ML20127C124

Forwards Proposed NRC Manual Chapter 0517, Mgt of Allegations, as Policy in Mgt of Allegations

ML20127C124
Person / Time
Issue date:	09/19/1984
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
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ML20126E047	List: ML20126E044 ML20127B201 ML20127C124
References
FOIA-85-82 NUDOCS 8410020575
Download: ML20127C124 (29)

Text

., , ..

0 September 19, 1984 MEMORANDUM FOR: Office Directors

! Regional Administrators l FROM: William J. Dircks

Executive Director for Operations l

SUBJECT:

PROPOSED NRC MANUAL CHAPTER 0517. " MANAGEMENT OF ALLEGATIONS" The attached proposed Manual Chapter is provided to you as policy in regard to management of allegations.

Since the Comission may shortly address the issues of confidentiality and last minute allegations separately, and their decisions may require some changes as a matter of administrative convenience, the manual chapter will not be published until these points have been addressed. In the meantime

,g the attachment will serve as policy on this matter.

(Signed)W[l' lam J.Dircks ,

William J. Dircks Executive tirector for Operations

Attachment:

As stated f

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! U.S. NUCLEAR REGULATORY C0001ISSION NRC MANUAL Volume: 0000 General Administration Part : 0500 Health and Safety IE CHAPTER 0517 MANAGEMENT OF ALLEGATIONS 0517-01 COVERAGE This chapter and its appendices define the policy and procedures for the proper receipt, processing, control, and disposition of allegations received by .NRC offices that concern NRC-regulated activities conducted by NRC licensees and their contractors and the policy and procedures for dealing with individuals who provide infomation to the NRC.

4 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: .

a. allegations are properly assigned for processing and assessed for safety significance to pemit 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 l

l basis; allegations not resolved by other formal

c. all means are processed in accordan.ce 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, l appropriate and possible, and notified of the resolution.

023 To assure that issues raised are promptly and adequately investi-gated.

[

l Approved:

s.,

,. NRC-0517-03 MANAGEMENT OF ALLEGATIONS 0517-03 RE'iPONSIBILITIES AND AllTHORITIES 031 Executive Director for Operations (ED0)

• Set policy and procedures for the receipt, processing, control, and disposition of allegations and establish policy for the treatment and confidentiality of those who provide information to the NRC. For those matters within the purview of 01 and CIA, only set policy and procedures governing their interfaces with other Offices and Regions.

032 All Office Directors / Regional Administrators

a. Establish internal procedures so that all employees are aware of requirements for receipt, processing, control, and disposition of allegations and for the accurate and timely updating of the status of those allegations for which their office is the Action Office.

(

C

b. Appoint an Office Allegation Coordinator (0AC) who serves as

'

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

.h

1. Ensure that the appropriate parts of the Allegation Data Form (NRC Form 307. Exhibit 1) are completed for all allega- .

tions received within the Office .or Region and that the j requested data are accurate and timely, l

l 2. Determine the appropriate Action Office and, if applicable, I

coordinate with the OAC of the affected Office or Region on each allegation received.

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

4. Forward the Allegation Data Form to the respective Action Office OAC when the Office or Region is not the Action Office.

5. Forward the completed Allegation Data Form to the NRR 0AC (and a copy to the Office of Nuclear Materials Safety and Safe- -

. - . guards (IMSS) 0AC, if appropriate] within 10 working days of receipt of an allegation when the Office is the Action Office.

i -

(For power reactors, during the period from 30 days prior to the construction completion date until the Commission meeting L

4 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 j

the identification of the Action Office in addition to com-j pleting the Allegation Data Form.)

L Approved: 2 R

)

)

MANAGEMENT OF ALLEGATIONS NRC 0517-032b6

6. Acquire input data on _new allegations (including those  ;

referred to 0I) from the staff within the Office or Region 1 and a timely ensure thisfor manner information placement is fomarded into the AMS.to the NRR 0AC in )

7. l Provide updates (using an AMS printout) on previous allega-tions (including those referred to 0I) from the staff within i the Office or Region and ensure this information is fomarded 4

to the NRR 0AC on a monthly basis for placement into the AMS.  !

