ML20211K838

Concurs W/Requirements Statement for Allegation Mgt Sys. Region V Procedure Re Mgt of Allegations Encl

ML20211K838
Person / Time
Issue date:	11/08/1984
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20211K772	List: ML20211K769 ML20211K789 ML20211K800 ML20211K811 ML20211K827 ML20211K833 ML20211K838 ML20211K845 ML20211K851 ML20211K858 ML20211K863
References
FOIA-86-183 NUDOCS 8612150175
Download: ML20211K838 (23)

Text

.

'I$E&EG arm w$ 'ur"c^n"$xIcEilSAEfEsse *,~ d

%....' Ilfl$ OCT -3 ,,

ADf 8 1984 M

• Gic:: y; , (pG &$3 eM~

"h I

MEMORANDUM FOR: Harold Denton, Director, Office of Nuclear Reactor Regulation FROM: J. B. Martin, Regional Administrator .

SUBJECT:

ALLEGATION MANAGEMENT SYSTEM; REQUIREMENTS STATEMENT FOR THE ADP PROGRAM The subject document was reviewed by members of the Region V staff in response to your request of November 1, 1984. Based upon the results of .this review I concur with t gations Management System Requirements Statement dated October 6, 19 4.

. . Martin Regional Administrator t

l

~

l  !

B '

,  ?

gg21lgj5e6121o GARDEBb-103 pop

\ 5.0b

~

)

, Ml qyfy =

Revision Responsibility - ORA s

('"

>d Region V Instruction No. 1303 MANAGEMENT OF AI.I.EGATIONS A. Purpose 3

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.

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 operation; reactor construction; radiography; control, use, and transportation of radioactive material; safeguards; environment; and employee discrimination complaints.

C. Definitions

1. Allegation is an assertion by an individual in the form of a statement, complaint, or concern that indicates a possible problem-in connection with NRC licensed activities, or activities within the jurisdiction of the NRC.

2. A11eaer is an individual who makes an allegation.

3. 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.

4. Cognizant Division Director is the Division Director responsible for the inspection activities affected or otherwise involved in the allegation.

l D. Responsibilities and Authorities ,

l 1. 'Reaional Administrator is directly responsible to the Executive Director for Operations to ensure proper and timely execution of NRC policies and procedures related to receipt, action and disposition of allegations that fall within the jurisdiction of Region V.

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

! f personnel as appropriate:

q -gp 3 g3 ~ ~ ~ . m -

b l G-?

i

_ a. Ensure that the Regional Administrator and the Office

(~'} Allegation Coordinator are immediately informed of allegations

(_,/ that he becomes aware of.

b. Serve as Chairman of the Allegation Panel.

c. Convene an Allegation Panel, evaluate available information,

, and within four (4) days of the receipt of the allegation formulate an action plan to approprirtely dispose of the ma tt e r.

d. Notify the responsible Licensing Office (NRR-NMSS) within two (2) days of the receipt of the allegation.

e. Prepare, sign and/or concur in all written communications 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.

3. Office Allegation Coordinator serves as the focal point for the management of information received from allegers and assures that the Regional Administrator and all responsible parties are informed

. of and kept current on the status of allegations. In particular the Coordinator shall:

a. Serve as a member of all Allegation Panels.

b. Verify that allegations are entered into NRC Allegation Tracking System within two-(2) working days of receipt.

c. Verify that written communications have been sent to alleger as-pre l scribed in Section E,.5 of this' instruction. Sign and/or .

c'oncur'in the letters sent to an alleger ~at'the' discretion of the cognizant Division Director. _-

d. Upon disposition and/or closure of an allegation, verify that the file is complete and contains all necessary documentation pertinent to the allegation.

e. Provide the cognizant Division Director, Enforcement Officer,

. State Liaison Officer, and Public Information Officer with copies of the Allegation Data Form when the d ta is entered into the NRC Tracking System. Thereafter, ir.oom the Director and Officers of all significant information s ubsequently obtained pertaining to the allegation.

