GENERAL AREAS) practices at (UTILITY)'s (SITE) nuclear power plant and to your subsequent (LETTER TO US DATED IN)(TELEPHONE CONVERSATION WITH NAME AND DATE DURING) which you provided !
(ADDITIONAL)(AND)(CORRECTED) information regarding your concerns. '
The enclosure to this letter represents a restatement of your concern (S) as we now understand (IT, THEM) based on the (CORRECTED) (AND) (ADDITIONAL) information you provided. However, as before, if the enclosure does not completely and accurately reflect all of your concerns, please contact me at (415) 943-3700 as soon as possible, (STANDARD CLOSING PARAGRAPH)
Again, we appreciate your informing us of your concerns anc your cooperation is ensuring that we understand them correctly.
Sincerely, (NAME)
(TITLE)
Enclosure:
~
Statement of Concerns - Rev.
(REV. NO.)
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(NAMd)
(ADDRESS) h (CITY, STATE, ZIP CDCE)
Dear (Mrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
SUBJECT:
(ALLEGATION FILE NUMBER)
(STANDARD INTRODUCTORY PARAGRAPH)
This refers to (TELEPHONE CALLS, MEETINGS, AND LETTERS) in which you expressed concerns related to (GENERAL AREAS) practices at (UTILITY)'s (SITE) nuclear power plant site.
(REOUEST FOR ADDITIONAL INFORMATION PARAGRAPH We have determined that we need addittional information from you before we can proceed with our inquiry into your concerns. We have attempted to contact you by telephone without success and I would appreciate your contacting rne collect at (415)943-3700- as soon as possible so that we can discuss this matter furtnee.
e (ADDITIONAL INFORMATION PROMISED BUT NOT RECEIVED)
Based on your telephone conversation with (NAME) on (DATE), it was our under-standing that you would provide additional information and I would appreciate your contacting me collect at (415) 943-3700 at your earliest convenience so that we may proceed with our inquiry into this matter.
Your cooperation and assistance would be appreciated.
Sincerely, (NAME)
(TITLE) :
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(DATE) 1 (NAME) O (ADDRESS) .
(CITY, STATE, ZIP CODE) -
Dear (Mrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
SUBJECT:
( ALLEGATION FILE NUMBER)
This refers to our letter to you dated (DATE) in which we requested that you contact us to provide additional information regarding your concerns related to (GENERAL AREAS) practices at (UTILITY)'s (SITE) nuclear power plant site which
. you discussed (IN YOUR LETTER TO US DATED (DATE)) (IN YOUR CONVERSATION WITH (NAME) ON DATE)).
In that you have not contacted us and provided the additional information we requested, the Regional Staff plans no further action regarding this matter. We have, however, alerted our inspectors to your general concerns so that they can pay particular attention to these areas during their routine inspections.
Should you have any questions regarding our disposition of this matter, please call me collect at (415) 943-3700 ,
Sincerely, (NAME)
(TITLE) l l \
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. e 1490 MARIA LANE. SulfI 210 WALNUT CREEF., CALIFORNIA edlet 1
(DATE) l (NAME) y !
(ADDRESS) l (CITY,. STATE, ZIP CODE)
Dear (Mrs.)(Mrs.)(Hs.)(Miss) (LAST NAME):
SUBJECT:
(ALLEGATION FILE NUMBER)
This refers to our letter to you dated (DATE) which indicated that we had I (INITIATED AN INQUIRY) (REQUESTED THAT OUR INSPECTORS LOOK) into your cenerns regarding (GENERAL AREAS) paractices at (UTILITY)'s (SITE) nuclear power plant site as documented in the enclosure to that letter.
(PARAGRAPH: ACTION COMPLETE - REPORT ENCLOSED)
Our (INQUIRY)(INSPECTION)(INVESTIGATION) regarding this matter has been completed andourfindin9saredocumentedintheenclosedreport(s). This concludes the Regional Staff s activities regarding this matter.
. (PARAGRAPH: ACTION COMPLETE -NOT ADDRESSED IN REPORT Our inspectors have looked into this matter; however, to maintain your confiden-tiality your concerns and the insnector's findings were not highlighted in their report. We have, however, documr.nted our findings relative to (YOUR CONCERN)-
(EACH OF YOUR CONCERNS) in an enclosure to this letter.
(PARAGRAPH: ACTION COMPLETE -INVOLVES 2.790 INFORMATION) 1 Our (INQUIRY)(INSPECTION)(INVESTIGATION) regarding this matter has been l completed. In that your conceros dealt with physical security matters, the details of which are exempt from public disclosure pursuant to 10 CFR 2.790(d),
we are unable to provide you with a copy of our report. We have, however, documented our findings in a general sense in an enclosure to this letter.
(PARAGRAPH: ITEMS OF NONCOMPLIANCE IDENYIFIED)
With regard to the item (s) of noncompliance identified during (INSPECTION) ,
(INVcSTIGATION), (UTILITY) is required to inform us in writing of the corrective actions they have taken or plan to take and our inspectors will continue to follow such actions to ensure proper resolution.
(PARAGRAPH: EXPLANATION OF UNSUBSTANTIATED)
I would like to explain that the finding "unsubstantiated" does not necessarily mean that we find the facts as you stated them to be untrue, rather it means only that we were unable to obtain objective evidence to corroborate your statements through interviews, document reviews and/or direct observation.
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(PARAGRAPH: STANDARD CLOSING) ;
We appreciate your informing us of your co,qcerns. We feel that our actions in this matter have been responsive to those concerns; however, should you have furthe,r questions regarding this matter, please feel free to contact me. Please b3 astured that we will continue to perform inspections to ensure that (AREA 0F CONCERN) procedures are properly followed at nuclear power plants to protect the health and safety of the public.
Sincerely, (NAME)
(TITLE) l l
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