ML20204H010

Forwards Matl Re Mgt of Allegations Superseding Previous Guidance,Including Rev 1 to NMSS Policy & Procedures Ltr 1-27 & 821208 NMSS Interim Procedures for NRC Allegation Tracking Sys.W/O Encl

ML20204H010
Person / Time
Issue date:	04/04/1985
From:	Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20204H001	List: ML20204G996 ML20204H010 ML20204H015 ML20204H025 ML20204H032
References
FOIA-86-183 NUDOCS 8608070440
Download: ML20204H010 (2)

Text

1-CM t A

/ 'o, UNITED STATES

[? ..fi NUCLEAR REGULATORY COMMISSION

.3 ,l WASHINGTON. D. C. 20555 tA .. y /

d g-l l

MEMORANDUM FOR: Division Directors, Deputy Directors, '

Branch Chiefs, and Section Leaders, NMSS FROM: John G. Davis, Director Office of Nuclear Material Safety and Safeguards

SUBJECT:

NMSS POLICY AND PROCEDURES LETTER 1-27 (REVISION 2)

MANAGEMENT OF ALLEGATIONS The enclosed material regarding Management of Allegations supersedes all previous guidance issued on this subject. It specifically supersedes the original and Revision 1 of NMSS Policy and Procedures Letter 1-27 (January and April 1984) and the December 8, 1982 NMSS Interim Procedures for NRC Allegation Tracking System.

The information contained in the Draft Manual Chapter 0517 - Management of Allegations, transmitted by the EDO memorandum of September 19, 1984, serves as the current Agency policy and procedures on this matter. Every NMSS tech-nical staff member must understand these procedures and recognize the importance of following these procedures whenever questions or expressions of concern re-lating to NRC-regulated activities are received from sources other than the NR.C (e.g., the media, individuals, organizations, etc.). This would include all such concerns communicated either verbally or in writing.

I The entire draf t Manual Chapter must be read to become familiar with the detailed procedures, however, the most important points for a staff member who receives an allegation are as .follows:

1. Obtain as much information as possible about the allegation and about the identity of the alleger for possible follow-up.

2. Protect the identity of the alleger (confidentiality). .*

3. Contact the Office Allegation Coordinator - Robert O'Connell, FCUF, x79025, Room 328 - for further guidance before proceeding. Above all, do not contact the licensee regarding the allegation until after consul-tation with management and the Office Allegation Coordinator.

Points 2 and 3 above are most important to avoid compromising this channel of in-formation regarding possible licensee activities that may jeopardize safety. The

! Agency has a tracking system designed to ensure that all allegations are promptly evaluated and followed to resolution. The success of this system depends on l

/

/

8608070440 860801 PDR FOIA GARDE 86-183 PDR

p 8

staff members understanding and following the procedures.

A briefing on Allegation Management was presented for all NMSS Division Direc-tors and Branch Chiefs in October 1984. These individuals should ensure that all technical staff members under their supervision have received a copy of the

-draft Manual Chapter and have been made aware of its most important points.

i

- 'Nlbi] s i bl%;fg'.4WL T.Jo1n G. Dakis, Director Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated O

P 9

i

- - . - . , . _ _ _ __.-------.-,-y - - ,, - w --w-, , ,--,--e--'r -- - *-v---w v- o-w r e v -- - *- e r = - - - = - - --

=  !

'.- /"s. e acg*o,, UNITED STATES

, 8 o NUCLEAR REGULATORY COMMISSION g . ,1 wAsmmorow, o. c.2osss g,*****/ -

September 19, 1984 MEMORANDUM FOR: Office Directors Regional Administrators FROM: William J. Dircks Executive Director for Operations

SUBJECT:

PROPOSED NRC MANUAL CHAPTER 0517, " MANAGEMENT OF ALLEGATIONS"

\.

The attached proposed Manual Chapter is provided to you as policy in regard to management of allegations.

Since the Consnission may shortly address the issues of confidentiality and last minute allegations separately, and their decisions may require some changes as a matter of administrative convenience, the manual chapter will .

not be published until these points have been addressed. Ir. the meantime the attachment will serve as policy on this matter.

(

W r Executive Director for Operations

Attachment:

As stated cc: PDR 4

4 U.S. NUCLEAR REGULATORY COPHISSION-NRC MANUAL i Volume: 0000 General Administration Part : 0500 Health and Safety IE CHAPTER 0517 MANAGEMENT OF ALLEGATIONS 0517-01 COVERAGE This chapter and its appendices define the policy and procedures for the proper receipt, processing, control, and disposition of allegations received by NRC offices that concern NRC-regulated activities conducted by NRC licensees and their contractors and the policy and procedures for dealing with individuals who provide information to the NRC.

0517-02 OBJECTIVES 021 To establish the pol. icy for the receipt, processing, control, and disposition of allegations and to define procedures by which the receipt, status, and disposition of allegations are tracked through the Allegation Management System (AMS), thereby assuring that:

a. allegatiens are properly assigned for processing and assessed for 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;

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; 022 To assure that individuals making allegations 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.

Approved:

q.

,' i NRC-0517-03 MANAGEMENT OF ALLEGATIONS .

