ML20244C781
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l- MEMORANDUM FOR: ' Richard C. DeYoung, Director, IE Thomas E. Murley, Regional Administrator,,R,J_,_ ----
James P. O'Reilly, Regional' Administrator, RII James G. Xeppler, Regional Administrator, RIII t/ John T. Collins, Regional Administrator, RIV l John B. Martin, Regional Administrator, RV i FROM: William J. Dircks Executive Director for Operations
SUBJECT:
POLICYONTHEDISTRIBUTIONOFDRAFTINSPECTIdNAND i INVESTIGATION REPORTS l l -
t I .have reviewed your coments with regard to the policy on distribution of 4 l draft inspection reports stated in my memoranda of March 24 and July 30, 1982.
T have also discussed.our policy on release of draft investigation reports 5 the Directors of OI and OIA.
ihe primary motivation of this policy statement is to ensure that official NRC f documents, and their inspection and investigative conclusions, are published without any taint, either real or perceived, of improper influence by those we regulate. Moreover, we will reinforce policies which strengthen the authority of the NRC field staff to comment freely on safety issues at the preliminary stages of fact collection and evaluation. The basic problem to be addressed by this policy is the fact that licensees shall not be afforded opportunities to modify NRC documents to their advantage outside the public arena.
In order to give suitable consideration to these issues, the policies stated in my memoranda of March 24 and July 30, 1982 are superseded by the following:
A. Objectives The following statements reflect the basic objectives of this policy statement:
- 1. To ensure that sufficient flexibility is provided to the Regional j Administrators so that they and their staffs will not hesitate to disseminate safety-related information to licensees during the inspection / investigation process, prior to distribution of the final reports, and
- 2. To ensure that inspection / investigation findings accurately represent the facts collected by, and the conclusions drawn by, the NRC staff, without improper influences by licensees or their agents A
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2 on the' content and/or conclusions of NRC reports of inspections or.
investigations.
-B. Safety and Security Issue Communications NRC policy recognizes that nuclear safety and security concerns must be addressed by prompt, positive actions. Accordingly, safety or security information must be promptly and clearly identified to responsible licensee management to obtain prompt licensee evaluation and, if appro-priate, safety-related corrective actions. Such clear communications are necessary to maintaining required levels of safety and security at licensed facilities. When such communications are made as a result of concerns that arise during the course of an inspection / investigation, the fact of the connunication should be noted in the inspection / investigation report, and a copy of any written communication should be included in the report.
Where approved by regional management, inspectors may, in preparation for exit interviews or enforcement meetings, provide to the licensee a f- listing of significant issues developed in the course of an inspection, in order to faci corrective actio,11
- n. tate communication However, of inspection notes, draft findings reports, draft which require evaluations, draft notices of violations or non-compliance, or other material containing preliminary inspection conclusions, findings and recommendations are not to be qvided to the licensee, except as required by safety or security concerns, as noted above.
Briefing materials prepared by the staff for use in meetings with licensees occasioned by inspection activities should be reviewed by regional management prior to distribution at a meeting, and appended to the inspection report.
C. Release of Draft Insoection Reoorts Under no circumstances should draft inspection reports, either in their ;
entirety or excerpts from them, be released to licensees or their agents, or !
to any source external to the NRC without the express permission of the EDO. I For the purposes of this policy, a draft inspection report is the preliminary draft of the document which will provide the account and conclusions of an official NRC inspection. It is to be considered a draft inspection report from its initial development, and throughout the period of supervisory and management review, until final publication and distribution in accordance with IE Manual Chapter 1025.
, In the event any draft inspection report is inadvertently or otherwise
! released contrary to this policy, the rnn <heuld be prcmotly advised in 1
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Ato, . The EDO will take or recomend action as appropriate.
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D. Release of Oraft Investigation Reports For the purposes of this policy, a draft investigation report is the l preliminary draft of the document which will provide the account and findings of an official NRC. inquiry or investigation. It is to be considered a_ draft. investigation report from its initial development .
[ and throughout the period of supervisory and management review, until
- final publication.
~ It is important to realize that OI is required by Comission directives E ,
to inform Regional Administrators of safety and security. issues as they are. developed in the course of an investigation. Regional Administrators shall.act on this information in accordance with the policies set forth' above for the prompt communication of. safety and security issues, and in addition shall observe the following procedure.
The Regional Administrator shall inform the' Director. 01, in advance that information related to an open investigation'is being considered for release to the licensee because safety or security concerns require
_" initiation of corrective actions before publication of the investigation report. The Dirsctor, 01, should review the information to be released and advise the Regional Administrator of the anticipated effect of.its release on the course of the investigation. The Regional Administrator
,. will release the infonnation only after determining that the safety or security concerns are significant enough to justify the risk of compromising the effectiveness of the investigation and, possibly, subsequent enforcement or prosecution options. Any such release of information should be recorded in the investigation report.
Pursuant to Commission approved OI policy, draft O! reports of
. investigation will not be circulated outside the NRC without the specific approval of the Chairman. (OIA draft reports of investigation will under no circumstances be reviewed with or given to licensees, 1 their agents, or to any source external to NRC, without the express '
permissionoftheDirector,OIA.) Requests for such pennission should be made through the EDO.
In the case of an emergency appeaHng to require immediate action, NRC 4 personnel shall provide the licensee with any infonnation they judge the !
circumstances warrant. If time permits, regional management should be l consulted first. '
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- The: foregoing policies are effective immediately. The EDO, following an appropriate evaluation period for this policy, will incorporate this '
policy into the NRC Manual. Also, the EDO is reviewing existing procedures
- and practices related to other types of communications under the Lcognizance of other NRC Offices and.will issue policy guidance where deemed appropriate.
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Willia J. Dircks Executive Director for Operations cc: H.'Denton
~J. Davis R. Minogue G. Messenger .
B. Hayes I
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UNITED STATES
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I DEC 3 31985 j Regional Office Policy Guide No. 0214, Revision 0 ACTION REQUEST TRACKING SYSTEM (ARTS) PROCEDURES <
A.
Purpose:
To establish procedures for tracking correspondence associated with a Region IV request for action from a party outside the Regional Office.
B. Discussion:
Regional staff often originate correspondence which requests an action from an individual or organizational entity
- outside the Regional Office (e.g. , program of fice staff or other government agency). In order to >
verify that responses to Regional requests for action are received in a timely manner, this guide establishes the Action Request Tracking System (ARTS). The primary responsibility for maintenance of this system will rest with the Action Request Coordinator (ARC). The ARTS will be maintained on the 5520.
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/ C. Action:
- 1. Secretary Responsibilities The secretary of the Region IV staff member initiating any correspondence requesting action from an external source will:
(1) call the ARC for an Action Request number; (2) complete an Action Request Control Form (enclosed); (3) attach the fonn to a copy of the correspondence; (4) copy the form and forward it to the ARC; and (5) place the original Action Request Control Form plus the correspondence copy into a tickler file until all requested action has been completed.
- 2. Action Request Coordinator Responsibilities After receiving a copy of the Action Request Control Form, the ARC will: (1) enter the information from the control form into the ART 5; (2) print out an ARTS listing and review for errors; (3) forward the listing to the mail room for distribution to principal staff members and all Regional Secretaries; and (4) maintain the Action Request Control Form copy in a pending file.
"It should be noted that the provisions of this guide do not pertain to correspondence sent to Region IV licensees.
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Regional Office Policy Guide _
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- 3. Closecut of Action Requests When a response is received, the cognizant secretary will: (1) remove the original Action Request Control Form and the !
correspondence copy f rom the tickler file; (2) complete the closeout '
portion of the form, attaching all written responses; and (3) forward the form and correspondence to the ARC. The completed package will constitute the Region IV Official File Copy.
The ARC will then remove and destroy the pending control form copy from the files, enter closecut data into the ARTS, and forward the Region IV Official File Copy to the Region IV File Room for the final phase of the closecut.
- 4. Outstanding Action Requests As noted above, the ARC will print a composite list of all outstanding action requests for distribution to the principal staff members and Regional Secretaries. This list will be distributed weekly. In addition, a compilation of all closed action requests
_ will be distributed on a quarterly basis.
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D.
Contact:
Any questions or comments concerning this Policy Guide should be directed to the Chief, Information Management Section (Ext. 121). ;
E. Cancellation Date:
This Policy Guide is effective upon issuan,ce.
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tYM Ybtf Robert D. Martin Regional Administrator
Attachment:
Action Request Control Form Distribution List C 9
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DEC 13 '1983 9
REGION IV ACTION REQUEST CONTROL FORM FOR THE ACTION REQUEST TRACKING SYSTEM (ARTS)
ACTION REQUEST NO.
DATESUBh,ITTED'FORENTRYINTOTHEARTS:
DATE OF. CORRESPONDENCE REQUIRING ACTION:
MEMORANDUM / LETTER T0:
FROM: ----
(ORIGINATOR):
.)
(ASSIGNEE):
SUBJECT.:
,, ACTION REQUESTED: VERBAL WRITTEN COMMENTS:
..]'
CLOSEOUT REMARKS:
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RESPONSE DUE DATE: 1 CORRECTED DUE DATE:
i DATE RESPONSE COMPLETED:
UNITED STATES
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$ ,8 REGION IV S 4 511 RYAN PLAZA DRIVE. SUfrE 1000
- '+o / ARLINGTON, TEXAS 79011 APR 211986 Regional Office Policy Guide No. 0220, Revision 0 MEANING OF CONCURRENCE A.
Purpose:
To establish a region-wide definition of what concurrence by a Region IV employee means on a concurrence sheet of a report, memorandum, or other documents.
B. Discussion:
This guide was necessitated by the apparent confusion of one or more employees as to what was the meaning of their individual concurrences its various documents.
C. Action:
When.a Reglon IV employee initials or signs his or her name on a concurrence sheet of a report, memorandum, or other document, the g ( employee is formally stating that he or she is in agreement with the report, memorandum, or other document in those areas for which the employee has knowledge, expertise, or responsibility. No employee should concur in any document if he or she does not agree with those aspects of the document for which he or she has knowledge, expertise, or responsibility. Disagreement as to a document should be worked out with supervisors or other appropriate parties, depending on the situation, in accordance with applicable policy. In some cases a nonconcurrence may be appropriate.
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D.
Contact:
Suggestions or comments should be directed to the Regional Counsel.
Ext. 271.
E. Effective Date:
This Policy Guide is in effect when issu .
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Robert D. Martin Regional Administrator Distribution List C L____--__--
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- .; NUCLEAR REGULATORY COMMISSION -
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AuG 2 51986 1
Regional Office Policy Guide No. 0334, REVISION 1 l NRC INSPECTOR OBJECTIVITY A.
Purpose:
To ensure that a specified and common set of criteria is used to assess the continued objectivity of NRC inspectors. ., j B. Discussion: .
IE Manual Chapter 0215, (MC 0215) "NRC Inspector Objectivity," was issued )
by the Office of Inspection and Enforcement on December 30, 1982, and revised June 1, 1986. In order to comply with Section 0215-05, "Implementa-tion," a form memorandum has been developed (attached) so that inspector objectivity will be documented annually.
C. Action:
- 1. The supervisor of each inspector, both resident and regional, will monito_r inspector performance for indications of reduceJ objectivity on a continuing basis. This will be accomplished through routine supervisory interaction with the inspector and through periodic site visits or inspection accompaniments. During these in.teractions,
! supervisory evaluations of inspector objectivity will be developed, and counselling provided if appropriate as outlined in MC 4215. 1
! 2. On an annual basis the objectivity of each inspector shall be compared to the criteria of 0215, paragraph 05, by the inspector's section or branch chief. This annual review shall be documented in a memorandum similar to the enclosure to the next higher level of supervision with a copy to the appropriate Division Director. A copy of the memorandum shall be provided to all covered staff members, and a file copy retained in the appropriate Division Director's office for a minimum of 2 years.
- 3. To aid in maintaining resident inspector objectivity, each resident inspector should spend at least I week per year performing inspections at another site or as a part of a team inspection.
l 4 First round objectivity evaluations shall be documented within l 60 days after issuance of this Policy Guide. Subsequent evaluations l will be perfonned during the month of October.
D.
Contact:
Deputy Regional Administrator (Ext. 222)
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Regional Office Policy Guide.. - -
-2 AA 2 5 We No.' 0334, Revision 1 E. Effective Date: -
This policy guide is effective upon issuance, and supersedes Policy Guide 0334, Rev. O, dated April 1, 1983 1
Robert D. Martin. - ~
'; . Regional Administrator t
Enclosure:
.As stated Distribution List C m
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i inclosure SAMPLE LETTER I
MEMORANDUM FOR: (Title)
FROM: (Title) - '
' 5UBJECT: STATEMENT OF INSPECTOR OBJECTIVITY The ' inspection' performance of all inspectors assigned to the (section/ branch)fortheperiodof- (BEGINNINGDATE)- to (ENDING DATE)- , have been reviewed against the objectivity criteria stated in IE Manual Chapter 0215. Based on this review.
no negative findings were identified.
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. Chief cc:
Division Director
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Regional Administrator 4
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- ARLINGTON. TEXAS 75011 MAR 211986 Regional Office Policy Guide No. 0450 Rev. 1 l THE QUALIFICATION JOURNAL AND INSPECTOR CERTIFICATION A.
Purpose:
To provide guidelines for the use of qualification journals and the documentation of inspector certifications.
B. Discussion:
l Inspection personnel must understand the facilities, processes, and activities they inspect and the criteria, techniques, and mechanics
., of inspections to be employed therein. Training activities for new
- inspectors and inspectors that have been transferred to a different field or seite will be documented in qualification journals. The basis for inspection qualification journal requirements and the resulting
, certification are given in IE Manual Chapter 1231. A qualification
- journal is an individualized training program for specific job functions. It incorporates applicable portions of MC 1231 and defines the required and supplemental training (formal and non-fonnal) that the Region has determined is necessary to each job function. Qualification journals will encompass the regulatory, administrative, and technical practices pertinent to each area of inspection. Inspector certifications will be unique to the types of inspector disciplines required in the Region, e.g., resident inspectors, project inspectors, specialist inspectors, radiation protection inspectors, security inspectors, emergency preparedness inspectors, and materials program inspectors.
The certifications for resident, project, and specialist inspectors will indicate construction inspections, operations inspections, or both.
It is not the intent of this Policy Guide to require inspectors to '
participate in each of the training activities required by their job function if they already possess the type and level of knowledge that would be acquired by completing the specified training. If inspectors, through previous work experience or training, are deemed to possess the appropriate knowledge level, then the appropriate re waive those training requirements (see Attachmen; 1)gional .
management .nsy Those inspectors who were considered qualified for certain inspection activities at the time of issuance of MC 1231 will be " grandfathered" for those inspection .I activities. Such grandfathering will be documented on the inspector's l certification sheet described below as Attachment 3. i l
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I Policy Guide No 0450 MAR 211986 Revision 1 ~
- The successful completion of a qualification journal including the 4 concomitant formal training courses, which are specified for the i particular inspection field covered by the journal, will constitute the minimum inspector qualification requirements. In general, only those inspectors who have successfully completed the required training for their field of interest will be allowed to perform independent inspections.
Moreover, until an individual inspector is specifically certified, the inspector will not sign the inspection report that documents his or her inspection activities. Instead the report will be signed by the lead certified s pector or the inspector's section chief.
If an inspector's management evaluates the background and performance of an individual inspector and concludes that the inspector has demonstrated an ability to perform unsupervised inspections in a certain area, even though the required training has not been completed, the individual can be certified to perfom inspections in such an area by the issuance of the interim certification form (Attachment 2). There will be occasions when an inspector needs to be assigned inspection activities in areas where technical qualification is not in the areas for which formal certification has been achieved by the inspector but in areas where technical quali-fication is unnecessary for the satisfactory perfomance of those specific inspection. activities. For those occasions, the' inspector's section chief's approval of the inspection plan will be the means whereby this
( type of inspection activity is authorized. Such authorizations of this i
' nature will, however, be limited to general activities not requiring detailed inspector knowledge.
Nothing in this Policy Guide shall prohibit or discourage an inspector from pursuing and identifying safety problems in an area for which he or she is not specifically certified if such problems are discovered during the course of an inspection.
C. Action: -
- 1. The individual inspector has the ultimate responsibility to complete his or her qualification journal within the specific time limits of MC 1231. The inspector shall also be responsible for assuring that the journal qualifications cards are maintained to reflect the current status of his or her training.
- 2. Division training coordinators are responsible for maintaining sufficient copies of the appropriate qualification journals (in accordance with MC 1231) and self-study quizzesc so that new employees can be provided with copies when they report for work.
- 3. Section chiefs are responsible for providing new tmployees (or !
employees changing to new inspector positions) with the qualifica-tion journals to be completed prior to certification. The section j chiefs will instruct their employees regarding the priority of the '
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i Policy Guide No. 0450 AMR 211985 Revision 1 i
areas in the journals to be covered and any areas requiring special emphasis. The section chiefs will also periodically review the journals of the personnel under their supervision on at least a quarterly basis. Section chiefs will advise their staff of the schedule for the training courses offered by the Technical Training Center and informal in-house training, which are to be completed to fulfill the certification requirements. Section chiefs will also initiate the waiver requests for required training, waiver requests for interim certification prior to qualification journal completion, and final certification as given in Attachment 1, 2 and 3. l
- 4. Senior Resident Inspectors (SRI's) in lieu of a section chief will i periodically review the journals of the resident inspectors assigned {
to their supervision. The SRIs will also provide guidance to the resident inspectors regarding the priority of the areas in the journals to be studied and the areas needing special emphasis.
- 5. Division directors are responsible for waiving specific training requirements for their assigned personnel on a case-by-case basis ;
, where previous experience or other circumstances make the training
_~ requirement unnecessar (It is expected that training waivers will be granted sparingly.)y. Division Directors are responsible for certi-fying 'the completion of qualification journals of those inspectors
' under their supervision. Division directors will periodically audit (at least annually) the provisions of this Policy Guide to assure that it is fully implemented. ,
- 6. The Regional Administrator is responsible for waiving the qualification requirements for independent inspections by inspectors who have not completed the certification program.
D.
Contact:
For questions or comments on this Policy Guide, contact the Regional Training Officer.
E. Effective Date:
This Policy Guide is in effect when issued and supersedes Regional Office Policy Guide No. 0450, Rev. O, dated 4/30/8 Robert D. Martin Regional Administrator s
Distribution List C I
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i ATTACHMENT 1 I
Waiver Request for Training Required by the Qualification Journal I
Inspector's Name: !
Required training for'which-
- a. waiver is requested:
Basis for waiver request (e.g., specif experience, equivalent training, etc.)y:
.,t... Recomended by:
Section Chief:
Branch Chief:
Division approval:
Date of approval:
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i ec: Division Director Inspector Division Training Coordinator Regional Training Coordinator Regional Training Officer Branch Chief Section Chief I
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ATTACHMENT 2 Waiver Request for-Interim Certification Prior To Qualification Journal Completion 1
Inspector's name:
Functional area for which waiver is requested:
Basis' for certification prior to completion of qualification journal:
. Recommended by: -
, Section Chief:
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' Branch Chief:
Division Director:
The inspector named above is hereby certified to perform independent inspections in the functional areas identified above based on the
. justification indicated . The' inspector may also perform independent inspection in related areas as authorized by the Section Chief's approval of the inspection plan.
Regional approval:
Date of approval:
cc: Inspector Division Training Coordinator Regional Training Officer Regional Training Coordinator Division Director Branch Chief. >
Section Chief !
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. ATTACHMENT 3 Certification of Employee to Conduct Inspections Inspector's Name:
Description of specific area (s)' covered by certification:
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Reconnendation for certification based the' facts that the ' candidate (1) has completed the Regional' indoctrination training and training required by IEMC1231,(2)caninde
- the subject area (s), (3) pendently and satisfactorily can independently conductconduct and satisfactorily inspections entrance in and exit meetings, and (4) can independently and satisfactorily document the inspection findings.
Reconnet.ded by:
Section Chief:
Branch Chief: _,
Division Approval:
Approval Date:
cc: Inspector
. Section Chief Branch Chief Division Director Division Training Coordinator Regional Training Coordinator i Regional Training Officer I
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%,, ,, / ARLINGTON. TEXAS 76011 SEP 0 91985 Recional Office Policy Guide 0601, Revision 0 DUTIES AND RESPONSIBILITIES OF THE PROJECT INSPECTOR A. purpose:
To describe the qualifications, duties, and responsibilities of the Project Inspectors.
B. Discussion:
A Project Inspector will be designated for each reactor facility or. site (NTOL plants may require additional project inspectors) to carry out the duties and responsibilities listed below. The Project Inspector will be an experienced region-based inspector, with the experience consistent with the status of the plant (s) for which the inspector is the designated Project Inspector.
The Project Inspector will maintain thorough familiarity with his l assigned reactor plant (s) through appropriate technical training, site T
visits, study of docket material, interaction with RIV inspectors, inter.ction with NRR and OIE, interaction with the licensee, etc.
Designations of Project Inspectors will be made by regional office notice.
In order to provide an opportunity for cross training of region-based personnel, assignments as Project Inspector will be rotated approximately every 3 years; for construction sites this may be extended due to the status of facility completion. j C. Action-(
Duties and responsibilities of the Project Inspector are as follows: I i
- 1. The Project Inspector maintains an awareness of the current status I of the inspection program for the facility and assists the Section Chief in preparing inspection schedules, taking into account l backlogged open actions and SALP results. This requires the Project Inspector to stay current on the results of inspections perfonned by )
the resident and other region-based inspectors.
- 2. The Project Inspector will remain current on plant status on a daily basis and will nonnally initiate the preparation of daily report '
items and preliminary notifications for his plant (s). He will also assist in the preparation of confirmation of action letters and l l escalated enforcement packages applicable to the assigned plant (s). !
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1 Regional' Office Policy Guide No. 0600(1) -
- 3. The Project Inspector maintains the Division's copy of the current facility open actions list and assists the Section Chief in coordinating the updates to this list.
- 4. ' The Project Inspector reviews Temporary Instructions,' Generic Letters, IE Bulletins, IE Notices and other correspondence to determine the applicability to the assigned plant (s) and assists the Section Chief in revising the inspection schedule and/or open actions list.
l S. The Project Inspector reviews inspection correspondence to and from l the licensee to determine adequacy of responses to NRC findings and assists the Section Chief in tracking inspection results and responses..
- 6. The Project Inspector performs an in-office review of'LERs, 50.55(e) reports and Part 21 reports to make an initial determination of l l adequacy of licensee response and recommendations for regional i response and works with the LER coordinator to determine the generic applicability of the item.
- 7. The Project Inspector is the principal focal point for the preparation and collection of SALP inputs and works closely with the ,
SALP coordinator to ensure timely completion of the report. !
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- 8. Since the Project Inspector is thoroughly familiar with the reactor plant and systems for the facility, he serves as a member of the Reactor Safety Team for emergency response purposes, and may act as a ;
backup to the resident inspector in case of absence.
- 9. The Project Inspector will maintain an up-to-date regional copy of Technical Specifications and other controlled documents, including necessary licensee procedures, required by the Division of Reactor j Safety and Projects. The Project Inspector will determine that the '
Division of Radiation Safety and Safeguards maintains similar documentation necessary for the execution of their responsibilities.
- 10. The Project Inspector reviews changes to the above documents and brings significant changes to the attention of the Section Chief and other regional inspectors who might be affected.
D.
Contact:
Questions or comments concerning this policy guide should be directed to the Director, Division of Reactor Safety and Projects.
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This policy guide is effective when issued.
4 D. Martin Regional Administrator Distribution B esp G
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. > NUCLEAR REGULATORY COMMISSION 5 , REGloN IV
[,d 611 RY AN PL AZA DRIVE, sulTE 1000 ARLINGTON. TEXAS 76011 December 7, 1982
.i SSIN 0250 O(A3 Regional Office Policy Guide 0501, Rev. 0 '
COMMUNICATION OF GENERIC REQUIREMENTS TO REACTOR LICENSEES A. Objective To control communications with licensees which impose or purport to express NRC generic requirements of NRC on one or more classes of reactors.
B. Policy or Practice In a memorandum from the Chairman to the Executive Director for Operations dated October 8,1981, the Comission expressed concern over 1
, conflicting or inconsistent directives and requests to reactor licensees
..' from various components of the NRC staff. By that memorandum, the Commiss. ion outlined certain recomended actions to establish control over the number and nature of requirements placed by NRC on reactor licensees. These included: establishing a Comittee to Review Generic
- Requirements (CRGR); establishing a new position of Deputy Executive Director for Regional Operations and Generic Requirements (DEDROGR);
conducting a survey of formal and informal mechanisms to communicate with reactor licensees; and developing and implementing procedures for controlling communications involving significant requirements covering one or more classes of reactors.
