ML20211K789
| ML20211K789 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/1984 |
| From: | Norry P NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Besaw W, Goldman P, Miller W NRC, NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20211K772 | List: |
| References | |
| FOIA-86-183 NUDOCS 8612150158 | |
| Download: ML20211K789 (53) | |
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OCT 011984 00II MEMORANDUM FOR:
Peter J. Goldman, Director, MDTS William O. Miller, Chief, LFMB William J. Besaw, Director, TIDC Paul E. Bird, Director, O&P Edward L. Halman, Director, DC John H. Corley, Director, FOS Raymond J. Brady, Director, SEC Joseph M. Felton, Director, R&R FROM:
Patricia G. Norry, Director Office of Administration
SUBJECT:
MANAGEMENT OF ALLEGATIONS By memorandum dated September 19, 1984, the EDO provided interim policy on the management of allegations in the form of a proposed manual chapter, which I circulated to you on September 21.
The policy requires the appointment of an Office Allegation Coordinator.
I am appointing Jim McDermott the Office Allegation Coordinator for ADM.
The policy also requires that each office establish internal procedures so that all employees are aware of requirements for receipt, processing, control, and disposition of allegations. To that end, please provide a copy of the attached procedures to every member of your staff.
Se-J Patricia G. Norry, Directo
. Office of Administration
Attachment:
As stated co:
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1.
Any ADM employee who receives a telephone call or visit from someone Who wishes to make an allegation should have to the ADM Office Allegation Coordinator (OAC)the caller or visitor referred McDermott, The ADM OAC is Jim Director, Program Support Staff, MN3B-2100, X27515.
2.
When it is not possible to refer the caller or visitor to the OAC, an employee receiving a telephone call or visitor should attempt to obtain the following information:
a.
full name, b.
complete mailing address, telephone number where the individual may be contacted, c.
d.
position or relationship to facility or activity involved, e.
nature of allegation.
3.
If the alleger declines to provide the above information, tell the individual that:
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If so requested, his/her identity will be kept confidential.
o Federal law prohibits an employer from discriminating against an o
employee for contacting the NRC.
You do not have the capability to evaluate the information.
o
-You would like to have someone else~ contact him/her to acknowledge o
receipt of the' allegation and to assure that the information has been correctly interpreted and understood.
4.
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 in 30 days or any other agreed upon period for information about any actions being taken on the information supplied.
5.
For allegations of discrimination for having contacted the NRC, inform the alleger that NRC will look into the complaint and any safety concerns identified by the alleger.
To assure personal employee rights are protected, advise the alleger that the complaint must be filed with the Department of Labor within 30 days of the occurrence of the discrimination event.
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The contact with the alleger and the results of any discussion
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should be documented and forwarded to the OAC.
7.
Personnel responsible for distribution of mail vill forward correspondence 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 containing 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.
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REGION III MANUAL TEMPORARY INSTRUCTION 0520 PROCESSING ALLEGATIONS, COMPLAINTS AND INVESTIGATIONS f
A.
Purpose To establish Regional Office policy and procedures for the proper processing, control and disposition of allegations, complaints and concerns involving NRC licensed facilities identified by, reported to, or received by any Region III staff member, and for the interface of such allegations with the NRC Allegation Tracking System.
B.
General E
Allegations, complaints and concerns pertaining to NRC licensed facilities and activities may come to the attention of the NRC staff by telephone, letter, or by direct verbal contact at facilities, offices, and meetings.
It is possible to receive allegations at social functions or through news media reports.
Allegations must be recognized as such by staff members, and processed professionally, promptly and with consistent treatment.
For the purposes of this procedure, an allegation is considered to be any assertion of wrongdoing *, lack of compliance with NRC requirements, or hazard to public health and safety or national security involving an NRC regulated activity.
Instances where a matter is brought to an inspector's attention during an inspection as a question, inquiry or item of concern (not as a flat assertion) need not be entered into ATS. However, all actual. allegations (assertions) made to the NRC must be entered into the system, even if resolved during the inspection or discussion.
(See Item G.10 re:
allegations made directly to licensees.)
- Any indication of wrongdoing identified in an allegation or during an inspection is to be brought to the prompt attention of the Investigation / Allegation Coordinator. As used in this context,
" wrongdoing" is broadly defined as any regulatory violations which appear to be knowing, willful, or deliberate and/or entail falsifica-tion of records or other attempts to cover-up or conceal a violation.
j It does not generally include errors of omnission or commission l
unless one or more of the above criteria are present.
In any case l
of doubt, contact the Investigation"11 cgm
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until discussed with the Region III Investigation /MM "'r-e^^"'M:
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and Office of Investigations.
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Information regarding suspected improper conduct of NRC employees will be brought to the attention of the Regional Administrator's Office for possible referral to the Office of Inspector and Auditor (OIA).
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3.
Inqui ry An activity involving minimal effort to determine the appropriate response to information reported to the NRC.
Typically, an inquiry entails the use of the telephone or written correspondence rather than formal interviews or other investigative measures; however, formal interviews will be conducted if required. The inquiry may be conducted by the Office of Investigations or the Regional staff.
4.
Investigation W601nLd f
Formal activitiesAconducted by the Office of Investigations at the request of the Regional Administrator, with or without technical assistance.
The Office of Investigations is the lead action office for all investigations.
5.
Inspection As used in this procedure, routine or special inspections are activities specifically designed to examine and subsequently resolve allegations. An inspection, may be either routine or reactive.
The routine inspection is essentially the planned program. The reactive inspection, involves response or reaction to some influence outside the defined program, usually initiated by an event or allegation.
6.
Alleger An individual who provides information to the NRC about inadequacies or improprieties (an allegation).
The individual may be a concerned private citizen, a current or former licensee or contractor employee, a representative of a local, state, or Federal agency, or an NRC employee.
7.
Confidentiality The term " confidentiality" refers to the protection of data which directly, or otherwise, could identify an alleger by name. The purpose of ensuring confidentiality is to protect against inadvertent disclosure of an alleger's identity.
It is a precautionary measure, and 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.
8.
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A process involving the prompt review by the cognizant technical supervisor and the wherein the facts associated with an alle-gation and other factors such as time sensitivity, importance to safety, plant status, and media interest are considered. This will permit determining appropriate response ti ing, coordination with
.the Office of Nuclear Reactor Regulation ~
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and Safeguards, necessity for. notifying licensing board, technical expertise required, and where to assign responsibility for further action.
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A Any employee who receives an allegat son must be aware that it is essentsal to protect t he adentity of the individual making the allegation to preclude the inadvertent or premature disclosure of the individual's idegtity#CMEF ~'n 97o this end, coordination with the Investigationf-outsjde NRC M&
HSE E is necessary.
This protection of an individual's identity is not to be confused with the principle of " confidentiality,"
which is discussed separately.
It is very important to note that where safety is involved, the NRC does not recognize the term "off the record." Individuals who wish to provide off-the-record information must be clearly advised that safety-related information cannot be treated off the record, rather the information will be accepted officially and acted upon as necessary.
It is the responsibility,of employees who receive allegations to take wh b ~s,p._
C#gt,ever_ gtegs are necessary to ensure that the Investigation /Allcs.iivir e--- I Mnder is verbally informed within one workday of receipt of an allegation.
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For Region III, the Investigation /Allcsoiica C;;r L oin is Charles H. Weil.
The alternate is cc
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- has the primary responsibility to ensure that all allegations are properly documented, screened, controlled, and expeditiously processed.
C.
Definitions 1.
Allegation An unvalidated statement that an inadequacy or improper activity has occurred.
This may include a general statement such as " periodic tests are being falsified," or a specific statement such as " field weld number AFXW-392 was not in accordance with welding procedure W-152 in that the wrong type of weld rod was used."
The implication is that something is wrong; however, the statements are treated as allegations until their validity is established.
I 2.
Complaint (a type of allegation)
A formalized protest against an individual or a licensee that may be in the form of a legal deposition, sworn statement or affidavit, intervenor petition, or congressional inquiry. The term " complaint" l
is limite5 to cases where individuals present formal allegations of deliberate actions taken by others, which are detrimental to the personal livelihood or safety of the allegers.
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XCS 1.