0517-03 ' RESPONSIBILITIES AND AUTHORITIES 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 timely updating of the status of those allegations for which their office is the Action Office.

b. Appoint an Office Allegation Coordinator (OAC) who serves as -

administrative point of contact for employees and other Offices and the Regions. The OAC will:

1. Ensure that the appropriate parts of the . Allegation Data Form (NRC Form 307, Exhibit 1) are completed for all allega-tions received within the Office or Region and that the requested data are accurate and timely.

2. Determine the appropriate Action O'ffice and, if applicable, coordinate with the OAC of the affected Office or Region on each allegation received.

3. Ensure the appropriate parts of the Allegation Data Form are completed for all allegations for which the Office or Region is the Action Office.

4. Forwarc 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 appropriate] 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 Commission meeting on full power authorization, the Receiving Office or Action Office for any allegation will, within 2 working days, tele-phonically notify the NRR Project Manager of its receipt and the identification of the Action Office in addition to com-plating the Allegation Data Form.)

Approved: 2

MANAGEMENT OF ALLEGATIONS NRC 0517-032b6

'6. Acquire input data on new allegations (including those referred to OI) from the staff within the Office or Region and ensure this information is forwarded to the NRR 0AC in a timely manner for placement into the AMS.

~

7. Provide updates (using an AMS printout) on previous allega-tions (including those referred to OI) from the staff within the Office or Region and ensure this information is forwarded to the NRR 0AC 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 Office or Region and establish schedules for the processing of allegations with the objective of resolving them prior to a licensing decision date, if applicable.

i

d. Review those allegations for which it is' the Action Office for -

potential board notification and recommend such notification to NRR or NMSS.

g

e. Refer all allegations involving wrongdoing, except those involving '

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 a's 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 need to inform other affected Offices for further action (e.g. ,

AE00 for operational data, RES for concerns affecti.ng 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 investigative intent. Determination of the need for an NRC investigation would rest with OI.

033 Director, Office of Investications Investigate allegations of wrongdoing by other than NRC em-l ployees and NRC contractors. Conduct interface responsibilities with the Offices and Regions as described herein.

l -

3 -____; ___ Approved:_ _ _

NRC-0517-034 MANAGEMENT OF ALLEGATIONS ,

034 birector, Office of Inspector and Auditor 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 Inspection and Enforcement

a. Resolve allegations affecting matters for which it is the respon-sible office including those that involve vendors or that are generic in nature in coordination with NRR or NMSS.

b. Monitor the allocation of resources for this activity by

. 'the regions.

036 Director, Office of Nuclear Reactor Reculation

.x Propose to the EDO for approval agency-wide policy and proca-dures regarding the processing of allegations. For those allegations that fall under the purview of 01, propose policy and procedures governing their interface with other Offices and Regions.

b. Review allegations concerning NRR licensees in coordination with the Action Office for potential board notification and make such notification, if required.

c. Evaluate implications of allegations re.lative to licensing deci-sions and plant safety concerning NRR licensees in coordination j 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 lafety and Safecuards

a. Review allegations concerning NMSS licensees in coordination with the Action Office for potential board notification and make such notification if required.

b. . Evaluate implications of allegations relative to licensing deci-sions concerning NMSS licensees in coordination with IE and the Region (s).

038 Office of Resource Manacement (RM)

a. Establish the ADP program and maintain the data base of information in the AMS.

b. Provide monthly (Exhibits 2 and 3) and special reports to Offices and Regions as requested.

Approved: 4

~

MANAGEMENT OF ALLEGATIONS NRC 0517-04 ,

0517-04 'VEFINITIONS 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 assigned the responsibility for resolving an allegation.

043 Allegation.

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 I 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 goverrm nt 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 beards, etc. Allegations that may result from these formal processes and are not resolved within these processes shall be subject to treatment under this manual chapter.

044 A11ecation Management System (AMS). A computerized information system that contains a summary of significant data pertinent to each allegation.

045 Allecer. An individual or organization who makes allegations.

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 directly, or otherwise, could identify an alleger by name.

It is not intended to deny staff members access to the identity of the alleger when such identification is required by staff members to evaluate and resolve allegations.

047 Inquiry. An activity involving minimal effort to determine the appropriate response to information reported to the NRC. Typi-cally, an inquiry entails the ~ use of the telephone or written correspondence rather than formal interviews or other investi-

, gative measures; however, formal interviews will be conducted. if

../ required.

,048 Inspection. A routine or special activity that may be used to

/ examine and subsequently resolve an allegation.

sv 1

5 Approved:

NRC-0517-049 -

MANAGEMENT OF ALLEGATIONS 049 Invectiaation. Formal activities normally conducted by the Office 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 Allegation Coordinator (OAC). A designated staff member in each Office or Region who serves as the administrative point of contact for that Office or Region regarding the processing of allegations.

051 Receivina 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 to its potential impact on the public health and -

safety.

053 Wronadoing For the purposes of this manual chapter, it includes tne 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 Applicability. The provisions of this chapter and appendices are applicaele to, and shall be followed by, all NRC employees.

052 Wronodoina. 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 01 (see Appendix 1, Part IX.2 of this manual chapter). OI will investigate allegations involving wrongdoing and provide ,either a report or a summary of its findings to the requesting Office or Region. Allegations involving wrongdoing received by a Regicn will be coordinated by the Region OAC with the OI Field Office Director in that Region -

and those received by Offices at NRC Headquarters will be coor- ,

dinated with the OI OAC. -

053 Action Office Assignments Allegations submitted by any source concerning NRC-regulated activities should be transmitted by the Receiving Office OAC to the OAC in the appropriate Offic: or Region for processing.