C. Action ,
The following procedures will be followed by Region IV for controlling such communications.
- 1. Except for emergency situations (see Section 2 below), all new generic requirements proposed to be imposed upon one or more classes of reactors through the type of communication identified in the attached Table I shall be submitted to the cognizant Headquarters Program Office (IE, NRR, NMSS, etc.) which will review the proposed requirements and, if deemed warranted, will forward them to the CRGR in accordance with the CRGR charter and cognizant Headquarters j Program Office procedures. '
As appropriate, the cognizant Headquarters Program office will ;
afford the submitting Regional office, other Regional offices and any other affected Program offices, an opportunity to participate in CRGR discussions on the proposed requirements.
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Regional Office Policy Guide 2 -
No. VS01, Rev. 0 bO)..
2, 'In those instances where it is judged by the Regional Administrator that an' emergency action.is needed to protect the health and safety of the public, no prior review by'the CRGR is 'necessary. However, !
the DEDROGR,'who is chairman of the'CRGR, will be promptly notified by the Regional Administrator of any such emergency actions taken.
Any such emergency action taken will be reported to the Commission by CGRG.
- 3. All documents, letters,'and other forms of communications to licensees (see attached Table.II) which establish or interpret NRC staff posi-tions or requirements on one or more classes of power reactors shall be' referred to.the cognizant Headquarters office for consideration as generic requirements unless the document (s) refer only.to requirements approved prior to November 12, 1981. In cases where.a requirement.was approved prior to November 12, 1981, the communication to the licensee must specifically cite and accurately state the requirement and in what previously approved document it is contained.
Communications involving the establishment or interpretation of NRC requirements.for individual power reactor facilities will continue to be handled through standard NRR, NMSS, IE, an.d Regior.al' office.
s channels without a requirement for submittal to CRGR for review.
' However, each new interpretation or requirment of this type must be carefully reviewed by the issuing office to assure it is only applicable to a specific facility and does not have generic applications.
- 4. For all other communications with licensees (see Table III ,
attached), no stateraents shall be used that might suggest new or l revised generic requirements,. staff positions, guidance or l recommendations unless such statements have been previously approved i by the E00 or the Commission. If there is any doubt about a i statement (s) which is proposed to be used in any communication, the !
statement (s) should be submitted for clarification to the cognizant !
Headquarters office by the Regional Administrator. !
D. Contact All proposed submittals, questions, suggestions, or comments should be directed to the Region IV coordinator (Tom Westerman, ext.145). j l
i
Regional Office. Policy Guide' 3 No. &&G1,>Rev 0
'00bh -
,E. Effective Date
.This Policy Guide.is in effect when issued.
1[ht 's .l;'!C:a i jdegionalAdministrator
Enclosures:
- 1. Table'I - Principal Mechanisms Used By .
.NRC Staff to Establish or Communicate Generic Requirements
- 2. Table II - Mechanisms Often Used to Interpret-Generic Requirements
- 3. . Table III - Additional Mechanisms Sometimes Used to Communicate Generic Requirements !
Distribution List AB 4
., . k_.
j t7
')
I a
r t.
Table I --
PRINCIPAL MECHANISMS USED BY NRC STAFF TO ESTABLISH L OR COMMUNICATE GENERIC REQUIREMENTS Rulemaking I!
{
Advanced Notices l Proposed Notices i Final Rules Polic:t Statements Othei ' Formal Requirements E
'Multiplant orders including show cause orders and confirmatory orders Staff' Requirements E!
Bulletins I
., Circulars
- Multiplant letters (including 50.54f and TMI Action Plan letters)
Regulatory Guides L SRP (including' Branch Technical Positions)
Standard Tech Specs ,
1/ While Rulemaking is an action of the Commission rather than the staff, 3 most rules are proposed or prepared by the staff.
2/ The document itself imposes a legal requirement; e.g. , regulatory orders l' license conditions.
3/ Mechanisms which reflect staff positions which, unless complied with or a l satisfactory alternative offered, the staff would impose or seek to have j imposed by formal requirement.
i i
I
- 4
(. TABLF II
' MECHANISMS ~OFTEN USED TO INTERPRET GENERIC REQUIREMENTS Action on' Petitions for Rulemaking Action on 2.206 Requests
- Approval of Topicals-Facility Licenses'and Amendments SER's e
FDA's, PDA's I&E Manual I&E (HQ) Positions NUREG Reports (other than USI's)
. Operator Licenses'and Amendments j SinglePlantbrders -
Staff Position on Code Committees Unresolved Issues Resulting.from Inspections i
i 1
i i
i J
1 I
TABLE III _.
1 ADDITIONAL MECHANISMS SOMETIMES USED TO COMMUNICATE {
GENERIC REQUIREMENTS 0ES., FES . i Entry, Exit & Management Meetings Information Notices Licensee Event Report; Construction Deficiency Reports (sent to other licensees)
NRC Operator Licensing People Contact with Licensees' ,
Phone Calls or Site Visits by NRC Staff or Commisison to Obtain Information (i.e., Corrective Actions, Schedules, Conduct Surveys, etc.)
p Pleedings i Preliminary Notifications Press Releases' Q
( Proposed Findings-
- l Public Meetings, Workshops, Technical Discussions Resident Inspector Day-to-Day Contact SALP Reports i SECY Papers (some utilities apparently sent operators to college based on recent SECY paper on operator qualifications)
Special Reports Speeches to Local Groups or Industry Associations Technical Specifications Telephone calls and meetings with Licensees, vendors, industry representatives, owners groups Testimony 1
i l
. ..2...,._. - . .. _ . . - . .
. . . . . . . . ~ .
N' " ^
AUG 0 l1986 t
Regional Office Policy Guid~e No. 0607, Revision 1 d
OPERATING REACTOR INSPECTION PROCEDURE ASSIGNMENTS A.
Purpose:
To assign responsibility for completion of the inspection program modules for the operating power reactor facilities consistent with the Systematic Assessment of Licensee Performance (SALP) evaluations.
B. Discussion:
The appended tabulation of inspection modules (procedures) lists the modules within each defined SALP functional area, separated into tnose modules defined by MC 2515/2525 as Minimum, Basic, or Supplemental program requirements. The responsibility for completion of each module is defined by specific Section within the Region, except that those modules assigned by the acronym RPS will be the responsibility of the Reactor Project Section having responsibility for specific power plants. Those modules assigned to the remaining Sections will be accomplished by that Section for all operating power reactor facilities.
~'
In addition to the assignment of responsibility, the historically based
_ per annum or per inspection average time expenditures for each module, and the defined inspection frequency are listed for use in establishing
~
the master inspection program for each" facility. The identified times for completion of the inspection modules are not to be construed as
- ( inspection objectives or requirements, but only as an aid to plan inspec-tion resource utilization; individual inspection conditions will continue to dictate the time necessary for inspector completion of the inspection programs. All indicated times should be increased 20% to accommodate the incorporation of independent inspection effort into the routine inspection modules.
C. Action:
- 1. Section Chiefs in the Division of Reactor Safety and Projects, and
, the Division of Radiation Safety and Safeguards, will coordinate on at least a quarterly frequency, the inspection plans for their staffs with the Reactor Project Section Chiefs to assure that the inspection plans are integrated into the master inspection plan for each facility.
- 2. Each applicable Reactor Project Section Chief within DRSP will utilize the appended table to prepare a master inspection program for his assigned facilities. He shall monitor inspection accomplishment for conformance with the master inspection plan and advise othe" section chiefs in the Region when inspections are due.
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Regional Office Policy Guide -?-
ho. 0607, Revision 1
- 3. Based on SALP results, each Reactor Project Section Chief shall cocument the planned inspection program for each operating power reactor facility assigned to his Section on a calendar year basis, 3 utilizing inspection plan input from the Sections in the Reactor i Safety Branch, and from the Division of Radiation Safety and Safe-guards. Utilizing the time requirements for each planned inspection !
procedure, tutal inspection time estimates for the DRSP shall be !
prepared and furnished to the Chief, Reactor Project Branch, for use !
in updating the Regional Operating Plan.
- 4. Special inspection activities are on occasion defined in Temporary Instructions (tis) as a supplement to the routine inspection program.
Each Reactor Section Project Section Chief will evaluate tis and add them to the master inspection plan for each facility to which they are applicable. By agreement with the Chief, Reactor Safety Branch, or the Chief, Radiological and Safeguards Programs Branch, resource requirements, responsibilities, and schedules will be defined. For :
.. purposes of the 766 reporting system, time will be coded to the artificial modules defined by the TI; for the RITS system, inspection time will be coded as reactive effort.
D.
Contact:
{
Director, Division of Reactor Safety and Projects, ext. 106.
E. Effective Date:
This Policy Guide is in effect when issued and supersedes Policy Guide 0607, Rev. O, dated December 19, 1985.
I .. ..g BY gYB Rk D. gARM Robert D. Martin Regional Administrator Distribution List B
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i a l ly t- j
+ l MAY 121986 j
et Recional Office Policy Guide No. 0600, Revision 0 i NRC USE'0F ItJP0 EVALUATION REPORTS ?O A.
Purpose:
To provide IE policy and guidance on the use of INPO Evaluation Reports k and other INPO-related site specific information in relation to the NRC int.pection process. B. Dijcussion:
, The enclosed nenorandum from J. M. Taylor, "NRC Use of INP0 Evaluation Reports," dated February 14, 1986, discusses the IE inspection effort that is to be related to the INP0 evaluation process. This letter discusses the INP0 evaluation process and reporting sequence, identifies the NRC desired inspection effort to be tied to the INP0 efforts, and provides guidance on the use uf the results of the NRC review of INPO reports.
C. _A_cti on:
~
- 1. When the final INP0 Evaluation Report, the licensee's corrective actions in response to the INP0 findings, and the licensee's six
. month status report are available onsite, the Resident Inspector
(' should review them to obtain a perspective on the licensee's
-9 programs and the corrective actions plane.ed where deficiencies have been' identified.
- 2. During routine visits to the site, the responsible Reactor Project Section Chief, or the Reactor Projects Branch Chief should also i review the reports for indications of disparities between NRC and INP0 perspectives as 1.ndicated in the eqclosure.
- 3. If review of the INP0 related documentation reveals immediate questions about nuclear safety in the short term, followup should be initiated by the Resident Inspector to assure that corrective actions are consistent with regulatory requirements. Region IV ,
management should he promptly informed of the need for immediate NRC followup on an INP0 finding. ! I i j i u__.m_ _ - -
.4 MAY 121986 i . _ . D.
Contact:
Suggestions or comments should be directed to the' Director, Division of . Reactor Safety and Projects (ext.106).
- E. Effective Date:
This-Policy e-"ide is in effect when issued. ;
"Driginal Signed Byt E.H. JOHNSON" Eric H. Johnson, Director Division of Reactor Safety and Projects
Enclosure:
As stated Distribution List C L D/DRSP DRSP hRSS AC Rh EHJohnson RL ngart WL own RDA tin '; [RrHal:enm f/86 Tt/g /86 4 '/8,6 4 A 4 i
l 1 l j Se ese
- 9. UNITED STATES
% NUCLEAR REGULATORY COMMISSION
, [ k 5 WA884tesOTOW. D. C. 20065 f l
\*.... February 14, 1986 O2IN L.
i MEMORANDUM FOR: Thomas E. Murley, Regional Administrator, Region I J. Nelson Grace, Regional Administrator, Region II James G. Keppler, Regional Administrator, Region III Robert 8. Martin, Regional Administrator, Region IV John 8. Martin, Regional Administrator, Region V FROM: James M. Taylor, Director Office of Inspection and Enforcement
SUBJECT:
NRC USE OF INP0 EVALUATION REPORTS This memorandum provides IE policy and guidance on the use of INPO Evaluation
.. Reports and other INPO-related site specific information in relation to the NRC inspection process.
INPO teams periodically conduct fomal evaluations of utility corporate offices and operating plants. k,sistance visits are conducted at NTOL facilities. h i Evaluation schedules are provided to IE and are further distributed to regional offices. INPO provides their schedules primarily for coordination purposes. IE has agreed that, absent special situations, NRC special inspections while INPO teams are onsite will normally be limited. INPO management exit meetings are held about one week following completion of onsite evaluation activities. The Senior Resident Inspector should attend the management exit meeting only if a specific invitation is initiated by licensee management. In the absence of an invitation initiated by the licensee, it is IE policy that NRC personnel not attend these meetings. Several months after the exit meeting, final INPO Evaluation Reports are completed and are available onsite for NRC review. The report includes the licensee's planned corrective action in response to INPO finding:. The INPO report nomally requests that the licensee submit to INPO a six month letter , report on the status of actions taken in response to the report. When each of these documents become available onsite, they should be reviewed by the Senior Resident Inspector. In addition, they should be reviewed by the Project Section Chief and/or Branch Chief during routine visits to the site. The , I following guidance is provided concerning NRC review of INPO plant specific 1 documents. l 1 l l
9
)
I February 14, 1986
' Regional Administrators -2
. The Coordination Plan for NRC/INPO Appraisal and Evaluation Activities states:
"Since INPO has its own system for obtaining member corrective action NRC's role in pursuing correction of INP0 evaluaticn findings will primarily involve only those potentially significant safety problems for which NRC has no other reasonable alternative in meeting its legislative responsibilities." This means that NRC will not systematically followup on the timeliness and adequacy of licensee actions taken in rssponse to specific INPO findings. However, if NRC review of documents does present the reviewer with specific infor1 nation which could substantially affect nuclear, safety in the short f erm, then these matters should be pursued by the Resident Inspector. Given the general nature of most INPO findings and INP0's review and acceptance of corrective actions as described.in Evaluation Reports, it is expected that NRC will rartly need to conduct specific followup activities. However, if NRC review of the INPC documentation does raise such insnediate questions, the Resident Inspector or regional supervisor, with agreement of the Regional Administrator, should request the licensee.to describe what followup has'been parformed. All specific followup actions and the results of any licensee infomation requests should be documented in a memorandum to the Director IE.
." INPO Evaluation Reports should also be reviewed by regional supervision in order to gain some perspective on INP0's apparent overall view of licensee perfomance in comparison to NRC's evaluation. The results of SALP and recent inspections should generally be compared to the INPO findings,through attention
- g. { to the following areas:
- The significance and number of findings (and good practices) in the various evaluation areas.
- The number and nature of significant findings which are highlighted in the executive summary.
- The nature of the findings (i.e., " program needs to be impleiaented" is more significt.nt than " program could be improved").
- The number and significance of previous INPO findings which have not been corrected (an appendix to the report).
- The number and significance of applicable Significant Operating Experience Reports (50ER) which have not been satisfactorily addressed.
A review of uncorrected findings and status of SOERs can provide an indication of the extent to which the licensee is responsive to the INPO evaluation program. In view of the Comission's willingness to recognize industry initiatives in self-regulation, it is important that the staff be knowledgeable of the extent to which individual licensees are being responsive to INPO. (Note that IE does periodically issue Temporary Inspection Procedures to examine response to 50ERs). Over the past several years, the Consnission has deferred the publication or development of new rulemaking in recognition of industry
e-1 Regional Administrators _ February 14. 1986 initiatives in such areas as ALARA programs, maintenance programs, equipment failure reporting, and training programs. The Comnission is currently considering the deferral of regulations pertaining to fitness fer duty programs for nuclear power plant personnel. In each of these cases INPO, through the plant and corporate evaluation program, serves as the industry instrument to ensure that individual utilities meet industry comitments. MRC review of INPO Evaluation Reports and licensee statJs reports should especially note the licenseas' actions in response to INPO findings and recommendations in these areas. This responsiveness can nomally be determined from a review of the INPO report and the licensees' corrective action status letter. If NRC review of this infomation raises significant concerns as to the licensees' responsiveness, the Regional Administrator should contact the Director, IE and discuss the matter. Following this discussion, if determined to be appropriate, arrangements will be made for making both INPO and licensee management aware of NRC cona rns. The results of any Regional management discussions with the licensee should be documented in a memorandum to the Director IE. For licensee performance areas which are subject to both NRC inspection and INP0 evaluations, it is expected that the overall results, in general, should not be markedly different. If the supervisor's review of an INPO report does indicate apparent significant differences in performance as seert by NRC and INPO, internal discussions with appropriate inspectors and regional management
^
should be initiated. For example (simplistic): NRC could view a licensee's
! k. maintenance program as a top Category 1 SALP performer during the same period in which an INP0 report reveals apparent weaknesses in a significant number of maintenance program areas. Rather than the inmediate scheduling of additional maintenance inspections, regional raanagement should first retrospectively review and examine the conduct of past NRC inspections as to completeness, thoroughness, and objectivity. If this review indicates the need for a new look, then appropriate routinc inspections should be planned in conjunction with the master inspection plan.for that facility.
Questions on specific cases should be directed to James G. Partlow. s W Ta re tor
/. fice of Inspe on and Enforcement l
)
j M~ . UNITED STATts
/ ,* 3 NUCLEAR REGULATORY COMMISSION < REGION IV
( - /,f 611 RYAN PLAZA DRIVE. SUITE 1000 1,, ,# ARUNGTON. TEXAS 7G011 l SE.8 IS ES5 Recional Office Policy Guide No. 0702, Rev. O POWER REACTOR INSPECTION RESOURCE REVIEW A. Purpose To describe to the staff the system that will be used for periodically evaluating the allocation of inspection resources to power reactors in Region IV. B. Discussion Regional management accumulates a number of inputs and does various assessments by which it judges the relative performance of the utilities in operating their nuclear power plants. It has long been the intent of IE that these assessments (e.g., SALP, regional and resident inspector _- input, management meetings) be factored into the inspection planning for different sites. Moreover, our requirement to have an Operating Plan for the region, which tracks resource expenditures against. budget allocations, suggests that some formality be introduced into the process to reassign i3 inspection resources to the different projects. The process outlined below will start, on an interim basis, in September 1985, and is expected to be modified as experience is obtained. Appropriate revised Policy Guices will be issued as changes occur. C. Action All staff members should be aware of the following actions taking place. Participants identified below should take specific note of their responsibilities.
- 1. On the third Thursday of every month, beginning in September 1985, the directors of DRSP and ORSS shall meet with the Regional Administrator and the Deputy Regional Administrator to discuss the status and performance of each nuclear power facility, including those under construction and test, to determine what reassignment of resources is ca'iled for to address either areas of concern or high quality perfonnance by licensees.
- 2. The Director, DRSP, should be prepared to make general recommendations, utilizing input from his staff, to the group for decision.
J
h , i , I- _. F.egional Office Policy Guide j No. 0702, Revision 0 1
- 3. The Director, DRMA, will attend to determine if suitable adjustments to the regional operating plan.are required as a result of resource
.. . real'1 oca ti ons . L
- 4. The . Regional Administrator's. secretary should attend these. meetings
~
for the purpose of preparing a summary of the major decisions reachec during the~ meeting. D. Contact Ouestions regarding this policy guide can be. directed to the Office of the Regional Acmini'strator. E. Effective Date This policy. guide.is in effect upon issuaned.
, . ,f
~
f.' _. u. Robert D. Martin
!b .. ,
Regional Administrator 1. Distribution: C 1 L
)
_ _ _ _ -- . - - - 1
l
. g#% UNrTED STATES
'g NUCLEAR REGULATORY COMMISSION
- s j
~~
REGION IV D #
% ,, ** 811 RYAN PLAZA DRIVE. SUITE 1000
, ARLfNGTON, TEXAS 7s011 ~
AUG 2 5 56 I Regional Office Policy Guide No. 1005, Revision 0 DOCUMENTATION OF SIMILAR OR RECORDS-RETRIEVAL VIOLATIONS . __ A .
Purpose:
To promulgate guidance on the documentation of (a) violations that are similar to previously identified violations and (b) violations related to i unsuccessful records retrieval for NRC inspection. B. Discussion: Similar Violations: - It is a desirable regulatory goal to encourage and support licensee initiative for self-identification and correction of violations. One means to implement this goal is to not cite a licensee for a violation that meets all of the following tests. 9
- 1. It was identified by the ideensee.
- 2. It fits the category of Severity Level IV or V.
- 3. It was reported, if required.
4 It was or will be corrected, including measures to prevent recurrence, within a reasonable time.
- 5. It is not repetitive or similar to a previous violation. A similar violation should be interpreted as a violation which could have been reasonably expected to have been prevented by the licensee's corrective action for a previous violation. In general, we will evaluate the similarity of a particular violation with other g
violations that have occurred over the prior two years or prior two inspections whichever represente the longer time period. Regardless of whether a licensee is or is not cited for a particular " violation, the inspection report shall provide a general descripeton of each type of first time occurrence. However, it is not necessary to transcribe all examples, nor all of the specific details, since this records information is already svailable in the licensee's records and ! would be an inefficient use of inspectors' time. If the decision on ' citability has not been made at the time that the inspection report is B l t
1 1 Regional Office Policy Guide AUG 2 5 EE6 : No. 1005, Rev. 0 . 1 being issued (e.g., the Notice of Violation is being held back pending an enforcement conference), then the violation should be addressed and characterized in the inspection report consistent with all other - violations. (N- e: Inspection findings of non-compliance are always to be characterized ' inspection reports as apparent, possible, or potential violations. This is especially true for those inspection findings of escalated nature that necessitate enforcement conferences thus resulting in the issuance of the Notice of Violation at a later date. Upon management's decision to cite a particular violation, then the i adjective (apparent, possible, or potential) is not used in the citation. ' Records-Retrieval Violations: When a licensee is required to perform a given task and to kee; a record of having done so but cannot produce that record for NRC inspection, a l i violation.has occurred. Consequently, the licensee is subject to i citation pursuant to the provisions discussed in the proceeding and following sections.
,, The ability of a license's record system to retrieve suitable records for inspection should be commensurate with the safety significance of the issue involv.ed. A generalized or prescribed time frame for records retrieval is not desirable. In general, recorde that are of the type I
that would typically not be involved in responding to an~ emergency , g should be retrievable on datand or within a matter of days. For auch - records that are not related to emergency needs and for which the ; licensee is unable to produce, the inspector should tell the licensee at I the exit interview that the licensee mar preclude a finding of noncompliance by submitting the requested records for review prior to the issuance of the inspection report. (The same opportunity holds true for other inspection findings related to open or unresolved items.) However, the issuance of the inspection report will not be delayed in order to afford the licensee additional search time. Albeit rare, for such records that are related to emergency needs and for which the licensee is unable to produce for inspection at the time of request, the finding of non-compliance will not be withdrawn even if the licensee subsequently provides such records prior to the issuance of the inspection report. C. Action: Inspectors and their management should be familiar with these licensee incentives discussed above and ensure that they are brought to licensee's attention and implemented into routine inspection activities. D. Conta;t_: Suggestions of comments should be directed to the Enforcement Officer.
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Regional ~ Office Policy Guide 25 E j
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, . No . 1005, Rev . O _ i E.. Effective Date:
'This Policy Guide is in effect when issu .
A cuh' l Robert D.14artin Regional Administrator s Distribution List AB 1 l
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% UNITED STATES NUCLEAR REGULATORY COMMISSION
[ r,. j j REoloN IV k, . y, [ til RYAN PLAZA DRIVE. SUITE 1000
, ,, ARLINGTON, TEXAS M011 OCT 2 0 BB6 Regional Office Policy Guide No. 1006 DEVIATIONS _ _.
A.
Purpose:
To inform the staff of a pending change in IE Manual Chapter 0400 concerning deviations. B. Discussion: The Director of Inspection and Enforcement has informed the Re'gional Administrators of his intent to revise IE Manual Chapter 0400. The change will specify a more restrictive definition of a deviation. A ' deviation will be defined as follows. A licensee's failure to satisfy a written comitment; for example, an FSAR comitment to conform to the provisions of applicable codes, standards, guides, or accepted industry
, practices, when the code, stand:.rd, guide, or practice involved has not been made a legally binding requirement by the Comission.
Accordingly, it will no longer be acceptable to site licensees or applicants for deviations against .spplicable codes, standards, guides, or accepted industry practices for which a written commitment has not been submitted. For some situations involving utilities, provisions do exist for citing deviations against non-committed practices and the like via the backfit policy's procedures. C. Action: Effective immediately the notices of deviation prepared by the technical j- staff shall conform to this guidance. 1 l D.