The PRC serves as a focal point for administrative proce g pg and control of all allegations received in Region Ill. The N is responsible for tg Qing allegations from initial receipt to final resolution. The W establishes and maintains files that clearly identify allegations, complaints, and suspected inadequacies and improper activities received by the Regi and documents actions initiated to resolve such matters. The ensures that management and cognizant staff are informed of allegations, kept current on the status of allegations in the Allegation Tracking System, and briefed on proposed final resolution of allegations.
JtCS 2.
The FAC assists technical staff members who are reviewing allegation information, primarily in the form of coordinatgactivities necessary to resolve issues.
In addition, the E may assist in the formulation of a course of action to resolve issues.
JDCS 3.
The PKC is the principal interface between Region III and the Office of Investigations. All requests for assistance i o the Office of Investigations will be immediately brought to the
's attention for coordination with the Office of Investigations.
E.
Receipt of an Allegation 1.
Allegations Received by Telephone or Personal Visit Any NRC employee who receives a telephone call from someone who wishes to make an allegation, express a conce r register a complaint, should transfer the caller to the whenever practical.
Likewise, if an individual appears in on at an NRC Office, the individual should be referred to the Technical emp1ppgs, when unable to refer the telephone call or the visitor to the M, shall obtain as much information as possible from the individual (see paragraph 4, below). Administrative employees should refer the individual to the cognizant technical staff supervisor.
If the caller seems to be timid or refuses to be transferred, the NRC l
employer should endeavor to obtain as much detail as possible from the caller. This will allow the NRC to obtain as much information before the caller has the opportunity to discontinue the call.
l Whenever possible the cognizant technical staff supervisor and the
'IdT MC will discuss the issues with the individual.
2.
Allegations Received by Mail Personnel responsible for opening and screening mail and NRC employees receiving unscreened mail (e.g., addressee only mail) will forward correspondence that appears to contain an allegation to the 1Dc5 LAC. 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 FAC.
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4.
Allegations Received by_ R_e_s i dent Inspectors Resident Inspectors will handle allegers as herein described.
sQ Resident Inspectors wi M elephone the cognizant technical staff supervisor and/or the M immediately after receiving the allegation.
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The Resident Inspector will document the allegation as described i
elsewhere in this procedure and provide the 1AC with the documented allegation within five workdays of its receipt.
5.
Discussions with A11eger Any employee receiving a telephone call or visitor, will obtain as much information as possible from the individual, acquiring the following information as a minimum:
a.
full name b.
complete mailing address home and business telephone numbers and the individual's c.
preference as where to be contacted d.
position or relationship to facility or activity involved detailed description of allegation, complaint, etc.
e.f the individual declines to provide the 'above information, ettempt to establish the reason (s) using the following guidance:
If the individual is concerned about protecting his identity, inform the individual that if he so requests, his identity will be kept confidential. Explain further, if necessary, that Public Law 95-601 j
prohibits an employer from discriminating against an employee for contacting the NRC. Unless the identity of the caller is learned, it may not be possible to provide the protection afforded by Public Law 95-601.
The individual may be informed that the NRC employee with whom he is in contact does hot have the capability to evaluate the information to determine followup action or to establish NRC jurisdiction; therefore, it may be necessary that someone else contact the individual for additional information.
The individual should be informed that it is NRC policy to send a l
1etter to the individual, at'an address he designates, documenting the NRC understanding of his allegations or concerns.' This will permit the alleger to review the information and inform the NRC if his information has been incorrectly interpreted. The individual l
will be advised of this policy and unless he objects, a letter will be prepared and forwarded in accordance with these procedures.
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It' the individual persists in not identifyins himself after'the above I
explanations, document the allegation in as much 91.. possible and advise the individual that be may contact the
' in thirty days, for information on the status of any actions being taken on the information supplied.
The individual providing allegations to the NRC staff must be treated with respect, consideration and tact.
Under no circumstances should they be dealt with brusquely or under an abusive atmosphere.
When allegations are received in writing, a prompt attempt to make contact with the alleger should be made.
Contact, when made, should be earnest and professional.
Without exception, the individual making the allegation should be advised of the results of the inspection made in response to their allegation (s), so that they are aware their problems have been addressed.
Allegations should be screened for importance and the more ser'ious addressed first. Serious or not, allegations should be addressed as promptly as resources will allow.
Follow up 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.
When a number of allegations point to or reinforce indications of a broader problem, it is appropriate to assume that such a problem may exist.
Prompt action to broaden the scope of our 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 person making the Ec*t allegation.
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F.
Action by the Investigation / Allegation Coordinator (I*e)
Tc3 1.
Upon receipt of an allegation, the I*e will assign a Regional Office Case File Number for entry into the tracking system, prepare an appropriate investigation / allegation case file folder and conduct a preliminary review of the file to determine the required coordination In addition to the foregoing initial administrative tasks, actipryq, ill also prepare an NRC Form 307, Allegation Data Form the Me v (attached) and forward the completed form to NRC Headquarters.
The NRC Form 307 serves as notification to NRC Headquarters that an
, allegation is being tracked within the Region. This form will also be used to forward allegations to other Regions or Offices if the action is to be taken by another Region or Office.
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Whenever the alleger's name and address is ow the IAC'will prepare
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and forward an acknowledgement )pgter to the leger, restating the individual's allegation. The EE will initiate the Region III Allegation Traveller (Attached) trancmission of the allegation to the cognizant division. The will also provide copies of the allegation documentation and the letter sent to the alleger (with the alleger's identity concealed) to the cognizant technical staff l
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allegation with the cognizant technacal staff supervisor at periodic S
intervals until the matter has been satt.g.ctorily resolved and g
documented by the cognizant division.
Then the case will be consid-ered closed and an entr de to that effect in the Allegation Tracking System by the
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The 1AC will coordinate allegation information with the technical staff and may assist in determining whether the information is sufficient to identify t W ssues.
If the information is determined to be insufficient, the W will assist in further contact with the alleger. A single point of contact with an alleger provides a means of better control of communications, aids in developing rapport, establishes continuity in the flow of information between the regional offices and the NRC, and aids in protecting of the alleger's identity.
TCS 4.
The FAC assists the cognizant technical staff in identifying and separating the issues involved in allegations into the following categories:
Allegations that are purely technical, such as inadequacies in a.
procedures, qualifications or training, inadequate implementa-tion of procedures, inadequate corrective actions, and radiation overexposures.
b.
Allegations that involve ~ wrongdoing, record falsification, willful or deliberate violations, material-false statements, or other improper conduct.
c.
Allegations involving NRC employees or contractors for which OIA must be notified.
l.
d.
Matters better handled by another NRC office (e.g., another region, NHR, NMSS, etc.,).
e.
Allegations that involve matters outside the jurisdiction of l
NRC.
5.
It should be recognized that technical issues involving failure to meet requirements have the potential for being willful or deliberate violations. However, in the absence of specific allegations or willfulness or deliberateness, such issues will normally be tracked separately as technical issues and resolved using inspection program resources.
If an allegation covers issues that affect other Regional or Headquarters Offices, followup activities will be i
coordinated with the affected offices and a. lead office will be designated.
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The MC serves as the routine point or cont.,g 3, sween Region 111 E
staff members and the Office of Investigations Field Office',
Region III (OI:RIII).
Region III staff gebers should normally 1'
coordinate their requirements with the W, who in turn wil erform any necessary coordination with OI:RIII.
Conversely, the will normally be the routine point of contact for OI:RIII, thereby eliminating the need for OI:RIII personnel to arrange for and conduct multiple briefings to the Region III staff.
G.
Documenting Allegations 1.
In order to ensure proper screening and evaluation, as much information as possible 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 relatively well defined. All allegations, regardless of source or how received, must be documented, screened, and evaluated.
2.
There will be occasions when the allegations obviously have no substance and appear to represent a distortion of facts. However, even in these cases, documentation is necessary that identifies the contact, the general content of any communications, and the, basis for a conclusion that the matter need not be pursued.
Instances such as these 1 be coordinated with the appropriate technical staff by the to ensure proper disposition.
3.
The importance of obtaining and documenting all possible details about an allegation can not be overemphasized. The evaluation of the allegation as well as the proposed ~ course of action that will be initiated to resolve the issue, will be based primarily on this information.