I O

Revision 0 JAN 6 E84

~

P

f. Ensure proper implementation of Region V Instruction 1302, y

• Allegation Tracking System.

L 3 Serve as the interface and principal contact person between the Region V staff and the staff of the Office of Investigations, Region V.

, 4. Enforcement Officer shall:

a. Serve as a member of all Allegation Panels.

b. Provide advise on potential violations and possible severity levels that may arise from the allegation.

c. Alert the Regional Administrator of alleged significant -

violations of regulatory requirements that potentially could result in escalated enforcement action.

5. State Liaison Officer shall inform state and local officials of information contained in allegations that fall within the jurisdiction of the state and local governments and provide notice to the appropriate officials of NRC findings and actions if and when appropriate as determined and directed by the cognizant Division Director, with due regard for the need to maintain the nature of the allegation and its source confidential.

6. Public Affairs Officer shall respond to requests from members of the (

O media and other members of the public for information concerning allegations. Information pertaining to an allegation shall not be released without approval of the cognizant Division Director.

7. Region V Employees shall, upon receipt of an allegation, complete an Allegation Report and deliver it to the Office Allegation Coordinator.

E. ACTION:

1. Receipt of Allegation

! a. Region V employees who receive an allegation in written form I shall immediately deliver the document to the Office Allegation

( Coordinator or, in the Coordinator's absence, to the Regional t Administrator.

b. Region V employees who receive allegations over the telephone l or during discussions with individuals shall obtain, if possible, the following information.

l (1) Full name of person.

(2) Telephone number where person can be reached (work -

! home).

(3) Mailing Address.

Revision 0 JAN 6 1584

\ . _ _ _ _ _ _ _ _ _ _ _ _ - - - . ._ . -. . _ _ _ _

..emem i

,, (4) Name of employer. '

r~'i 1

.(_,) (5) Place of employment.

(6) Job or position title.

(7) Name of licensee.

s (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 significance.

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.

c. A standard allegation report form is attached as Appendix A to this instruction and should be used to document all allegations. The Office Allegation Coordinator will assist, if needed, with the completion of the report and review all reports for completeness. At the same time, an Allegation Data Os Form should be completed per RV Instruction 1302. Both documents should then be immediately delivered to the Office Allegation Coordinator who shall then immediately notify the cognizant Division Director and provide the Director with copies of~the A11esation Report.

d. If an employee receiving an allegation believes-it would be better for the . alleger to discuss the1 matter with another' .

employe'e, and if the alleger consents,' transferthe 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.

c. Many persons reporting a particular matter to NRC wish to i remain anonymous. If the alleger refuses to give a name, inform the person that:

(1) NRC will, if the alleger so requests, treat the individual's identify as confidential. (See paragraph 7 of this section for additional detail.)

(2) All matters involving public safety will be examined and i evaluated. The individual's identity may, however, be l

revealed where required by law, when necessary to insure Revision 0 ,. , a 1994  !

- - - - - c.-..- -.--._, - - - - - - - . - - . - - - - - - - - - - - . - -.

._-n-, . - - - . - , - . - _ - . - _ . _ , , - - - - , - . - - - - - ,- . . _

EBF .,

public health and safety, pursuant to congressional -

directives, where he himself makes -the matter public or B 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.

o (3) If the individual is alleging discrimination, refer the person to the Enforcement Officer or to an investigator in the Office of ILvestigations Region V. If this cannot be done, obtain as much information as possible about the problem and then inform the person that a complaint must be filed with the Department of Labor within 30 days of the acts complained of in order to obtain the Department's assistance. (See paragraph 6 of this section for additional detail.)

(4) 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. 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 auch information as possible and advise the individual to 9 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'allegat' ions that involve conditions that

~

s.

. 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 four (4) 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:

(1) Ensure that issues raised in the allegation are identified and understood.

(2) Evaluate the safety significance of all issues.

(3) Identify potential violations of regulatory requirements and potential enforcement action.

(4) Determine what additional information must be obtained.

(

(5) Consider time sensitivity.

( )

Revision 0 JAN 6 884

IBF .