Contact:
Any coments or questions should be directed to Dale Powers, Enforcement Officer (ext. 195). E. Effective Date: - This Policy Guide is in effect when issued. Ro ert D. Martin l Regional Administrator l Distribution List AB '
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L J** *%d UNITED STATES -
- p. NUCLEAR REGULATORY COMMISSION
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"/ E REGloN IV _.
. . -* 611 RYAN PLAZA oRIVE, sulTE 1000
%, , ARLINGTON. TEXAS 76011 MAR 2 51983 SSINS No.
Regional 0ffice Policy Guide 1051, Revision 0 ' PROCEDURES FOR ALLEGATIONS AND INVESTIGATIONS A. Objective l To outline the procedures that will be used in Region IV for handling i allegations and interfacing with the Office of Investigations staff. B. Policy * ' It is Region IV policy that all allegations received by the regien, whether directly or from another NRC office, that affect a Region IV
,~ licensee or a company covered by the vendor inspection program be tracked
_ by Region IV from start to closecut. This will include those allegations received by the OI Field Office, Region IV. It is also the policy of
- b gion.IV to cooperate fully with the Office of Investigations in closing l
out all allegations affecting Region IV licensees and vendors. C. Definitions
- 1. Allegation Review form - each allegation is opened by completing an .
Allegation Review form. This form contains basic information on the allegation such as alleger, facility involved, substance of the allegation, and action party. This . form becomes an individual file entry in the allegation data file and is the cover for the allegation package.
- 2. ' Allegation Package - a manila folder containing all supporting documents on the allegation (letters, memoranda, inspection reports closing out the allegation, etc). When an allegation is assigned to the action party for completion, the allegation package is forwarded to that party and is held until the allegation is closed out. The package is then returned to the Enforcement Officer for archiving.
For allegations that are turned over to Investigators, the supporting documentation will remain in the OI Files and a copy of the completed 4 Investigation Report will be archived with the completed allegation form in the Enforcement Officer files. ( s __._..._.___m_____ --
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,. F.egional Office Policy Guide No. 1051, Revision:0 2
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'3. Inquiry - an activity conducted'by the OI alone or in concert with the regional' inspection staff to gather additional information on-an allegation. The.results of the inquiry will' determine whether an allegation may be closed with no further action, needs investigation, or should be the subject of regional routine or special' inspection.
- 4. Investigation - activities conducted by the Office'of Investigation, with or without technical assistance from the regional inspection !
staff. The Office of Investigations is the lead action party for all 1 investigations. Investigation reports will be forwarded to the
. Regional: Administrator = for disposition.
- 5. : Inspection'- routine or special inspection ~ activities by the Regional Inspection staff to closeout allegations. These activities may involve limited assistance from the investigative staff to closecut certain nontechnical issues. The investigative staff will prepare an -
. Assist to. Inspection Report (AIR) to document this close~out. The regional inspection staff retains the lead on allegations closed out by , inspection.
- 6. . Assist to Inspection-Report (AIR) - a report prepared by the investi-gative staff-to document findings when the nature of the allegation ,
is'primarily technical but-limited investigative effort is required. " The AIR will be forwarded to the regional-inspection staff, and may be appended to the inspection report as considered netessary. A copy of the AIR will be sent to the Regional Administrator. 7.- Action Party - Generally the cognizant section chief. The action party is responsible for keeping all necessary Region IV staff informed 1as to the progress in closing out allegations. He will assure that the OI list is updated to show the close out of allegations. D. procedures for Handling Allegations The method of_ handling allegations is divided inte four procedures as follow: receipt of allegations; processing allegations; review of allegations (including whether inspection or investigation is warranted); and closecut of allegations. These procedures are detailed below:
- 1. Receipt of Allegations
- a. All allegations received are to be forwarded to the Enforcement Officer as soon as possible after receipt.
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Regional' Office Policy Guide No. 1051, Revision 0 3 Allegations not dealing with Region IV licensees or_ vendors will be forwarded to the appropriate NRC office by the Enforcement Officer. 1
- b. The person receiving the allegation, whether by telephone or '
personal contact,Lshall attempt to get information as follows:
. allegers name, phone numbers (work and home and when the alleger can be contacted), address, job title and organizatT6n, nature-of the allegation, and what facility, license or company it is related to.
- c. This information shall be forwarded by informal memo or by use of.the allegation rev.iew form shown in attachment 1. Any additional supporting information shall be included. If the allegation is received by personal contact or by mail. all original documents (including envehpe) shall be forwarded.
Note: An offer of confidentiality shall not be offered unless specifically requested. If the alleger requires confi-dentiality, the phone call shall be transferred to an investi- , ( gator, if available. If an investigator is not available then take down as much detail as possible and try to get a phone
!! number where the alleger can be contacted.
- 2. processing Allegations
- a. The Enforcement Officer shall complete the allegation review form and assign an allegation number to the package of information,
{L r Appendix A describes the allegation review form and allegation data < file in more detail. b.- The alleg& tion shall be entered into an index. ; I
- c. The allegation will then be submitted for preliminary. review by j the Region IV field office of the Office of Investigations. j
- d. The Enforcement Officer will fill out the Allegation Data Form I (NRC Form 307) blocks 1 thru 10 and block 13 and will forward to l IE,HQ.
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2 , - . ,.a u - -. . ...,.g.>. ..a.~ ..:.. -. -. . a . a . . - - - - -- [. . Regional Office Policy. Guide
'No. 1051,. Revision 0 4
- 3. Review of Allegations
.a. Approximately monthly, or more often if needed, an Allegation-Review Board will meet to consider allegations. This board will consist of:
.. : Deputy Regional Administrator, *
. Enforcement Officer - Chairman, ..
Director, Office of. Investigation, Region. IV Field Office, or his representative, Representative of the Vendor. Programs. Branch,. Representative of the-Technical Programs Branch, Representatives of Division of Resident, Reactor Project and Engineering Programs'(each branch). Attendance by Division Directors is encouraged.
'b. The primary purpose of the board shall be to review all new allegations to determine whether the allegation is best handled by-investigation, inspection on whether further inquiry is needed and, if so, who shall do this. Priorities.for.investi- .. gative/ inspection activities will be identified'by the board.
- - The Regional Administ.etor is informed of the results of these decisions. -
- c. The secondary function of.the review: board shall be to provide the up-to-date' status of each allegation. To this end, each board member must be prepared to discuss the current status of all allegations being handled by his/her branch or division.
Information as to date of proposed inspection or investigation, when completed, report in preparation, etc., will be made available. The status of current investigations will be made available to the board. i
- d. Following the meeting, the Enforcement Officer shall update I
the allegation index showing the new status of allegations and I assignments decided upon.
- e. A final function of the board is to act as a forum to discuss investigation policy, so as to maintain an understanding of the current NRC investigation policy and ensure close liaison with the Region IV OI Field Office.
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. l Regional Office Policy Guide j No. 1051, Revision 0 5 l
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- f. Following the designation of the action party by the board, the l Enforcement Officer shall forward the allegation package to the l action party for followup and closecut. !
- g. Closecut of Allegations If an allegation assigned to the Region IV staff requires investigative support, such as for assistance during an inspection, direct liaison between the Branch /Section Chief and investigative staff is authorized to define the needs and to establish mutually agreeable dates.
NOTE: If an allegation is to be closed out through regional l inspection activities during the course of which, additional 1 facts come to light that suggest an investigation is warranted, the inspector shall make immediate contact with his Section Chief and the Enforcement Officer for instructions. Contact with RIV, 01 Field Office is the usual course of action in such cases.
- 4. Closecut of A11eoations
- a. Following inquiry, inspection or investigation that satisfies an i allegation, it may be closed. '
- b. Inspection reports which closecut allegations shall be routed through the Enforcement Officer for concurrence. He, in turn, will discuss the findings as may be appropriate with the Director, OI Field Office to determine if referral to OIA is nece s sary. -
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- c. The action party shall return the completed alle<;ation package to the Enforcement Officer with all supporting naterial (originals of documents excepting NRC reports, where applicable).
The completed package must include a copy of the closeout document (investigation or inspection report, memorandum for - file, or the like). For investigations, supporting material will be maintained by the Office of Investigations.
- d. Completed packages shall be maintained on file by the Enforcement Officer.
E. Procedures for Handling Investigation Reports j I
- 1. Investigation reports AIR's and Reports of Inquiry will be forwarded i to the Regional Administrator from the Office of Investigations. )
8. They will be in ready to issue condition at this time. l
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No.'1051, Revision 0 6
- 2. Generally. AIR's will have been written in support of a regional inspection. AIR's may be included with the inspection report as a separate . appendix. These reports will generally contain confidential information and will need to be appropriately " sanitized" prior to release. The issues of the report has the responsibility for checking with the OI, Field Office for assistance in preparing a releasable version.
1
- 3. . Each investigation report will be received by the Regional Administrator in form an unexpurgated version (plain language) l ed r ;qwseied (; -iti{,d) a s;r:!=. Only the latter varsion is to i
be reieased outside N p MyfuswQ,na.u"y#
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- 4. The.following procedures shall be used to handle investigation reports that are to be released.
- a. Both versions of the investigation report will be forwarded by
.. ,the Enforcement Officer to the Division Director for review and processing.
- b. The plain language version will be returned to the Enforcement Officer for retention.
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- c. A cover letter and appropr' ate enforcement notice, when necessary, are prepared under the direction of the Division Director.
- d. A sequential inspection report number is assigned to the report.
L e. Normal report distribution lists will be followed for distribu-tion of the sanitized investigation report, except that a copy shall be sent to the Director, RIV 01 Field Office. NOTE: Since " original" sanitized versions of investigation reports received from OI are photocopies, it will be necessary for the Director, RIV OI Field office to certify the report as an original. F. Contact Questions on allegations, investigations or interface procedures with the RIV OI Field office shall be referred to the Enforcement Officer (Eric Johnson, ext. 141). O
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Regional.0ffice Policy Guide No. 1051,. Revision 0 7 G. Effective Date This Policy Guide is effective'when issued.
. ,$c o* f* /? J L&ccd John T. Collins Regional Administrator Appendix: Description of the Allegation Tracking Data File i Distribution'n List AB es*
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APPENDIX DESCRIPTION OF THE ALLEGATION TRACKING DATA FILE Each allegation that is the responsibility of RIV will be entered into the allegation tracking . data file. This file is on the IBM 5520 based file system. It is used to enter, track, and maintain a historical file of allegations. i Allegations received are entered into the file using the worksheet shown in A-3. A variety of summary printouts are available from the system. The following is a description of the worksheet fields. Field Description
- 1. Case Number Allegation Number f.e., 4-83-A-xx
.. 2. Date Opened Date received by DES
- 3. Facility Name Can be used for the name of the vendor, material licensee, etc..
t-\ 4. Subject Concise statement of allegation
- 5. Source of Allegation Name and title of alleger, or " anonymous is anonymity is requested" -
- 6. Number of Allegations Self explanatory
- 7. Assigned to Division / branch designation
- 8. Cross Reference Number 01 case number
- 9. ' Action scheduled Concise statement of what the next expected actions are to be
! 10. First/Last Name Branch contact
- 11. Date Assigned Date forwarded form DES to the branch
- 12. Report Number Allows tracking of report numbers t
- 13. FTS Number Telephone number of contact
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l Appendix '2
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- 14. Due Date Can be used to assign a suspense date l
L 15. Allegations Substantiated Listed in the form allegations made/ allegations substantiated l 16. Sort Code The following codes are used to sort data: A - RPS A P - PSS 1 B - RPS B S - SP ! C - RPS C T - Transferred : D - RPS D U - URO I - EP 'V - VPB M - TPB X - Closed O - OI Z - Other
.. 17. Date Closed When all actions have been completed
- 18. Action Office Always RIV
- 19. Text Up 'to 1000 characters of text. For g completed actions this will include a summary of enforcement actions taken Access to this, data base is authorized b9 the Director, ES.
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u I . WorksheetforAllegationsTrackingSystemiRIi:'2/23/83 e
- 1. CASE NUMBER .........
- 2. DATE OPENED ..........
l 3. FACILITY NAME. ............ ............ ............ 4 SUBJECT ......................... .........................
- 5. SOURCE OF ALLEGATION..................... .................... ....................
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- 6. NUMBER OF ALLEG. ..
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- 7. ASSIGNED'TO ..........
.. 8. CROSS REF. NO. ..........
- 9. ACTION SCHEDULED .................... .................... ....................
- 10. FIRST/LAST NAME ...............
- 11. DATE ASSIGNED ........
- 12. REPORT. NUMBER , 1st:......
2nd:....... Lst:......
- 13. FTS NUMBER 8 ... ....
- 14. DUE DATE ..........
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- 15. ALLEGATION SUBSTANT .....
16 SORT CODE .
- 17. DATE_ CLOSED ........
- 18. ACTION OFFICE i
( l TEXT 1 l TEXT 2
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FormxNRC-1 . 4 (RIV i 82) l U. S. NUCLEAR REGULATORY COMMISSION REGION IV
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TRANSMITTAL SHEET FOR POLICY GUIDE AND/0R NOTICE N Policy Guida No 051 - PROCEDURES FOR ALLEGATIONS AND INVESTIGATIONS TRANSMITTED: SUPERSEDED: Policy Guide No. 1051 Rev. O Policy Guide No. n/a Series Notice No. Rev.\ Dated: l No. of Pages g( - Distribution: AB (A-Administrative Staff; B-Professional; AB-All Employees)
. REMARKS:
This policy provides gu inc og the handling of allegat s and investi-gations in Region IV. a I h a \ W 5 . bq
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L 6 yf4y . i / /) of' +l \ Tic. H Prepared by: E. H. Johnson Approved by: h d[# E 8 # J M Mf JohnT.Colfins, "I
Title:
Enfo'rcement Officer
Title:
Regional Administrator Date Approved: 3Io// 7
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cf UNITED STATES . p' '; NUCLEAR REGULATORY COMMISSION f
'h REGION IV
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[ ~ 611 RYAN PLAZA DRIVE, SUITE 1000 ARLINGTON, TEXAS 76011 f JUN 171985 .
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l Regional Office Policy Guide No. 1101, Rev. O CONFIDENTIALITY PROCEDURES FOR ALLEGERS A.
Purpose:
To establish regional policy and procedures for the granting of confidentiality to allegers consistent with proposed NRC Manual Chapter 0517, " Management of Allegations," (copy attached). .The proposed manual' chapter is the agency's interim policy pending final-policy guidance and shall be fully implemented by RIV. B. Discussion:
- 1. This regional policy guide is intended to supplement rather than replace the proposed NRCM 0517. The emphasis on this guide is-on the important role of confidentiality in the management of allegations.
J
- 2. Confidentiality refers to the protection of data that directly, or-
!' otherwise, could identify an alleger by name. It is not intended i to deny staff members access to the identity of the alleger when i such identification is required by staff members to evaluate and resolve allegations.
- 3. All allegers will either (a) be explicitly granted confidentiality I by virtue of a confidentiality agreement (copy attached to NRCM 0517) signed by both the alleger and by the Regional Admini-strator or (b) they will not be explicitly granted confidentiality, but their identity will be reasonably protected.
C. Action:
- 1. A confidentiality agreement should only be executed for those allegers who either (a) specifically request it or (b) 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 not be given until an assessment of the usefulness of the infonnation provided can be made, and only if such a determination can be made in a timely manner after consultation with the Regional Administrator through the supervisory chain of connand. A confidentiality agreement should never be routinely offered to any person not meeting the above criteria.
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1 e Regional Office Policy (' Guide No. 1101, Rev. 0 a n 1985 - The confidentiality agreement form sets forth the conditions under which confidentiality will be maintained. If at any time for any reason confidentiality is breached or jeopardized, regional manage-ment should be informed. The alleger should be advised, the reason explained, and remedial measures taken, if possible, to reduce the impact of disclosure. As a general rule, the "need to know" principle will be implemented for all allegers. However, 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 identi-fying information in internal NRC discussions, unless absolutely necessary, and by expurgating the r,ame and other identifying informa-tion from documents before disseminating these to the staff. Dissemi-l nation of expurgated documents will be the exception rather than the rule. Unless absolutely required for the job by a RIV employee, documents containing identifying infomation about an alleger will be used in accordance with the " check out" system provided for in paragraph C.3., below. The NRC considers the identity of allegers who sign confidentiality agreements as being exempt from the disclosure requirements of the Freedom of Information Act.
- 2. For those allegers without a confidentiality agreement, reasonable protection of their identity shall be maintained by RIV employees; i.e., the "need to know" principle will also be operative. This means
( avoidance of unnecessary use of the identity of the source and other
,,, identifying information in discussions and in documents. However, expurgation of the name and other identifying information is not required for internal dissemination of such documents, when such dissemination is necessitated by the special programmatic needs of the agency As in paragraph C.1., above, documents containing identifying information about an alleger will normally be used in accordance with the " check out" system provided for in paragraph C.3., below, unless absolutely required for the job by a RIV employee. Thus, allegers without a confidentiality agreement should be made aware of the fact that the protection of their identity is a matter of discretionary caution rather than an absolute mandate. For example, records containing identifying information on such allegers would normally not be exempt from the disclosure requirements of the Freedom of Information Act.
- 3. The RIV Allegations Coordinator will maintain the official allegations files for RIV. All records containing the names and other identifying information on persons making allegations after the effective date of this policy guide shall be sent to the Allegations Coordinator. A
" check out" system for records containing the names and other identifying information of all allegers within the jurisdictional responsibility of RIV will be developed by the Coordinator. Employees of RIV who have a need to kr.ow information contained in those records may review such records in accordance with the procedures developed by the Allegations j
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Regional Office Policy Guide No. 1101, Rev. 0 JUL 17 $85 l
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Coordinator. The allegations files will be maintained by the Allegations Coordinator and those files are, therefore, exempt from the requirements
,of Regional Office Policy Guide No. C200(5) " Completeness of Official Files."
D.
Contact:
Questions regarding this Policy' Guide should be directed to the Regional Counsel. f E. Effective Date: This Policy Guide is in effect when issued.
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' [ Robert D. Martin Regional Administrator.
Enclosure:
Proposed NRCM Chapter 0517 Distribution List: C 9 l l [. . J
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Jul.171985 U.S. NUCLEAR AEGULATORY CDP 911SSION NRC' MANUAL i volune: 0000 General Administration Part : 0500 Health and Safety IE CHAPTER 0517 MANAGEMENT OF ALLEGATIONS 0517-01 COVERAGE This chapter and its appendices define the policy and procedures for the proper receipt, processing, control, and disposition of allegations received by HRC. offices that concern NRC-regulated activities conducted by NRC licensees and their contractors and the policy and procedures for dealing with individuals who provide information to the NRC. 0517-02 OBJECTIVES
- 021 To establish the policy for the receipt, processing, control, and disposition of allegations and to define procedures by which the receipt, status, and disposition of allegations are tracked through the Allegation Management System (AMS), thereby assuring that: ,
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- a. allegations are properly assigned for processing and assessed for safety significance to permit ranking and resolution in a timely manner;
- b. timely and accurate information on all allegations is maintained and made available to NRC Offices and Regions on a need-to-know ,
basis;
- c. all allegations not resolved by other formal means are processed in accordance with these procedures and the resolution of all allegations is properly documented; 022 To assure that individuals making allegations to the NRC are properly treated, provided confidentiality when necessary, appropriate and possible, and notified of the resciution.
023 To assure that issues raised are promptly and adequately investi-gated. e Approved: ________-___D
t 8.'l 17 G35
, NRC-0517-03 DRNAGEMEC OF t.LLEGC20K5 e
( _ _ . { 0517-03 RESPONSIBILITIES AND. AUTHORITIES 031 Executive Director for Operations (E003, I j Set policy and procedures for the receipt, processing, control, I and disposition of allegations and establish policy for the { treatment and confidentiality of those who provide information to the NRC, For those metters within the purview of DI and CIA, only set policy and procedures governing their interfaces with I other Offices and Regions. 032 All Office Directors /Recional Administrators
- a. Estabiish internal procedures so that all employees are ware of requirements for receipt, processing, control, and disposition of allegations and for the accurate and timely updating of the status of those allegations for which their office is the Action !
Office.
- b. Appoint an Office Allegation Coordinator (OAC) who serves as achinistrative point of contact for employees and other Offices
_- and the Regions. The OAC will:
- 1. Ensure that the approp'rfate parts of the Allegation Data Form (NRC Fors 307, Exhibit 1) are completed for all allega-tions received within the' Office er Region and that the
? i requested data are accurata and timely. > {
- 2. Determine the appropriate Action Cffice and, if applicabis, coordinate with the OAC of the affected Office or Region nn each allegation received.
- 3. Ensure the appropriate parts of the Allegation Data Fors are completed for all allegations for which the Office or Region is the Action Office.
- 4. Forward the Allegation Data Fors to the respective Action '
Office OAC when the Office or Region is not the Action Office.
- 5. Forward the completed Allegation Data Fon. to the NRR CAC [and a copy to the Office of Nuclear Materials Safety and Safe-guards (N".55) DAC, if appropriate] within 10 working days of receipt of an allegation when the office is the Action office.
(For power reactors, during the period from 30 days prior to the construction completion date until the Commission meeting on full power authorization, the Receiving Office or Action Office for any allegation will, within 2 working days, tele-phonically notify the NRR Project Manager of its receipt and ( the identification of the Action Office in addition to com-pleting the Allegation Data Fors.) j
, Approved: 2
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AW. l'? B35 MANAGEMEKi Or ALLEG'TIONS t E7.*. 0517-032n6
- 6. Acacire input data on new aliepations (in:1uding those referred to CI) free the staff within the Offin or Region and ensure this information is forverded to the NRR DAC in a timely manner for placement into the AMS.
- 7. Provide updates -(using an AMS printout) on previous allege-tions (including those referred to 01) froe the staff within the Office or Region and ensure this information is forwarded to the NRR CAC on a monthly basis for placement into the AMS.
1
- 8. Provide reports as described in Appendix 1, Part IX, 4 and 5.
- c. Determine the safety significance and generic implications of those allegations that fall within the programmatic responsibi-lity of that Office or Region and establish schedules for the processing of allegations with the objective of resolving ther prior to a licensing decision date, if applicable.
- d. Review thc.se allegations for which it is the Action Office for potentiel board notification and recommend such notification to
,- NRR or HMSS.
- e. Refer all allegations involving wrongdoing, except those involving NRC employees or NRC contractors, to the Office of Investigations and provide technical assistance to 01 for investigating allege-tions as requestad.
- f. Prior to taking a major action such as a licensing decision or escalated enforcement, review the status and resolution of allegations for that project in the AMS especially those related to the action. ,
- g. For technical concerns with generic implications, consider the need to inform other affected Offices for further action (e.g.,
AE00 for operational data, RES for concerns affecting research activities,etc.)
- h. For discrimination complaints received concerning possible violation of Section 210(a) of the Ener2y Reorganization Act, refer the complainant to DOL and promptly notify DOL to ensure their awareness of the complaint and to determitie DOL's investigative intent. Determination of the need for an NRC investigation would rest with 01.
033 Director, Office of Investigations Investigate allegations of wrongdoing by other than NRC en-ployees and NRC contractors. Conduct interface responsibilities with the Offices and Regions as described herein. 3 Approved:
JUL 171985 NRC-0517-034 MAN G v.i- M t.; LEGATIONS
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034 Director, Office of Inspector and Auditor Investigate allegations of wrongdoing by MRC employees and NRC contractors. Such allegations do not fall under the purview l of this manual chapter and are not entered in the AMS. ! 035 Director, Office of Inspection and Enforcement !
- s. Resolve allegations affecting satters for which it is the respen-sible office including those that involve vendors or that are 1
generic in nature in coordination with NRR or NMSS.
- b. Monitor the allocation of resources for this activity by l the regions.
036 Director, Office of Nuclear Reactor Reculation
- a. Propose to the EDO for approval agency-wide policy and proce-dures regarding the processing of allegations. For those
,* allegation:, that fall under the purview of 01, propose policy and procedures governing their interface with other Offices
.. and Regions.
- b. Review allegations concerning NRR licensees in coordination with the Action Office for potential board notification and make such notification, if required. i 9
- c. Evaluate implications of allegations relative to licensing deci- ) '
sions and plant safety concerning NRR licensees in coordination with IE and the Region (s).
- d. Resolve those allegations pertaining to reactor licensing issues I assigned to NRR. .
1
- e. Maintain the AMS ~ and any necessary improvements to modify its capabilities, in coordination with RM.