In some cases, the information may be so substantial, technical, or indicative of possible wrongdoing, that a personal g interview with the alleger is warranted.
In these cases, the fAC will codsult with Region III management to determine the best way to obtain the details required. Depending on the nature of the allega-l tion and the time sensitivity, ascistance from the Office of Investigations (OI).
If OI assistance is appropriate, a formal l
request for an OI investigation will be made by the Regionag Administrator.
This request will be prepared by the FAC F 4.
As soon as ponsible after receiving an allegatippgor becoming aware l
of information that indicates wrongdoing, the W shall be notified.
l No actions will be taken to verify the validity of the allegations i
or concerns, nor.p)gli such matters be discussed with licensees
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until after the NE and the cognizant technical branch chief have briefed appropriate NRC management.
5.
Information regarding suspected improper conduct of NRC employees i
will be documented in inter-office memorandum and brought to the attention of Regional Administrator for possible referral to the Office of Inspector and Auditor (OIA).
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copies of the Allegation McPort shall c eadc or retained. This protection to both the alleger and will provide an extra measure of any individua,1 against whois the allegation is being made.
The f*C E5 may copy and distribute an Allegation Report if required. However control of these copies is required to ensure the identity of the person (s) involved is not compromised.
1*C S 7.
The HtC is responsible for reviewing all information received in conjuction with an allegation and ensuring that management and cognizant technical staff membetra are fully informet!.
8.
Allegations normally should not be discussed in Preliminary Notification (PNs) or Daily Reports (DRs); however, if it is determined that PN or DR entries are appropriate, the approval of appropriate management (Division Director or higher) shall be obtained by the originator of the PN or DR.
Sl' S 9.
The Wre is responsible for notifying other. agencies whenever appropriate. Notification of other federal law enforcement ageiscies of possible criminality or nationally significant information contained in allegations shall be coordinated first with the Office of Investigations Field Office and/or the Office of Inspector and Auditor, as appropriate.
(See Regicnal Procedure 1450 - Contacts with the Department of Justice /FBl.) Coordir.ation with the Department of Labor is specified in Regional Procedure 1460, Working Arrancemet,ts for Implementing the Memorandum of Understanoing with the Department of Labor.
10.
Occasionally NRC may learn of an allegation concerning a catter of NRC regulatory interest, but made directly to the licensee.or a licensee contractor, rather'than to the NRC.
In such cases, the substance of the allegation shall be reviewed at the Branch Chiet level for significance to. determine the need for, and timing of, any NRC action. If deemed to be of significance (and involving a power reactor) the allegation shall be entered into the Outstanding Items List (but not the Allegation Tracking System) as an open or unree alv-ed item, tracked, pursued to resolution and ultimately closed out.
For licensees other than power reactors, any such allegations deemed-to be significant shall be documented by memo describing the plenned NRC action, and tracke.d to resolution 1/y the responsible Divisica.
If deemed not significant, Regional action may be limited to' accer-taining that the licensee has' inplace an adequate system' for resolv-
,ing such matters and that the allegation in question has been' put' into the system for followup. Allegations in this latter category need not be tracked.
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H.
Action / Evaluation by Cognizant Technical Division res 1.
Upon receipt of an allegation package from the JAC, the cognizant technical division will reviey,3he documentatior and within three working days propose to the W a course of actica to resolve the issues.
The cognizant technical division is responsible for development, initiation, and follow-through on corrective actions.
There are several areas to be considered by the cognizant technical division during review of the allegation, such as:
Determine whether the allegation package contains sufficient a.
.information for a thorough evaluation.
If it does not, identify the additional information that is needed.
b.
Determine if the allegation can be examined and resolved during a routine, scheduled inspection.
If this is not possible, determine the best way to address the issues.
Determine whether the identity of the alleger is necessary for c.
a thorough evaluation.
d.
Determine what specific issues are involved in the allegation, and whether the issue can be adequately addressed by a technical inspection.
Determine whether the allegation has the potential to require e.
escalated enforcement action, licensing board notification or other regulatory action.
f.
Determine the time sensitivity of the allegation, and what immediate actions are necessary.
Schedule for resolution if action is retained in the Region.
Notify the NRR Project Manager or NMSS as appropriate, of the g.
existance of the allegation.
And, if the facility is before a licensing board or is pending Commission decision, recommend board notification to the Director, Division of Licensing, NRR.
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h.
Determine whether investigative assistance will be needed or if the matter should be refe'rred to OI for them to take the lead.
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Identify peripheral issues that could develop.
The p yosed course of action will be reviewed for completeness by the N and the appropriate Branch Chief within the cognizant I
technical division.
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It is the responsiblity of the cognizant technical division to resolve each allegation that falls under its jurisdiction.,Yollow up on allegations, whether they are general or specific, shall focus not only on the specific allegation but on the overall area of concern, including the potential for generic implications.
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The cognizant technical division will notify the 1AC of the proposed plans and methods to resolve the allegations and the action (s) taken so that the status of each allegation can be tracked. Final resolu-tion of an allegation shall be documented and a copy placed in the IAC case file.
3.
The cognizant technical division will provide the IAC with copy (s) of all (Public Document Room - PDR) reports and memoranda in which the allegation was discussed and finally resolved.
TC6 I.
Allegation Closecut by IAC Upon receipt of the document (inspection report, memoranda, etc.) from the cognizant t nical division in which the allegation has been addressed, the
- will:
1.
Review the document to determine if all aspects of the allegation have been resolved.
2.
Coordinate with the cognizant technical division any apparent discrepancies in addressing the various aspects of the allegations (s).
3.
Notify the alleger of the allegation closecut, including providing the alleger with copies of the closeout documents.
4.
Transmit a closing copy of NRC Form 307, Allegation Data Form, to NRC:HQ.
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With the completion of the above the allegation will be considered closed.
J.
Expiration This Temporary Instruction will remain in effect until superseded by a formal implementing Regional Proced cte following issuance of the NRC i
Manual Chapter.
Attachments:
1.
NRC Form 307, Allegation t
Data Form 2.
Region III Allegation T w:- % - 7CAV6Ldk l
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RECIoN III ALLEGATION TRAVELER Facility Name:
Allegation No.
Facility Docket No:
Description of Allegation:
Number of Allegations:
I.
Allegation Receipt Date of Verbal Allegation:
Allegation Ltr Date:
Date Received Date Received by Date when NRC 1st Received:
in RIII Allegation Coordinator NRC Employee Receiving Allegation Office Receiving Allegation A.
Immediate Action by Allegation Coordinator Date Allegation Report Sent To:
Cognizant Division
- OI Alleger
- Other hrben To flL Ute w [spnoz M B')
B.
Immediate Actions by Cognizant Division Safety Signifiance:
High (Resolve Immediately)
Medium (Resolve in 90 Days)
Low (Resolve in 12 Months)
None (Reason)
Applicant's Estimated Fuel Load Date (Construction Sites Only)
Licensing Board Notification Appropriate?
.Yes No Date Follow-up Board Notifications, if Necessary Date NRR/NMSS Project Manager Notified: Date Cognizant Division Assigned Allegation Section Chief Assigned Allegation Proposed Resolution Schedule: Initiation Date Estimated Completion Revised Completion Dates:
Recontact with Alleger Necessary?
No Yes When j
(Recontact must be coordinated with Allegation Coordinator)
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Revision Responsibility - ORA iggg g,0 O 10 59 Region V Instruction No. 1303 MANAGEMENT OF ALLEGATIONS REG!ON y p; A.
Purpose To ensure that allegations involving NRC licensed activities or activities within the jurisdiction of the NRC expressed to, received by, or reported to any Region V employee are properly and timely documented, evaluated, handled, controlled, and dispositioned in accordance with.NRC
- s Manual Chapter 0517.
B.
Scope This instruction provides for the actions to be taken by Region V employees whenever they may be the recipient or otherwise learn of an allegation that may adversely impact on the NRC or NRC licensed activities, or activities within the jurisdiction of the NRC including, but not limited to, reactor operatica; reactor construction; radiography; control, use, and transportation of radioactive material; safeguards; environment; and employee discrimination complaints.
C.
Definitions 1.
Action Office. The NRC Office or Region that is responsible for reviewing and taking action, as appropriate, to resolve an-allegation.