8. ovide reports as descr'ibed in Appendix 1, Part IX, 4 and

c. Detemine the safety significance and generic implications of those allegations that fall within the programmatic responsibi- i 1

lity of that Office or Region and establish schedules for the  !

processing of allegations with the objective of resolving them i prior to a licensing decision date, if applicable.

d. Review those allegations for which it is the Action Office for potential board notification and recommend such notification to )

g NRR or fMSS.

I e.

Refer all allegations involving wrongdoing, except those involving i NRC employees or NRC contractors, to the Office of Investigations

• and provide technical assistance to 0I for investigating allega-

'tions as requested.

f.

Prior to taking a major action. such as a licensing decision or escalated enforcement, review the status and resolution of 1

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.,

AE0D for operational data, RES for concerns affecting research

activities,etc.)

h. For discrimination complaints received concerning

- possible violation of Section 210(a) of the Energy Reorganization Act, refer the complainant to 00L and promptly notify 00L to ensure

. their awareness of the complaint and to determine DOL's 4

investigative intent. Determination of the need for' en NRC -

i investigation would rest with 01.

033 Director. Office of Investinations Investigate allegations of wrongdoing by other than NRC en- I ployees and NRC contractors. Conduct interface responsibilities j with the Offices and Regions as described herein. I i

! i 5

s 1

3  : Approved: '

. - . - - - . . - - - - - - - - . . - .- ,--.--,,---- , _ _ .- .----.,-a-,---,-- - , - - - - , - - - ,

l . 's,

. . l NRC-0517-034' MANAGEMENT OF ALLEGATIONS  !

. 034 Director Office r,f Inspector and Auditor  !

Investigate allegations of wrongdoing by NRC employees and NRC

contractors. Such allegations do not fall under the purview of this manual chapter and are not entered in the- AMS.

035 Director. Office of Inspection and Enforcement

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

b. Monitor the allocation of resources for this activity by.

the regions.

036 Director, Office of Nuclear Reactor Reculation

a. Propose to the ED0 for approval agency-wide policy and proce-i dures regarding the processing of allegations. For those l allegations . that fall under the purview of 01, propose policy i

and procedures governing their interface with other Offices

y and Regions.

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

notification, if required.

f: c. Evaluate implications of allegations relative to licensing deci-sions and plant safety concerning NRR licensees in co' ordination  ;

with IE and the Region (s),

l . d. Resolve those allegations pertaining to reactor licensing issues  !

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 M.iterial Safety and Safeauards i

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

. b. Evaluate implications of allegations relative to licensing deci-sions concerning 1915S Ifcensees in coordination with IE and the

~

Region (s).

038 Office of Resource Management (RM)

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

in the AMS.

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

I <

j Approved: 4

3 l MANAGEMENT OF ALLEGATIONS NRC 0517-04 0517-04 DEFINITIONS 041 Action Office. The NRC Office or Region that is responsible for reviewing and taking action, as appropriate, to resolve an allega-tion.

l 042 Action Office Contact. The staff member in the Action Office who is assigned the responsibility for resolving an allegation.

043 A11eastion. A declaration, statement, or assertion of impro-priety or inadequacy associated with NRC-regulated activities, the i 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 l regarding activities at a licensee's site. Excluded from this i definition are matters being handled by more femal processes such as 10 CFR 2.206 petitions, hearing boards, appeal boards, l etc. Allegations that my result from these formal processes and are not resolved within these processes shall be subject to treatment under this manual chapter.

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

045 Allecer. An individual or organization who makes allegations. '

The individual or organization may be a concerned pri.vate 4:iti-zen; a public interest group; a licensee, vendor or contractor employee; a representative of a local, State, or Federal agency .

(NRC employees should be aware of procedures for presenting differing i professional opinions NRC Manual Chapter 4125).