037 Director. Office of Nuclear Material Safety and Safecuards
- a. Review allegations concerning NMSS licensees in coordination with 8
the Action Office for potential board notification and make such notification if required.
- b. Evaluate implications cf allegations relative to licensing deci-sions concerning NMSS licensees in coordination with IE and the Region (s). -
j 038 Office of Resource Manaoement (RM) 1
- a. Establish tne ADP program and maintain the data base of information l in the ARS. !
- b. Provide sonthly (Exhibits 2 and 3) and special reports to offices and Regions as requested. '
Approved: , 4
l JA. li 1335 y/m D'.D of t..LEGt.TIOR5 ( NRC 0517-04 l 0517-C4 DEFINITIONS 041 Action Office. The NRC Office or Region that is responsible for reviewing and taking action, as appropriate, to resolve an allega-tion. 042 Action Office Contact. The staff member in the Action Office who is assignec the responsibility for resolving an allegation. 043 A11ecation. A declaration, statement, or assertion of impro-priety or inadequacy associated with NRC-regulated activities, the validity of which has not been established. This includes all safety concerns identified by sources such as the media, indi-viduals or organizations outside the NRC, and technical audit efforts from Federal, State or local 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 forsal processes and are not resolved within these processes shall be subject to t eatment under this manua,l chapter. 044 A11ecation Management System (AMS). A computerized infonsation system each that contains a summary of significant data pertinent to allegation. 045 A11eoer. An individual or organization who makes allegations. T"he individual or organization may be a concerned private citi-zen; a public interest group; a licensee, vendor or contractor employee; a representative of a local, Stata, or Federal agency . (NRC employees should be aware of procedures for presenting differing professional opinions, NRC Manual Chapter 4125).
~
046 Confidentiality. The ters that refers to the protection of data It nat cirectly, or otherwise, could identify an alleger by name. of is not intended to deny staff members access to the identity , the alleger when such identification is required by staff siembers to evaluate and resolve allegations. 047 Inouiry. An activity involving minimal effort to determine the appropriate response to information reported to the NRC. Typi-cally, an inquiry entails the ' use of the telephone or written correspondence rather than formal interviews or other investi-gative measures; however, formal interviews will be conducted if required. 046 Insoection. A routine or special activity that may be used to examine and subsequently resolve an allegation. t i i 5 Approved:
JUL 17 BBS .f NC-0!"7-049 ( _ MANAGEMENT OF ALLEGATI0g , l 049 I nve r ti ce ti er.. Formal activities notically conducted by the j 1 Office of Investigations on its own volition, or at the request ! of the coerrission, EDO, or Regional Administrators, with or 1 without technical assistance. The Office of Investigations is N~ the lead Action Office for all investigations involving wrong- i doing, excluding wrongdoing by WRC employees and NRC contractors which is handled by 01A. 050 office A11ecation coordinator (OAC). A designated staff member in each Of fice or Region wno ssrves as the administrative point of contact for that Office or Region regarding the processing of allegations. 051 Receiving Office. The Office or Region that initially receives I an allegation. In scoe cases, the Action Office and Receiving l Office will be the same if the allegation falls within the functional responsibility of the Receiving Office. 052 Safety Significance. A measure of the importance of an allega-tion relative to its potential impact on the public health and safety.
~
053 Wronodoine For the purposes of this manual chapter, it includes the alleged deliberate, purposeful, or willful violation of NRC regulations, license technical specifications, licensee commitments to the NRC, or other laws or statutes of interest to NRC. 0517-05 BASIC REQUIREMENTS 051 Applicability. The provisions of this chapter and appendices are applicable to, and shall be followed by, all NRC employees. 052 Wronedoine. Allegations of wrongdoing at NRC regulated facili-ties, as opposed to those involving technical issues, fall within the purview of the Office of Investigations (allegations of wrongdoing by NRC employees or NRC contractors fall within the pyrview of 01A and are not entered into the AMS). The Office or hgion will enter allegations of wrongdoing into the AMS using inforr.ation provided by 01: (see Appendix .1, Part IX.2 of this manual chapter). OI will investigate allegations involving wrongdoing and provide either a report or a summary of its findings to the requesting office or Region. Allegations - involving wrongdoing received by a Region will be coordinated by the Region OAC with the 01 Field Office Director in that Region and those received by Offices at NRC Headquarters will be coor-
'dinated with the OI OAC.
053 Action Office Assignments Allegations submitted by any source concerning NRC-regulated activities should be transmitted by the i Rcceiving Offica CAC to the OAC in the appropriate Office or Region for processing. Approved: 6
JUL 171%5 u uGEKENT of ALLEGATIONS NRC 0517-0M s -. 054 Confidentiality. The identity of individuals making allegations should not be revealed by the NRC unless it is clear that the individual concerned has no objection. A confidentiality agreement (Exhibit 4) should be executed for those allagers 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 unawart that such an agreement is available. The offer of a confidentiality agreement should be contingent- upon an assessment of the usefulness of the infomation provided, if such a determination can be made in a timely manner. provided. For other individuals, confidentiality need not be As a general rule, implemented for however; the "need to know" principle should be 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 infomation 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 infomation in discussions and in documents. It aust be made clear to all concerned if and on what taras 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.
The confidentiality agreement may be signed by Office Directors and Regional Administrators gn_1y and any be transmitted to the alleger for signature by mail orTn person as convenience dictates. If at any time for any reason confidentiality is breached or , jeopardized, Office or Regional management should be infomed and the person should be advised, the reason explained and remedial measures taken, if possible, to reduce the impact of disclosure. Since 01 has established policies and practices for the protection of confidentiality for its activities, the above are not necessarily applicable to 01. 055 Respondino to A11eoers. These who provide allegations to NRC staff aust be treated with respect, consideration, and tact. Under no circumstances should they be dealt with brusquely or ebusively. When allegations are received in writing, a prompt attempt to maka personal contact must ordinarily be made in each case either by a letter, talaphone call or even a personal meeting. Contact should be earnest and professional. The a11eger should be promptly advised of the results of followup action and, in instances of unusual delay in providing the results, should be advised of the status periodically so that there is an awareness that the allegation is not being ignored. - l 7' Approved: 1
.- - - El l ~ 933 ;
NR -0517-049 I
-i KWJD'.D~ 0~ ALLEGtTIM5 ,
056 Screenine of A11ecations. A11egaticas should be screened fer significance to safety and the more seriws bnes should be addres-sed first. - All allegations should be addmssed as promptly as resources will allow and as the need is identified. Screening of allegations should be considered diligently to the point where some any. be dismissed early in the process for logical reasons (i.e., lack of specificity after masonable followup, lack of safety significance, etc.) to conserve staff resources. Followup on allegations, whether they are general or specific, should focus not only on the specific allegation but on the everall area of ! concern, including the potential for generic implications as well j as criminal activities. In this regard, note that an allegation
~ directed toward a non safety ites or activity any, through generic considerations, affect a safety ites or activity. j l
When a neber of allegations point to or reinforce indications of a broader probles, prompt action to broaden the scope of the inquiry should then be taken te determine whether cr not such is tha case. While the safety significance of an allegation is an- i incportant factor in determining the extent and promptness of staff resources commitment, it should not affect the staff triestment of
- the alleger as discussed in section 055, above. ,
1 057 Timeliness of Resolvino A11ecations. The Action Office should resolve all allegations in a manner which is timely under the t circumstances and professional in scope and depth. Allegations having relatively high safety significance should be addressed - expeditiously. Less significant allegations should be addressed as priorities and resources permit, but usually within 6 months _ of receipt. If it is appropriate, an inspection should be made. A plant visit with the person making the allegation should be made if necessary and if the individual is willing to make such a visit to find the exact location of a problem. Access issues should be addressed on a case-by-case basis. Travel costs for the individual only can be offered, if necessary 'and are turne by the Office or Region extending the offer. Care should be taken to avoid embarrassment or abuse of the individual, e.g., schedule visit on off-shift / weekend, etc. 058 Involvement of Licensees or Other Affected Organization. For allegations involving a potentially significant and immediate impact on the public health and safety, the affected organization should be promptly informed to assure proper and timely action. For other allegations, once information from allegers is received and understood by the Office / Region and if it is deemed appropriate ' by the Office Director / Regional Administrator, the licensee / vendor should be advised specifically by letter of the area of concern and should be requested to address it, subject to further audit by NR , in order to minimize the expenditure of NRC resources. In all instances, however, confidentiality must not be breached and the i effectiveness of investigations / inspections should not be com-promised, such as by prematurely releasing or appearing to release Approved: 8
~
E. I'! BB5 NR:-05D 056
\' -
E!^GEMIKI 0F ALLEGr N an NRC inspection report (nou exceptions discussed below). Tne alleger must be informed that this is not handing a matter over te the affected organization, but that NRC will review and evaluate the actions of the affected organization and perfom independent ' activities as necessary. The affected organization should be informed regarding the resolution of the allegation if appropriate (See Appendix I Part VIII). There are two exceptions to the above. The first exception is where the infomation cannot be released in sufficient detail to be of' use to the licensee or vendor without compromising the identity of the confidential source. In such cases release should normally not be made vitess the release is necessary to prevent an. imminent threat to r.he public health and safety. The EDO shall be consulted in all cases wnere it appears there is a need to release the identity of a confidential source. The second exception is where a licensee / vendor c'ould compromise an investigation / inspection because of knowledge gained from the release of information, especially if wrongdoing is involved. The- Regional Administrator for inspections and the Director of
,, the Office of Investigations for investigations shall decide whether or not to release the infomation to avoid compromising NRC action. Release of information to a licensee / vender is axpected to be the exception for 01 investigations.
9 Note that 10 CFR 19.16(a), involving radiological working condi-tions, requires that a worker's allegation in writing be made available to the licensee no later than at the time of inspec- ; tion, and that confidentiality be provided' at the worker's l request. In addition to expurgating names and other identifying ' infomation, protection of confidentiality could also involve , ntyping an alleger's handwritten notice. In the event the i potential for wrongdoing is involved. 01 should be requested to perform an investigation in which case the licensee would not be informed. l 059 "Lest Minute" A11ecations. When a large number of issues are 4 raisec at the same time, as has occurred with several plants as they approach issuance of an OL, the difficulties in executing the above policy guidelines are compounded. Consideration should be given to organizing a task force, comprised of both headquarters and regional personr.e1 with a senior NRC manager as the task force leader, to resolve these issues within the usual short time frame ;
. between the date the issues were identified and the proposed date I for issuance of an OL. A high degree of organization in the initial stages will be required in order to deal with these particular situations. To conserve NRC resources in resolving these large numbers of issues, the involvement by the licensee except as noted above will be appropriate. It say also be quite appropriate to categorize the large number of issues into two \ <
9 ADaroved-
\ - l- { l
~ -
@L 17198S
~
MANAGEMENT Or l' LEGr~:Ou gg 0517-058 t generr.1 groups, one group in which tht' issues are judged to .be significant anc therefore require resolu-ion prior to OL issuance, and a second group in which the issues are of lesser importance persitting resolution over a longer time frame, even subsequent to l OL issuance. With!n the former group, subdivisions may be i appropriate consistent with the planned stages 'of licensing for the f acility (i.e. , criticality, 5% power, full power). 060 Appendix 1. This appendix provides procedures for receipt, control, processing, and disposition of allegations assigned to NRC Offices or Regions and the procedures and guidelines used to record the receipt, status, and disposition* of allegations in the AKS. i END 1 1 es i 4 l i Approved: 10 -
,. .~. . . - . . ~ . . . . - . . ~. -
._ M 171985 MW.EK D' ALLEGATIONS ADPENDIX 1. NRC 0517 PROCEDURE 5 FDL SCREENING, ASSESSING. AND CONTROLLING ALLEGATIONS AND FOR ALLEGATION MANAGEMENT SYSTEM (AMS)
Part I: General This part establishes procedural guidance for screening, assessing, and controlling allegations that come to the attention of the NRC staff. These ! fun'etions are to be established within each Region and Office under the control of an individual Office Allegation Coordinator (OAC), or a panel of staff personnel or other appropriate staff technical persons. The Regions and Offices will establish procedures.. cons;istent with this guidance and where appropriate provide the required training to ensure that their staf fs are fully informed regarding the proper management of allegations. Allegations pertaining to NRC-licensed facilities and activities may come to the attention of the NRC staff by telephone, letter, news media reports, or by direct verbal contact at sites, in offices, at meetings, and even at social functions. All allegations, no matter how originated, are subject ' to processing in accordance with this manual chapter. It is. imperative . tt_~ allegations be recognized as such by staff members and processed pro-fL lonally, promptly, and with consistent treatment. ! It is very important to note that where safety is involved, the NRC does not recognize the term "of f-the-record. " A11egers who wish to provide
- off-the-record information must be clearly advised that information impor-tant to safety cannot be treated off the record, but that the infonaation l? will be accepted officially and acted upon as necessary. The name of the alleger and other identifying information will be protected, however, under the confidentiality guidelines presented herein.
{ Any employee who receives an allegation must be aware that it is essential to protect the identity of the alleger if such anonymity is requested or implied by his/her actions (i.e., an alleger who employs circuitous means to contact the NRC or makes several phone calls anonymously and then subse-quently identifies himself as the one who has been making the anonymous calls). To this end, coordination with the appropriate Office or Region A11eDation Coordinator must comply with the confidentiality guidelines discussed separately '(Basic Requirement 054). If necessary, the identity of an alleger may be revealed, but only if a confidentiality agreement has 1' not been executed. As a general rule, the "need to know" principle should be used when dealing with the protection of a person's identity. I NRC employees, particularly resident and regional inspectors, regional supervisors, and DACs who are expected to receive the majority of allega-tions, should become fully familiar with the prescribed policies and proce-dures to ensure that the required actions are performed. It is the responsibility of all employees who , receive allegations to take whatever steps are necessary to ensure that an appropriate OAC is promptly informed. Whenever possible, the person making the allegation should be referred to either the OAC, ether individus1s as designated by the Region or Office, or arrangements should be made for the OAC or designated staff member to recontact the individual. Al-1 Approved:
i
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Nd I? 198S i NF.f M '.
- I t :i1:31 '
KANAGEMENT OF ALLEGATIONS Pe.rt II: The Office Allegation Coordinator (OAC)
- 1. The initial responsibility of the OAC is to identify the proper Action Of fice to which the allegation should be assigned for. evaluation and resolution or Regions). in coordination with other DAC's (either in the Offices j
- 2. The OAC serves as a focal point for administrative processing and con-trol of all allegations assigned to the Regions and Offices. The OAC ]
is responsible for tracking allegations from. initial receipt to final 3 I resolution. The OAC assures establishment and -maintenance of files ! that clearly identify allegations assigned to the Region or Office and documents actions initiated to resolve such matters. The OAC i ensures that managec.mnt ' and cognizant staff are informed of allega-tions under their purview, kept current on the status of such alle- ; i gations by providing accurate and timely information to the AMS, and d briefed on the proposed final resolution of allegations. The OAC also ensures that the final resolution is properly documented. 3. The OAC assists technical' staff members who are reviewing allegation infomation, primarily in the form of coordinating activities neces-sary to resolve issues. In addition, the OAC may assist in the forsuistion of a course of action to resolve issues. (-
- 4. A panel, which includes the OAC as a sesber, may be designated with
'9 the primary responsibility to ensure that all allegations are promptly assigned and properly evaluated, and that the actions taken to resolve the allegation, as well as the resolution, are properly documented and transmitted priate. to the alleger and the affected organization as appro-
- 5. The OAC will serve as the point of c.ontact with DDL on matters i involving discrimination under Section 210(a) of the Energy Reorganization Act and will coordinate as necessary with 01 and ,
i the Enforcement Staffs. Part III: Receiot of an A11ecation
- 1. i A11ecations Received by Telephone or Persenal Visit Any NRC employee who receives a telephone call from someone who wishes to make an allegation should have the caller transferred to the OAC or appropriate technical staff member in the Office or Region.
Likewise, if an individual appears in person at an NRC Office, the individual should be referred to the OAC or other technical staff member. Technical employees, when unable to refer the telephone call or the visitor as described, shall obtain as auch information as possible from the individual (see item 3, below). When unable to locate the OAC or other technical staff member, administrative en-
; ployees should refer an individual to a technical staff supervisor.
l Approved: Al-2 '
i i 1
+
j M.171985 i MANAGEF.ENT OF ALLEGATIONS 4- - APPENDIX 1, NT,: om '
.\
- 2. A11ecations Received by Mail i
Personnel responsible for distribution of sati will forward cor-despondence that appears to contain an allegation to. the OAC. Both letters and _ envelopes . will be forwarded and no copies will be made. An esployee who receives direct correspondence, including internal NRC-samoranda, to the OAC. that contains allegations shall forward the correspondence - ) All personnel who say come into possession of this type- 1 of correspondence also should be made aware that correspondence con-taining confidential source information should be transmitted in a sealed envelope marked "To Be Opened by Addressee Only;" for expedited transmittals (e.g., _ electronically), confidential source information should be deleted from correspondence.
- 3. Discussions with A11eoer I Any employee receiving a telephone call or visit, as discussed in itemindividual.
the 1, shall attempt to obtain as such information as possible from It is crucial to identify:
- a. full name
.. b. complete mailing address
- c. telephone number where the individual may be contacted
- d. position or relationship to facility or activity involved g .. t ,
- e. nature of allegation If the ' a11eger declines to provide the above information, attempt to establish the reason (s) using the following guidance:
Inform the individual that if so requestad, his/her identity will be kept confidential. Explain further, if necessary, that Public Law 95-601 affords protection to the alleger by prohibiting an employer from discriminating Requirement 054 against an employee for contacting the NRC. Basic confidentiality. provides further information regarding protection of The alleger may be inforsed that the NRC employee with whom he/she is i in contact does not have the capability to evaluate the information, to determine follow-up action, or to establish NRC jurisdiction; therefore, it may be necessary that someone else contact the alleger for additional information.
.The alleger should be informed also, that--unless an objection is' registered--he/she the allegation. This will be recontracted as sosn as possible regarding a letter to the alleger, may be done by telephone, personal visit, or by at an address designated, which will also acknowledge the receipt of the allegation. This process will pemit the alleger to review the infomation with the NRC to provide maximum assurance understood.
that the' informatiten has been correctly interpreted and Al-3 Approved:
l
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M.1'l 25 j- NRC 0517, APPE C:X1 MANAGEMENT OF ALLEGATIONS If the alleger persists in not offering. identific ction afte'r the above-explanations, document the allegation in as auch aMail as possible and advise the alleger that he/she may contact the OAC or designated staff member in 30 days or any other agreed upon period, for infomation on the . status of any actions being taken on the infonsation supplied. , For allegations of discrimination that fall under Section 210(a) of the I Energy Reorganization Act, infore the allegers that NRC will look into the complaint and any safety concerns identified by the alleger, and that appropriate enforcement actions will be taken .against the-employer if the allegation is substantiated. To assure personal } employee rights are protected, advise the alleger that the complaint ( must be . filed with DOL within 30 days of the occurrence of the discrimination event. Part IV: Action by the Receivino Employee and the Office A11ecation Coordinator (DAC) 1. When an allegation concerning a NRC-regulated activity is received, the employee receiving the allegation will provide the information obtained
- to the Receiving gation Data Fom. Office OAC who will complete an NRC Fors 307, Alle-completed fom is forwarded The Action to theOfficeActionisOffice then OAC.
identified and the c Until direct inptrt/ update capability is provided to the Regions and Offices, a copy s .of the completed fem will be forwarded to the NRR DAC, and one copy to
' the NMSS CAC, if appropriate. for the issue.
NRC Form 307 serves as notification to NMSS and NRR that an allegation has been received that may affect their , licensing activity; NRR will enter the pertinant infomation in the AMS in accordance with these procedures. All allegations must be entered into the AMS. . In this way an " audit trail" will be established so that NRC actions can be properly monitored and completed.
- 2. The Action Office OAC or other designated staff member will ensure that the alleger is properly contacted to acknowledge receipt of the allegation and to confirm the specifics of the allegation. Depending on the nature of an allegation, the DAC will provide copies of the allegation documentation and the letter sent to the alleger (with the alleger's identity and identifying information concealed) to the cognizant technical staff supervisor for evaluation and initiation of action. Such. copies also will be forwarded to 01 Headquarters of to the ~ cognizant 01 Field Office for infomation. When responsibility for the handling of an allegation is transferred from one organizational unit to another, the a11eger should be notified of the new point of contact (name and telephone number) by the individual who is relieved as contact in order to assure continuity. A single point of contact should be the rule.
1
, The OAC will follow up on the allegation with the cognizant technical I staff supervisor at periodic intervals until the matter has been 1 satisfacterfly resc1vad. When the case is closed, an update should be made to that effect in the AMS.
c s.. .a. **'* 1
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JUL 171985 L _ _ FANAGEMENT OF ALLE_CATIDNS _ AD D E C D *. . L ' ~ OE17
- 3. The 0AC~ vill coordinate allegation information with the te:hnical staff - and say assist in determining whether the infomation is suffi-cient to identify the issues.
If the infomation is detemined to be insufficient, the OAC or designated staff member will assist in further contact with the alleger. A single paint of contact with an alleger provides a means of better controlling connunications, aids in
. developing rapport, establishes continuity in the flow of infomation between the Regions and other NRC Offices, and aids in protection of the alleger's identity.
- 4. The OAC assists the cognizant technical staff in identifying and separating the issues involved in an allegation into one of the follow-ing categories:
- a. Allegations that involve purely technical matters , such as:
inadequacies in procedures, qualifications, or training; inade-quate implementation of or inadequate corrective actions; or overexposure (s) procedures; to radiation,
- b. Allegations that involve wrongdoing such as: record falsifi-cation; willful or deliberate violations; saterial false state-ments; discrimination under Section. 210(s) of the Energy Reorganization Act; or other improper conduct.
(~ c. Allegations that involve matters outside the jurisdiction of NRC.
- 5. Technical issues in category 4a involving failure to meet requirements have the potential for being willful or deliberate violations. However, in the absence of specific allegations of wi11 fulness or deliberateness, such issues will nomally be tracked separately as technical issues and resolved using program resources. If an allegation covers issues that affect other Regions or Offices, follow-up activities will be coordin-ated with the affected Offices and a Lead Office will be designated. The OAC will contact the affected Offices which should result in a mutual agreement as to which Office or Region should have the lead. If agree-ment cannot be reached at the OAC level, then the Regional Adminis-trators or Office Directors will resolve which Office or Region should take the lead.
- 6. Allegations in category 4b, should be referred to DI Field or Head-quarters personnel except for those involving NRC employees or NRC contractors.
- 7. When applicable and after coordination, the Action Office should notify other ag.ncies such as the Occupational Safety and Health Administration, DOE, etc. in dealing with allegations in category 4c. Notification to other Federal law enforcement agencies and State and local jurisdictions of possible criminality involved in allegations should be handled by the appropriate OI office or the i
Office of Inspector and Auditor (for matters falling within its purview caly.) n .c 4. ... s .
. . - _ . _ . ~++ + -
- - ~ ~ ~ - ~ ~ - ~ ~ ~ - - " -
*b l
I JUL l'I G5 L KR* CC . OPEND 1 MANAGEMENT OF ALLEGATIONS j 6. The OAC ensures that a discrimination complainant under Section 210(a) cf. the Energy Reorganization Ar.t is properly referred to D0L complaint must be filed with DOL within 30 days of its occurrenc(the e), and that DOL is promptly notified of the complaint. Complaints should be filed with the Office of the Akinistrator, Wage and Hour Division, Employment Standards Administration, 'U.- 5. Department of Labor, Room 53502, 200 Constitution Avenue, N. W. , Washington, D. C. 20210. The Regional Administrator or Office Director should be promptly informed. The OAC also maintains awareness of DOL's investigative intent, and ensures NRC consideration of the need for its orm investigation by timely referral to 01. The OAC will take reasonable steps to facilitate DDL's investigation by assisting DOL in obtaining access to licensed - facilities and any necessary security clearances. This type of allegation should also be entered into the AMS.
- 9. If an allegation is determined to have generic implications, other i Of / ices and/or Regions with responsibilities that may be affected will l i
be appropriately notified by the Action Office (e.g. , AE00 for opera- I tional data, RES for concerns affecting research activities, etc.)
.. 10. Information regarding r,uspected improper conduct by NRC employees and ~ NRC . contractors will be brought to the attention of appropriate management for possible referral to the Office of Inspector and i
Auditor (01A). Pa'rt W Decumentino A11ecations .