(6) Determine a strategy for handling allegations, i.e., inquiry, '

routine inapection, special inspection or investigation.

D 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 falsification; willful or deliberate violation of a regulatory requirement; material false statements, or improper conduct which affects licensed activities should be referred to 01 for investigation.

(7) Recommend referrals to other NRC Offices, or to other Federal, State or Local governmental agencies.

(8) Identify the need for additional expert technical or

. investigative skills.

(9) Determine what information should be maintained confidential.

b. After evaluating the available information, the Allegation Panel shall provide the cognizant Division Director witn recommendations in the form of an action plan as to what actions should be taken to appropriately resolve the matter.  ;

[ c. If inquiry or inspection activities are conducted to verify or

' obtain additional information about an allegation, the 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 in'terview, 'the date, time, location, name of person, and the answers obtained plus any additional relevant information obtained during the inte rview. 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 be maintained as part of the official agency file.

(2) Infonmation obtained f rom 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 i forms" or " daily radiation survey forms," obtain only copies of selected samples.

( )

i Revision 0 -

l

. For dotaments believed to contain vital information to. - t support or refute an allegation, and if a copy cannot be obtained at the time, request permission to date and initial or otherwise mark the document for future identification and then hand copy or otherwise record all information contained on the document.

, (3) If the inspection strategy involves sampling, make sure the technical basis of the sample size is clearly stated.

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 fN s_- individuals that may require referral to the Department of Justice.

All notification decisions'shall be made with due regard for the need to maintain the nature of the allegation and its confidentiality.

4. Documentation

a. Each allegation received chall be documented on an allegation report form prepared as called for by Appendix A to this instruction.

b. kesults of evaluations of Allegation Panels shall be documented in a memorandum to files signed by the cognizant Division Director.

c. Action plans to resolve allegations shall be documented and approved by the cognizant Division Director.

d. Details and results of inquiries and inspections shall be documented in the standard IE formats except that all documents obtained during follow-up activities including original interview documents should be filed with the reports.  ;

I O'

Revision 0, JAN 6 E84 e l

P

• i

(_,

- e.

f- e. All documents includina letters to and from an alleger relating '

{ ) to an alleastion shall be filed in an appropriate facility ts _,) docket file. Confidential and/or sensitive material should be marked as " official use only." ,

I

f. The purpose of all reports and other documents is to set forth sufficient facts and information in a manner such that a y 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.

5. Letters to Allegers Acknowledging Receipt of Allegations All allegations received from concerned citizens will be acknowledged by a letter to the individual who presented the allegation. 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 rho received the allegation. The purpose of the letter is to assure the alleger that his concern will be examined as appropriate, and that the examination will address all of the specific concerns expressed by the alleger.

\

The Office Allegation Coordinator (OAC) is responsible for preparing acknowledgement letters to allegers. No members of the Region V staff will prepare and forward any correspondence to allegers without first coordinating such action with the OAC, to ensure that a single point of contact can be maintained for the alleger.

Generally there are six types of letters which could be sent to allegers. These are as follows:

i .

1. Normal first letter

2. Restatement of Concerns

! 3. Request for Additional 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.

6. Employee Discrimination Complaints

a. Background C

Revision 0, JAN 6 B94

A Memorandum of Understand 6me (MOU) etS**d W ashC med 19he ' ,,

Department of Labor (dol) f ac s t a t.tes coordanetton and cooperation between the agencies in the processing of s, t

violations of the employee protection provisions of Section 210(e) of the Energy Reorganization Act. Subsequently, working arrangements were developed and points of contact established at regional and headquarters levels for each

, agency. ,

b. Working Arrangements The working arrangements between NRC and DOL establish certain commitments that must be carried out by the regional contacts -r for the NRC. The working arrangements provide that NRC will , ,

refer complaints to DOL, advise DOL of complaints received concerning employee discrimination, inform DOL of investigations that NRC is conducting into these matters, and

' facilitate DOL investigations by assisting in gaining access to NRC-licensed facilities.