MANAGEMENT OF ALLEGATIONS NRC 0517-054' 054 iconfidentiality. The identity of individuals making allegations should 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 confidentiality agreement, 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 terms 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. ,

i 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, Office or Regional management should be informed and the person should be advised, the reason explained and remedial measures i taken, if possible, to reduce the impact of disclosure.

Since OI has established policies and practices .for the protection of confidentiality for its activities, the above are not necessarily applicable to 01.

055 Responding to Allecers. Those who provide allegations to NRC staff must be treated with respect, consideration, and tact.

Under no circumstances should they be dealt with brusquely or "

abusively. When allegations are received in writing, a prompt attempt to make personal contact must ordinarily be made in each case either by a letter, telephone call or even a personal meeting.

Contact should be earnest and professional. 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 periodically so that there is an awareness that the allegation is not being ignored.

7 Approved:

I NRC-0517-049 MANAGEMENT OF ALLEGATIONS .

056. Screening of Allegations. 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 not only on the specific allegation but on the overall area of concern, including the potential for generic implications 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 allegation is an important factor in determining the extent and promptness of staff resources commitment, it should not affect the staff treatment of the alleger as discussed in section 055, above.

057 Timeliness of Resolvino Allegations. 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 allegations 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 willing 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 Oraanization. For allegations involving a potentially significant and immediate impact on the public health and safety, the affected organization should be 'promptly informed to assure proper and timely action.

For other allegations, once information from allegers is received and understood by the Office / Region and if it is deemed appropriate by the Office Director / Regional Administrator, the licensee / vendor should be advised specifically by letter of the area of concern and should be requested 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 investigations / inspections should not be com-promised, such as by prematurely releasing or appearing to release Approved: 8

NRC-0517-056 MANAGEMENT OF ALLEGATIONS .

'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).

There are two exceptions to the above. The first exception is 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 / vendor 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), involving 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 handwritten notice. 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" A11ecations. 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 senior NRC manager as the task force leader, to resolve these issues within the usual short time frame between the date the issues were identified and the proposed date for issuance of an OL. A high degree of organization in the initial stages will be required in order to deal with these particular situations. To conserve 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 the large number of issues into two q Annenvad.

MANAGEMENT OF ALLEGATIONS NRC 0517-058 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 i

permitting resolution over a longer time frame, even subsequent to j OL issuance. Within the former group, subdivisions may be l

appropriate consistent with the planned stages of licensing for the facility (i.e. , criticality, 5% power, full power). ,

060 Appendix 1.  !

This appendix provides procedures for receipt, control, processing, and disposition of allegations assigned to NRC Offices or Regions and the procedures and guidelines used to record the receipt, status, and disposition of allegations in the AMS.

END Approved: 10

MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517 I PROCEDURES FOR SCREENING, ASSESSING, AND CONTROLLING ALLEGATIONS AND FOR ALLEGATION. MANAGEMENT SYSTEM (AMS)

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 of 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 and activities may come to the attention of the NRC staff by telephone, letter, news media reports, or by direct verbal contact at sites, in offices, at meetings, and even at social functions. All allegations, no matter how originated, are subject to processing in accordance with this manual chapter. It is imperative that allegations be recognized as such by staff members and processed pro-fossionally, promptly, and with consistent treatment.

It is very important to note that where safety is involved, the NRC does not recognize the term "off-the-record." A11egers who wish to provide off-the-record information must be clearly advised that information impor-tant to safety cannot be treated off the record, but that the information will be accepted officially and acted upon as necessary. The name of the alleger and other identifying information will be protected, however, under the confidentiality guidelines presented herein. '

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 alleger 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 calls). To this end, coordination with the appropriate Office or Region Allegation Coordinator must comply with the confidentiality 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, particularly resident and regional inspectors, regional supervisors, and 0ACs who are expected to receive the majority of allega-tions, should become fully familiar with the prescribed policies and proce-dures to ensure that the required actions are performed. /

j  ;

It is the responsibility of all employees who receive allegations,to take whatever steps are necessary to ensure that an appropriate OAC ivpromptly informed. Whenever possible, the person making the allegation'should be referred to either the OAC, other individuals as designated-byithe Region or Office, or arrangements should be made for the OAC or designated staff member to recontact the individual.

i Al-1 Approved:

NRC 0517, APPENDIX 1 MANAGEMENT OF ALLEGATIONS Part II: The Office Allegation Coordinator (0AC) l 1. The initial responsibility of the OAC is to identify the proper Action

• Office to which the allegation should be assigned for evaluation and resolution or Regions). in coordination with other 0AC's (either in the Offices i 2. The OAC serves as a focal point for administrative processing and con-

! 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 i

that clearly identify allegations assigned to the Region or Office i

i 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 providing accurate and timely information to the AMS, and briefed on the proposed final resolution of allegations. The OAC also ensures that the final resolution is properly documented.

! 3. The OAC assists technical staff members who are reviewing allegation information, primarily in the form of coordinating activities neces-1 sary to resolve issues. In addition, the OAC may assist in the formulation of a course of action 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 1 assigned and properly evaluated, and that the actions taken to resolve j

' the allegation, as well as the resolution, are properly documented and transmitted to the a11eger and the affect'ed organization as appro-priate.