- 1. When an a'llegation 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 1
files, interviews, and summaries of telephone conversations, discus-sions, 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 j documented about each allegation. In addition to obtaining basic ; information, attempts should be made to expand and clarify the i information so that the issue is well defined All allegations, regardless of source or how received, sust be documented. Records or files containing the name of a confidential source or other identifying ! information (i.e. a confidentiality agreement has been axecuted) should be stamped This material contains confidential source information." { l
- 2. There will be occasions when the allegations obviously have no sub-stance and appear to represent a distortion of facts. However, even in these cases, documentation is necessary that identifies the con-tact, the general content of any communications " and the basis for a conclusion that the matter need not be pursued. ' instances such as these will be coordinated with the appropriate technical ' staff by the OAC to ensure proper disposition.
- 3. The importance of obtaining and decu=cnting all partir. ant information about an allegation cannot be overemphasized. Evaluation and. screen .
ing of the allegation, as well as the proposed course of action that will be adopted to resolve the issue will be based primarily on this information. In some cases, a. person,al interview with the a .. . .a . . - -
, , , 1
, , _ , , _ , , _ , , _ , , , , .,_,,m.,__ ;
]
JUL 171985 I ( r,aGEMEK~ 0~ A.;L* *J ' . : . ADPENDIX 1, NR* 0-h a11eger say bc vstranted. MRC management In these cases, the OAC will consult with quired. to determine the best way to obtain the details re-Depending on the nature of the allegation and the time sensi-tivity, assistance fece the. Office of Investigations (01) or other resources may be requested. 4. As soon as possible after receiving an allegation or becoming aware of information that indicates inadequate or improper activities, the person receiving the allegation shall notify the OAC. Normally, no action will be taken to verify the validity of the allegations, nor shall such satters be discussed with licensees, if necessary, until after the OAC or designated staff member has briefed appropriate NR; sanagement. 5. The DAC or other designated staff member is responsible for reviewing all information received in conjunction with an allegation and for ensuring fully informed. that management and cognizant technical staff , members are ; 6. Allegations normally should not be addressed in Preliminary Notifica-
.. tions (PNs) or Daily Reports (DRs); however, if it is determined that PN or DR entries are appropriate, the approval of an Office Director or a Regional Administrator should be obtained. .
7. If allegation documents must be sent to other NRC personnel, they should le be appropriately handled to protect the identity of the confidential alleger. The confidential alleger's identity or other identifying information (See Basic Requirement should not054). be released unless there is a "need to know" Part VI: Evaluation bv Coonizant Technical Staff 1. When an allegation package is received, the technical staff within the Office er Region will review the documentation to determine if there is a safety concern that requires immediate action. The technical ; staff is responsible for development, initiation, and follow-through on corrective actions. Allegations or documents containing a sub-stantial number of allegations once entered in the AMS can be screened using the following criteria: a. Is there an insnediate safety concern which must be. quickly addressed? I b. Is the allegation a specific safety or quality issue or a gener-alized concern?
- c. Has the staff previously addressed this issue?
- d. Detertine whether the allegation package contains sufficient
(, information for a thorough evaluation. If it does not, identify the additional information that is needed. Al-7 Approved:
-___-- ___ ______________ a
dl 171953 j U: 'i'.7. ADPENDIX 1 MANAGEMENT OF ALLEGATIONS - -
- e. Determine whether all defined and described to pemit or require a meaningful and e sive evaluation. This is a screening process that may result in a decision not to consider the allegation further.
If the latter is the decided course of action, the alleger should be so informed in a courteous and considering diplomatic manner along with the rationale for not it further.
- The, potential for adverse publicity must be recognized when taking this action.
f. l Determine thorough whether the identity of the alleger is necessary for a evaluation, g. Determine what specific issues are involved in the allegation and whether the issues can be adequately addressed by a technical inspection. h. Determine if the allegation a routine, scheduled can be examined and resolved during inspection. mine the best way to address the issues.If this is not possible, deter-i.
~-? Determine whether licensee / vendor resources can reasonably be used in resolving the allegation to conserve staff resources.
Consider potential problems associated with " turning the issue over to the licensee." 3
- j. Determine whether the allegation' has the potential to require escalated enforcement action,
- k. Detemine the time sensitivity of the allegation, and what immed-iate actions are necessary,
- 1. Determine whether investigative assistance will be needed.
m. Identify peripheral issues that could c'evelop. n. Consider if any licensing actions or board proceedings are pending which could be influenced or affected by the allegation. When an allegation involves a case pending before a licensing or appeal board or the Commission, information concerning it should be provided to NRR or NK15 as socr. as possible to assist in the determination of whether or not a board notification should be made. This decision must be made promptly by NRR or W.SS in accordance with office procedures. -
- c. Determine if other NRC Offices that may have an interest should be notified.
- p. As soon as possible after the receipt of an allegation and the relevant information has been reviewed and evaluated, the Action Office will nake a preliminary determination of the safety signi-ficance of the itan and the need for imedicte rsgulatory action.
This determination will be reported in the next AMS upda.te. Approved: Al-8
- i
~
_ 3 r
- 1. 7 1985 .
{ MANAGEwl C Or ALLEGATIONS AePECIX L NR: On? q. Establish' a schedule for the resciution of each allegation which is consistent with the licensing schedule, if applicable.
- r. !
Notify or the(s) action OAC or designated staff member when the status changes is complete.
- 2. ]
It is - the responsibility of the technical staff within the Office or Region to resolve each allegation that falls under its jurisdiction, and subsequently, to notify the OAC or designated staff member of the action taken closecut. so that the status of each allegation can be tracked to Final resolution of an allegation shall be documented and placed in the working file along with all supporting documentation. The final report should state the facts clearly, in a style that does not belittle or disparage the a11eger.
- 3. k For those allegations resulting in the need for corrective action, the j affected organization (s) shall be properly infomed. t Part VII: A11ecation Resolution Documentation 1.
Allegation resolution documentation officially closes the file for that case and shall be placed in the working file which new becomes a closed case file. Closed case files shall be retired to inactive storage through according the Document Management Branch, TIDC, and destroyed i to the Comprehensive Records Disposition ! (NUREG-0910). Schedule Appmpriate documents, including those necessary for an individual to understand the incoming allegation and its resolution, shall be placed in the NRC records system (PDR, LPDR, Docket File, alleger. File, DCS) and must be treated to protect the identity of the Subject l
)
- 2. A final report should be prepared that sets forth the facts about the allegation and its resolution clearly and conclusively. The fhal re-port can be a memorandum for a relatively minor matter, an inwstiga-tion generic/ inspection matter. report, or a technical paper for a complex or major proximate to OL Itissuance. can be an SER supplement for su1tiple allegations It should not contain the name of, or s.aterial that could be used to identify, the ' alleger (See Basic Requirement 054),
3. The final report should include a summary of the concern, a descrip-tion of the evaluation performed and the conclusions drawn. It should be written in a style that does not belittle or disparage the alleger.
- 4. Appropriate entries should be made in the AMS to close out the allega-tion.
- 5. When the final report has been approved (i.e., the case is closed), all allegation documentation is subject to release under the FOIA with 1
appropriate precautions to protect confidentiality. Until that time,
'all allegation docus,entation is exempt from release under the F01A 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 FDIA m ouest for miease when the case ~ is closed should a subsequent FDIA request be received. '
al-4 A-a.
8d.17'33h I NRC 0517. APPENDIX 1 MANAGE 68.ERT OF ALLEGAT1ts Part VIII: Dissemination of Final Report
'1. A copy of the final report shall be sent to the alleger and, if appre-priate, to the affected outside organization!(s). A transmittal letter may be needed to stammarize the matter. '-
2. As in. Part VII.1 above, copies of the final report shall be placed in the NRC records system, and she'uld be treated so as not to reveal the identity of the a11eger.
- 3. The foregoing does JgLt apply to DI investigative reports.
F - PART IX: ALLEGATION MANAGEMENT SYSTEM
- 1. General
- s. For purposes of the Allegation Management System (AMS) the defini-tion provided for an allegation is very general and broad. The l significance or nonsignificance of an allegation will be judged J.-.
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 tions. and retrieving all key information regarding,all allega-The Action Office determines the necessary action to be taken based upon the specifics of the case. Some allegations may be received and closed out the same day.
- b. The AMS provides basic descriptive and status information and ~
serves as a referral systes. 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 reso,ved l and provides reference to the close out documentation. c. When an allegation is received, it is not necessary to identify by separate entry into the AKS every component or subset of the 1 allegation. For example, if an allegation is received that con-sists of 15 separate concerns of wrongdoing and technical def t-ciencias, the allegation say be entered as one allegation. However, the description of. the allegation s;hould include the number of separate concerns and their subject aret. In some cases there may be a distinct grouping of concerns, for example, in taro areas such as training and quality assurance. In such a case it say be appropriate to enter two allegations. A sain 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. e e
~
d\)U171985 i I MANAGEMENT OF AMEGATIONS copi cIx 1. NRC 0517
~f
- d. Sensitive information such as the names of persons making allege-tions shall not be entered in the systaa. All infomation entered on the form shall be unclassified and shall .not contain any safe-guards information or any proprietary or commercial (2.790) infor-nation. 1
- e. Some allegations may require action by two or more offices. 'For purposes of entering the allegation into the AMS either separate entries should be made for each Action Office for their essigned action or one entry may be made with the involved DACs agreeing on the lead Action Office for followup of the allegation.
1 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 '
- s. The Office of Investigations has . jurisdiction over all ' allegations of wrongdoing except those involving NRC empicyces or NRC contractors and will forward all allegations of a technical nature to the appropriate Office or Region. The Office or Region will be
;- responsible for entering all allegations--even those under the
_~~ purview of OI--into the AMS using a Region or Office AMS nasaber. i b. For those allegations of wrongdoing, except those involving NRC t employees or NRC contractors, assigned to the Region or Office: , (1) The Region or Office OAC will coordinate with the 01 Field Director or 01 Headquarters representative to detemine if sensitive information is- included which should not be placed into the AMS. All sensitive infomation 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 artent possible. (2) The Region or Office OAC will assign a Region or Office AMS number. The 01 Sssigned number should be entered in the AMS j as a cross reference. ! 1 (3) The name and phone number of the OI Field Director or 01 ' Headquarters representative will be placed in the appropriate section of the form as the Action Office contact. (4) The OI Field Director will keep the Region or Office OAC apprised of the status of .the allegation investigation and provide timely infomation necessary to determine the safety significance of the allegation to appropriate Regional or Office management and for use in updating the AMS. i , I 9# Se
JUL 171985 p.: 0517. 0 5* CIT 1 MANAGEMENT OF ALLEGATIONS (5) The allegation vill be considered closed when the investiga-tion report has been issued and as long as no technical issues remain. If technical issues or an investigation maain, the allegation rematns open, reference is made to the technical 1 report schedule or 01 for investigation report if either is complete, and a { > resolution . of the allegation is placed in the Allegation Data Fort or in the AMS update. c.
- For allegations of wrongdoing received by DI, the OI Headquarters or Field Director will coordinate with the respective office or Region DAC to complete the items 2.b(1) through (5), above.
d. For allegations of a te:hnical nature received by 01, the 01 Head- l quarters or Field Director will contact the respective Office or Region and follow the procedures as indicated in itse 3 below for the Receiving Office.
- 3. Receivine Office Upon receipt of an allegation involving an NRC-regulated activity, the person receiving the allegation will provide the infomation rela-tive to the allegation (see Exhibit 1) to the OAC who will initiate
'gation stepsinto reouired the AMS. to identify the Action Office and to enter the alle-
- The Receiving Office OAC should, in addition to determining the appro-priate Action Office, coordinate with the Action Office, and receive i
concurrence from the Action Office before transfer of responsibility. l
- 4. Action Office. The Action Office shall :
a. Ctaplete .that portion of the A11agation Data Form marked " Action Office," assign an allegation number to it, and foNard a copy of the fore to the NRR DAC for entry into the AMS, and to the NK55 OAC, of the ifallegation appropriate, within 10 working days of the date of receipt for information. b. Provide AMS updates to the NRR DAC on a monthly basis by indicating updates on the previous sonth's status report. Updates are due I to NRR by the 25th of each month. All input to NRR for the AMS should be sent in " addressee only" envelopes to, " Allegation Management System, Mail Stop 528. Completion of the follow-up action for an allegation will be recorded by updating the monthly status report. Name and telephone of Office or Regional A11ega-tion Coordinators will be indicated at the top of the update sheets; any changes in the designation of CACs will be made here.
' c. As soon as possible after the receipt of an allegation and relevant information has been reviewed and evaluated, make a preliminary
(. determination of safety significance and the need for any regu-1 story action. This determination will be reported in the next AMS updata. Approved: Al-12
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JUL 171985
.( MANAGEW.Eh*T Or (. LEGATIONS APPENDIX 1, WRC 0517 d.
Schedule the resolution of each allegation to be consistent with the licensing schedule and the safety significance of the alle-pation.
- e. ;
Make a determination regarding the need for a board notification to NRR or NK55. in nature, a follow If theupinitial board notification is preliminary notification is sent to boards when evaluation is completed, or whenever significant relevant infoma-tion is identified during the course of evaluating the allegation. This l determination should be made as soon as possible in ' accordance with the Action Office board notification procedures. { f. Develop and saintain 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 estab-lished for each concern. g. Provide iter.s c-f,status above.information to the NRR DAC for the AMS regarding'
. I
... h.
- Thirty days prior to the construction completion date (appli-cant'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 data, with a recom-sendation as to whether any or all of them constitute grounds for delaying license.
- issuance of (or otherwise restricting) an operating i Thirty days prior to a Commission decision on authorizing full-power operation, a r' aport similar to item h above, will be prepared.
- j. Ensure protection of the identity of all allegers when confiden-tiality is requested or implied by their actions, j
- 5. NRR OAC
- a. Upon receipt of an Allegation Data Fors and updates, the NRR OAC j will perform a quality check and will transmit the information to the Office of Resource Management (RM) for input into the AKS.
This procedure will be modified when direct input or update capability to the Av.S can be obtained for Offices and Regions.
. b. NRR will coordinate with RM to provide Offices and Regions monthly status reports during the first week of each month. The monthly report will include a list of all open allegations and a list of those allegations closed during the last 30 days. The femat for the status report is provided (Exhibit 3).
t l n.-e e ... a . j
m . WL I? 1985 ) yx,ACEK F 0: ALLEGAT100 EKHIBIT 3. W;.C O m (; _. NR; Fors 307 ALLEGATION DATA FORM
- 1. ALLEEATION NUSER: . -A. !
~
J 2. FACILITY: j Name Unit he. Docket No. I
- a. l
- b. ]
- c. 1
- 3. TYPE OF REGtr ATED ACTIVITY:
- a. Reactor Ob. Vendor O c. Materials Od. Safeguards
- e. Other 4 ERIALS LICERSE NUMBER:
- 5. FUNCTIONAL AP.EA(s):
$ Oa. Operations O b. Construction O c. Safeguards
= d. Transportation O e. Emergency preparedness g f. Onsite health and safety Og. Offsite health and safety
- h. Other
[ 6. DESCRIPTION: _ l 3@
*- [ 7. MuttLR DF Goh;LRM5:
- 8. SOURCE:
- a. Contractor employee O b. Licensee employee
- c. NRC employee O d. Former esployee i e. hews media O f. Private citizen
- g. Organization
- Q i. Anonymous
- h. Other
- 9. CONFIDENTIALnt REQutuw: O Yes O ne
- 10. DATE ALLEGATION RECEIVED: / /
r 11. DFLOYEE/0FFICE RECEIVING AEEIK1 TON: 1 12. ACTION OFFICE CONTACT / PHONE:
- 13. 5AFETY $1GNIFICANCE:- O Ni O Macium C Low Q None 14.BDARDNOTIFICATIONRECopMENDgh D: O Yes O No ,
- 15. 01 NOTIFIED: O Yes O No
- 16. STATUS:
l 0 0 pen O Closed Scheduled Coripletion Date: _/_/_ Date Closed: / -/ - g 17. NAS ALLEGAT10h % FART 1ATED: C Yes O ho O Partially
- 18. NAS ENFORCEMENT ACT10N TAKEN: C Yes C ho O ln Process g SEVERITY LEVEL: O! O !! Q 111 O lv QV
, 19. WAS 01 INVESTIGATION PERFORMED: C Yes C he OIn Process 3 20. DID D15PQ51T10N RESULT IN LETTER TO MODIFY OR REVDKE LICENSE:
E O Yes O ho 050.54(f) 030.32(d) 070.22(d) C 40.31(b) Disposition: -
- 21. ALLEGER NOTIFIED of LL95 LOU 1: O Tes G ho l '
, 22. RE%RKS:
T 73. cross RLtLRLNEL:
- 24. PROJECT MANAGER /PMDht:
F 25. APPLICANT'S CONSTRUCTION cumuloh DATL: / 3 26. BOARD NOTIFICAT10N ISSUED: O Yes O E _/~ , 8 1 ; . F1-1 Amorevedt
i RL 171985 K[0EM. EXHIBIT 1 @ % Ev.~N~ Of A;'.Et :0g
~
INSTRU;TIONS.
- 1. Allegation but>er Action Office fill in the boxes to uniquely iden.
tify this allegation DFFICE official NRC office abbreviation for the Office responsible for followup activities. YEAR last two digits of the calendar year in which the allegation at reported to NRC. A teentifies this number as an allegation IEner.
- frJ8SER sequential nuut>er asstyned by the Office or hetion responsible for the followup activities. -
EIAMPLE The 24th allegation received by IE in Facility (tes) 1982 would be shown as IE-82-A-0024
- 2. Give the name of the facility (ies) or campany(ies) involvec about whom the allegation is ande. Write the Cocket number, if appropriate in the spaces to the right. If the allegation is made about a specific individual or if tk infomation in this itam is otherwise sensitive, write SENSIT1YE. If j mots than three facilities or companies are in.
volved writa EEXERIC.
- 6. Description triefly describe the allegation (1 or 2 sentences).
k concise. If an allegation includes several in-stancas of technical deficiencies or wrongdoing, q
- list the assertions separately or group them by 1 trot. '
f* NOTE: . If the description of the allegation is sensitive, write only SENSIT!YE.
- 7. Weer of Write the total number of concerns given in the Concerns allegation. Note that each Office or Region any
' need to establish a working file for each concern. ,
- 8. Source Check the box that most clearly describes the l affiliation. DO NOT include the asse of the indi.
widual asking the allegation. .
- g. Confidentiality Reguested Indicate whether confidentiality has specifically been requestad.
- 13. Safety Provide an estiasta of the safety significance of Significance , allegation Ezample (a) Check 'high' for en alleged defi-ciency in an operating plant that could have an tamediate and great offact on public health and safety (b) Check
- Lor" for an alleged deficiency ir. a plar.1 under construction that would have a minor effect on public health and safety
- 20. Did Disposition Cneck apptc;riate bcx(es) and bMefly describe Result in Letter to %dtfy or method of disposition rtport. inspection report.(e.g.. letter.)
SD., etc. andtechnical identify Aeroke License document.
- 22. l'entrks Include additional infocustion as appropriate.
E1AMPLES: list other allegations r:1sted to this allegation; list other NRC officas responsible for followup activities en this allegation.
- 23. Cmss neference Identify other related allegations and investipa. I
- tions Ity alpha-numeric designation.
- 25. Applicant's For plants under construction, enter the app 11
' Construction cant's estiastad construction campletion date; CompetionData there is no need to provide this information until 3 or 4 senths prior to tha estiasted deta.
- 26. Soard Notification Indicate whether a board notification was issued.
Issued .
?
I a ,.d. F1-2
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. EL 171985
, V W aE e :~ U te. LEG:~10S5 D F.i! P 4 , N t 05 17
_. ~ CONTIDENT! Atm AGREEENT i I have infomation Regulatory Commission that(RC). I wish toI provide request in confidence to the U.S. huclear tiality as a condition of providing this infomation to the NRC.an express pledg not provide this infomation I will tiality being extended to me. voluntarily to the NRC without such confiden. I I It is my understanding, consistent with its legal obligations, the NRC. by agreeing to this confidentiality, will adhere to the following conditions: l (1) The HRC NRCaccument, initiated will not identify conve rsation, at by name or personal identifier in any public which relates directly te the infomation or communication ymyided byreleased to the me. I un6er. stand tne terr. "public release" to encompass any distribution outs 16e cf the NRC with the excep* ton of other pubite agencies which any require this information in furtherance of their responsiblitties under law or public trust. (2) The NRC will disclose my identity within the NRC only to the extent required for the conduct of NRC.related activities. ; (3) During the courst of the inquiry or investigation the NRC will also mate every effort consistent with the investigative needs of the Comission
-. , - to avoid actions which would clearly be azoected to nsult in the discio. - sure of my 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 my identity. my identification could be compelled by orders or subpoenas issued by courts of law hearing boards, or similar legal entities. fidentiality and any In such cases, the basis for granting this promise of con. other relevant facts will be communicated to the authority ordering the disclosure in an effort to maintain ny confiden. tiality. If this effort proves unsuccessful, a representative of the NRC will attempt to infom me of any such action before disclosing sy identity. I also understand that the NRC will consider at to have waived my right to confidentiality disclose if 1 take any action that any be reasonably expected to my identity. to have waived my I further unoerstand that the NRC will consider at viously provided) rights to confidentiality if I pavide (or have pre. information to any other party that contradicts the information that I provided to the NRC or if circues*ances indicate that I set intentionally providing false information to the NRC. Other Conditions: (if arty) I have with itsread and fully understand the contents of this agreement. provisions. I agree Late hame: Address: Algreed to on behalf of the U.S. Aclear Regulatory Connission. j l Date 51gnature be=c:
Title:
- E4-1 Approved:
t
1 TES ( uNiito ST A COMMISSION
- R REGULATORY - l NUCLEA ReoroN svDRIVE, 79011
$UffE 1000 l t
PLAZA RYAN
$11 AMuhoTON, TEXAS !
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FEB 2 81985 Regional Office Policy Guide No. 1901, Revision 0 DOCUMENTATION OF MEETINGS
\
A.
Purpose:
To systemize the practices and procedures for documenting meetings with applicarits, licensees, vendors, contractors, or interveners. B. Discussion: Proper and timely notification of all interested parties, both before and after a meeting, is generally a requisite to an efficient and productive meeting. A meeting notice with an agenda pemits preparation for the meeting by interested parties. An inspection report or meeting sumary
~
f documents that the meeting was held, who attended, subject discussed, and conclusions or decisions made. Sending the report or meeting sumary to the POR announces the same information to the general public and - identifies names of individuals or organizations that interested parties may contact for additional information. Meetings at the regional level may have a significant impact on licensing actions. In such cases it may be expedient and efficient to have representation from the appropriate licensing office. A Notice of Significant Licensee Meeting will be sent to IE Headquarters, as required by Inspection and Enforcement Manual Chapter 1100, to alert NRC Headquarters of such meetings. Section 1100-03 defines whether a planned meeting is significant in this context. C. Action
- 1. Corporate Manaoement Meetings Initiated by Region IV The subject of these meetings can vary greatly. It often is an ,,
enforcement meeting because of a Region IV concern, but can also be an information exchange meeting, or a combination of both. All corporate management meetings initiated by Region IV will be ! confimed by a letter to the appropriate' corporate officer prior to l the meeting. An agenda will nomally be included with the cenfima-tion letter; however, as a minimum, major topics will be identified in the text of the letter. The meeting will be documented in a meeting q sumary and transmittal letter subsequent to the meeting. Both the confirmation letters and the subsequent sumary will have the nomal I ( cc and bec distribution. ' l. L b
1 Regional Office Policy Guide r No. 1901, Revision 0 FEB 2 8 ISS5 l Enclosure 1 is a sample letter used to confirm in advance the date, 'I time, place and substance of meetings. The sample includes an agenda format. The RIV signature level should be at a level commensurate with the level of the addressee representative.
- 2. Corporate Manacement Meetinos Initiated by an Applicant, Licensee, Venoor, or Contractor The subject of these meetings also can vary greatly but normally is an area of concern or an area in which more information or I clarification is needed by the applicant, licensee, vendor, or I contractor. I All corporate management meetings initiated by an applicant, licensee, vendor, or contractor will be confimed by a letter to the appropriate corporate officer prior to the meeting, and by a Meeting Summary subsequent to the meeting. An agenda if available will be included with the confirming letter; however, as a minimum, major topics will be identified in the text of the letter. The letter will have the normal cc and bec distribution, plus other interested
_ parties as a cc or bec as appropriate. Enclosure 1 is a sample confirmation letter. Judgment must be exercised in the preparation of'the Meeting
! Sumary. There can be no " secret meetings" so the date and general subject must at least be identified and placed in the PDR. It is not required to reproduce detail such as found in the Details section of an inspection report. If decisions or comitments are made, it is desirable to define them well. We must not penalize licensees, vendors, applicants or contractors who ask for a meeting by revealing information which is not related to our area of concern. Care must nevertheless be taken to assure that all information required to be made public is included in the Meeting Sumary.