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 a'ce'ess to all.information it.cbtains conce'rning'a.

particular allegatlon 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.

c. Processing of Complaints If a complaint is received concerning a possible violation of Section 210(a), the OAC will refer the complainant to the Enforcement Coordinator, the Region V point of contact i

responsible for the regional implementation of the NRC-DOL MOU.

Region V will not normally initiate any action on such a complaint if DOL is conducting, or has completed, en investigation and found no violations; however, the matter will be documented on an Allegation Report and entered into the Region V Allegation Tracking System.

1

' Revision 0, JAN 6 1984

F ,

7. Confidentiality

a. Background The ability of the NRC to obtain information, particularly adyerse 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 :eporting 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 fear of being out of work for an extended period of time while going through the legal process.

Confidentiality is a means by which the NRC protects and withholds the identity of an individual who provides It is NRC incriminating and/or adverse information to the 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 Confidentiality should not be routinely offered to individuals making allegations or otherwise providing information during the course of an NRC inquiry, inspection or investigation.

'b However, if a Region V staff member is of the opinion that he would not receive the information, or if the individual providing the information requests anonymity, then a grant of j confidentiality will be proffered. Before confidentiality has i

been granted, the individual should be informed that, although the pledge ,is not absolute, it is NRC policy not to divulge the identity of people granted. confidentiality.' Also, the individual should be told that their name #ill no~t normally appear in the publicly released reports. The individual's identity may, however, be revealed where required by law, when necessary to insure public health and safety, pursuant to Congressional directives, 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 In these cases, provide a basis for guessing their identity.

NRC will neither confirm or deny requests to verify the identity of a source of information. One point regarding promises of confidentiality should be clearly understood by all Region V staff 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.

i f.-. Should a Region V staff member grant confidentiality, all facts

(

JAN 6 1984 Revision 0,

and circumstances surroundina the pledge must be documented in a memorandum to the OAC who will coordinate the in f o rmat ion D with the cognizant Division Director.

c. Restrictions _

Within Region V, the identity of any individual making

• allegations, expressing concerns, or registering complaints shall be treated as "0FFICIAL USE ONLY" information. Their  !

names shall not appear in any report (except as noted above regarding the preparation of Allegation Reports or related  !

memorandum) or any internal memorandum or other document placed l in normal mail distribution, nor will it be divulged to any NRC employee or outside individual who does not have a need for such informatioL. 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 aball 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 i guesses the identity of the individual, the Region V staff O members will respond that the NRC position is.to neither confirm nor deny the validity of such guesses and refuse to discuss the matter further.

APPROVED: John B. Martin. , ,

, Regional Administrator Date': JAN 6'B84 l

Revision 0, JAN 6 1984 l

l I

99V .

APPENDIX A PREPARATION OF ALLEGATION REPORT k

A. Purpose Allegation Reports (AR) serve as the basic document for initiating an

. allegation file within Region V. All allegations should be documented on the Allegation Report form in accordance with the following instructions:

B. Documentation Region V personnel shall document information regarding an allegation, complaint or concern as follows:

a. Name

- Enter the full name of the individual providing the information.

b. Addresa - Enter the mailing address of the individual providing the information.

c. Phone - Enter the residential and/or business phone number of the individual providing the information.

d. Allegation - Enter a concise statement describing the allegation, concern or complaint (e.g., improper welding procedures used in containment).

)

e. Facility - Enter the name of the facility involved in the allegation, complaint or concern (e.g., Trojan).

f. Docket No. - Enter the docket number of the facility if known.

g. File No.

- Leave blank. -The Of.fice - Allegation , Coordinator (AOC).will assign an NRC' tracking number.

~

h. Date and Time - Enter the date and time of initial contact with the individual who provided the information.

i. Confidenti- - If the individual who provides the information ality Requested was granted confidentiality, so indicate and provide details.

j. Summary of - Enter the details of the information provided Information by the individual.

k. Prepared By - Enter your printed name and signature. ,

l

1. Date - Enter date document was prepared.  ;

m. Action - Leave blank. OAC will use this space for I

Required internal administrative actions.