5. The OAC will serve as the point of contact with DOL on matters involving discrimination under Section 210(a) of the Energy Reorganization Act and will coordinate as necessary with 0I and i the Enforcement Staffs.

l Part III: Receipt of an Allegation

1. Allegations Received by Telephone or Personal Visit i Any NRC employee who receives a telephone call from someone who wishes

. to make an allegation should have the caller transferred to the OAC

! or appropriate technical staff member in the Office or Region.

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 employees, when unable to refer the telephone call or the visitor as described, shall obtain as much information as possible from the individual (see item 3, below). When unable to locate the OAC or other technical staff member, administrative em- ~

ployees should refer an individual to a technical staff supervisor.

Approved:

Al-2

l., -

i

MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517

2. Allegations Received by 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-l 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.

3. Discussions with Allecer Any employee receiving a telephone call or visit, as discussed in item 1, shall attempt to obtain as much information as possible from the individual. It is crucial to identify:

n. fu11 name ~

b. complete mailing address I c. telephone number where the individual may be contacted

d. position or relationship to facility or activity involved

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 i

kept confidential. Explain further, if necessary, that Public Law 95-601 affords protection to the alleger by prohibiting an employer i

from discriminating against an employee for contacting the NRC. Basic i Requirement 054 provides further information regarding protection of confidentiality.

l The alleger may be informed that the NRC employee with whom he/she is i in contact does not have the capability to evaluate the information, to determine follow-up action, or to establish NRC jurisdiction; therefore, it may be necessary that someone else contact the alleger for additional information.

The alleger should be informed also, that--unless an objection is j

registered--he/she will be recontacted as soon as possible regarding .

the allegation. This may be done by telephone, personal visit, or by a letter to the alleger, at an address designated, which will also acknowledge the receipt of the allegation. This process will permit -

the alleger to review the information with the NRC to provide maximum assurance that the information has been correctly interpreted and j understood.

i j Al-3 Approved:

NRC 0517. APPENDIX 1 MANAGEMENT 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 member in 30 days or any other agreed upon period, for information on the status of any actions being taken on the information 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 by 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 DOL within 30 days of the occurrence of the discrimination event.

Part IV: Action by the Receivino Employee and the Office Allegation Coordinator (OAC)

1. When an allegation concerning a NRC-regulated activity is received, the employee receiving the allegation will provide the information obtained 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 as notification to NMSS 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 ensure that the alleger is properly contacted to acknowledge receipt of the allegation and to confirm the specifics of the allegation. Depending 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 0I Headquarters or to the cognizant OI Field Office for information. When responsibility for the handling of an allegation is transferred from one organizational unit to another, the alleger should be notified of the new point of contact (name and telephone number) by the individual who is relieved as contact in order to assure continuity. A single point of contact should be the rule.

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.

w. isn

! MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517 ,l

3. The OAC will coordinate allegation information with the technical staff and may assist in determining whether the information is suffi-cient to identify the issues. If the information is determined to be

insufficient, the OAC or designated staff member will assist in 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 i 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 procedures; or inadequate corrective actions; or overexposure (s) to radiation.

~

b. Allegations that involve wrongdoing such' as: record falsifi-

, cation; willful or deliberate violations; material false state-

ments; discrimination under Section 210(a) of the Energy Reorganization Act; or other improper conduct.

c. Allegations that involve matters outside the jurisdiction of NRC.

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, follow-up activities will be coordin-ated with the affected Offices and a Lead 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.

l 7. When applicable and after coordination, the Action Office should i' notify other agencies such as the Occupational Safety and Health Administration, DOE, etc. in dealing with allegations in category Notification to other Federal 4c. law 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.)

6 a

l i

j .

, NRC 0517, APPENDIX 1 l MANAGEMENT OF ALLEGATIONS

8. The .0AC ensures that a discrimination complainant under Section 210(a) of the Energy Reorganization Act is properly referred to DOL (the complaint must be filed with DOL within 30 days of its occurrence),

and that DOL is promptly notified of the complaint. Complaints should be filed with the Office of the Administrator, Wage and 1:our Division, Employment Standards Administration, U. S. Department of Labor, Roon 53502, 200 Constitution Avenue, N. W. , Washington, D. C. 20210. The Regional Administrator or Office Director should be promptly informed.

The OAC aiso maintains awareness of 00L's investigative intent, and ensures NRC consideration of the need for its own investigation by timely referral to 0I. The OAC will take reasonable steps to facilitate D0L's investigation by assisting DOL in obtaining access to ifcensed

, facilities and any necessary security clearances.

This type of i allegation should also be entered into the AMS.

9. If an allegation is determined to have generic implications, other i

Offices and/or Regions with responsibilities that may be affected will l be appropriately notified by the Action Office (e.g. , AEOD for opera-l tional data, RES for concerns affecting research activities, etc.)

10. Information regarding suspected improper conduct by NRC employees and I

NRC contractors will be brought to the attention of appropriate management for possible referral to the Office of Inspector and Auditor (0IA).

Part V: Documentina A11ecations I

i 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 i files of the Action Office in an officially designated location.

l 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 allegations 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 not be pursued. Instances such as these will be coordinated with the appropriate technical staff by

the OAC to ensure proper disposition.