2.
Action Office Contact. The staff member in the Action Office who is assigned the responsibility for resolving an allegation.
3.
Allegation. A declaration, statement, or assertion of impropriety or inadequacy associated with NRC-regulated activities, the validity of which has not been established. This includes all safety concerns identified by sources such as the media, individuals or organizations outside the NRC, and technical audit efforts from Federal, State or local government offices regarding activities at a licensee's site. Excluded from this definition are matters being handled by more formal processes such as 10 CFR 2.206 petitions, hearing boards, appeal boards, 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.
4.
Allegation Management Sys' tem (AMS). A computerized information syste,m that contains a summary of significant data pertinent to each allegation.
j
~
j I Revision 1, October
, 1984 OCT 16 B84 G-P
p _ _.,
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o 5.
Alleger. An individual or organization who makes allegations. The individual or organization may be a concerned private citizen; 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).
6.
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.
.s 7.
Inquiry.
An. activity involving minimal effort to determine the appropriate response to information reported to the NRC. Typically, an inquiry entails the use of the telephone or written correspondence rather than formal interviews or other investigative measures; however, formal interviews will be conducted if required-.
8.
Inspection. A routine or special activity that may be used to
^
examine and subsequently resolve an allegation.
9.
Investigation. 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 wrongdoing, excluding wrongdoing by NRC employees and NRC contractors which is handled by OIA.
10.
Office Allegation Coordinator (OAC). A designated staff member in 4
each Office or Region who serves as the administrative point of contact for that Office or Region regarding the processing of allegations.
11.
Receiving Office. The Office or Region that initially receives an allegation.
In so'e cases, the Action Office and Receiving Office m
will be the same if the allegation falls within the functional responsibility of the Receiving Office.
12.
Safety Significance. A measure of the importance of an allegation relative to its potential impact on the public health and safety.
13.
Wrongdoing. For the purposes of this manual chapter, it includes the alleged deliberate, p,urposeful, or willful violation of NRC regulations, license technical specifications, licensee commitments to the NRC, or other laws or statutes of interest to NRC.
Revision 1, October 1984 OCT is se4 s --
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24.
Allegation Panel is a group of Region V employees 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.
15.
Cognizant Division Director is the Division Director responsible for the inspection activities affected or otherwise involved in the allegation.
D.
Responsibilities and Authorities s
~
1.
Regional Administrator is directly responsible to the Executive Director for Operations to ensure proper and timely exe.cution of NRC policies and procedures related to receipt, action ano disposition of allegations that fall within the jurisdiction of Region V.
2.
Division Directors shall ensure that the instructions contained herein are properly and timely executed.
In particular, the Cognizant Director shall upon receipt of an allegation by Region V personnel, as appropriate:
Ensure that the Regional Administrator and the Office a.
Allegation Coordinator are immediately informed of allegations that he becomes aware of.
b.
Serve as Chairman of the Allegation Panel and implement the panels recommendations, as appropriate.
Timely convene an Allegation Panel, evaluate available c.
information, formulate an action plan to appropriately dispose of the matter.
d.
For power reactors, during the period from 30 days prior to the construction completion date until the commission meeting on full power authorization, notify the responsible NRR Project t
Manager within two (2) days of the receipt of the allegation and identify the action office.
Prepare, sign and/or concur in all written communications e.
between Region V and the alleger.
f.
Establish a file for each allegation which provides current information that is readily retrievable throughout the course of an inquiry / inspection / investigation.
g.
Determine need for confidentiality.
Revision 1, October 1984 00I 16 EE4 J
.s f
' i 3.
Offsce Ajiczataan Coordanator serves as the a da s n a s t r a t a ve point of contact for the management of 2nformation 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:
Ensure that the appropriate parts of the Allegation Data Form a.
(NRC Form 307, Exhibit 1) are completed for all allegations received within the Region and that the requested data are" s
accurate and timely.
b.
Determine the appropriate Action Office and, if applicable',
coordinate with the OAC of the affected Office or Region on each allegation received.
Ensure the appropriate parts of the Allegation Data Form are c.
completed for all allegations for which the Region is the Action Office.
d.
Fordard the Allegation Data Form to the respective Action Office OAC when the Region is not the Action Office.
Forward the completed Allegation Data Form to the NRR OAC (and e.
a copy to the Office of Nuclear Materials Safety and Safeguards (NMSS) OAC, if appropriate) within 10 working days of receipt of an allegation when the Region 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, telephonically notify the NRR Project Manager of its receipt and the identification of the Action Office in addition to completing the Allegation Data Form.
f.
Acquire input data on new allegations (including those referred to OI) from the staff within the Region and ensure this information is forwarded to the NRR OAC in a timely manner for placement into the AMS.
g.
Provide updates (using an AMS printout) on previous allegations (including those referred to OI) from the staff within the Region and ensure this information is forwarded to the NRR OAC on a monthly basis for placement into the AMS.
l h.
Assure reports described in Section F.4 of this instruction are prepared and submitted as prescribed.
i.
Serve as a member of Allegation Panels.
Revision 1, October
, 1984 OCT 16 534
j s
2 7
- 4r J.
Verify that wra t t en c ommunic a t a ons have been sent to allcaer as prescribed in Section E.5 of this anstruction. Sagn and/or concur in the letters sent to an allcaer at the damcretion of the cognizant Division Director.
k.
Upon disposition and/or closure of an allegation, verify that the file is complete and contains all necessary documentation pertinent to the allegation.
3 1.
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 s
~
into the NRC Tracking System.
Thereafter, inform the Director and Officers of all significant information subsequently obtained pertaining to the allegation.
Upon recommendation of the allegation panel, promptly notify m.
DOL of complaints concerning possible violations of Section 210(a) of the Energy Reorganization Act.
Serve as the interface and principal contact person between the n.
Region V staff and the staff of the Office of Investigations, Region V.
Ensure that copies of the allegation data form and allegation o.
report are provided to the Regional Administrator and cognizant Division Director within the next working day after receipt.
p.
Monitor status of completion of each received allegation and routinely inform regional management of such status.
4.
Enforcement Officer shall:
Serve as a member of Allegation Panels.
a.
b.
Provide advice on potential violations and possible severity levels that may arise from the allegation.
Alert the Regional Administrator of alleged significant c.
violations of regulatory requirements that potentially could result in escalated enforcement action.
t 5.
State Liaison Officer shall inform state and local officials of information contained inl allegations that fall within the jurisdiction of the state and local governments and provide notice l
to the appropriate offici'als of NRC findings and actions if and when l
appropriate as determined and directed by the cognizant Division i
Director, with due regard for the need to maintain the nature of the allegation and its source confidential.
t l
Revision 1, October 1984 O' i 16 GS4 v
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Information pertaanang to an allegation sha!! not be I
released without approval of the cognizant Division Director.
7.
Region V Employees shall, upon receipt of an allegation, promptly (within same day of receipt) complete an Allegation Report and deliver it to the Office Allegation Coordinator.
E.
Action:
- s 1.
Receipt of Allegation Region V employees who receive an allegation shall immediately a.
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 poss'ible, the following information.
(1) Full name of person.
(2) Telephone number where person can be reached (work -
home).
(3) Mailing address.
(4) Name of employer.
(5) Place of employment.
(6) Job or position title.
(7) Name of licensee.
(8) Name of facility.
(9) Nature of Allegation - obtain as many specific details as 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 signifidance.
NOTE:
Regardless of any personal opinions, employees shall communicate with allegers in a professional manner showing 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 will assist the individual in reaching the appropriate authority.
Revision 1, October 1984 0UT 16 E04
c.
A standard allegation report form is attached as Appendix A to this instruction and should be used to document all allegations, as appropriate. The Office Allegation Coordinator will assist, if needed, with the completion of the report and review all reports for completeness. At the same time, an Allegation Data Form should be completed per this Instruction.
Both documents should then be immediately delivered to the Office. Allegation Coordinator who shall then immediately notify the Regional Administrator and cognizant Division Director.and provide each with copies of the Allegation Report.
d.
If an employee receiving an allegation believes it would be
_. s better for the alleger to discuss the matter with another employee, and if the alleger consents, transfer the call to or refer the person to the Office Allegation Coordinator.
If that individual is unavailable, 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.
