ML20207H361
| ML20207H361 | |
| Person / Time | |
|---|---|
| Issue date: | 08/15/1988 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20207A593 | List: |
| References | |
| NRRL-1000, NUDOCS 8808250348 | |
| Download: ML20207H361 (4) | |
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'o UNITED STATES I 8"' o NUCLEAR REGULATORY COMMISSION l I
f , WASHINGTON, D. C. 20!55
+,*****,o August 15: 1988 MEMORANDUf1 FOR: All NRR Employees i FROM: Thomas E. Hurley, Director Office of Nuclear Reactor Regulation
SUBJECT:
NRR OFFICE LETTER NO. 1000, REVISION 2 l REQUESTING 01 INVESTIGATIONS AND NOTIFICATION l TO 01 0F POTENTIAL WRONGDOING PURPOSE This office letter establishes NRR procedures for (1) requesting the Office of 4 Investigations (01) to conduct investigations into matters involving wrongdoing ! on the part of employees of licensees or licensee contractors, and (2) notifying OI when staff is aware of a matter involving potential wrongdoing. This revision supersedes NRR Office Letter No. 1000, Revision 1 dated December 7, 1987. j DEFINITION ! Wrongdoing. Intentional violations of regulatory requirements and those ! violations that result from careless disregard of or reckless indifference to l regulatory requirements amounting to intent. ' RESPONSIBILITIES AND AUTHORITIES
- 1. The Executive Director for Operations (EDO) is responsible for approving all requests to 01 for investigations originating in NRR.
- 2. The Director, NRR, authorizes all OI investigation requests being forwarded to the E00 for final approval. ,
- 3. Division Directors, NPR, are responsible for:
- a. Ensuring that all requests for 01 investigations are prepared in accordance with the guidance in this revised office letter.
- b. Ensuring that the priority assigned to O! investigation requests is in accordance with the Connission-approved guidance. (See Basic Requirements.)
- c. Ensuring that there is a regulatory need for the 01 investigation.
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l r All NRR Employees 4. The NRR Office Allegation Coordinator (0AC) is responsible for:
- a. Reviewirg and concurring on all requests to 01 for investigitions before they are submitted to the Director, NRR, for approval,
- b. Making recommendations to the Director, NRR, concerning the regulatory need, priority assignment and other aspects of requests '
for 01 investigations,
- c. Maintaining a system for tracFing all 01 infestigation requests, aM maintaining a comprehensive file of all such requests originating in NRR.
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- 5. All NRR employees who are involved with matters of potential wrongdoing by licensee or licensee contractor employees are responsible for ensuring i that such matters are brought to the attention of 01, consistent with the I guidance contained in the memorandum (Enclosure 1) dated August 11, 1987, l from V. Stello to Office Directors and Regional Administrators, subject:
"Notification to 01 of Potential Wrongdoing." '
BASIC REQUIREMENTS I A. Requesting 01 Investigations l NRC Manual Chapter 0517. "Management of Allegations," dated June 20, 1987, provides agency policy with regaro to initiating, prioritizing and terminating O! investigations. NRC Appendix 0517, Part III, provides, at Exhibit 3, a standard form for requesting investigations. A copy of this form is Enclosure 2 to this revised office letter; the form will be used for all 01 investigation requests. j As required by HRC Manual Chapter 0517, requests to 01 for investigation of i wrongdoing should be initiated when (1) there is a reasonable basis to believe that wrongdoing is involved; and, (2) staff determines an investigation is necessary for it to decide whether enforcement or other regulatory action is required. The Commission, in its response to SECY 85-369, "Threshold and Priorities for Conducting Investigations," stated, "A reasonable basis for I belief of wrongdoing exists when, from the circumstances surrounding it, a violatien of a regulatory requirement appears more likely to have been inten-tional or to have resulted from careless disregard or reckless indifference than from error or oversight." ) All requests for investigation will be assigned a priority by the originating l organization, and the basis for that priority will be clearly stated. l Enclosure 3 is an excerpt from NRC Appendix 0517, Part III. This enclosure j provides examples of the three priority levels and must be used in determining ' the priority of all requests for investigation. l l I l l
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l i ,. All NRR Employees 3 Allrequeststo01willbesubmittedonthestandardform(EncEsure2)which will be prepared for the signature of the EDO. A transmittal memorandum, summarizing the request and recommending ED0 approval, shall be prepared for the signature of the Director, NRR. The NRR OAC must be placed on the concurrence list for this memorandum. 1 If the ED0 approves the 01 request, the signed form will be returned to NRR l for dispatch to 01 Headquarters. All 01 requests will receive limited distribution. Access to the information should be on a need-to-know basis. The NRR 0AC will maintain one complete i copy and the originating branch member shall maintain one copy. No copies are ' to be placed in the docket file, the DCS, PDR or LPDR. Copies shall be provided l to (1) the appropriate Regional Administrators, (2) the EDO, (3) OE, and (4) OGC. ' No other distribution should be made. All copies will be 'Jispatched in sealed I envelopes marked "addressee only." In addition, OE is responsible for tracking i activities associated with OI investigations and shall receive copies of all / correspondence that relates to the status of OI referrals and investigations. i B. Notification to O! of Potential Wrongdoing The memorandum from the EDO (Enclosure 1) requires that 01 be notified when staff is aware of a matter involving potential wrongdoing. This notification , is to be made independent of and should not await a subsequent decision by ' staff to make a fornal request to 01 for an investigation. Under the NRC's :
"open door policy," employees are free to contact 01 directly when they feel the need exists to do so. H uever, in most situations the matter should be i raised to the Branch Chief or .'roject Director level for 01 notification.
Oral notifications to 01 are permitted, but care should be taken to document l that such notification tonL place. ; EFFECTIVE DATE This office letcer is effective innediately. l T 50 mas E. Murley, n ector O ffice of N~. . de : tor Regulation
Enclosures:
As stated cc: See next page Distribution Central Files PDTSS R/F NRC PDR RBrady l TCox *SEE PREVIOUS CONCURRENCE ' (1000REV2)
*Tf :PTSB *TPSS:PTSB *TPSS:PTSB *PTSB *D:PMAS *ADT R
$ ady :TCox HSmith CThomas FGillespie THartin ley ir8/03/88 : 8/03/88 8/04/88 8/05/88 8/08/88 8/09/88 . /fr/88 t/rq$t _
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All NRR Employees 4 cc: V. Stello, ED0 J. Ta; lor, ED0 J.Partlow,OSP(70) W. i;cDonald, ARM J. Lieberman, OE B. Hayes 01 W. Russell, R-I J. Grace, R-II A. Davis, R-III R. Martin, R-IV J. Martin, R-V SECY OGC NRC PDR o T t 4 I 8
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