046 _ Confidentiality. The term that refers to the protection of data that directly, or otherwise, could identify an alleger by name.

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

l 047 Inquiry. An activity involving minimal effort to detemine the appropriate response to information reported to the NRC. Typi-cally, an inquiry entails the

• use of the telephone or written L correspondence rather than femal interviews or other investi-gative measures; however, formal interviews will be conducted if required. ,

048 Inspection. A routine or special activity that m4y be used to examine and subsequently resolve an allegation.

l 5 Approved:

. 's.

e NRC-0517-049 -

MANAGEMENT OF ALLEGATIONS l

[ 049 Investination. Formal activities normally conducted by the i

Office of Investigations on its own volition, or at. W request of the Commission, EDO, or Regional Administrators, with or without technical assistance. The Office of Investigations is

.the lead Action Office for all investigations involving wrong-doing, excluding wrongdoing by NRC employees and NRC contractors i

l which is handled by OIA.

050 Office Allegation Coordinator (0AC). A designated staff member '

in each Office or Region who serves as the administrative point of contact for that Office or Region regarding the processing of allegations.

051 Receivino Office. The Office or Region that initially receives an allegation.

In some cases, the Action Office and Receiving l

Office will be the same if the allegation falls within the functional responsibility of W Receiving Office.

052 Safety 51onificance. A measure of the importance of an allega-l

'

• tion relative to its potential fapact on the public health and safety.

053 Wronadoino 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. e i

052 Wronodoina. Allegations of wongdoing at NRC-regulated facili-i ties, as opposed to those involving technical issues, fall within l

the purview of the Office of Investigations (allegations of wrongdoing by NRC employees or NRC contractor fall within the purview of DIA and are not entered into the AM.s). The Office or i

Region will enter allegations of wrongdoing into the AMS using information provided by 01 (see Appendix 1, Part IX.2 of this

. manual chapter). OI will investigate allegations involving

wrongdoing and provide ,either a report or a summary of its ,

(

findings to the requesting Office o'r Region.

Allegations

• l

. involv' ng wrongdoing received by a Region will be coordinated by '

i the Region OAC with the 0I Field Office Director in that Region  ;

and those received by Offices at NRC Neadquarters will be coor- '

i dinated with the OI 0AC. <

b I

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

l Approved: 5

MANAGEMENT OF ALLEGATIONS NRC 0517-054

, . l I

054 Confidentiality. The identity of individuals making allegations i

should not be revealed by the NRC unless it is clear that the individual concerned has no objection. A confidentiality agreement (Exhibit 4) should be executed for those allegers who specifically request it, and should be offered for execution to those allegers i

' who by their actions convey the inference that their identity will be protected by the NRC but who are apparently unaware that such an l agreement is available. The offer of a confidentiality agreement i

should be contingent upon an assessment of the usefulness of the information provided, if such a determination can be made in a timely manner. For other individuals, confidentiality need not be provided.

As a general rule, however, the "need to know" principle should be implemented for all allegers. For those allegers with a confidentiality agreement, this means that the identity of the source must be protected by not referring to the name or other identifying infomation in discussions unless absolutely necessary and by expurgating the name and other identifying information from documents before wisseminating these to the staff.

For those allegers without a confidentiality agreement, this means avoidance of unnecessary use of the identity of the source and

-g other identifying information in discussions and in documents. It must be made clear to all concerned if and on what terms the anonymity of a person making an allegation is to be protected. A clear record should be maintained for the files to preclude later ,

misunderstandings.

l The confidentiality agreement may be signed by Office Directors and Regional Administrators only and may be transmitted to the alleger for signature by mail or in person as convenience dictates. If at i any time for any reason confidentiality is breached or jeopardized, .

Office or Regional management should be informed and the person l should be advised, the reason explained and remedial measures 1 taken, if possible, to reduce the impact of disclosure. l Since OI has established policies and practices for the protection of confidentiality for its activities, the above are not necessarily applicable to 01.