Many persons reporting a particular matter to NRC wish to e.
remain anonymous.
If the alleger refuses to give a name, infonn the person that:
(1) NRC will, if the alleger so requests, treat the individual's identity as confidential.
(See paragraph 7 of this section for additional detail).
i (2) All matters involving public safety will be examined and evaluated.
The individual's identity may, however, be revealed where required by law, when necessary to insure public health and safety, pursuant to Congressional directives, where he himself makes the matter public or where the nature of the allegations or the limited number of people with access to the reported information may provide a basis for guessing their identity. This might be avoided if the NRC were aware of whose identity should be withheld.
(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, obtain as much information as possible about the 1
problem and then inform the person that a complaint must be filed with the Department of Labor within 30 days of the acts compla'ined of in order to obtain the Department's assistance.
(See paragraph 6 of this section for additional detail).
Revision 1, October
, 1984 OCT 16 RM a
4 o
(4) Normally, NRC Region V policy is to send a letter to the alleger which documents the NRC's understanding of the
}
allegation to assure that the NRC has correct information, unless the Alleger is a member of an organization that is being kept informed of NRC actions or has or will be promptly interviewed by NRC personnel, and issues are clear. 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).
(5) If the alleger insists on remaining anonymous, obtain.as
_ s 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 concerns have been properly addressed.
2.
Evaluation of Allegation Except for those allegations that involve conditions that a.
require immediate action such as theft of SNM, sabotage, and immediate threats to the health and safety of the public, governed by NRC Emergency procedures, within ten (10) days of receipt of an allegation, the cognizant Division Director shall convene an Allegation Panel to evaluate the information and develop an action plan to resolve the matter.
The Panel shall determine:
(1) That the issues raised in the allegation are identified and understood.
(2) Whether there is an immediate safety concern which must be quickly addressed and the need for immediate regulatory action.
(3) Whether the allegation is a specific safety or quality issue or a generalized concern?
(4) Whether the staff has previously addressed this issue?
(5) Whether the allegation package contains sufficient information fog a thorough evaluation.
If it does not, identify the additional information that is needed.
l l
I Revision 1, October 1984 OCT 10 E04 i
p o
n.,
(6)
Whether af.1 aspects of the allegation are adequately
..g defined amd described to permit or require a meaningful and extemsive evaluation.
This is a screening process that may result in a decision not to consider the allegatice. further.
If the latter is the decided course
]
of actice. the alleger should be so informed in a courteous and diplomatic manner along with the rationale for not c nsidering it further.
The potential for adverse publicity must be recognized when taking this action..
(7) Whether the identity of the alleger is necessary for a thorough evaluation.
_ s (8) Wat specific issues are involved in the allegation and whether the issues can be adequately addressed by a technical inspection.
(9) If the allegation can be examined and resolved during a routine, scheduled inspection.
If this is not possible,
. determine the best way to address the issues.
(10) Wether 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.
(See NRC Manual Chapter 0517 Section 058).
(11) Wether the allegation has the potential to require escalated enforcement action.
(12) The time sensitivity of the allegation, and what immediate actions are necessary.
(13) Whether additional expert technical or investigative assistance will be needed.
(14) The identity of peripheral issues that could develop.
(15) If any licensing actions or board proceedings are pending which could be influenced or affected by the allegation.
E en an allegation involves a case pending before a licensing or appeal board or the Commission, information concerning it should be provided to NRR or NMSS as soon as possible to assist in the determination of whether or not a board notification should be made. This decision must be made promptl'y by NRR or NMSS in accordance with office procedures.
(16) If other NRC Offices that may have an interest should be notified.
Revision 1, October 1984 00T 161984
/
i
J 9
(17) A strategy for handling allegations, 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 actions; radiation overexposures; etc. should be handled via the inspection program. Allegations involving wrongdoing such as record f alsification; willful or deliberate violation of a regulatory requirement; material f alse statements, or improper conduct which affects licensed activities should be referred to 01 for investigation.
~ s (18) Appropriate referrals to ther NRC Of fices, or to other Federal, State or Local governmental agencies.
(19) What information should be maintained confidential.
(20) A schedule for the resolution of each allegation which is
" consistent with the licensing schedule, if applicable.
b.
After evaluating the available information, the Allegation Panel shall provide the cognizant Division Director with recommendations in the form of an action plan as to what actions should be taken to appropriately resolve the matter.
If inquiry or inspection activities are conducted to verify or c.
obtain additional information about an allegation, the activities should be clearly defined and the following shall be included in the action plan.
(1)
If the inspection activities 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 any additional relevant information obtained during the interview. Offer the document to the interviewee to read 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 documents must he maintained as part of the official agency file.
Revision 1, October 1984 OCT 16 E84 l
l
(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 tschnical basis of the sample size is clearly stated.
3.
Notifications As Chairman of an Allegation Panel, the cognizant Division Director shall assign individuals, as appropriate to:
a.
Notify Licensing Office (s) and transmit appropriate documents.
b.
Notify State and Local authorities and refer issues to them that fall within 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 01 Region V of any potential wrongdoing by individuals that may require referral to the Department of Justice.
g.
Notify Regional Management of any alleged improper conduct of NRC employees and NRC contractors for possible referral to Office of Inspector and Auditor (OIA).
h.
Notify OAC when stat 6s changes or action (s) is complete.
i.
Notify affected orgadizations promptly of the need for corrective action, as appropriate.
All notification decisions shall be made with due regard for the need to maintain the nature of the allegation and its confidentiality.
Revision 1 October
, 1984 OCT 16 884 l
4 g <ym..e.esen a.
Each allougat ion received should be documented on an allegation report f oorm prepared as called for by Appendix A tp this instructizen or in an equivalent manner that provides the pe rtinen t-information.
b.
Results aaf evaluations of Allegation Panels shall be documented in a mema3randum to files signed by the cognizant Division Director..
Action p lans to resolve allegations shall be documented and c.
~ '
approved by the cognizant Division Director.
d.
Details arnd results of inquiries and inspections shall be documentani.in the standard IE formats except that all documents obtained during follow-up activities including original interview documents should be filed with the reports.
All doctanents including letters to and from an alleger relating e.
to an allegation shall be filed in the appropriate allegation file. Confidential and/or sensitive material should be marked as " official use only".
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 discourage persons from bringing matters to its attention. Under no circumstances is the report to be written such that it attacks or disparages the alleger.
Pejorative language is to be avoided.
g.
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, discussions, and meetings. This file shall be maintained in the official files of the Action Office in an officially designated location. To ensure proper evaluation, full and. complete information should be documented about each allegation.
In addition to obtaining basic information, attempts should be made to expand and clarify the information so that the issue is well defined. All allegations, regardless of source or how received, must be documented. Records or files containing the name of a confidentini source or other identifying information (i.e. a confidentiality agreement has been executed) should be stamped "This material contains confidential source information."
Revision 1, October
, 1984 00T 1G 1984 i
m-
<=
_-M
h.
There will be occ usa s ons when the attesettone obviounty have no
~
substance and appu.ar to represent a distortion of facts.
However, even in tc he s e cases, documentation is necessary that identifies the comt act, the general content of any.
communications, anu! the basis for a conclusion that the matter need not be pursuusd.
Instances such as these vill be coordinated with t:he appropriate technical staf f by the OAC to ensure proper dispsosition.
i.
The importance of obtaining and documenting all pertinent information about Jai allegation-cannot be overemphasized.
Evaluation and screening 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 alleger may be warranted.
J.
Allegation resolutdon documentation officially closes the file for that case and shall be placed in the working file which now becomes a closed case file. Closed case files shall be retired to inactive storage through the Document Management Branch, T1DC, and destroyed according to the Comprehensive Records Disposition Schedcle (NUREG-0910). Appropriate documents, including those necessary for an individual to understand the incoming allegatien and its resolution, shall be placed in the NRC records systen (PDR, LPDR. Docket File, Subject File DCS) and must be treated to protect the identity of the alleger.
k.
A finsi report should be prepared that sets forth the facts about the allegation and its resolution clearly and conclusively. The final report can be a memorandum for a relatively minor catter, an investigation / 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.
1.
The final report should include a summary of the concern, a description of the evaluation performed and the conclusions drawn.