The Meeting Sumary will list the applicant, licensee, vendor, or contractor, and identify the appropriate facility with the docket and license or construction permit number. If 10 CFR 2.790 information was discussed, this should be sumarized on a separate enclosure and proper markings applied. If the entire meeting was 10 CFR 2.790 information, the transmittal letter should make this clear. In this case both documents are needed since the letter will go to the PDR but the 2.790 enclosure will not. The Meeting Sumary will include a list of attendees which may be i prepared as an attachment.. The sumary will be dated and signed by I the writer. Enclosure 2 to this instruction is a sample Meeting Sumary with a sample attendance list. l l I t 1
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- Regional Office Policy Guide No. 1901, Revision 0 FEB 2 81355 The transmittal letter will include the normal ec and bec distribution for the licensee involved with the meeting plus all licensee representatives attending the meeting. This may be relaxed somewhat if a licensee brings a large number of people to the !
meeting. Any licensee corporate officer or high-level manager should be listed on the cc distribution. The letter will be addressed to the highest ranking licensee representative attending the meeting. Use the normal addressee if higher ranking individuals were not present. Enclosure 3 is a sample letter used to transmit the Meeting Sumary. The RIV signature level should be at.a level commensurate with the level of the addressee representative.
- 3. Other Scheduled Meetings with Applicant, Licensee. Vendor, Contractor, or Intervenor
- Meetings may be requested by any party and may involve management ,
below the corporate level, such as site management. Such meetings are typically to discuss specific technical issues or some aspect of a security plan or quality assurance program.
-~
These meetings will be confirmed by letter to the normal corporate addressee prior to the meeting and in Meeting Sumary following the meeting. All aspects of documentation of this type meeting will be the same as in Section C.2. However, more technical detail will be included in the agenda and Meeting Sumary than is nonnally done for meetings with corporate management.
- 4. Meetings Without Advance Planning or Notice On occasion visitors may " drop in" with little or no advance warning because they happen to be in the area and want to meet people, or wish to discuss general information.
In those instances wherein a meeting is held with an applicant, licensee, vendor, or contractor and there is insufficient time to , confinn the meeting by prior letter, the meeting will be subsequently { documented by a Meeting Sumary or letter. If the meeting can be f characterized as an unannounced " drop in" visit and no issues were discussed, a letter to the visitor with a copy to the appropriate corporate officer is adequate. A person stopping at the office to l meet the Regional Administrator or other members of his staff is an l- example. The letter should state who came to visit that we welcome i the opportunity to meet such persons and make the point that there were no technical issues discussed. If this is not the case and I technical issues were discussed, comitments made, or decisions reached, a Meeting Sumary will be prepared as described in Sectior. C.2. In either case, normal cc and bec distribution will be
( Regional Office Policy Guide No. 1901, Revision 0
-4 -
M 2 C ES made with other interested parties included on either the cc or bec list as appropriate.
- 5. Corporate Management Meetinas Recuired by the Routine Inspection Program Scheduled meetings which are part of the routine inspection program will be handled in all respects as an inspection and need not be confirmed by a letter prior to the meeting. The normal inspection report and transmittal letter are required.
- 6. Notice of Significant Meeting After a decision has been made to hold a significant licensee meeting, a draft Notice of Significant Licensee Meeting should be prepared *by the appropriate Section Chief '- his designee and submitted to his Branch Chief for approval. The notice will then be typed in final form. All significant meetings should be included in the. Daily Report, and should be prepared by the responsible
~. Branch Chief. In addition, a Daily Staff Note should be prepared on all enforcement meetings and submitted with the meeting notice.
The Branch Chief obtains the Director's approval and has the Notice transmitted to Headquarters by 5520 or, as a less desirable 3 alternate, facsimile. _ Enclosure 4 to this policy guide is a typical Notice of Significant Licensee Meeting. NOTE: In completing the Notice, the title of all attendees must be included. The appropriate Branch Chief and Assistant Director in NRR or NMSS must also be included by name in the distribution. D. Contact Questions or coments regarding this policy guide should be addressed to William L. Brown, Regional Counsel. l l
l Regional Office Policy Guide FEB 2 C Ee5 _ No. 1901, Revision 0 . E. Effective Date This policy guide is effective when issued.
- I e obert D. Martin Regional Administrator
Enclosures:
- 1. Sample Confirmation Letter
. 2. Sample Meeting Summary.
- 3. Sample Transmittal Letter
- 4. Sample Notice of Significant Licensee Meeting Distribution List AB ,
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""INEcYok TtIIs' NI Sample Confirmation letter Name of Licensee Address of Licensee City, State, Zip Gentlemen:
This is to confirm arrangements made with you during our telephone conversation on (date) , for a management meeting in the Region IV office on (date) . (Soecify the purpose of the meeting, who requested the meeting, and identify tne general subject to be addressed.) A proposed meeting agenda is enclosed. Should you have any questions concerning these arrangements, we will be pleased to discuss them. Sincerely, m'
;' (Name)
(Title)
Enclosure:
Proposed Agenda bec w/ encl. DMB IE45 (reactor) DMB IE46 (materials) Resident Inspector RIV File State of (other bec's as appropriate)
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t ENCLOSURE I (Page 2 of 2) Sample Proposed Agenda
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1 1 PROPOSED AGENDA (Name-of Licensee) Meeting with NRC (Date and Time)
~I. INTRODUCTION'AND PURPOSE OF MEETING (Name)
II. (State Meeting Subjects) (Name)- III. DISCUSSION (Name) IV. NRC COMMENTS-(Name) _- V. LICENSEE COMMENTS (Name) VI .- CLOSING C0MMENTS (Name)
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98 ENCLOSURE 2"(Page 1 of 2) . Sample Meeting Sumary MEETING
SUMMARY
I Licensee: _(As appropriate)
< Facility: -(As appropriate)
License No.: (As appropriate) i Docket No.: (As appropriate)
Subject:
(In topic form)- l On (date) , representatives of (Name of Licensee) , met
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.. with Region IV personnel in Arlington, Texas, to discuss (state subjects)
_~ The attendance list is attached as Appendix A to this Summary. The meeting
.was held at the. request of (state who reauested meeting) .
(state sumary of the meeting)
-S )
(Name) (Date) (Title)
Attachment:
Attendance List J 1 l 1 i I- j i
Y ~ ENCLOSURE 2-(Page 2..of 2) ! Sample Attendance List ' i I ATTENDANCE LIST Attendance at the (Licensee) . - NRC meeting on (date) , at the NRC Region IV office. (Licensee) (List names, titles, and organizations, as appropriate) NRC, Region IV (List names, titles, and organizations, as appropriate) , I I l 1
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ARUNGTON, TEXAS 79011 Name of Licensee Address of Licensee City, State, Zip
. Gentlemen:
This refers to the meeting conducted at (part_v making request) request in the NRC Region IV office on (date) . This meeting related to activities authorized by NRC License No, for (name of facility) and was attended by (list attendees unless there are too many and attenoance list is needed). The subjects discussed at this meeting are described in the enclosed Meeting Summary. It is our opinion that this meeting was beneficial and has provided for a better understanding of (meeting subject). In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document f Room. Should you have' any questions.concerning this matter, we will be pleased to { discuss them. s-l' Sincerely, (Name) (Title)
Enclosure:
Meeting Sumary I bec w/ encl: DMB IE45 (reactor) i DMB IE46 (materials) Resident Inspector RIV File 1 State of l i (otherbec'sasafpropriate) {
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~ ENCLOSURE 4 Sample Notice (Date)
NOTICE OF SIGNIFICANT MEETING 3 Name of Licensee: (as appropriate) Name of Facility: _(as appropriate) Docket Number: (as appropriate) Date and Time of Meeting: Location of Meeting: Purpose of Neeting:- '(Specify the purpose of the meeting, who reouested the meeting, and identify t1e general subject to be addressed.) NRC Attendees: (List name and organization, as appropriate) _. ? Licensee' Attendees: (List name, title, and organization, as appropriate) Other Attendees ~: (List name, title, and organization, as appropriate) NOTE: Attendance at this meeting by NRC personnel other than those listed above should be made known by (time /date) via telephone call to (specify contact) FT5 (specify). Distribution: (Listname, title, organization) DMB IE45 (reactor) DMB IE46 (materials) DEDROGR Director IE Director, Quality) Assurance, Safeguards and Inspection Program IE (asappropriate Director Division of Emergency Preparedness and Engineering Response, IE (as appropri;te) Director, Enforcement Staff IE (as appropriate) Director and Chief Counsel, Regional Operations and Enforcement. ELD (asappropriate) ' Other NRC Offices and staff (as appropriate) ( i i I i
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*# . ARLINGTON. TEXAS 70011 AUG 2 9 586 Reaional-Office Policy Guide No. 2201, Revision 0 DISPOSITION OF INSPECTION FINDINGS A.
Purpose:
To provide!the staff with an understanding of the definite expectations of regional management concerning the identification,' classification, , and documentation of inspection findings, with particular emphasis on the l mechanism for resolution.of inspection findings involving . differing professional opinions. B. Discussion: The function of NRC inspectors during inspections is to verify compliance of a licensee with requirements incumbent upon him, and comitments he has made to the NRC. f Inspector findings are nomally discussed with the licensee during inspection ex,it meetings, during which the findings are nomally
.; categorized as apparent violations, deviations, unresolved items. -( followup items or improvement items. The licensee should be cautioned by the inspectors that .the findings as he portrays them may be revised after consideration by regional supervision and management. In no case should the licensee be advised of the fact that the severity level of a violation has been determined or that escalated enforcement is being planned based on the findings from a specific inspection. After review of the inspection findings by_ regional supervision, determinations of severity level, and the need for e enforcemnt conference will be established. Subsequent correspondenva With tht ticensee will be processed from the region, and if an enforcement conference is held,= severity level determinations will be finalized after the enforcement conference.
Inspectors also identify weaknesses in licensee programs or practices which are not at variance with requirements and comitments, but which, in the opinion of the inspector should be corrected. In some I cases, inspector findings may require revision of NRC requirements or interpretation of the applicable requirements or commitments. In cases ; of this nature and in cases needing program office guidance, the ; matter shall be identified by the inspector to his supervisor. If requested by the supervisor, a memorandum shall be prepared by the inspector to his supervisor, identifying the problem and proposing the appropriate resolution or posing the question on which guidance is sought. After discussion, the
- inspector's Branch Chief may endorse the inspector's memorandum, and transmit it to his counterpart in the appropriate program office for assistance in resolution, t
2 9 1986 3 .. Recional Office policy Guide No. 2201 , Revision O. The process of review of inspection findings r y lead to issuance of an NRC inspection report that differs in some substantial way from the inspector's original judgement. Supervision and management are responsible for evaluating the significance of an inspector's findings and for assuring ! that correspondence relating'to these findings-.is consistent with NRC policy and. guidance. . Whenever-any inspector believes that his positions are not being adequately considered as part of the. normal discussion of work matters, and his concern cannot be resolved through discussion'with co-workers and itsnediate supervision, and. if the inspector believes additional review of the matter is necessary, regional management considers the individual to be under a positive professional obligation to utilize the appeal process of Manual Chapter 4125. " Differing Professional Opinions," to assure consideration of his concerns by appropriate management. Similarly, supervisors and management have the positive responsibility and obligation to process the individual's concerns in accordance with the procedures and schedules contained within Manual Chapter 4125. Failure to utilize and follow the provisions of Manual
.:. Chapter 4125 to assure resolution of identified concerns should be considered not only as nonprofession61, but also may be an indicator of unacceptable. perfonnance.
a C.. Action: E The following procedures are designed to assure proper consideration, documentation and resolution of inspector findings.' The enclosure depicts the logic flow for resolution of findings.
- 1. Supervisors should discuss inspection findings with inspectors during or immediately following the inspection and solicit the views of other NRC staff on the matters under discussion. Differing viewpoints shall be discussed with the involved inspector and resolved at that stage if possible. If the issue can be resolved, the inspection report draft will
'be edited to reflect the final detennination and issued. Satisfactory resolution includes the case where the difference is recognized to be a matter of judgement and the inspector accepts the judgement of the supervisor. Should there remain cases where a mutually acceptable understanding cannot be agreed to by all parties, or one party feels that his viewpoints have not been adequately considered, the issue shall be referred to the next higher level of supervision for resolution.
The issue may also be discussed with regional management including the Regional Administrator if the concerned individual feels that further consideration may resolve the issue before issuance of the inspection report. The inspection findings should not be altered or deleted after the involved inspector has signed the report cover sheet without discussion with, and concurrence of, the involved inspector. If (
. . . . . . - . . ...:a- ;-..-.-.-.- =-.= ==.==:=. = -
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Recional Office Policy Guide No. 2201 Revision 0 agreement cannot be obtained, the supervisor shall direct the involved inspector to remove the item from the inspection report for ; sepa ra te . consideration. The inspection report shall then be issued without the questioned item.- j
- 2. After-issuance of a report, should there remain concerns on the part-'
of any person involved in the inspection report preparation process regarding the technical adequacy or accuracy of the issued inspection report, or should any party feel that his viewpoints have not been adequately considered, the concerned individual may document his concerns for full and complete consideration in accordance with NRC Manual Chapter.4125. " Differing Professional Opinions." For each item, the concern of the inspector should be identified along whh' the appropriate regulatory references. Each item should contain sufficient information to pennit full review and consideration without referring to other documentation. The documentation shall be 4 sufficiently complete to accurately portray the technical aspects of !
.- the concern and to explain significance to safety. The handling of the item, and the outstanding concern shall be described if appropriate.
t 3. The inspector's. supervisor and next higher level of supervision shall
- -* review the submitted item of concern, its basis for. disposition, discuss the matter with the involved personnel, and prepare a memorandum acknowledging receipt of the concern as required by NRC Manual Chapter 4125. The response shall be discussed with the
- concerned individual, and a copy given to him for his records. A copy of the initial concern and the response shall also be placed in the regional docket file if it pertains to a docketed facility. If the matter concerns an issue under review by a hearing board, the NRR Project Manager or appropriate program office contact shall be 4 infonned by the Branch or Section Chief. l
- 4. If the responses prepared by supervision are not sufficient to allay the concern of the individual following the discussion, the matter shall be processed in accordance with NRC Manual Chapter 4125 for consideration by appropriate regional and headquarters management.
D.
Contact:
Suggestions or conments should be directed to the Deputy Regional Administrator (ext. 222).
)
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m :.= =:=..s = = - =. = a....,:.... . .. . . . . a.,.......................... 1' I AUG 2 S F?h r, L. Regional Office Policy Guide No. 2201 Revision 0 . l E. ' Effective Date:
.This Policy Guide is in effect when issued.
l l y. obert D. Martin - Regional Administrator
Enclosure:
Logic flow chart Distribution List C l.9*3
\
i
MG 2 S SP6 1 LOGIC FLOW CHAPT Enclosure to - R0PG 2201 Inspector Observation : or Finding Significant Findings Reviewed by Telephone with Sect, ion Chief Inspection Findings s Discussed with Licensee at Exit , i o Discuss Findings with Section Chief and Draft Report r Agreement !
.:. on Findings?
1 2
,( ( ,
Inspector Documents Write Final Report Finalize Differing Viewpoint without Item Inspection. l Report Y \ Branch Chief Rev1ews Issue Repott u j and Documents his Issue Report j
Response
3 i y y v 1 Agree? Prepare and Process Dispose of Drafts .I DP0 per NRC MC 4125 and non-agency
% Records per R0PG 0206 j s I v i Requests meeting l with Div. Dir.- i i
and/or Reg. Adm?
,, L 2 7 Accepts Regional Decision? 5/30/86 5
1 I kE 22906 _ l Regional Office Policy Guide 2230. Rev. 5 REACTOR INSPECTION REPORTS AND ASSOCIATED CORRESPONDENCE ISSUED TO REACTOR LICENSEES q A. Purpose This Policy Guide vill define the necessary steps to follow for issuing reports and correspondence to reactor licensees. B. Discussion To describe the system for issuing inspection reports for reactor facilities in operation or under construction that will assure proper report numbering, concurrence chains, and the appropriate distribution. C. Action i
- 1. Signing Inspection Reports and Associated Correspondence
- a. Letters transmitting inspection reports generated by the Division of Reactor Safety and Projects which involve clear reports, reports identifying deviations, and reports identify-ing Levels IV and V violations, vill be signed by the Reactor t ( Projects Branch Chief, if no escalated enforcement action is involved.
- b. Letters transmitting reports generated by the Division of Radiation Safety and Safeguards, which involve inspections of facilities assigned to the Reactor Projects Branch and which meet the conditions identified in paragraph C.I.a. will be signed by the Reactor Projects Branch Chief.
- c. Letters transmitting reactor facility summary investigation reports generated by the NRC Office of Investigation staff, and any associated correspondence, vill be signed by the Reactor Projecto Branch Chief.
RIV:DRSP EO y; f DR DRSP WCSeidle:g je DAPowers RL t ERJopnson rtin 4///86 4//5 /86 4/p/86 4/gg/86
[. - v o -.. (
- Regional' Office Policy II E06 Guide 2230. Rev. 5 '
- d. Correspondence, other than the report transmittal letters, directed to the licensee, which is associated with the reports covered in paragraphs C.I.a. C.1.b. and C.I.c will be signed by i the Reactor Projects Branch Chief. This correspondence includes ;
interim acknowledgement letters requesting supplemental information from the licensee on an inadequate response to a violation or deviation; and transmittal letters (without reports attached) that promptly transmit enforcement correspondence
~ covering violations detected by RRI's early in a report period.
Transmittal letters containing licensee management action paragraphs (e.g., a request for licensee commitments to strengthen their QA/QC program) will be signed by the Director of DRSP or DRSS. !
- e. The Directors of URF0, IE, and other Program Offices will sign all orders issued to licensees. All other escalated enforcement actions and associated correspondence directed to the licensee l will usually be signed by the RA or his management designee
,' (i.e., typically a branch chief). A designee is normally permissible if the violation (s) being cited are categorized as either Severity Level IV or V and NRC is not aggregating such Violations into a Severity Level III.
- 2. Distribution of Reactor Inspection Reports
- a. Report Distribution The distribution of an inspection report will be the respo.isibility of the DRMA staff in accordance with Policy Guide 0200(2),
Revision O. Regional- distribution of the report will include sending the original concurrence copy to the Document Management Branch (DKB) marked with the appropriate RIDS code; all inspectors involved in the inspection; resident inspector; branch and section chiefs to whom the facility is assigned; D/DRSP; Regional Administrator; MIS section (along with original SF-766). j IE Manual Chapter 0611, dated September 14, 1984, terminates the practice of routinely sending inspection reports to licensees for their proprietary review in accordance with 10 CPR Part 2.790(a) prior to placing the inspection reports in the PDR, except in those cases as outlined in that MC.
~
(. .- Regional Office Polfey APR 2 2 526 Guide 2230, Rev. 5 b. Draft Inspection Reports Draft inspection reports will not be delivered to anyone outside 1 the NRC without prior specific approval by the Executive Director for Operations.
- 3. Inspection Report Numbers The inspectors will obtain inspection report numbers from their branch secretaries. The branch secretaries obtain these sequential report numbers from the RSTS operator, DRMA. The inspector must enter the report number in the blank after " SEQUENTIAL REPORT NO " on the Inspector's Travel Request form prior to going on travel. If inspections are planned and begin during nonregular hours (e.g.,
during a weekend), then it is the responsibility of the inspector or his section chief to notify the branch secretary of this situation as soon as possible during regular working hours. The responsible branch secretary must be notified promptly by the
,_~~ inspector if an inspection is cancelled so that she can initiate a letter to the licensee cancelling the report number.
l 4 Concurrence Chain for Inspection Reports IS
- a. Inspection Reports without Escalated Enforcement and
( Clear Reports (DRSP reports) Concurrence Chain: 1 (1) Originator (prepares final report); (2) Originator's Section Chief; (3) Counterpart Section Chief (if inspection I performed by another branch) (4); Counterpart Branch Chief (if 4.a(3) is applicable); (5) Originator's Branch Chief; (6) Allegations Coordinator (if inspection report discusses , allegations). l
- b. Inspection Reports without Escalated Enforcement and Clear Reports (reactor reports prepared by DRSS)
Concurrence Chain: (1) Originator (prepares final report); (2) Originater's Section Chief; (3) Originator's Branch Chief; (4) DRSP Section Chief responsible for facility; (5) DRSP Reactor Projects Branch Chief responsible for facility; (6) Allegations i Coordinator (if inspection report discusses allegations). l
~
Regions! Office Policy APR 22 1986 Guide 2230 Rev. 5 ;
- c. Inspection Reports with Escalated Enforcement Action, 01 Synopses or requests for Enforcement Conferences Concurrence Chain:
l The concurrence clain will be the same as specified in paragraphs C.4.a and C.4.b; in addition to adding Director, DRSP; Director, ' RSS (if C.4.b is applicable); and Enforcement Officer.
- d. Concurrence Chain Format-l The concurrence chain will show the typed initials of the office, section, branch or division above the surname. This information will be provided to the typist by either the originator or the branch secretary. .This will provide the reader with the identity of the group originating the letter and various groups who have concurred in these documents.
#~
EXAMPLE: RIV:PS-A PS-A RPB DRSP Inspector JPJaudon JEGagliardo ERJohnson D. Contact-1 (' Any suggested changes should be marked on the current copy of this PG by adding or deleting material as necessary and routing it through your supervisor to Director, DRSP, for concurrence. E. Effective Date This Policy Guide is a general revision and supersedes Regional Office Policy Guide No. 2230 Rev. 1 (3/25/83); Rev. 2 (9/15/83); Rev. 3 (2/31/84); and Rev. 4 (8/27/84). This PG is in effect when issued. 4 J _ Robert D. Martin Regions 1 Administrator Distribution List C { ;
l l l' j#"% '* UNffED STATES NUCLEAR REGULATORY COMMISSION
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- nie S REGION IV
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. .# 811 RY AN PLAZA DRIVE. SUITE 1000 l \ , ,y,, *# ARLINGTON. TEXAS 7s011 ;
I MAY 0 71995 1 ! Regional Office Policy Guide No. 2231, Rev. 3 ] STAh"DARDIZED REPORT LETTERS FOR RIV REACTOR LICENSEES
)'
A.
Purpose:
j The purpose of using the standardized letters for inspection reports and i related correspondence is to bring about improvement in the quality of this type of correspondence by using our automated typing equipment, and j to expedite its preparation and processing as much as possible. ! l l B. Discussion: All inspection reports issued to the licensees of power and research l reactors shall use the standard letters which are attached to this
.. Policy Guide (PG). These standard report paragraphs and response letters
/ are in the IBM 5520 system and vill facilitate more timely preparation of
'our inspection reports. Deviations from this PG must be approved by the Director,' Division of Reactor Safety and Projects (D/DRSP) prior to the preparation of the report.
I t C. Action: Normally, the 10 CFR 2.790 paragraphs will not be used in an inspection report. However, if significant doubt arises regarding the proprietary nature of material in a report, use one of the paragraphs, as applicable, listed in Attachment 1. (See MC 0611 (10/24/84) for further guidance.) The standarc report letters and responses to licensee replies are listed ; in Attachments 2 and 3, respectively. The document names for these letters, current lists of addresses, and
'bec' distribution for each licensee are in the 5520 as listed in Attachment 4. The RIDS codes for various types of reports are also listed in this attachment.
D.
Contact:
Any suggested changes should be marked on the current copy of this PG by adding or deleting material as necessary and routing it through your supervisor to Director, DRSP, for concurrence. Additional standardized paragraphs or letters covering special report needs may be added to this PG by following the above procedures.
i
.l' Regional Office Policy 2 MAY_0 7 586 l Guide No. 2231, Rev. 3 i
E. Effective Date': This Policy Guide is a general revision and ersedes Regional Office Policy Guide No. 2231, Rev. 0 (4/11/83); 2231, Rev.1 (4/29/83); and PG 2231, Rev. 2 (9/13/83). This PG is effect when._ A sjsed. N A
/ /
il l/ % Robert D. Martin j Regional Administrator Attachments: ' 1
- 1. Proprietary Paragraphs
- 2. Standard IR Letters, {'
Report Cover Page, j NOV and Deviation l
- 3. Standard IR Response Letters I
~~'
- 4. IBM 5520 Document Names j
_- and RIDS Codes ' Distribution List C i i t
'l l-1 l.
i
- l. !