1

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 personal interview with the Approved: Al-6

\

MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517 alleger may be warranted. In these cases, the OAC will consult with NRC management to determine the best way to obtain the details re-quired. Depending on the nature of the allegation and the time sensi-tivity, assistance from the Office of Investigations (OI) or other resources may be requested.

4. As soon 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 1

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 b'e appropriately handled to protect the identity of the confidential

alleger. The confidential alleger's identity or other identifying i information should not be released unless there is a "need to know"

(See Basic Requirement 054). .

Part VI: Evaluation by Coanizant Technical Staff

1. When an allegation package is received, the technical 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 immediate safety concern which must be quickly addressed?

b. Is the allegation a specific safety or quality issue or 'a gener-alized concern?

c. Has the staff previously addressed this issue?

l

d. Determine whether the allegation package contains sufficient information for a thorough evaluation. If it does not, identify the additional information that is needed.

Al-7 Approved:

l l

. l NRC 0517, APPENDIX 1 MANAGEMENT OF ALLEGATIONS

e. iDetermine whether all aspects of the allegation are adequately defined and described to permit 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.

g. Determine what specific issues are involved in the allegation and 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-q mine the best way to address the issues, i.

Determine 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-fate actions are necessary.

1. Determine whether investigative assistance will be needed.

m. Identify peripheral issues that could develop.

n. Consider if any licensing actions or board proceedings are pending which could be influenced or affected by the allegation. When an allegation involves a case pending before a licensing or appeal board or the Comunission, infomation 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. This decision must be made promptly by NRR or NMSS in accordance with office procedures,

o. Determine if other NRC Offices that may have an interest should be notifie,d. ,

I . p. As soon. as possible after the receipt of an allegation and the l releverit information has been reviewed and evaluated, the Action l Offic'e will make a preliminary detemination of the safety signi-

_ficance of the ites and the need for immediate regulatory action.

l -

" This determination will be reported in the next AMS update.

l Approved: Al-8

I

~

i i

\

MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517

q. Establish a schedule for the resolution of each allegation which is consistent with the licensing schedule, if applicable,

r. Notify the OAC or designated staff member when the status changes or action (s) is complete. ,

l

2. It is the responsibility of the technical staff within the Office or t Region to resolve each allegation that falls under its jurisdiction, l 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: Allegation Resolution Documentation

1. Allegation 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 according to the Comprehensive Records Disposition Schedule (NUREG-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 belittle or disparage the alleger.

4. Appropriate entries should be made in the AMS to close out 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 CFP 9.5 Exemption (7) due to actual, or the potential for, law enforcement action. File docueents, however, are frozen by the FOIA request for release when the case is closed should a 1 subsequent FOIA request be received. 1 Al-9 Anorovad- )

NRC 0517. APPENDIX 1 MANAGEMENT OF ALLEGATIONS 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.

2. As in Part VII.1 above, copies of the final report shall be placed in the NRC records system, and should be treated so as not to reveal the

identity of the alleger.

I 3. The foregoing does not apply to 0I investigative reports.

i PART IX: ALLEGATION MANAGEMENT' SYSTEM

1. General l a. For purposes .of the Allegation Management System (AMS) the defini-1 tion provided for an allegation is very general and broad. The significance or nonsignificance of an allegation will be judged 4

during the Action Office review and follow-up activities. There i is to be no screening of allegations 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, i

storing and retrieving all key information regarding all allega- .

l tions. The Action Office determines the necessary action to be i taken based upon the specifics of the 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 to contact for more specifics on an allegation. Additionally, 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 area. In some cases there may be a distinct grouping of concerns, for example, in two areas such as training and quality assurance. In such a case it may be appropriate to enter two allegations. A main objective is to ensure that the receipt of an allegation is entered and tracked in the system. An allegation is not completed and closed until an Action Office supervisor determines that appropriate action has been taken.

1 I i 1

l i /wr:rarrtL. NL-Wit

MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517 -

1

d. Sensitive information such as the names of persons making allega-tions shall not be entered in the system. All information entered on the form shall be unclassified and shall not contain any safe-guards information or any proprietary or commercial (2.790) infor-nation.

e. Some allegations may require action by two or more offices. For 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 0ACs 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

a. The Office of Investigations has jurisdication over all allegations of wrongdoing except those involving NRC employees or NRC contractors and will forward all allegations of a technical nature to'the appropriate Office or Region. The Office or Region will be responsible for entering all allegations--even those under the

purview of OI--into the AMS using a Region or Office AMS number.

b. For those allegations of wrongdoing, except those involving NRC employees or NRC contractors, assigned to the Region or Office:

(1) The Region or O'ffice OAC will coordinate with the OI Field i

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 descriptive material to assist the AMS user to the maximum extent possible.

(2) The Region or Office OAC will assign a Region or Office AMS i number. The 01 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.

!- (4) The OI Field Director will keep the Region or Office OAC apprised of the status of the allegation investigation and

provide timely information necessary to detemine the safety significance of the allegation to appropriate Regional or Office management and for use in updating the AMS.

.4 NRC 0517. APPENDIX 1 1

MANAGEMENT OF ALLEGATIONS .