It should be written in a style that does not belittle or disparage the alleger.
Appropriate entries should be made in the AMS to close out the m.
allegation.
I Revision 1, October 1984 OCT 10 E04
e n.
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 F01/. in accordance with 10 CFR 9.5 Exemption (7) due to actual, or the potential for, law enforcement action. File documents, however, are frozen by the FOIA request for release when the case is closed should a subsequent FOIA request be received.
A copy of the final report shall be sent to the alleger and, if o.
appropriate, to the affected outside organization (s). A
-- s transmittal letter may be needed to summarize the matter.
p.
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.
5.
Letters to A11egers Acknowledging Receipt of Allegations All allegations received from concerned citizens should be acknowledged by a letter to the individual who presented the allegation unless other satisfactory contacts are maintained such as interviews, or numerous telephone contacts. This letter, in addition to stating an acknowledgement of the contact, will also contain a " Statement of Concerns" as an enclosure to the letter.
The statement will detail the allegation as 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. Letters will only be sent to parties of an NRC proceeding or other organizations as deemed appropriate by the cognizant Division Director.
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 Addition,a1 Information 4.
Close-out for Lack of Response 5.
Close-out for Action completed Samples of the above letters are attached to this instruction as Appendix B.
Revision 1, October 1984 0T U E64
nw.
6.
Employee Disc rimination Complainte a.
Backaroumd A Memoranndum of Understanding (MOU) signed by NRC and the Departmemnt of Labor (DOL) facilitates coordination and cooperatiion between the agencies in the processing of violatiorns of the employee protection provisions of Section 210(a) off the Energy Reorganization Act. Subsequently, working arrangemeents were developed and points of contact established at regionaal and headquarters levels for each agency.
s b.
Workina AArrangements The work:bsg arrangements between NRC and DOL establish certain commitsemts that must be carried out by the regional contacts for the BNRC. The working arrangements provide that NRC will refer ccumplaints to DOL, advise DOL of complaints received concernimg employee discrimination, inform DOL of investigations that NRC is conducting into these matters, and facilitase DOL investigations by assisting in gaining access to NRC-licammed facilities.
i Section 210 of the Energy Reorganization Act prohibits any employer, 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 purposes of either the Energy Reorganization Act or the Atomic 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 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 confidentiality of information identified as sensitive that was supplied to it by the other agency.
i Revision 1, October
, 1984 OCT 10 E04
\\
c.
Processing of Complainte If a complaint is received concerning a possible violation of Section 210(a), the OAC will refer the complaint to the Enforcement Coordinator, the Region V point of contact responsible for the regional implementation of the NRC-DOL HOU.
Region V will not normally initiate any action on such a complaint 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.
-s 7.
Confidentiality a.
Background
The identity of individuals making allegations should not be revealed by the NRC unless it is clear that the individual concerned has no objection. The ability of the NRC to obtain information, particularly adverse information from sources who wish to remain confidential, depends on the subsequent handling of such information by the NRC and its ability to protect the identity of individuals providing the information.
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 lengthy, and burdensome so employees may still be reluctant to provide information for l
fear of being out of work for an extended period of time while 1
going through the legal process.
Confidentiality is a means by which the NRC protects and withholds the identity of an indivudual 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 to NRC.
b.
Use of Confidentiality e Confidentiality should not be routinely offered to individuals e 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 th& information, or if the individual providing the information requests anonymity, then a grant of confidentiality will'be proffered. Before confidentiality has been granted, the individual should be informed that, although the pledge is not absolute, it is NRC policy not to divulge Revision 1, October
, 1984 00T is 1984
1 1
individual should be told that their name will not normally 8PPear in the publicly released reports. The individual's identity may, however, be revealed where required by law, when necessary to ensure public health and safety, pursuant to Congressional directives, where he himself makes the matter public or where the nature of the allegations or the limited 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. One point regarding i
promises of confidentiality should be clearly understood by all
_s Region V ctaff members and explained to the individual providing information. A pledge of confidentiality shall not be made (or will not be 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 willful violation of NRC requirements.
-+ [Should a RegionJ_ staff member grant confidentiality, all f acts g94 and circuinstances surrounding the pledge must be documented in i
k" a memorandum to the OAC who will coordinate the information j
withthecognizantDivisionDirectorJ l
A confidentiality agreement (Exhibit 4 NRC 0517, attached) 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.
Revision 1, October 1984 00T 10 g
j ti The confidentfality agreement may be signed by Office Director 6 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 percon should be advised, the reason explained and remedial measures taken, if possible, to reduce the impact of disclosure.
c.
Restrictions Within Region V, the identity of any individual making
_s 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 KRC employee or outside individual who does not have a need for such information.
If it is necessary to provide the name of an individual reporting information (alleger) to an inspector assigned to followup an allegation, or to other NRC offices, the OAC will coordinate the request for release with the cognizant Division Director. Every effort shall be made to preclude the inadvertent or premature disclosure of the identity of an individual providing information in connection with an allegation, complaint or concern.
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 NRC position is to neither confirm nor deny the validity of such guesses and refuse to l
discuss the matter further.
F.
Allegation Management System 1.
General 1
For purposes of the Allegation Management System (AMS) the a.
definition provided for an allegation is very general and i
broad. The significance or nonsignificance of an allegation will be judged during the Action Office review and follow-up activities. There is to be no screening of 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, storing and retrieving all key information regarding all allegations. The Action Office determines the necessary action to be taken based upon the specifics of the case. Some allegations may be received and l
closed out the same day.
Revision 1, October 1984 QCT 161984
}
_q
I i-m v %.1 -
c 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.
When an allegation is received, it is not necessary to identify c.
by separate entry into the AMS every component or subset of,the allegation.
For example, if an allegation is received that consists of 15 separate concerns of wrongdoing and technical deficiencies, 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, d.
Sensitive information such as the names of persons making allegations shall not be entered in the system. All information entered on the form shall be unclassified and shall not contain any safeguards information or any proprietary or commercial (2.790) information.
Some allegations may require action by two or more offices.
e.
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 OACs 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 Investigations The Office of Investigations has jurisdiction over all a.
allegations of wrongdoing except those involving NRC employees or NRC contractors and will forward all allegations of a technical nature to che appropriate Office or Region. The Office or Region vil2 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:
Revision 1, October 1984 00T 10 004
-w U-(1) The Region or 0 flee OAC will coordinate with the 01 Field Director or OI 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 number. The OI assigned number should be entered in the AMS as a cross-reference.
~s (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 01 Field Director will keep the Region or Office OAC apprised of the status of the allegation investigation and provide timely information necessary to determine the safety significance of the allegation to appropriate Regional or Office management and for use in updating the AMS.
(5) The allegation will be considered closed when the investigation report has been issued and as long as no technical issues remain.
If technical issues or an investigation remain, the allegation remains open, reference is made to the technical report or OI investigation report if either is complete, and a schedule for resolution of the allegation is placed in the Allegation Data Form or in the AMS update.
c.
For allegations of wrongdoing received by 01, the OI Headquarters or Field Director will coordinate with the respective Office or Region OAC to complete the items 2.b(1) through (5), above.
d.
For allegations of a technical nature received by OI, the OI Headquarters or Field Director will contact the respective Office or Region and follow the procedures as indicated in item 3 below for the Receiving Office.
3.
Receiving Office Upon receipt of an allegation involving an NRC-regulated activity, the person receiving the allegation will provide the information relative to the allegation (see Exhibit 1, NRC 0517, attached) to the OAC who will initiate steps required to identify the Action Office and to enter the allegation into the AMS.
Revision 1, October 1984 OCT 10 G34
i We' The Receiving Office OAC should, in addition to determining the appropriate 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 forward 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 th.e follow-up action for an allegation will be recorded by updating the monthly status report. Name and telephone of Office or Regional Allegation Coordinators will be indicated at the top of the update sheets; any changes in the designation of OACs will be made here.
As soon as possible after the receipt of an allegation and c.
relevant information has been reviewed and evaluated, make a preliminary determination of safety significance and the need for any regulatory action. This determination will be reported in the next AMS update.
d.
Schedule the resolution of each allegation to be consistent with the licensing schedule and the safety significance of the allegation.
Make a determination regarding the need for a board e.
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 information 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 procedurgs.
f.