}

JAN 6 1984

l l

as Reviewed By - Leave blank.

O. Date - Leave blank.

1 l

1

-1 1

1 I

e i

s 1 0 l

I i

l l

i

, e I

l i

1

• l

. \

NW$ - .. .

i s

FILE No:

- _18tESS :

OATg:

-7

• TIME:

l l

NO DOC NO:

CONFIDENTIALITY REQUESTED YES PHONE:

SUMMARY

OF INFORMATION:

wW l' '

\

i l t Past DF DATE PCEPallED SY ACT800s REOUIRED 1

1 DATE grEviEWED SY l JAn 6 1984 opnciat USE ONLY , - DO NOT DISCLOSE

s weemaniaoAus.=

WALNUT CRE E K. CALIFOg,. ,,m.

n v

(DATE)

(NAME) .

' 'i (ADDRJSS)

(CITY, STATE, ZIP CDE)

SUBJECT:

(ALLEGATION FILE NUMBER)

(STANDARD INTRODUCTORY PARAGRAPH)

This refers to (TELEPHONE CALLS, MEETINGS AND/OR LETTERS) in which you expressed concerns related to (GENERAL areas of allegation) practices at (NAME OF UTILITY AND/OR SITE).

(STANDARD PARAGRAPH - INQUIRY INITIATED)

An enclosure to this letter documents your concerns (S) as I understand (IT/THEM) based on (OUR CONVERSATION)(MY CONVERSATICN WITH )(OUR MEETING) (OUR LETTER). We nave initiated an inquiry eegarding this matter, therefore, if the m enclosure does not completely anc accu-ately reflect all of your concerns, please

[V \ contact me collect as soon as possible at (415) 943-3700 so that we can assure that they are adequately addressed during our inquiry. If you should call and I am not available, please leave a message so that I can return your call.

(STANDARD. PARAGRAPH.- INSPECTION REQUESTED)

An enclosure to this letter documents your concern (S). as I uncerstanc (IT/THE").

j cased' on (OUR. CONVERSATION)(MY CONVERSATION With .)(0UR MEETING)(YOUR LETTER).

I have requested' that our . inspectors look into t.his matter curing one.of .tneir "

upcoming inspeci. ions, therefore, i'f t'he enclosure idoes not completely and l

accurately reflect all of your concerns, please contact me ceilect as soon 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 available, please leave a message so that I can return your call.

(STANDARD PARAGRAPH - ACKNOWLEDGE REQUEST FOR CONFIDENTIALITY)

Regarding your request for confidentiality, let me assure you that we will make every attempt to handle this matter in such a way as to maintain your anonymity.

In this respect, I would like to point out that licensees sometimes correctly guess the identity of the individual providing information to us. In such cases our policy is to neither confirm or deny the accuracy of their guess.

l JAN 6 1964

.i O

(STANDARD PARAGRAPH-CLOSING)

In closing, we appreciate your bringing your concerns to our attention. If you have additional questions, or If I can be Tf further assistance in this matter, please do not hesitate to contact me.

Sincerely, (NAME)

(TITLE)

Enclosure (s):

Statement of Concerns s

l b

. Jr. '. C 1"i t-

lg..

" " " * * ~

D  :::-

(DATE)

(NAME) .,

(ADDRESS)

(CITY, STATE, ZIP CODE)

SUBJECT:

(ALLEGATION FILE NUMBER) t (STANDARD INTRODUCTORY PARAGRAPH)

This refers to our letter to you dated (DATE), the enclosure to which documented our understanding of your concerns relative to (GENERAL AREAS) practices at (UTILITY)'s (SITE) nuclear power plant and to your subsequent (LETTER TO US DATED IN)(TELEPHONE CONVERSATION WITH NAME AND DATE DURING) which you providec (ADDITIONAL)(AND)(CORRECTED) information regarding your concerns.

The enclosure to this letter represents a restatement of your concern (S) as we now understand (IT, THEM) based on the (CORRECTED) (AND) ( ADDITIONAL) information you provided. However, as before, if the enclosure does not completely and accurately reflect all of your concerns, please contact me at (415) 943-3700 as F O- soon as possible.