055 Respondina to A11eoers. Those who provide allegations to NRC staff must be treated with respect, consideration, and tact. -

Under no circumstances should they be dealt with brusquely or abusively. .When allegations are received in writing, a prompt attempt to make personal contact must ordinarily be made in each case either by a letter, telephone call or even a personal meeting.

Contact should be earnest and professional. The alleger should be promptly advised of the results of followup action and, in instances of unusual delay in providing the results should be advised of the status periodically so that there is a,n awareness that the allegation is not being ignored.

7 Approved:

. _ . _ _ _ _ _ _ _ _ _ . _ . . _ _ _ . _ ~ . - -- - _ _ . - -

l

.. l 2 -

NRC-0517-049 MANAGEMENT OF ALLEGATIONS l 1

056 Screening of Allegations. Allegations should be screened for l l significance to safety and the more serious ones should be addres- l sed first. All allegations should be addressed as.promptly as j resources will allow and as the need is identified. Screening i of allegations should be considered diligently to the point where i some may be dismissed early in the process for logical . reasons  !

(i.e., lack of specificity after reasonable followup, lack of safety significance, etc.) to conserve staff resources. Followup i

on allegations, whether they are general or specific, should focus not only on the specific. allegation but on the overall area of  :

concern, including the potential for generic implications as well ,

as criminal activities. In this regard, note that an allegation  ;

directed toward a non-safety item or activity may, through generic considerations, affect a safety item or activity. ,

l l When a number of allegations point to or reinforce indications l , of a broader problem, prompt action to broaden the scope of the inquiry should then be taken to determine whether or not such is 7 the case. While the safety significance of an allegation is an E important factor in determining .the extent and promptness of staff (

- resources commitment, it should not affect the staff treatment of  !

p the alleger as discussed in section 055, above.

l 057 Timeliness of Resolving Allegations. The Action Office should i resolve all allegations in a manner which is timely under the -

t circumstances and professional in scope and depth. A11egatior.s having relatively high safety significance should be addressed  !

expeditiously. Less significant allegations should be addressed as i priorities and resources permit, but usually within 6 months of i receipt. If it is appropriate, an inspection should be made. A '

plant visit with the person making the allegation should be made

. if necessary and if the individual is willing to make such a visit to find the exact location of a problem. Access issues should be addressed on a case-by-case basis. Travel costs for the individual only can be offered, if necessary, and are borne by the Office or Region extending the offer. Care should be taken to avoid embarrassment or abuse of the individual, e.g., schedule visit on off-shift / weekend, etc.

058 involvement of Licensees or Other Affected Croanization. For I allegations involving a potentially significant and immediate j

~

. 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 l should be advised specifically by letter of the area of concern i . and should be requested to address it, subject to further audit by l NRC, in order to minimize the expenditure of NRC resources. In all .

instances, however, confidentiality must not be breached and the effectiveness of investigations / inspections should not be com-promised, such as by prematurely releasing or appearing to release Approved: 8

. 1 .

. L l

NRC-0517-056

. MANAGEMENT OF ALLEGATIONS ,

1

'. an NRC inspection report (note exceptions discussed below). The a11eger must be informed that this is not handing a matter over to  ;

the affected organization, but that NRC will review and evaluate the actions of the affected organization and perform independent activities as necessary. The affected organization should be .

informed regarding the resolution of the allegation if appropriate

(See Appendix I part VIII).

1 There are two exceptions to the above. The first exception is where the information cannot be released in sufficient detail to 4

be of use to the licensee or vendor without compromising the i identity of the confidential source. In such cases release should normally not be made unless the release is necessary to prevent an imminent threat to the public health and safety. The i

' ED0 shall be consulted in all cases where it appears there is a need to release the identity of a confidential source. The second exception is where a licensee / vendor could compromise an 1

investigation / inspection because of knowledge gained from the i

release of information, especially if wrongdoing is involved, i The Regional Ahinistrator for inspections and the Director of l -

the Office of Investigations for investigations shall decide 4 whether or not to release the information to avoid compromising NRC action. Release of information to a Itcensee/ vendor is

} expected to be the exception for 01 investigations.

l 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-l tion, and that confidentiality be provided at the' worker's request. In addition to expurgating names and other identifying information, protection of confidentiality could also involve

. retyping an alleger's handwritten notice. In the event the potential for wrongdoing is involved 0! should be requested to perform an investigation in which case the licensee would not be informed.