Develop and maintain a working file for each allegation, which will contain all related documentation. For those allegations comprised of multiple concerns, separate working files may need to be established for each concern.
g.
Provide status information to the NRR OAC for the AMS regarding items c-f, above.
Revision 1, October 1984 i
OCT 10 E04
I
~
~~
h.
Thfrey days prior to the construction r.ompletion date (applicant 's estimate) for each pending OL. each Action Office will forward to the Division of Licensing /NRR, an evaluation of the safety significance of all allegations not scheduled to be resolved before the construction completion date, with a recommendation as to whether any or all of tl'em constitute grounds for delaying issuance of (or otherwise restricting) an operating license.
1.
Thirty days prior to a Commission decision en authorizing full-power operation, a report similar to item h. above, will be prepared.
-- s j.
Ensure protection of the. identity of all allegers when confidentiality is requested or implied by their actions.
fi APPROVED:
J. B. Martin Regional Admir.istrator OCT 16 7384, DATE:
i I
i t
s i
i b
l l\\
Revision 1, October 1984 1
OCT 10 E04
......_m
- - -Mr AhEGATION REPORT A.
Pu rpos e 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:
3.'
Documentation Region V personnel shall document information regarding an allegation, complaint or concern as follows:
Enter the full name of the individual providing m.
Name the information.
Enter the mailing address of the individual b.
Address providing the information, c.
Phone Enter the residential and/or business phone.
number of the individual providing the information, Enter a concise statement describing the d.
Allegation allegation, concern or complaint (e.g., improper welding procedures used in containment).
Enter the name of the facility involved in the e.
Facility allegation, complaint or concern (e.g., Trojan).
Enter the docket number of the facility if f.
Docket No.
known.
Leave blank. The Office Allegation Coordinator g.
File No.
(AOC) will assign an NRC tracking number.
Enter the date and time of initial contact with h.
Date and Time the individual who provided the information.
If the individual who provides the information 1.
Confidenti-ality Requested was granted confidentiality, so indicate and provide details.
Enter the details of the information provided J.
Summary of Information by the individual.
Enter your printed name and signature.
k.
Prepared By Enter date document was prepared.
1.
Date Leave blank. OAC will use this space for m.
Action Required internal administrative actions.
JAN 6 S 84 OCT 16 084
e t
Eneve blank.
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e 1
e e
e f
W G
G I
OCT 16 7384
i.
r2 u no:
, w esss DATE:
_....._ j TIME:
Et CONFIDENTIALITY RECA>ESTED YES NO DO:; NO:
SUMMARY
OF INF0m4ATION:
e N
N e
e b
O em O
e e
MSI 9'
e SATE XEPARES gy g
gy,
=cmwse av 6*
oo uor msetosc
- wncut use oaty -
001 16 T384
1' (DATE) 1 (NAME)
(ADDRJS$)
(CITY, STATE,21PCODE)
Dear (Mrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
SUBJECT:
(ALLEGATION FILE NUMBER)
_s (STANDARD INTRODUCTORY PARAGRAPH)
This refers to (TELEPHONE CA'LLS, MEETINGS AND/OR LETTERS) in which you exD*essec concerns related to (GENERAL areas of allegation) practices at (NAME OF UTILITY AND/OR SITE).
(STANDARD PARAGRAPH - INQUIRY INITIATED)
An enclosure to this letter documents your concerns (S) as I understand (IT/THEP) based on (OUR CONVERSATION)(MY CONVERSATICN WITH
)(OUR MEETING) (OUR LETTER). We have initiated an inquiry eegarding this matter, therefore, if the onclosure does not completely anc accu-ately reflect all of your cencerns, please so that we can assure contact me collect as soon as possible at (415) 943-3700If you should call and I that they are adequately addressed during our inquiry.
cm not available, please leave a message so that I can return your call.
(STANDARD PARAGRADH - INSPECTION REQUESTED)
An enclosure to this letter documents your concern (S) as I ur.ceestanc (IT/THE")
)(00R MEETING)(YOUR LETTER).
Dased on (DUR CONVERSATION)(MY CONVERSATION With I have requested that our inspectors look into this matter curing one of snei-upcoming inspections, therefore, if the enclosure does not come etely and accurately reflect all of your concerns, please contact me ccMect as soor as possible at (415) 943-3700 so that we can assure that they are adequately addressed during the planned inspection. If you should call and I am not ovailable, please leave a message so that I can return your call.
(STANDARD PARAGRAPH - ACKNOWLEDGE REOUEST FOR CONFIDENTI ALITY)
Regarding your request for confidentiality, let me assure you that we will make Gwery attempt to handle this matter in such a way as to maintain your anonymit).
In this respect, I would like to point out that licensees sometimes correctly In such cases guess the identity of the individual providing information to us.
cur policy is to neither confirm or deny the accuracy of their guess.
JAN 6 E64 OCT 10 884
I (STANDARD PARAGRAPH-CLOSING 3)
In closing, we appreciate yvour bringing your concerns to our attention.
If you have additional questions, or If I can he%f further assistance in this ratter, please do not hesitate to econt.act me.
a Sincerely,
~s (NAME)
(TITLE)
Enclosure (s):
Statement of Concerns S
4 e
9 4
9 Jr. '.
C St.
OUT 16 884
I
- r*
(DATE)
(NAMi)
(ADDtE55)
(CITY, STATE, ZIP CODE)
Dear (Mrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
SUBJEET:
(ALLEGATIDN FILE NUMBER)
(STANDARD INTRODUCTORY PARAGRAPH)
This refers to our letter to you dated (DATE), the enclosure to which documented cur understanding of your concerns relative te (GENERAL AREAS) practices at (UTILITY)'s (SITE) nuclear power plant and to your subsequent (LETTER TO US DATED IN)(TELEPHONE CONVERSATIDN WITH NAME AND DATE DURING) which you providec (ADDITIONAL)(AND)(CORRECTED) information regarding your concerns.
The enclosure to this letter represents a restatement of your concern (5) 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 onsuring that we understand them correctly.
Sinte-ely, l
(NAME)
(TITLE) l
Enclosure:
Statement of Concerns - Rev.
i l
(REV. NO.)
JAN C 1954 OM H W
, 3, M LMt#7 2
L8' A lA M
(DATE)
(NAME)
(ADDRESS)
(CITY, STATE, ZIP CODE)
Dear (Mrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
SUBJECT:
(ALLEGATION FILE NUMBER)
(STANDARD INTRODUCTORY PARAGRAPH)
This refwrs to (TELEPHONE CALLS, MEETINGS, AND LETTERS) in which you expressec concerns related to (GENERAL AREAS) practices at (UTILITY)'s (SITE) nucleae power plent site.
(REOUEST FOR ADDITIONAL INFORMATION PARAGRAPH We have determined that we need addititonal information from you before we car proceed with our inquiry into your concerns.
We have attempted to conta:t yc.. by telephone without success and I would appreciate your contacting me colle:t a-(415) 943-3700 as soon as possible so that we can discuss this matter fu -me -
[A_D.DITIONAL INFORMATION PROMISED BUT NOT RECEIVED)
Based on your telephone conversa' tion with (NAME) on (DATE), it was our unce--
standing that you would provide additional information and I would appre:iate your contacting me collect at (415) 943-3700 at your earliest convenience se.5a:
we may proceed with' our inquiry into this matter.
Your cooperation and assistance would be appreciated.
Sincerely, (NAME)
(TITLE)
JA"
- i. 51
~~ -
. :::~
(DATE)
(NAME)
(ADDRES5)
(CITY, STATE, ZIP CODE) -
Dear (Mrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
SUBIECT:
(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 relatec 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 informatior 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 car.
pay particular attention to those areas during their routine inspections.
Should you have any questions re' carding our disposition of this matter, please call me collect at (415) 943-3700 Sincerely, (NAME)
(TITLE) 1 i
- .?
vw!
OCT 10 S84 1M
J l
. ~,
pggM g st RMsA 086 LeP l
(DATE)
(NAME)
(ADDRESS)
(CITY,-STATE, ZIP CODE)
Dear'(Mrs.)(Mrs.)(Ms.)(Miss) (LAST NAME):
SUBJECT 1 (ALLEGATION FILE NUMBER)
This refers to our letter to you dated (DATE) which indicated that we had (INITIATED AN INQUIRY) (REQUESTED THAT OUR INSPECTORS LOOK) into your coneens 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 and our findings are documented in the enclosed report (s). This concludes the Regional Staff's activities regarding this matter.