(STANDARD CLOSING PARAGRAPH)

Again, we appreciate your informing us of your concerns anc your cooperation is ensuring that we understand them correctly.

Sincerely, (NAME)

(TITLE)

Enclosure:

Statement of Concerns - Rev.

(REV. NO.) .

I O

- JAN 6 BC4

l y .

an"mnYeIuNirEEEEases D ....*

1 (DATE)

(NAME)

(ADDRESS) . ,,

(CITY, STATE, ZIP CODE) 1 i

SUBJECT:

(ALLEGATION FILE NUMBER)

(STANDARD INTRODUCTORY PARAGRAPH)

This refers to (TELEPHONE CALLS, MEETINGS, AND LETTERS) in which you expressed concerns related to (GENERAL AREAS) practices at (UTILITY)'s (SITE) nuclear power plant site.

(RECUEST FOR ADDITIONAL INFORMATION PARAGRAPH We have determined that we need additiional information from you before we can proceed with our inquiry into your concerns. We have attempted to contact you by telephone without success and I would appreciate your contacting me collect a:

(415) 943-3700 as soon as possible so that we can discuss this matter furtne".

{ ADDITIONAL INFORMATION PROMISED BUT NOT RECEIVED)

^

Based on your telephone conversation with (NAME) on (DATE), it was our uncer-standing'that you would provide additional information and I would appreciate your contacting me collect at (415) 943-3700 at your earliest convenience so that we may proceed with our inquiry into this matter.

Your cooperat' ion and assistance would b'e appreciated.

Sincerely, (NAME)

. (TITLE)

- jai 2 i. *

• use n AnUe.~eusya no WAI. NUT CREEK, CAUFORNIA 94506

,/

D (., ...

.*..v (DATE)

(NAME)

(ADDRESS)

(CITY, STATE, ZIP CODE)

SUBJECT:

(ALLEGATION FILE NUMBER)

This refers to our letter to you dated (DATE) in which we requested that you contact us to provide additional information regarding your concerns related to (GENERAL AREAS) practices at (UTILITY)'s (SITE) nuclear power plant site which you discussed (IN YOUR LETTER TO US DATED (DATE)) (IN YOUR CONVERSATION WITH (NAME) ON DATE)).

In that you have not contacted us and provided the additicnal information we requested, the Regional Staff plans no further action regarding this matter. We have, however, alerted our inspectors to your general conceri., so that they can j pay particular attention to those areas during their routine inspections. 2 Should you have any questions re'garding our disposition of this matter, please call me collect at (415) 943-3700 Sincerely,  ;

-(NAME)

(TITLE) l h

'O pe!

I

y .

7 -

, _ _ . _ . _ _ . ..q.

1480 MARIA LANE. SUITE $10 D ' **.'.',*** / WALNUT CREEK. CALIFORNIA 94586 (DATE)

(NAME) '

(ADDRESS)

(CITY, STATE, ZIP CODE)

SUBJECT:

(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 conerns 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 natter.

(PARAGRAPH: ACTION COMPLETE -NOT ADDRESSED IN REPORT Our inspectors have looked into this matter; however, to maintain your confiden-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) 0'ur (INQUIRY)(-INSPECTION)(~INVESTIGATIDN) regar' ding this m'atter has.been completed. In that 'your concerns dealt with physical security r"tters, the details of which are exempt from public disclosure pursuant to lo CFR 2.790(d), ,

we are unable to provide you with a copy of our report. We have, however, documented our findings in a general sense in an enclosure to this letter.

(PARAGRAPH: ITEMS OF NONCOMPLIANCE IDENTIFIED)

With regard to the item (s) of noncompliance identified during (INSPECTION)-

(INVESTIGATION), (UTILITY) is required to inform us in writing of the corrective actions they have taken or plan to take and our inspectors will continue to follow such actions to ensure proper resolution.