! e i

(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 j Allegation. Data Form or in the AMS update. t l c. For allegations of wrongdoing received by OI, the OI Headquarters

or Field Director will coordinate with the respective Office or i

Region OAC to complete the items 2.b(1) through (5), above.

d. For allegations of a technical nature received by OI, the OI Head-quarters or Field Director will contact the respective Office or Region and follow the procedures as indicated in item 3 below l for the Receiving Office.

i j 3. Receivino 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 :

a. Complete that portion of the Allegation Data Form marked " Action Office," assign an allegation number to it, and fonvard a copy of the form to the NRR OAC 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. Completion of the follow-up action for an allegation will be recorded by updating the monthly status report. Name and telephone of Office or Regional A11ega-tion Coordinators will be indicated at the top of the update sheets; any changes in the designation of OACs will be made here.

c. As soon as possible after the receipt of an allegation and relevant -

information has been reviewed and evaluated, make a preliminary determination of safety significance and the need for any regu-latory action. This determination will be reported in the next AMS update.

Approved: Al-12 - - - - - -

MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517 .

^; d. Schedule the resolution of each allegation to be consistent with the licensing schedule and the safety significance of the alle-gation.

2

e. Make a determination regarding the need for a board notification to NRR or NMSS. 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 determination 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 comprise'd 4

of multiple concerns, separate working files may need to be estab-lished for each concern.

g. Provide status information to the NRR OAC for the AMS regarding 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 fomard 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 recom-i mandation as to whether any or all of them constitute grounds for delaying issuance of (or othe mise 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,

j. Ensure protection of the identity of all allegers when confiden-tiality is requested or implied by their actions.

5. NRR OAC

a. Upon receipt of an Allegation Data Form and updates, the NRR OAC will perform a quality check and will transmit the information to the Office of Resource Management (RM) for input into the AMS.

I This procedure will be modified when direct input or update capability to the AMS can be obtained for Offices and Regions.

b. NRR will coordinate with RM to provide Offices and Regions monthly status reports during the first week of each month. The monthly report will include a list of all open allegations and a list of those allegations closed during the last 30 days. The format for the status report is provided (Exhibit 3).

l .

_ _ A1~ 13_ .Agroved:_ _ _ _ _ _ _ _ . _ _ _

MA AGEMENT OF ALLEGATIONS EXHIBIT 1. NRC 0517 NRC orm 307 ALLEGATION DATA FORM

1. ALLEGATION NUMBER *: - -A.

A 2. FACILITY:

Name Unit No. Docket No, a.

b.

c.

3. TYPE OF REGULATED ACTIVITY:

a. Reactor O b. Vendor O c. Materials O d. Safeguards

e. Other . '

4. ERIALS LICENSE NUfGER:

5. FUNCTIONAL AREA (s):

$ O a. Operations O b. Construction O c. Safeguards C d. Transportation O e. Emergency preparedness 5 f. Onsite health and safety O g. Offsite health and safety

h. Other I 6. DESCRIPTION:

3 7. NUPEER OF GUNGERN5: -

8. SOURCE:

O a. Contractor employee O b. Licensee employee O c. NRC employee O d. Former employee O e. News media O f. Private citizen O g. Organization O i. Anonymous

• O h. Other

9. CONFIDENTIALITY REQutsitu: O Yes O No

10. DATE ALLEGATION RECEIVED: / /

4 *

11. DFLOYEE/0FFICE RECEIVING AlIEUlTUN: -

n 12. ACTION OFFICE CONTACT / PHONE:

13. SAFETY SIGNIFICANCE: O High C) Medium O Low O None

14. BOARD NOTIFICATION RECOP9 TENDED: O Yes O No

15. 01 NOTIFIED: O Yes O No '

16. STATUS:

C 0 pen O Closed Scheduled Completion Date: _/_/_

Date Closed: / / -

$ 17. WAS ALLEGATI0ff3lK5T RTIATED: O Yes O No O Partially C 18. WAS ENFORCEMENT ACTION TAKEN: O Yes O No C In Process 3 SEVERITY LEVEL: OI O II O III O IV OV e 19. WAS O! INVESTIGATION PERFORMED: O Yes O No O In Process

• 20. DID DISPOSITION RESULT IN LETTER TO MODIFY OR REVOKE LICENSE:

O Yes O No O SO.54(f) 0 30.32(d) 0 70.22(d) Q 40.31(b)

M Disposition:

21. ALLEGER NOTIFIED OF GLD5EQUT.:

'O Yes O No

22. REMARKS:

F 23. GR055 REFERENGE: ,

/

24. PROJECT MANAGER / PHONE:

I 25. APPLICANT'S CONSTRUCTION GOMPLETION DATE: / ,/ .

g 26. 80ARD NOTIFICATION ISSUED: O Yes O llis _/- , 7 ~

J:! /

. /

.w El-1 Approved:

1 l

l

NRC 0517. EXHIBIT 1 MANAGEMENT OF ALLEGATIONS l '

INSTRUCTIONS ,

l

1. A11ega, tion Mus6er Action Office fill in the boxes to uniquely iden . . 6 tify this allegation 0FFICE official NRC office abbreviation for the )

Office responsible for followup activities.

YEAR last two digits of the calendar year in '

1 which the allegation was reported to NRC.

A identifies this number as an allegation number.