059 "Last Minute" Allegations. When a large number of issues are raised at the same time, as has occurred with several plants as they approach issuance of an OL, the difficulties in executing the above policy guidelines are compounded. Consideration should be given to organizing a task force, comprised of both headquarters and regional personnel with a senior NRC manager as the task force

.. .. ./ leader, to resolve these issues within the usual short time frame between the date the issues were identified and ,the proposed date for issuance of an OL. A high degree of organization in the initial stages will be required in order to deal with these particular situations. To conserve NRC resources in resolving these large numbers of issues, the involvement by the licensee except as noted above will be appropriate. It og also be quite appropriate to categorize the large number of issues into two e

9 Approved:

?* 1. _

. r .

MANAGEMENT OF ALLEGATIONS

- NRC 0517-058 general groups, one group in which the issues are judged to be i significant and therefore require resolution prior to 0L issuance,  ;

and a second group in which the issues are of lesser importance i permitting resolution over a longer time frame, even subsequent to-OL issuance. Within the former group, subdivisions may be l appropriate consistent with the planned stages of licensing for the facility (i.e., criticality, 5% power, full power).

060 Appendix 1. This a provides control, processing, ppendix procedures for receipt, and disposition of allegations assigned to NRC Offices or Regions and the procedures and guidelines used to record the receipt, status, and disposition of allegations in the AMS.

.1 END

.i t

I l

1

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l l

i Approved: 10

MANAGEMENT OF ALLEGATIONS APPEN0!X 1. NRC 05U PROCEDURES FOR SCREENING, ASSESSING, AND CONTROLLING ALLEGATIONS AND FOR ALLEGATION MANAGEMENT SYSTEM (AMS)

Part I: General

' This part[ establishes procedural guidance for screening, assessing, and controlling allegations that come to the attention of the NRC staff. These i

functions are to be established within each Region and Office under the control of an individual Office Allegation Coordinator (0AC), or a panel of staff personnel or other appropriate staff technical persons. The Regions and Offices will establish procedures consistent with this guidance and where appropriate provide the required training to ensure that their staffs l are fully informed regarding the proper management of allegations.

Allegations pertaining to NRC-licensed facilities and activities may come j

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

fossionally, promptly, and with consistent treatment.

I 4 It is very important to note that where safety is involved, the NRC does

! not recognize the term "off-the-record." Allegers who wish to provide off-the-record information must be clearly advised that information impor- -

tant to safety cannot be treated off the record, but that the information will be accepted officially and acted upon as necessary. The name of the alleger and other identifying information will be protected, however, under the confidentiality guidelines presented herein. -

Any employee who receives an allegation must be aware that it is essential

, to protect the identity of the alleger if such anonymity is requested or

' implied by his/her actions (i.e., an alleger who employs circuitous means to contact the NRC or makes several phone calls anonymously and then subse-quently identifies himself as the one who has been making the anonymous i calls). To this end, coordination with the appropriate Office or Region j

Allegation Coordinator must comply with the confidentiality guidelines ,

l discussed separately (Basic Requirement 054). If necessary, the identity of an alleger may be revealed, but only if a confidentiality agreement has f i

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. l NRC employees, particularly resident and regional inspectors, regional supervisors, and 0ACs .who are expected to receive the majority of allega-tions, should become fully familiar with the prescribed policies and proce-dures to ensure that the required actions are performed.

l It is the responsibility of all employees who receive allegations to take  ;

i whatever steps are necessary to ensure that an appropriate OAC is promptly i informed. Whenever possible, the person making the allegation should be l referred to either the OAC, other individuals as designated by the Region or l Office, or arrangements should be made for the OAC or designated staff member l to recontact the individual.