(PARAGRAPH: EXPLANATION OF UNSUBSTANTIATED)

I would like to explain tnat the finding " unsubstantiated" does not necessarily mean that we find the facts as you st..ted them to be untrue. rather it means only I that we were unable to obtain objective evidence to corroborate your statements g through interviews, document reviews and/or direct observation.

JAN d B84

(PARAGRAPH: STANDARD CLOSING)

We appreciate your informing us of your concerns.

We feel that our actions in this statter have been responsive to those concerns; however, should you have Please further questions regarding this matter, please feel free to contact me.

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, (NAME)

(TITLE) l I

I I

l l

l .

I JAN 1994-

7 h r li N fov ike nr we ni o

tf co e

rnl mi rt s

n o

ei f

o n 3 _

?

Cnc I ue C r i oo Dit tP oc Fa no l

ip fu 8

Ho C f p w rOo lOoo1 ou ro oat n w el ssi no tl tad ol so chn il af &

- a e to I ml i

- tot af e

- nht l m i sl l owa na e

- rt i

/

- C( on i f fe as e /

1i l

i nm te 7llly -

iu c

nv ii tC aB e

t w

o eo td ae mc i cC 1 Q

nri ifd

/ae a nr ke ct at lli e

l&

p m8 Cr I

C&

e A l o ds pt u -

ilIOni C

wtm-Aidi oda sm mr f

DD tl aL rOi e

g5 e

l nt li o A/l we

~

Ti o3 C2 iII

~1 sr ea sw loro Cf d

Q tAv st e.ce s l

~0 I (r en l o

m d te tgrl 8 N rsf ay am at 3 o m

0 1

wal i e ta inMfo lI 2

e 3 t

C rdl id ol m m E o i ne res s r R F2w Il ony n o o oaa o f t H ii CPd si g C tt I s Ii U lll cc R e l EM O ea l II t R p s u HE H so e bt l TT S

T il l

au l o v

t e

is ri tl L

L Y

L NY IS I

D g

S E 1 llI l t S N al o s I0 N E 3

I l E N C s G cl m ic F1 O GT S 3R O N I N t N io l o Dc NN O n c ST C IE L ~,

G FS 0 C O I nf EN O SM C e O OR n 1 I e T h S I A OE r R E T O T -m E cC ' C TE-uP s

oS NP O

IG fa

t io C A I T

D1I C

A eut rcr poo E

M TA eC lO1 N

I C

I AS^

C IS<

YlI B

11 LG CA SA N

N O

I w

TN f g7 S R S L wn T l LI~ T l'N c

nO EI CI AV I ae0 tl2 S. l

'C O

A W

R

'C I

Nos

,d e

. ,R r's c E N

A P

ii eo vs es C

A iIi

,7 P

UY DP O

T U

O E

TM N

EN MO G

E A

L g

T E Aml1A O C i L

A C l r F eu Ra n0 CC S UI G E ato i i Sdt l a2 I O CT A m n OA E

L L

A II R

ie huR cnf nrsI i

Ml a Aot n

fS lI rgo ini ait C&

C I

L DG CL IL E

1 i

cc gsI hsa F eon ii i eR Com CA O TDo sr l r 7 san ocoi tnf T l 0 A pi .I R 2 en ,*

A Ili ll o i H s mg d C e e et8 e i wr mM3 t m W f eu 2 on te O i l it sl L r l va de, m '

e en nn7 ou mc F IlI t.~

v & Ro ea0 SP3 eo f i f C 8 rs mdn .~

a O 3 t lll o Ls tsi A 2 G-t S uat C lI , t'f c c1 eO 7r ne eCu 0e eii sI r vA) 1 jI1i tol yi l

3t t {

mh eC loCts p ate ,e g Con <

ti r t 7l dn s tda 0 eo e rs J sri 2 li rei i ad w, wt agh n e so oc imm mom en pk ne kS pet el ,

dri yc c o rl n .

A( TA A& o w

Pai lli lj1 ll o 5 sl el .

to aF i

n 1 t4 lIlllIIII ia Q*

nc ii Ch n h,;

Oc .

Ae T

[

il l

D lN