(PARAGRAPH: ACTION COMPLETE -NOT ADDRESSED IN REPORT Dur inspectors have looked into this matter; however, to maintain your conficen-tiality your concerns and the inspector's findings were not highlighted in their report.
We have, however, documented our findings relative to (YOUR CONCERN)-
(EACH OF,YOUR CONCERNS) in an enclosure to this letter.
(PARAGRAPH:
ACTION COMPLETE -INVOLVES 2.790 INFORMATION)
Our (INQUIRY)(INSPECTION)(INVESTIGATION) regarding this matter has been completed.
In that your concerns dealt with physical security matters, the l
details of which are exempt from public disclosure pursuant to 10 CFR 2.790(d).
I w2 are unable to provide you with a copy of our report. We have, however, i
documented our findings in a general sense in an enclosure to this letter.
(PARAGRAPH:
ITEMS OF NONCOMPLIANCE IDENTIFIED)
With regard to the item (s) of noncompliance identified during (IN5DECTION)-
l (INVESTIGATION), (UTILITY) is required.to inform us in writing of the corre: ive 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.
l
___ AAN, G;BB4
(PARAGRAPH:
STANDARD CLOSING)
We appreciate your informing us of your co,ncerns. We feel that our actions in this agitter have been responsive to those concerns; however, should you have further questions regarding this matter, please feel free to contact me.
Please be assured 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,
- tc e
L (NAME)
(TITLE) 7
~1C a
5 1
i JAN
- 1984 0? 1] WL
~
CONFIDENTIALITY AGREEMDIT I have infomation that I wish to provide in confidence to the U.S. Nuclear Negulatory Commission (MC).
I request an empress pledge of confiden-tiality as a condition of providing this infomation to tne NRC.
I will not provide, this information voluntarily to the NRC without such confiden-tiality being extended to me.
It is g understanding. consistent with its legal obligations. the NRC. by agreeing to this confidentiality, will adhere to the following conditions:
(I) The NRC will not identify me by name or personal identifier 'in any
-s 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 stay require this information in furtherance of their respons1bilities under law or public trust.
(2) The NRC will disclose sy 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 consistant with the investigative needs of the Commission to avoid actions which would clearly be expected to result in the disclo-sure of sy identity to persons subsequently contacted by the NRC.
At a later stage I understand that even though the NRC will aske every reason-able effort to protect sy identity, sy identification could be compelled by orders or subpoenas issued by courts of law, hearing boards, or siellar i
legal entities.
In such cases, the basis for granting this promise of cen-fidentiality and any other relevant facts will be communicated to the authority ordering the disclosure in an effort to maintain sy confiden-tiality.
If this effort proves unsuccessful, a representative of the NRC will attempt to inform me of arqy such action before disclosing my identity.
I also understand that the NRC will consider me to have waived sy right to confidentiality if I take any action that any be reasonably expected to disclose my identity.
I further understand that the NRC will consider me i
to have waived ay rights to confidentiality if I provide (or have pre-(
viously provided) information to any other party that contradicts the infomation that I provided to the RC or if circumstances indicate that I an intentionally providing false information to the NRC.
Other Conditions: (if arty)
I have read as4 full with its provisions. y understand the contents of this agreement.
I agree s
Date name:
Address:
Agreed to on behalf of the U.S. Eclear Regulatory Commission.
Date 51gnature Name:
Title:
E4-1 Approved:
nt'J 1 E M
~
o A
n.<~***
~
,; :;3, _ __
NRC Form 307 ALLEGATION DATA FORM l
-A-1.
ALLEGATION NUMBER:
o 2.
FACILITY:
Name Unit No.
Docket No.
a.
b.
c.
~'
3.
TYPE OF REGULATED ACTIVITY:
O a. Reactor Ob. Vendor Oc. Materials Od. Safeguards Oe. Other 4.
MATERIALS LICENSE NUMBER:
5.
FUNCTIONAL AREA (s):
O a. Operations O b. Construction O c. Safeguards C
Od. Transportation O e. Emergency preparedness B
O f. Onsite health and safety O g. Offsite health and safety Oh. Other c,,
5 6.
DESCRIPTION:
3
~
7.
NUtBER OF CONCERN 5:
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 1. Anonymous O h. Other l
9.
CONFIDENTIALITY REQUESTED:
O Yes O No
- 10. DATE ALLEGATION RECEIVED:
/ /
- 11. EMPLOYEE /0FFICE RECEIVING AI.TEEK1 TUN:
- 12. ACTION OFFICE CONTACT / PHONE:
n
- 13. SAFETY SIGNIFICANCE:
O High CJ Medium O Low O None
- 14. BOARD NOTIFICATION RECOPt4 ENDED: O Yes O No
- 15. 01 NOTIFIED:
O Yes O No
- 16. STATUS:
0 0 pen O Closed Scheduled Cc gletion Date: _/_/_
Date Closed:
/ /
- 17. WAS ALLEGATIOPO MITIE TIATED:
O Yes O No O Partially C
- 18. WAS ENFORCEMENT ACTION TAKEN: O Yes O No O In Process 8
SEVERITY LEVEL:
- 19. WAS O! INVESTIGATION PERFORMED: O Yes O No O In Process l
cS
t O Yes O No 050.54(f) 030.32(d) 070.22(d) 0 40.31(b)
Disposition:
1
- 21. ALLEGER NOTIFIED or LLO5E0VI:
'O Yes O No l
- 22. REMARKS:
F
- 23. CROS5
REFERENCE:
- 24. PROJECT MANAGER / PHONE:
[
- 25. APPLICANT'S CONSTRUCTION COMPLEll0N DATE:
/
O EI _f-I E
- 26. BOARD NOTIFICATION ISSUED:
O Yes 3
REGION V DISTRIBUTION COMPLETED ON Date OCT 10. m4
~.
O INSTRUCTIONS 1.
Allegation ihm6er Action Office fill in the bones to sniquely iden.
tify this allegation CFFICE official NRC office abbreviation for the Office responsible for followup activities.
YEAR last tuo digits of the calendar year in which the allegation was reported to NRC.
~
A identifies this number as an allegation number.
IRNSER ntial num6er assigned by the Office or on responsible for the followup activities.
EXAIFLE 24th allegation received by IE in 1982 would be shoun as IE-82-A-0024
~s 2.
Facility (fes)
Give the name of the facility (tes) or company (tes)
Involved about whom the allegation is made. Write the docket nuu6er. 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 $!NSITIVE. If more than three facilities or companies are in-volved write GENERIC.
6.
Description Briefly describe the allegation (1 or 2 sentences).
Se concise. If an allegation includes several in-
)
stances of technical deficiencies or wrongdoing.
list the assertions separately or group them by E$ If the description of the allegation 15 sensitive, write only SENSITIVE.
7.
Ihaber 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 the box that most clearly describes the affiliation. 00 Il0T include the name of the indi-vidual making the allegation..
g.
Confidentiality Indicate whether confidentiality has specifically Requested been requested.
- 13. Safety Provide an estimate of the safety significance of Significance allegation Example (a) Check "high" for an alleged deft-ciency in an operating plant that could have an 1suadiate and great effect on plic health and safety (b) Check" Low for an alleged deficiency in a plant under construction that would have a minor effect on public health and safety
- 20. Did Disposition Check appropriate bcx(es) and briefly describe Result in Letter method of disposition (e.g., letter,) technical to Modify or report. inspection report. SER, etc. and identify Revoke License document.
- 22. Remarks Include additional information as appropriate.
EXAlstES: list other allegations related to this allegation; list other lett offices responsible for followup activities on this allegation.
- 23. Cross Reference Identify other related allegations and.investiga-tions ity alpha-numeric designation.
. 25. Applicant's -
For plants under construction enter the appit-Construction cant's estimated construction completion dates Completion Data there is no need to provide this information untti 3 or 4 months prior to the estisated date.
- 26. Board Notification Indicate whether a board notification was issued.
Issued Approved:
El-2 OCT 1: m
.