1 --___---_____--_D
MAY 0 7 -1985 j, ATTACHME1C 1 PROPRIETARY PARACRAPHS PROPRIETARY 1 - Power Reactors In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) vill be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10' days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1) . PROPRIETARY 2 - Research Resetors In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter with the enclosed inspection report vill be placed in the NRC's Public Document Room. If this report contains any information that you believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within 10 days from the date of this letter of your intention to file a request for withholding; and (b) submit within 25 days from the date of this letter a written application
/
_. to this office to withhold such information. If your receipt of this letter has been delayed such that less than 7 days are available for your review, please notify this office promptly so that a new due date may be established. Consistent with Section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the information which identifies the
%' ~( document or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claimed that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CTR 2.790(b)(4).
The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room. PROPRIETARY 3 - Research Resetor Safeguards Inspection (use for material control and accountability) In accordance with 10 CFR 2.790(d), the documentation of fi-Aings of your control and accounting procedures for safeguarding special nuclear materials and your facility's security procedures are exempt from disclosure. Therefore, the inspection report will not be placed in the Public Document Room and distribution vill be limited. PROPRIETARY 4 - Power Reactor Physical Security Inspection 1 The material enclosed herewith contains Safeguards Information as identified by 10 CFR 73.21 and its disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended. Therefore, the material with the exception of the report cover page which is an inspection summary, vill not be placed in the Public Document Room.
__----___________.__.m..___....,_....;.. . i a- , _ alAY 0 71SES - 4 1 0 ATTACHMENT 2 1 I RPB FORM LETTER 1 CLEAR INSPECTION LETTER
] '
l In Reply' Refer To- I Docket (s): 50- (Refer to RON 2230 for 50- correspondence issued to TUCCO)
-ATTN:
Gentlemen: This refers to the inspection conducted by of this of fice. during the perf.od of activities authorized by NRC (Operating License / Construction Permit) for , and to the discussion of our findings with
, and other members of your staff at.the conclusion of the inspection.
~~
Areas examined during,the inspection included y - Within.these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the. inspector (s). The inspection findings are documented in the enclosed inspection report. Within. the scope of the inspection, no violations or deviations were identified. unresolved item (s)'is/are identified in ' paragraph (s) of the enclosed inspection report. We.have also examined actions you have taken with regard to previously identified inspect:iori findings. , The ti:stus of these items is identified in paragraph ,_ of the' enclosed report. i i 1 1 o________. - - - _ _ _ _ - . _ _ _ .
lr. - MAY 07 19s
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1 Should you have any questions concerning this. inspection, we vill be pleased to' discuss them with you. Sincerely. l
. Chief.
Reactor Projects Branch
Enclosure:
Appendix -'NRC Inspection Report 50-50-ec w/ enclosure: 4 G I' , l i ! l \ 1
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- 7 $PS RPB FORM LETTER 2 NV INSPECTION LETTER __
In Reply Refer To: Docket (s): 50- (Refer to RON 2230 for 50- correspondence issued to TUGCO) ATTN: Gentlemen: This refers to the inspection conducted by of this office during the period of activities authorized by NRC (Operating License / Construction Permit) for , and to the discussion of our findings with
. , and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations 'oy the inspector (s). The inspection findings are documented in the enclosed inspection report. I' During this inspection, it was found that.certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to this/these violation (s), in writing, in accordance with the provisions of Section 2.201 of the FRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter. unresolved item (s) is/are identified in paragraph (s) of 4 the enclosed inspection report. l l We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph of the enclosed report. l 1
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2 The response directed by this letter and the accompanying Notice is not subject to.the clearance procedures of the Office of Management and Budget as required by the Paperwork' Reduction Act of 1980, PL 96-511. Should.you have 'any questions concerning this inspection, we vill be pleased to discuss them with you. Sincerely,
, Chief Reactor Projects Branch
Enclosures:
- 1. Appendix A - Notice of Violation
- 2. Appendix B -.NRC Inspection Report 50-50 .
cc w/ enclosures: W 1 l l l 1 1 d' !
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1 1 1 c.____ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ . _ _
MAY 0 7 Elas RPB FORM LETTER 3 1 - DEVIATION INSPECTION LETTER In Reply Refer To: Docket (s): 50- (Refer to RON 2230 for 50- correspondence issued to TUGCO) i ATTN: Gentlemen: This refers to the inspection conducted by of this office during the period of activities authorized by NRC (Operating License / Construction Permit) for , and to the discussion of our findings with
, and other members of your staf f at the conclusion of the inspection.
Areas examined during the. inspection included Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector (s) . The inspection findings are documented in the enclosed inspection report. ( During this inspection, it was found that certain of your activities appeared to deviate from accepted industry standard (s)/ commitment (s) made to the NRC. This/These item (s) and reference (s) to the standard (s)/ commitment (s) is/are identified in the enclosed Notice of Deviation. You are requested to respond to this/these deviations (s) in writing. Your rebponse should be based on the specifics contained in the Notice of Deviation enclosed with this letter. unresolved item (s) is/are identified in paragraph (s) of the enclosed inspection report. We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph of the enclosed report. i
L MAY 0 71986 (. _ 1 The response directed by thfs letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as
~
required by the Paperwork Reduction Act of 1980, FL 96-511. Should you have any questions concerning this inspection, we vill be pleased to discuss them with.you. Sincerely, ~' t
',, Chief Reactor Projects Branch
Enclosures:
- 1. Appendix A - Notice of Deviation.
- 2. Appendix B - NRC Inspection Report 50-50-
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, j MAY 0 t 1985 1 1
). RPB FORh* LETTER 4 <, .
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/ NV ONLY LT.TTER I (no tt? ort) h I 3 /, , ( (
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in Reply' Refer Tot < f " 4 Docket (s): 50- (RSfer to RON 2230 for' l 50- correspondence issued to TUCCO) ATTN: -
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< ,s Gentlemen:
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d This refers to the inspection conducted by ,of this , 5 office during the period _ of activities authmized by e'
/.1 NRC (Operating License / Construction Permit) , v';
for , and to the discussion of our findings with
, and other remberr;of your staff ar,the conclusion ,
of the inspection. >
,e /
53 i Areas examined during the inspection inclcded , / a. I Within.these areas, the inspection consis';ed of selective examination of d procedures and representative records, interviews with personnel, and observations by the inspector (s).
\
During this inspection, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to this/these violation (s), in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, T2t3e 10, code of Federal Regulations. Your response should be based on the spes.1.fics contained ' in the Notice of Violation encioned,with this letter. j Details of this inspection will he included in a report 'to bu J.ssued in the near future and identified n ,NRC Taspection Report ' ' e
- c. ,
TheresponsedirectedbythisletterandtheaccompanyipgNoticef4pdifk I subject to the clearance procedures of the Of f:.tia of Mariagement'and' h.Qat as required by the Paperwork Reduction Act of 19,80. PL 96-51Y. f- i '. r)L ,
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Should,. yol have any questicm{e concerning this inspection, we vill be pleased to dWhss them with 'you. # 3j
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't,. '. 4 Reactor Projects Branch
{; ff- $ Enclosures ,
.g Appundix.A - Netice of Violation !
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,,", .. ,, g T RPB FORM LETTER 5 . 4 INSPECTION LETTER (NV forwarded earlier)
In Reply Refer To: Docket (s): 50- (Refer to RON 2230 for 50- __ correspondence issued to TUCCO) ATTN: Gentlemen:
-This refers to the inspection conducted by of this office during the period of activities authorized by NRC (Operating License / Construction Permit) for , and to the discussion of our findings with
, and other members of your staff at the conclusien of the inspection.
Areas examined during the inspection included Within these are,as, the inspection consisted of selective examination of procedures'end representative records, interviews with personnel, and observations by the inspector (s). The inspection findings are documented in
~ , the enclosed inspection report. ~
(. During this inspection, it was found that certain activities under your license appeared to be in violation of NRC requirements. The violation (s) reported in paragraph (s) of the enclosed inspection report was/were forwarded to you by our letter and Notice of Violation, dated ; therefore, this letter does not require further written response. unresolved item (s) is/are identified in paragraph (s) of the encioned inspection report. We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph of the enclosed report.
.I y,
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Should you have any questions ~concerning this. inspection, we will be pleased..
. to discuss them with you.
Sincerely.
. Chief Reactor Projects Branch
Enclosure:
) Appendix - NRC Inspection Report 50-' 50-ec w/ enclosure:
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MAY 0 7 '386
, RPB FORM LETTER 6 l
_ NV & DEVIATION LETTER i I In Reply Refer To- 1
-Locket (s): 50- (Refer to RON 2230 for 50- correspondence issued to TUGCO)
ATIN: Centlemen: This refers to the inspection conducted by of this office during the period of activities authorized by NRC (Operating License / Construction Permit) for , and to the discussion of our findings with
, and other members of your staff at the conclusion of the inspection. ;
Areas examined during the inspection included j
~
Within these areas, the inspection consisted of selective examination of j procedures and representative records, interviews with personnel, ant l t observations by the inspector (s). The inspection findings are documented in j the enclosed inspection report.
.)
! ( During this inspection, it was found that certain of your activities were in . violation of NRC requirements. Consequently, you are required to respond to { this/these violation (s), in writing, in accordance with the provisions of ' Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10 Code of Federal Regulations. Your response should be based on the specifics contained ! in the Notice of Violation enclosed with this letter. 1 Also during this inspection, it was found that certain of your activities appeared to deviate from accepted industry standard (s)/ commitment (s) made to the NRC. This/These item (s) and reference (s) to the standard (s)/ commitment (s) is/are identified in the enclosed Notice of Deviation. You are reernested to respond to this/these deviations (s) in writing. Your response should be based on the specifica contained in the Notice of Deviation enclosed with this letter. unresolved item (s) is/are identified in paragraph (s) of the enclosed inspection report. , We have also examined actions you have taken with regard to previously identified inspection findings. The status of theee items is identified in paragraph of the enclosed report.
- .. ~UY C 7 *',pc ,
3- _ j 1 1; The responses directed by this letter and the accompanying Notices are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980 PL 96-511. Should you have any questions concerning this inspection, we vill be pleased to discuss them with you. t. Sincerely,
, Chief Reactor Projects Branch T.nclosure s :
- 1. Appendix A - !!otice of Violation
-2. Appendix B - Notice of Deviation
- 3. Appendix C - NRC Inspection Report 50-
._ - 50 i
cc w/enclosurest o .- ( l 1 _-_-___________________-________-____-______A
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MAY C 7 500 RPB FORM LETTER 7 ESCALATED ENFORCEMENT / ENFORCEMENT CONT. LETTER in Reply Refer To: ! Docket (s): 50- (Refer to RON 2230 for 50- correspondence issued to TUGCO) i ATTN: Gentlemen: This refers to the inspection conducted by of this office during the period of activities authorized by NRC (Operating License / Construction Permit) , for , and to the discussion of our findings with l
. and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included Within these areas, the inspection consisted of selective examination of
< procedures and representative records, interviews with personnel, and observations by the inspector (s) . The inspection findings are' documented in the enclosed inspection report.
l' During this inspection it was found that certain of your activities appeared to be in violation of NRC requirements. As discussed in our telephone conversation of with (you/your) staff, we have scheduled an enforcement conference in our office at on to discuss your understanding of (this/these) appareEt violation (s), the reasons for occurrence, and your corrective actions. *ie vill also discuss any potential enforcement options available to the NRC, if appropriate. An agenda for this meeting is enclosed. unresolved item (s) is/are identified in paragraph (s) of the enclosed inspection report. We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph of the enclosed report.
.m.. . . . _ _ _ ,, _ ,, _ ,,, .. _ _ m,,,,, _ _ _ _ _ _ _ . . . , _ . ,
P'Y-; ? t;as 1
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- Should you have any questions concerning this inspection, we will be pleased
.to discuss them with you.
Sincerely,
. Chief Reactor Projects Branch
Enclosures:
- 1. Appendix - NRC Inspection Report 50-
.50-
- 2. Meeting Agenda ec v/ enclosures:
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. _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ _ - _ A
_ _ _ _ _ - _ _ _ _ ~. . -- - _ EAY 07 585 RPB FORM LETTER 8 INVESTIGATION REPORT LETTER (NO NV/ND) ? LI n Reply Refer To: Docket (s): 50- (Refer to RON 2230 for 50- correspondence issued to TUGCO) ATTN: Gentlemen: This refers to the investigation conducted by of the NRC Office of Investigations Region IV Field Office, during the period
, of activities authorized by for .
This investigation was conducted to determine
. The
,' findings of this investigation are sunnarized in the enclosed Syndpsis to the Inve>cigation Report.
Vithin the scope of the investigation, no violations or deviations of NRC requirements were identified.
- g_.
Should you have any questions concerning this investigation, we will be pleased to discuss them with you. Sincerely,
, Chief Reactor Projects Branch
Enclosures:
Appendix - ! Cover Page and Synopsis for NRC Investigation Report Case Number cc w/ enclosures: l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ A
MAY 0 7 Bes RPB FCAM LETTER 9 i ' INVESTIGATION REPORT LETTER (w/NV) In Reply Refer.To: Docket (s): 50- (Refer to RON 2230 for l 50- correspondence issued to TUGCO) ATTN: Gentlemen: This refers to the investigation conducted by of the NRC Office of Investigations Region IV Field Office, during the period
, of activities authorized by .
for the . 1 This investigation was conducted to determine ' The. findings of this' inspection are summarized in the enclosed Synopsis to
.. the investigation Report.
During this investigation, it was found that certain of your activities were
; in violation of NRC requirements. Consequently, you are required to respond to this violation, in writing, in accordance with the provisions of
-( Section 2.201 of the NRC's " Rules of Practice," Part'2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter.
The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as required by the' Paperwork Reduction Act of 1980, PL 96-511. Should you have any questions concerning this investigation, we will be pleased to discuss them with you. Sincerely, l
, Chief Reactor Projects Branch
Enclosures:
- 1. Appendix A - Notice of Violation
- 2. Appendix B - Cover Page and Synopsis for NRC Investigation Report Case Number
/. cc w/ enclosures:
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._ 07 W>
REPORT FORM REPORT APPENDIX A/B/C U.S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50- License /CP: Docket (s): 50 - Category: Licensee: Construction Permit Expiration Date: Facility Name: Inspection At:
-Inspection Conducted:
Inspector (s): -
*NAME/ JOB TITLE /SECTION/BRAFCH Date (pars. _ ')
1 {
*NAME/ JOB TITLE /SECTION/ BRANCH Date (pars. )
Approved:
*NAME/ JOB TITLE /SECTION/ BRANCH Date l
- REFER TO REGIONAL OFFICE NOTICE 2230 FOR REPORTS BEING ISSUED TO TUGCO.
i
MAY 0 71966 ) Inspection Sut:=ar'y _ . . 1 Inspection Conducted (Report 50- ) Areas Inspected: Routine Nonroutine, announced unannounced inspection of , 1 l l l Results: Within the area (s) inspected, no violations or deviations were identified.
***** OR ***** ,
Results: Within the area (s) inspected, violation (s) deviation (s) was/were identified ( , paragraph (s) ). j { We e a I
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04 q -, M0 710% - i' RPB FORM NV (( -
' APPENDIX A NOTICE OF VIOLATION Docket No.:
License No.: Permit: During an NRC inspection. conducted on , (a). violation (s)'of NRC requirements was/were identified. The violatien(s) involved In accordance with the " General Statement of Policy and Procedure for NRC l Enforcement Actions," 10 CFR Part 2. Appendix C (1985), the violation (s). 1
~is/are.. listed below:
l j 1 t I 1 '.3 f Contrary to.the above.- i I 1
)
This is a Severity Level violation. .(Supplement ) ( /86_- ) l- l l ) l 1
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i NhY 0 7 526 i Pursuant to the provisions of 10 CTR 2.201, is hereby i required to submit to this of fice.vithin 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted, (2) the corrective steps which have been taken and the results achieved. (3) the corrective steps which vill be taken to avoid further violations, and l (4) the date.when full compliance vill be achieved. Where good cause is { shown, consideration vill be given to extending the response time. j Dated at this day of 1986
****** OR ******
Pursuant to the provisions of 10 CTR 2.201, is hereby required to submit'to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted, (2) the corrective steps which have been taken and the results achieved, 1 (3) the corrective steps which will be taken to avoid further violations, and
~
(4) the date when full compliance vill be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Where good cause is shown,
; consideration vill be given to extending the response time.
N ( Dated at this day of 1986
NYl'l h$. I RPB FORM ND
~~
, : t] t APPENDIX B NOTICE OF DEVIATION Docket (s): 50-License: Permit: Based on the results of an NRC inspection conducted on
-(a) deviation (s) of your. was/were identified.
The. deviation (s) consisted of . In .
- accordance with the " General Statement of Policy and Procedure for NRC !
Enforcement Actions," 10 CTR Part 2. Appendix C (1985), the. deviation is listed below: 2 (' In deviation from the above, l 2
. 1
( /86 -
)
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l . MAY 0 71986 , J
.g is hereby requested to submit to this office within l 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each deviation: (1) the reason for the deviation if admitted, (2) the corrective steps which have been taken and the'results achieved, (3) the corrective steps which will be taken i to avoid further deviations, and (4) the date when full compliance will be l achieved. Where good cause is shown, consideration will be given to extending ]
the response time. Dated at this day of 1986 I l
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3
j i MAY o 71933 -
- c. ATTACHMENT-3 4-
'o __ RPB FORM LETTER 11 RESPONSE - ADEQUATE In Reply Refer To: l Docket (s): 50- (Refer to RON 2230 for. 50- correspondence issued to TUGCO)-
. ATTN:
Gentlemen: Thank you for your letter (s) of , , in response to our letter (s) and Notice of Violation dated 19_. We have reviewed your reply and find it responsive to the concerns raised in i our Notice of Violation. We will review the implementation of'your corrective
~
actions during a future. inspection to deterinine that full compliance has been achieved and will.be-maintained.
-9 j~~ j Sincerely, i
j
, Chief Reactor Projects Branch cc:
4 1
UNI f 'j yG RPB FORM LETTER 12 [. " RESPONSE - ACCEPTABLE' (Original NV Involved Enf. Conf. 1 In Reply Refer To: , Docket (s): 50- (Refer to RON 2230'for 'I 50- correspondence issued to TUGCO)
]
ATTN: Centlemen: As. discussed with you during the (telephone) enforcement conference, of , , we regard the violation (s) discovered during this inspe:: tion with great concern and indicated that we would review your' response (s) including the actions you propose to improve management controls, to determine if additional enforcement actions are necessary. Thank you for your letter (s) of , , in response to our letter (s) and Notice of Violation (and Proposed Civil Penalty (fes)) dated .
,, Based on our review of your response (s), we have no further questions at this time pn your proposed corrective actions. We will review the implementation of these. actions.during a future inspection to ensure they have been effective in precluding future noncompliance. .
j: [ Sincerely,
, Chief Reactor Projects Branch cc: !
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-I RPB FORM 1.ETTER 13
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RESPONSE - INADEQUATE i I In' Reply Refer'To: l Docket (s): 50- (Refer.to RON 2230 for - I 50- correspondence issued to TUGCO) i ATTN: Gentlemen: Thank you for your letter of . in response to our letter ! and the attached Notice of' Violation dated- . As a result i of our review, we' find that additional information, as discussed with your Mr. (during a telephone call on- ). is needed. Specifically, , 1' Please provide the supplemental information within days of the date of this letter.
?' s
Sincerely, l~
, Chief i Reactor Projects Branch i cc: , l
(. _mm_ - _ _ _ _ _ - - _ _ _ . ___.____.
i MAY 0 7 506 RPB FORM LETTER 14 t RESPONSE - 2ND OR SUBSEQUENT - INADEQUATE 3 l l In Reply Refer To: Docket (s): 50- (Refer to RON 2230 for 50- correspondence issued to TUcco) 3 I ATTN: n. Gentlemen: i Thank you for.your letters, dated , , and I
, in response to our letters, dated ,
, and . We continue to be in need of additional information as discussed with your Mr. (during a telephone j conversation /at'the site) on .
Please provide the supplemental information within -days of the date of this letter.
. Sincerely,
, (' , Chief
~
Reactor Projects Bran:h ce: . l
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I 1
EY 0*< 1906 RPB FORM I.ETTER 15 ( RESPONSE - 2ND OR SUBSEQUENT - ADEOUATE - In Reply Refer To: Docket (s): 50- (Refer to RON 2230 for 50- correspondence issued to TUCCO) ATIN: Gentlemen: Thank you for your letters, dated , , and , in response to our letters, dated ,
, and . We have no further questions at this time and will review your corrective action during a future inspection.
Sincerely, I I
. Chief
, Reactor Projects Branch j cc:
i 1 l
P.l't 0 ? 1Kr, ATTACHMENT 4
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DOCUMENT NAMES ) A. Efeensee Addresses (Code "GET" RPB ADD /CCd(page #) cc bec GSU. 1 2 .I HL6F 3 4 LP&L 5 6 NPPD 7 8 PSC 9 10 TUGC0 11 12 ANO 13 14 KG&E 15 16 OPPD 17 18 TAMU (50-059) 22 23 U of Utah (50-072) 28 -- U of OK (50-112 19 20 TAMU (50-128) 24 25 VA Hospital (50-131) 29 -- U of KS (50-148) 21 --
.. KS State U (50-188) 27 --
U of TX (50-192) 30 -- U of NM (50-252) 31 -- Brigham Young U (50-262) 32 -- . USGS (50-274) 26 -- Idaho State U (50-284) 33 -- l' ( U of Utah (50-407) 34 - U of TX (50-602) 35 -- B. Standard IR Letters RPB Fom Letter 1 (Clear IR Letter) RPB Form Letter 2 (NV IR Letter) RPB Form Letter 3 (Deviation IR Letter) ' RPB Form Letter 4 (NV to Licensee Early; No Report) RPB Form Letter 5 (IR Letter - NV S0nt Earlier) RPB Form Letter 6 (NV & Deviation Letter) ! RPB Form Letter 7 (Escalated Enforcement / Enforcement Conf.) RPB Form Letter 8 (Investigation Rpt - Clear) RPB Form Letter 9 (Investigation Rpt - w/NV Proprietary 1 (Power Reactor - 2.790 paragraph) Proprietary 2 (Research Reactor - 2.790 paragraph) Proprietary 3 .(Use for Material Control and Accountability) Proprietary 4 (Power Reactor Physical Security) RPB Form NV (Outline of Notice of Violation) RPB Form ND (Outline of Notice of Deviation) RPS Form Report (Outline of Report Cover Page) i I l
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.'GY 0 7 Tg5 RPB Tom Letter II (Response - Adequate) l RPB Form Letter 12 (Response - Acceptable [ Orig. NV Involved Enf. Conf])
- . RPB Fom Letter 13 (Response - Inadequate)
RPB Fom Letter 14 (Response - Subsequent Insdequate) RPB Form Letter 15 (Response - Subsequent Adequate) RIDS CODES IE01 - Report /NV Response (50 Dkt) IE02 - Safeguards 2.790(d) Report /NV Response (50 Dkt) IE04 - Safeguards non-2.790 Report /NV Response (50 Dkt) IE06 - Environmental & Radiological - Report /NV Response (50 Dkt) IE35 - Emergency Preparedness Oe v. O e i i I i - _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ - - . . _ l
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- f. . '; NUCLEAR REGULATORY COMMISSION q.- $'
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f ~ REGloN IV
. ! S11 RYAN PLAZA DRIVE. SufTE 1000 5, ,,
*# ARLINGTON. TEXAS 70011 JUN 121996 Regional Office Notice No. 0610 BACKFIT REVIEW PANEL A.
Purpose:
To define a review panel to consider potential items relative to the backfit' rule. B. Discussion: Regional Office Policy Guide 0701, " Plant-Specific Backfit Procedure," defines the procedures to be followed for consideration and processing of
. NRC-imposed changes having a potential for falling under the provisions of the NRC Manual Chapter 0514. "NRC Program for Management of Plant-Specific Backfitting of Nuclear Power Plants," which implements Title 10, Code of Federal Regulations, Part 50.109. The decision to prepare a Regulatory
., Analysis is assigned by RPG 0701 to the appropriate Division Director.