NUPSER sequential number assigned by the Office or i Region responsible for the followup activities. -

EXAMPLE Ine 2?th 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 nus$er, 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 sentences).

8e 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 sensitive. write only SENSITIVE.

7. Numer of Write the total number 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 tha box that most clearly describes the affiliation. DO NOT include the name of the indi-

! vidual making the allegation. . . .

9. Confidentiality Indicate whether confidentiality has specifically -

Requested been requested.

13. Safety Provide an estimate of the safety significance of Significance allegation l Example (a) Check "high" for an alleged deft-ciency in an operating plant that could have an 1smediate and great i

effect on public health and safety 4

' (b) Check" Low"foranallegeddeficiency 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 to Modify or method of disposition report, inspection (e.g.,

report, SER, letter,)

etc.technical and identify Revoke License docusunt.

Include additional information as appropriate.

i 22. Remarks

! EXAMPLES: list other allegations related to this I allegations list other NRC offices responsible ,

! for followup activities on this allegation.

23. Cross Reference Identify other related allegations and investiga- .

tions by alpha-numeric designation.

! 25. Applicant's For plants under construction, enter the appli-

• Construction cant's estimated construction completion date;

Cunpletion Data there is no need to provide this information until j 3 or 4 months prior to the estimated date.

26. Board Notification Indicate whether a board notification was issued.

Issued Approved: El-2 l

.. '. 3O$$M on

-._o5

. m2 ;G A m E @,U

)

4 ) ) ) ) ) ) ) ) ) )

8

/ S W (

• ( ( ( ( ( ( ( ( (

s N I 4 e s  : 4 r e 4 O

/

FO T OI A e a s n n e 5

4 S T L 5 O EADP LEGEE 9 _

ASESp

T PLOu _

E OULLC T TNACI A

D

) )

N M ) ) ) ) ) ) ) ) )

U R

EW STI (

( ( ( ( ( ( ( ( (

NST S  : s e s s FOYA OIS[

s i u e r

s a

s i i n 5 2

T g 0 1

SAEo LEGHc ASETi T S L c OLLNi_

TNAI SD NL 2 o i s i o r o 7 OO s a s s r a 4 I R TSE 3 AYD GAL NEDO EL PL0R OA9O Y

R 4

4 S_

IH ) ) ) ) ) ) ) ) )

)

9 S ET

• 9 N N ( ( ( ( ( ( ( ( ( (

t O EO s 2 n 4 z e r e e S4 0

I HM e e r r e s 7 T T 4 L9 A E An G FH C ENOT '

IY LE TA LPSF SM I

AOAO T

A T S S N -

d O H e I T O o e e 2 o s o o 8 v T N n 1 l ADGO o GENM v ESI n LORE i LLUH ACDT s

. n r

S e N C O H n ID T O TE q a O a o n a i e 2 7 C AVGo 2 GINH f EEI O LCRE LEUH r ARDT '

e b

m u

3 n 3

l 6 E S a 4 C L t 2 I S A o 1 F S n i I v T T R

- F O

E I

n N

a N 0 n r

n a

i n

v a

O T

• 1A 3 g 3<I.

, .[.j<. . I  : l

] ....- .

i i

R-8246128 RUN DAIEs 04/08/84 PAGE I

)

l LIST OF ALL ALLEGATIONS 9

m FACILITY HAME AL L EGATION . HimBER CONIACT FIS PHONE STATUS  %

o (BISCO FIRE SEAL 5) NRIII-83-A-0029 W GULDEMOND 388-5608 '

SPEN AMERICAN TESTING LABS DIR4-83-A-0043 RK NERR 728-8110 SPEN N

r-AMERICAN TESTING LABS RIV-83-A-0023 TF WESTERMAN 728-8802 CLSSED F1 AMERSHAM CORP ARKAN5A5 182 RII-84-A-0026 RIV-84-A-0008 8 URYC TF HE5fERMAN 242-4893 728-4800 SPEN SPEN

-4 ARKANSAS 182 RIV-84-A-0048 IF WESTERMAN 728-8800 l

ARMED FORCE 5 RADI0 BIOLOGY RES INST RI-83-A-0089 JD KINNEMAN 488-8252 ePEN OPEN st ARH0/DAP CORP. MICNIGAN CITY. IN NRIII-84-A-0013 DJ SRENIAW5KI 388-5688 CLOSED M ATLANTIC CITY MEDICAL CENIER RI-84-A-9024 JE GLENN 488-1264 CLOSES ATLANTIC NUCLE 4R SERVICE 5 RII-83-A-0107 GA TOCD 242-4893 CLOSED

AUBURN STEEL MILL RII-83-A-0085 GA TODD 242-4893 CLOSED SANMSON. INC. RII-84-A-0049 B URYC 242-4393 CLOSED i

BARCLAY INTERN 4TIONAL RIV-83-A-0082 TF WESTERMAN 728-8100 OPEN BASIC ENGINEERS NATIONAL VALVE. PA KIE-84-A-0003 EW MER5CHOFF 492-4572 OPEN 3

C BAYTOWN INDUST X-RAY CONSI CO RII-83-A-002) GA 100D 242-4893 CLOSED i 8 DEAVER VALLEY I R I-8 3- A-0 0 7 4( * * ) LE TRIPP 488-1227 CLOSED i BEAVER VALLEY I RI-83-A-0080 LE 1RIPP 488-8227 CLOSED l BEAVER VALLEY l RI-83-A-0084 LE TRIPP 408-1227 CLOSED

! BEAVER VALLEY l ; RI-84-A-0006 LE IRIPP 488-8227 CLOSED j BEAVER VALLEY l RI-84-A-0007 LE TRIPP 488-8227 OPEN BEAVER VALLEY 2 RI-83-A-0088 LE 1RIPP 488-1227 OPEN BEAVER VALLEY 2 RI-84-A-0001 LE IRIPP 484-8227 OPEN BEAVER VALLEY 2 LE TRIPP 488-1358 OPEN BECNTEL RI-84-A-0043 RIV-83-A-0035 (**) IF WESTERMAN 728-8800 CLOSED BELLEFONTE I RII-83-A-0039 GA TODD 242-4893 CLOSES i BELLEFONIE 1 Ril-83-A-0040 GA 100D 242-4893 CLOSED BELLEFONTE I RII-83-A-0090 GA TODO 242-4993 CLOSED l@ BELLEFONIE I RII-83-A-0122 5 URYC 242-4993 OPEN l 13 BELLEFONTE I RII-83-A-0123 B URYC 242-4193 OPEN i y SELLEFONIE 1 RII-84-A-0001 B URYC 241-4193 OPEN m 1

l l < BELLEFONIE I RII-84-A-0009 GA 1000 242-4993 OPEN ><  !

1 BELLEFONTE I BELLEFONTE I RII-84-A-0034 RII-84-A-0052 JB LANKFORD JB LANKFORD 242-4994 242-4994 OPEN CLD5ED 3ou BEST INDUSTRIES INC. ARLINGTON VA BETHESDA N05P. CINCINNATI. ONIO RII-84-A-0027 A TILLMAN DJ SRENIAW5KI 242-5413 348-5688 CLOSED y 1 RIII-83-A-0071 Cl05ED l BIG ROCK POINT RIII-83-A-0067 LA GREGER 388-5644 CLOSED 68 j BKK WASTE DUMP. W. COVINA. CA '

RV-84-A-0041 RD IN0MA5 463-3763 CLOSED j BORG WARNER RIV-43-A-0029 TF WESTERMAN 728-8100 OPEN 2 i

l B"!IDE PRODUCT:5 INC 30 VARI ELECTRIC INC RIV-83-A-6460 OIR4-83-A-0077 RK NERR RK NERR 728-8880 728-8190 OPEN SPEN 5

j BPR INSTRUMENTS INC. EVAN5 VILL. IN DJ 5RENIAWSKI 388-5681 BRAIDWOOD 1 RIII-84-A-0034

• MS LITTLE 388-5574 CLO5ED @

j N R I I I A-0 0 ldi( ** ) OPEN y l -

i i N MULf!PLE FAC1LillES ASSOCIATED WITH THIS ALLEGATION NUMBER

• • ihanber Of C0rcerns involved in this allegation. -

] ..- ,

i

- ~ - ' - -- ~

MANAGEMENT OF ALLEGATIONS EXHIBIT 4, N'RC 0517 CONFIDENTIALITY AGREEMENT -

. I have infomation that I wish *a provide in confidence to the U.h Nucleer Regulatory Comission (NRC). I request an express pledge of confiden-tiality as a condition of providing this information to the NRC. I will not provide this infdrastion voluntarily to the NRC without such confiden-

. tiality being extended to me.

It is my understanding, consistent with its legal obligations, the NRC, by agreeing to this confidentiality, will adhere to the following conditions:

(1) The NRC will not identify me by name or personal identifier in any NRC initiated document, conversation, or communication released to the public which relates directly to the information provided by me. I under-stand the term "public release" to encompass any distribution outside of the NRC with the exception of other public agencies which may require this information in furtherance of their responsibilities under law or public trust.

(2) The NRC will disclose my identity within the NRC only to the extent required for the conduct of NRC-related activities.

(3) During the course of the inquiry or investigation the NRC will also make every effort consistent with the investigative needs of the Commission to avoid actions which would clearly be expected to result in the disclo-sure of my identity to persons subsequently contacted by the NRC. At a

' later stage I understand that even though the NRC will make every reason-able effort to protect my identity, my identification could be compelled by

' orders or subpoenas issued by courts of law, hearing boards, or similar legal entities. In such cases, the basis for granting this promise of con-fidentiality and any other relevant facts will be communicated to the

) authority ordering the disclosure in an effort to maintain my confiden- -

tiality. If this effort proves unsuccessful, a representative of the NRC will attempt to inform me of any such action before disclosing my identity.

I also understand that the NRC will consider me to have waived my right to confidentiality if I take any action that may be reasonably expected to disclose my identity. I further understand that the NRC will consider me to have waived my rights to confidentiality if I provide (or have pre-viously provided) information to any other party that contradicts tne information that I provided to the NRC or if circumstances indicate that I an intentionally providing false information to the NRC.

Other Conditions: (ifany)

I have read and fully understand the contents of this agreement. I agree with its provisions.

Date Name:

Address:

Agreed to on behalf of the U.S. Nuclear Regulatory Consnission.

Date Signature Name:

Title:

E4-1 Approved:

.-- - . . - _ - _ _ . . - _ .. - - ._ - - - _ - - ... - - -. ._. --