7 .. 5 As an interim aid to the Division Directors, and to assure consistent
' application of the backfit rule within the region, a panel is hereby comissione~d to consider. potential backfit items and to reconsnend to the -
appropriate Division Director the need for a Regulatory. Analysis if judged ( necessary to comply with the above referenced requirements. The panel will be composed of the following or their designated alternate: W. L. Brown, Regional Counsel Chainnan D. A. Powers, Enforcement Officer E. H. Johnson, Division Director, DRSP R. L. Bangart, Division Director, DRSS C. Action:
- 1. The above panel will meet when convened by the chainnan.
- 2. Items to be considered by the panel will be identified by either Division Director assigned to the panel.
- 3. Copies of applicable documentation shall be distributed by the chairman to each panel member in advance of a meeting to consider 1 potential backfit items. I
- 4. Minutes of each panel meeting shall be kept by the chairman to reflect the items considered and the panel recommendations to the appropriate Division Directors.
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ee _ JUN 12 BBS D.
Contact:
Regional Counsel, Ext. 271. I E.- Cancellation bate: This Notice remains in effect until superseded or until its provisions are incorporated into a subsequent revision to RPG 0701. ; i tg. IsTL Robert D. Martin Regional Administrator Distribution List B, 6 i
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[- _ ARLINGTON. TEXAS 79011 DEC 11985 Regional Office Notice No. 1003 EXPEDITED PROCESSING OF ESCALATED ENFORCEMENT MAIL A.
Purpose:
To establish a regional procedure whereby Region IV will provide copies to 1 the Office of Inspection and Enforcement (IE) of all applicant or licensee responses to escalated enforcement mail, which have been received by Region IV but not IE. B. Discussion: l To maximize applicant and licensee understanding of and compliance with
- applicable regulations, license conditions, and legal connitments binding upon them, it is important that NRC's enforcement program be implemented as expeditiously as possible. This is particularly true since corrective measures may be needed to regain compliance and preclude future violations.
In fulfilling that intent, Region IV must ensure that IE receives T applicant and licensee responses to escalated enforcement mail, especially when IE has responsibility for the initial NRC response to the applicant or licensee submittal. This precautionary effort is necessary not only because the external and internal mail distribution systems may fail us but also because the applicant or licensee may neglect to comply with the request given in NRC's letter to provide IE with copies of their response. IE has agreed to institute a reciprocal policy for the Regions. C. Action:
- 1. Each first-line supervisor or person acting in such capacity over a Region IV organizational entity that receives such mail, which is responsive to their area of responsibility, will promptly notify the Enforcement Officer.
l l 2. The Enforcement Officer will in turn promptly contact the appropriate IE reviewer to ascertain IE receipt.
- 3. If IE is unsuccessful in locating the subject mail within a reasonable I time (i.e., 4 working hours), the Region will upon request from IE -
transmit via facsimile or express mail a copy of the subject mail. 1 J l
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j Regional Office Notice No. 1003 - DEC 111985 - i 1 I ( D.
Contact:
Any cements regarding the information in this notice should be referred to the Enforcement Officer. E. Cancellation Date: This notice remains in effect until superseded.
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Regional Administrator Distribution List C . e 0 l
fp" ""k UNITED STATES
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NUCLEAR REGULATORY COMMISSICN REGION IV i sit nyAu ptazA DRIVE. SUITE 1000 ~
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AUG g i 1986 i l l j l Regional Office Notice No. 1106
. FORMAL CORRESPONDENCE WITH ALLEGERS A. Purpose :
To remind the staff of the inte o guidance controlling formal correspondence with allegers. B. Discussion: The revision of Regional Offi:e Policy Guide No.1051, " Procedures for Allegations and Investigation.s," is being deferred pending Headquarters issuance of NRC Manual Chapter 0514 " Management of Allegations." Until
.. such time as Regional Office Policy Guide No. 1051 is revised, the staff is encouraged to closely reardinate with the Allegations Coordinator (AC) prior to contacting allegers. Also, the signature authority on all fernal correspondence to allegers has been delegated to the AC. In the event that a particular situation arises where it is more appropriate for another 9 staff member to sign a letter to an allager, then the outgoing letter should be routed to the AC for concurrence and coordination with the Regional Administrator.
C. Action: The staff should coordinate with the AC prior to making any contacts with allegers. All individuals who directly receive mail from allegers shall provide such mail to the AC for inclusion into the official allegation files. Any official response to such mail will be the responsibility of the AC. D.
Contact:
Suggestions or cenaments should be directed to the Enforcement Officer, ext. 195. E. Cancellation Date: This Notice remains in effect until superseded by Revision 1 to Regional Office Policy Guide No. 1031. ,, Af I ~ ( \ I sobert D. Martin I l Regional Adafnistrator Distribution List C i
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_. ARLINGTON. TENAS 76011 JN - 7 M87 ! Regional Office Notice No. 3200(5) REGIONAL 0FFICE POLICY GUIDE TABLE OF CONTENTS , A '.
Purpose:
Topro$u~igatetheTableofContentsforRegionalOfficePolicyGuides , presently in effect. '~
) v.
B. Discussion: / e j i The attachment is the' updated list of the subject guides. C. Action: ,
~~
- Insert the attached listing in the front of your Regional' Office Policy Guide book. Please review those guides' originated by your respective offices. '
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D.
Contact:
'0, Any questions c" requests for copies should be directed to Connie Spagnoli (ext. 290). I E. Cancellation Date: ' This Notice remains in effect until superseded. J j -{ 'l Ro'bert D. Martin Regional Administrator i
Attachment:
As stated Distribution List C
- NOTE: Please make the following pen-and-ink change: PG No. 2701 changes to PG No. 2304.
? NOTE: Flease remove PG No. 0214 entitled " Collect Telephone Calls" from yotr I Policy Guide files. This guide has Been cancelled.
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*(The Policy Guide entitled " Action Request Tracking System (ARTS) ;
Procedures ('PG No. 0214) is to remain in your files.) 1 _z_._____________ _ _ _ _ _ _ _ _ _ _ . _
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,w JAN -T 1987
_ J { REGION iV POLICY GUIDES __ TABLE OF CONTENTS i i POLICY GUIDE TITLE DATE ISSUED DISTRIBUTION 0100
'0 ORGANIZATION (GENERAL) 0100, R'ev. 2 Region IV Delegations 0102, Rev. 1 08/05/85 C
-Communications Regarding Items of Immediate Interest 07/29/85 0103, Rev. O Designation of Lead- E Responsibility for Resolution of Lisensee-Related Technical Issues and Incidents 04/29/85 0104, Rev. O Inspection Program for Nonpower B
Reactors 06/21/85 AB
.0200' ADMINISTRATIVE SERVICES.(GENERAL) 0200, Rev. 3 System of Policy Guides and' Notices- 03/27/86 0200(2),Rev.O' Division of Resource Management:
C and Administration Report Status TrackingSystem(RSTS) 12/05/84
,. 0201, Rev. 0' System of RIV Calendar. AB 0202, Rev. 1 10/07/85 C
' Daily Reports - Preparation and Transmission 02/21/85 0203, Rev. 3. Freedom of Information and AB Privacy Act 06/30/86 0204, Rev. 1 C
' Conference Room and Special Equipment Reservations-
'0205, Rev. O 05/22/86 C Response to Private Litigants and State Agencier Seeking Testimony 03/25/83 0206, Rev. O Completeness of Official Files B 0207, Rev. O 01/28/85 AB Facsimile Service Requests 02/15/85 0208, Rev. O Incoming Mail Processing Procedures AB 0209, Rev. O 03/06/85 AB-Action Item Tracking System Procedures (AITS) 03/25/85 C.
0210, Rei. O Policy an the Distribution of Draft Inspection and Investigation Reports 10/21/83 8 0211, Rev. O Policy on Control of NRC Reports and Other Documents and O! Referrals 05/06/85 0213, Rev. O File Room Check-Out Policy C
.0214, Rev. O 09/04/85 C Action Request Tracking System (ARTS) Procedures 12/23/85 C
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. JAN -T 1987
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. TABLE OF CONTENTS . POLICY GUIDE TITLE DATE ISSUED DISTRIBUTION 0216, Rev. 0 Notification of Employees Concerning Inclement Weather -
and Emergency Situations 12/16/85 C 0217, Rev. O Microcomputer Usage 0218, Rev. 0 03/12/86 C Office Services 01/16/86 0219, Rev 0 10 CFR 50.54(p) NMSS Safeguards C Licensing Activities 05/01/86 C 0220, Rev. 1 Meaning of Concurrence 0221, Rev. O 12/29/86 C Postal Services Express Mail Procedures 08/31/82 AB 0222, Rev. O Copying, Supply Requisitioning, and Facsimile Machine Services 08/30/82 AB 0223, Rev. O Supply Services 0226, Rev. O 05/05/86 C Preparation of Backgrofund Papers for Commission Visits to Region IV Sites 12/09/86 - C 0231, Rev. O Documentation of PDR Docket
.' Material 08/11/82 AB 0232, Rev. O Marking of Documents Exempt from Public Inspection 08/11/82 AB 0241, Rev. 3 Use of Government Vehicles 07/29/83 AB 0300 PERSONNEL (GENERAL) 0320, Rev. O Time and Attendance 0321, Rev. O 03/30/84 A Leave Administration 03/30/84 AB 0322, Rev. O Compensation for Approved Overtime 03/30/84 AB 0334, Rev. I NRC Inspector Objectivity 08/25/86 C 0400 TRAINING AND EMPLOYEE DEVELOPMENT (GENERAL) 0400, Rev. 0 Training 04/02/84 AB 0401, Rev. O RIV Radiological Training Program 01/25/85 AB 0402, Rev. 2 Region IV In-House Training Program 10/22/86 C 0403, Rev. O Resident Inspector Cross-Training 03/19/86 B 0450, Rev. 1 The Qualification Journal and Inspector Certification 03/21/86 C J
0500 RESOURCE MANAGEMENT (GENERAL) l 0501, Rev. 0- The Requisition Process 07/16/85 C 0502, Rev. O Transportation and Motor Vehicles 07/30/85 C 0503, Rev. 1 New City Pairs Airline Contracts 12/30/85 C i 0504, Rev. 1 Request for Travel / Advance and Inspection Plans ) 05/28/86 C 1
m ..; x.gu.;;. . . .. . ..- ,. --. . - - -- s i JAN -T 1987 i t ' TABLE OF CONTENTS - POLICY GUIDE TITLE DATE ISSUED DISTRIBUTION 0600 PROJECT AND RESIDENT PROGRAMS (GENERAL) 0601, Rev. O Duties and Responsibilities of the Project Inspector 09/09/85 0602, Rev. 0 . Systematic Assessment of Licensee 8 Performance (SALP): Preparation and Transmission 05/17/85 0503, Rev. O Communication of ' Generic._ C Requirements to Reactor Licensees 12/07/82 0604, Rev. 1 Transmittal of Vondor Inspection AB j Reports to RIV Licensees 04/19/84 0606, Rev. O NRC RIV Technical Review Program AB for Houston Lighting & Power Company vs B&R Litigation Record Review 11/01/85 0607, Rev. 1 8 ! Operating Reactor Inspection ProcedureAssignments(DRSP)
." 0608, Rev. O 0610, Rev. O NRC Use of INPO Evaluation Reports 08/01/86 05/12/86 B
C Handling of 10 CFR 21 Reports 12/18/86 0611, Rev. O Handling of IE Bulletins, IE B Information Notices, and Generic Letters for Reactor Facilities 12/18/86 8 0630 Rev. O Division of Vendor and Technical Programc Inspection Report Tracking System 12/15/83 AB 0700 ENGINEERING AND OPERATIONAL PROGRAMS (GENERAL) ! 0701, Rev. 2 Plant-Specific Backfit Procedure 11/26/86 B
' NOTE: ROM 3204 transmitted pen-and-ink changes to PG 0701, Rev. 1.
0702, Rev. O Power Reactor Inspection Resource Review 09/19/85 C 0800 EMERGENCY PREPAREDNESS AND MATERIALS SAFETY PROGRAMS (GEN 0800, Rev. O Copying of Materials Docket Files for Inspection Purposes 12/10/85 AB 0801, Rev. O RIV Radiation Protection Program 0802, Rev. O 08/03/82 8 Dissemination of Infomation to NRC Fuel Facility and Material Licensee Applicants 08/03/82 8 0803,'Rev. O Personnel Dosimetry Program 0804, Rev. O 02/13/85 AB Licensee Emergency Plans and Implementing Procedures 02/10/86 C 0900 SAFEGUARDS (GENERAL) t
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_ JAN - 71987 - ( - l l TABLE OF CONTENTS -4.
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I POLICY GUIDE TITLE DATE ISSUED DISTRIBUTION' 1000 i ENFORCEMENT (GENERAL)
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1000, Rev. O ! Timeliness of Escalated 1001, Rev. 1 Enforcement Actions 04/18/85 AB Handling of Confirmatory Action Letters 12/04/85 1002, Rev. 2 C Enforcement Conferences 12/22/86 1003, Rev. O Typing of Escalated Enforcement AB Packages l 1004, Rev. C Pending Codification of 11/27/85 C Enforcement Policy 01/15/86 1005, Rev. O AB Documentation of Similar or 1006, Rev. O Records-Retrieval Violations 08/25/86 AB Deviations 10/20/86 1051, Rev. O Procedures for Allegations and AB Investigations 03/25/83
. AB
.D 1100 INVESTIGATIONS (GENERAL) 1101, Rev. O Confidentiality Procedures for 1
j Allegers 07/17/85 1102, Re'. v O Concurrence on Allegation Material C 12/23/85 C 1200 SECURITY (GENERAL) 1200, Rev.-0 Physical Security for Parkway Central Building 10/29/84 AB 1300 INFORMATION DATA PROCESSING SYSTEMS - COMPUTER SYST 1300(3),Rev.1 Staff Procedures for Handling RITS Forms 01/21/85 1301, Rev. 3 AB Inspection and Enforcement Regulatory Information Tracking System (RITS) Codes and j Definitions 09/30/86 1302, Rev. 1 Nuclear Materials Safety and B Safeguards (NMSS) Regulatory Limited Information Tracking System NMSS &
- 1303, Rev. 1 (RITS)CodesandDefinitions 03/18/85 URF0 Implementation of Open Item Tracking System for Resident Sites and Regional Office 09/04/86 C 1304, Rev. 1 Validity Check nf Information j
Entered into the Regulatory 1 Information Tracking System (RITS) 03/19/85 AB l l
J4N - 71987 TABLE-0F CONTENTS 1 l POLICY GUIDE TITLE DATE ISSUED 13C5, Rev. O DISTRIBUTION NuclearReactorRegulation(NRR) 1306, Rev. O RITS Codes and Definitions 03/18/85 \ General Activity RITS Codes and B ' Definitions 03/13/85 AB 1400 l TECHNICAL AUDITS AND APPRAISALS (GENERAL) 1500 EMERGENCIES, INCIDENTS, AND ACCIDENTS (GENERAL) 1520, Rev. O Responsible Onsite NRC Representative - Unplanned Events 08/20/82 B i 1600
~~ STATE AND AGENCY RELATIONS (GENERAL) 1602, Rev. 1 Heetings between Resident inspectors and Local Officials 04/16/85 C 1700
- i. PUBLIC AFFAIRS (GENERAL) 1700, Rev. O NRC Public Affairs Policy 08/25/86 C 1800 CONOUCT OF EMPLOYEES (GENERAL) 1801, Rev. O COI Policy Regarding Assignment of Inspectors 1802, Rev. O 01/24/85 8 Acceptance of Illegally Obtained Material k 1803, Rev. O 10/07/B5 B Acceptance by NRC of' Commercial i Discounts !
02/13/86 C 1900 COMMUNICATIONS (GENERAL) 1901, Rev. 0 1902, Rev. O Documentation of Meetings Staff Meetings 02/28/85 AB 1910, Rev. 3 07/09/85 1951, Rev. O Preliminary Notifications (PNs) 09/03/86 C Telephone and Visitor Reception C Procedures 09/12/82 AB 2000
' DUTY OFFICEP.S (GENERAL) 2010, Rev. 1 Responsibilities of Regional Outy Officer 05/7/84 B i
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TABLE OF CONTENTS _ POLICY GUIDE TITLE
., DATE ISSUED DISTRIBUTION p100 PERSONNEL AND 0FFICE SAFETY (GENERAL) 2100, Rev. O Criteria for Designation of Personnel for Respiratory Medical Examinations 03/25/85 C 2101, Rev. O Respiratory Protection Program and Bioassay 08/25/86 C 2111, Rev. O Region IV Occupational Safety ' - - ~
(Note: Includes and Health Program corrections pro- 07/12/82 AB mulgated in Rev. 1 dtd 11/20/82.) 2120, Rev. 1 Region IV Occupant Emergency Plan 12/15/83 AB 2200 INSPECTIONS (GENERAL)
."- 2200(3), Rev. O Communications Regarding Inspections 12/21/84 AB 2201, Rev. O Disposition of Inspection findings 08/29/86 C 2205, Rev. O Supervisory Accompaniment of Staff 2230, Rev. 5 08/26/85 C Reactor Inspection Reports and Associated Correspondence Issued to Reactor Licensees 04/22/86 C 2231, Rev. 3 Standardized Report Letters for RIV' Licensees 05/07/86 C 2235, Rev. O Materials and fuel Cycle Inspection Reports and Associated Correspondence 09/20/83 AB 2236, Rev. O Standardized Reports and Correspondence for Naterial and Fuel Cycle Licensees 09/20/83 AB 2300 REGIONAL COUNSEL (GENERAL) 2300, Rev. O Participation in Privately-Sponsored Seminars or Conferences for Compensation 12/18/85 B 2301, Rev. O Requests for Testimony or Documents from NRC Employees 12/18/85 C 2302, Rev. O Licensee Pledges of Confidentiality and NRC Authority to Obtain Information 12/27/85 8 2303, Rev. 0 00E/NRC Relationships 08/12/86 C 2304, Rev. O Hearing Board Notification Procedure 12/09/86 C
i JAN : 71927
. TABLE OF CONTENTS -
' POLICY GUIDE TITLE DATE ISSUED DISTRIBUTION 2400 REACTOR LICENSING (GENERAL) 2401, Rev. O Handling of Operating Reactor Licensing Actions Within RIV 12/24/85 C 2500 MATERIALS LICENSING (GENERAL) 2600 OPERATOR LICENSING (GENERAL) 2700 0FFICE OF THE REGIONAL ADMINISTRATOR (GENERAL) 2000 DIVISION OF' RESOURCE MANAGEMENT AND ADMINISTRATIO 2900 DIVISION OF REACTOR SAFETY JAND PRO'ECTS (GENERAL) 3000 1 DIVISION OF RADIATION SAFETY AND SAFEGUARDS (GENERAL 3100 URANIUM RECOVERY FIELD OFFICE (GENERAL) 3200 POLICY GUIDE CHANGES (NOTE: The 3200 series will transmit changes to the Regional Office Notices, Policy Guides, and Table of Contents.)
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l 0 * % UNITED STAVES [j.. ' NUCLEAR REGULATORY COMMISSION - k
. 7 REGION IV f, . #' *
[8 611 RYAN PLAZA ORIVE SUITE 10t 1 -
%, , ARLINGTON. TEXAS 76011 t'
JAN -71987
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1 I 1 1 Reaional Office Notice No. 3201(7) REGIONAL OFFICE NOTICE TABLE OF CONTENTS A.
Purpose:
To promulgate the Table of Contents for Regional Office Notices presently in effect. l B. Discussion: I l- The attachment is the updated list of the subject notices. C. Action: Insert the attached listing in the front of your Regional Office Notice . book. Please review those notices originated by your respective offices. l l O.
Contact:
1 l Any questions or requests for copies should be directed to Connie Spagnoli (ext. 290). E. Cancellation Date: This Notice remains in effect until superseded. 1 ' L
. Robert D. Martin Regional Administrator
Attachment:
As stated-Distribution List C l 4
, , m.. ... ........... .. - l REGIONAL OFFICE' NOTICES n JAN -71987 TABLE OF CONTEf:TS I:,
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0FFICE
.DATE CANCELLATION-NOTICE TITLE -
ISSUED DISTRIBUTION DATE 0121 Region IV Organization Chart - 1986 06/20/86 C Until-superseded 0200- Priority Telephone Res tora tion 12/31/84 i AB Until superseded
.0215 Initiatives to Improve the File Room 07/15/85 C Until superseded 0222(1) List of Contacts 09/04/86 C Until superseded 0224 Telephone Number Changes 03/18/86 C 03/18/87 0231 -Personal Mail 12/18/86 C Until superseded by forthcoming PG
_~ 0232 Missing Property 12/29/86 C 03/01/87 0306 Illegal Acts Committed g Against Region IV Employees 03/11/85 AB Until superseded j 9 0326 Solicit Nominations for the Congressional Fellowship Program 10/07/85 C Until superseded 0331 Personnel Action 10/30/85 C Until superseded l 0332 Organization / Personnel 4 Changes (Administrative . ManagementBranch) 10/30/85 C Until superseded 1 0335 Regional Training Officer 12/09/85 C Until superseded 0336 Awards Ceremony 12/04/85 C Until superseded I 0343_ Suggested Topics for Regional Administrator Meetings with Staff 03/12/86 C Until superseded 0350 Regional Property Custodian 07/21/86 C Until superseded 0824 Replacement of EE0 10/02/85 C Until superseded 0427(3) Training Comittee g Membership 07/10/86 C Until superseded __.-_--.--.-_--_a
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A -7 1987 !
]ABLEOFCONTENTS- _
(of 3 pages) 0FFICE DATE NOTICE TITLE CANCELLATION
} -
ISSUED DISTRIBUTION DATE . _ .
- i 0433(9)- Regional Training Calendar 12/04/86 C Until superseded 0439 Information on Academic Curricula 07/24/86 C Until superseded 0505 1 ravel Advances - Trip-By- ,
Trip Settlement and Debt
. Collection Procedures 01/28/86 C Until superseded 0507 Revised Federal Travel Regulations 06/06/86 i C Until superseded '
0508 . Travel Cost Comparison 06/11/86 C Until superseded 0509 Transportation Requests (TR's) 06/11/86 C Until superseded 0510 Damage Claims to Rental Cars 07/15/86 C Until superseded
~ 0511 Official Travel Lodging and Meals and Incidental Expense (M&IE) Rates 07/24/86 C Until superseded i 0514 Trave-Related Items 09/19/86 C Until superseded l- 0517 Transportation Requests 12/19/85 C 01/30/87 i
0602(8) SALP Schedule for Region IV (1986-1987) 08/18/86 C 06/30/87 0622 South Texas Project SALP Schedule 11/05/86 C 04/03/87 l 0623 SALP for Arkansas Nuclear One 12/17/86 C 03/01/87 0624 Temporary Special Assignments 01/06/87 C Until superseded 0708
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Agenda for Regional ' Meeting of Resident Inspectors 10/06/86 C Until superseded l 0709 Attendance Requirements - October Resident l -- Inspectors' Neeting 10/08/86 l C Until superseded 0809(1) Region IV 1986 Exercise Participation 12/17/86 C 12/01/87
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~ TABLE OF CONTENTS (of 3 Paggs)
F OFFICE DATE NOTICE TITLE CANCELLATION ISSUED DISTRIBUTION DATE-E 0810(3) Region'.lv Duty Officer 12/12/86 AB 02/17/87 0811 Use.of the Emergency Communications Networks During Exercises and Emergencies 11/18/86 B Until superseded 1003 Expedited Processing of
- Escalated Enforcernent Mail 12/11/85 C Until superseded 1106 Formal Correspondence with A11egers 08/21/86 C Until superseded by RPG1051, Rev. I 1301 FY 1087 NMSS and NRR RITS Codes 09/29/86 B Ur. il superseded 1605(3)- Directory of State Officials 11/24/86 Special 03/31/87 i 1803(2) Information Regarding Conflicts of Interest 08/07/86 C Until superseded
(~ 3001 Division Representative for Freedom of Information Act 08/24/86 E Until superseded 3101 Short-Term Realignment of Duties, URFO' 04/24/86 G Until superseded 3103 Alarm Installation, URF0 04/22/86 G Until superseded 3200(5) Policy Guide Table of Contents 01/07/87 C Until superseded 3201(7) Regional Office Notice Table of Contents 01/07/87 C Until superseded l l 1 ! 1 i 5 _ _ - - _ _ . _ . _ - _ _ _ - - -}}