Al-1 Approved:

NRC 0517. APPENDIX 1 ,

MANAGEMENT OF ALLEGATIONS Part II: The Office Allegation Coordinator (OAC)

]

1. The initial responsibility of the OAC is to identify the proper Action

' Office to which the allegation should be assigned for evaluation and ,

resolution in coordination with other 0AC's (either in the Offices or Regions).

2. The OAC serves as a focal point for achsinistrative processing and con-  !

trol of all allegations assigned to the Regions and Offices. The OAC is responsible for tracking allegations from initial receipt to final resolution. The OAC assures establishment and maintenance of files l that clearly identify allegations assigned to the Region or Office i

and documents actions initiated to resolve such matters. The OAC i ensures that management and cognizant staff are informed of allega-tions under their purview, kept current on the status of such alle-gations by providing accurate and timely information to the AMS, and briefed on the proposed final resolution of allegations. The OAC also j ensures that the final resolution is properly documented.

l *

. 3. The OAC assists technical staff members who are reviewing allegation information, primarily in the form of coordinating activities neces-l f. sary to resolve issues. In addition, the OAC may assist in the i formulation of a course of action to resolve issues. l l 4. A panel, which includes the OAC as a meeber, may be designated with ' '

i the primary responsibility to ensure that all allegations are promptly assigned and properly evaluated, and that the actions taken to resolve i

the allegation, as well as the resolution, are properly doc,umented and transmitted to the alleger and the affected organization as appro-

priate.

I

5. The OAC will serve as the point of contact with DOL on matters involving discrimination under Section 210(a) of the Energy i

Reorganization Act and will coordinate as necessary with 01 and the Enforcement Staffs. ,

Part III: Receipt of an A11eastion

1. Allegations Received by Telephone or Personal 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 en NRC Office, the individual should be referred to the OAC or other technical staff c member. Technical employees, when unable to refer the telephone call

[ or the visitor as described, shall obtain as much information as

[

possible from the individual (see item 3, below). When unable to locate the OAC or other technical staff member, administrative en-ployees should refer an individual to a technical staff supervisor.

Approved: Al-2

MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517

2. Allegations Received by Mail Personnel responsible for distribution of mail will femard cor-i respondence that appears to contain an allegation to the OAC. Both letters and envelopes will be forwarded and no copies will be made.

! An employee who receives direct correspondence, including internal NRC semoranda, that contains allegations shall forward the correspondence to the OAC. All personnel who say come into possession of this type i

i of correspondence taining confidentialalso should be made aware that correspondence con-

! source information should be transmitted in a sealed envelope marked "To Se Opened by Addressee Only;" for expedited (e.g.,

transmittals electronically), confidential source information j should be deleted from correspondence.

3. Discussions with Allecer I 1

Any item 1 employee receiving a telephone call or visit, as discussed in  ;

shall attempt to obtain as such information as possible from i the individual. It is crucial to identify: ,

i  !

I . a. full name  !

l b. complete mailing address l I c.  !

I telephone number where the individual av be contacted

d. position or relationship to facility or activity involved  !

e. nature of allegation j j

If the alleger declines to provide the above information, attempt to i

! establish the reason (s) using the following guidance: l l

1 Inform the individual that if so requested, his/her identity will be kept confidential.

)

Explain further, if necessary, that Public Law '95-601 affords protection to the alleger by prohibiting an emplo/er from discriminating against an employee for contacting the NRC. Basic  ;

Requirement 054 provides further information' regarding protection of

! confidentiality. j i i The alleger may be informed that the NRC employee with whom he/she is in contact does not have the capability to evaluate the information, {

to determine folloc up action or to establish NRC jurisdiction; j therefore, it my be necessary ,that someone else contact the alleger j for additional information.

t 1

. The alleger should be informed also. that--unless an objection is' -

! registered--he/she the allegation. This will be recontacted as soon as possible regarding '

may be done by telephone, personal visit, or by

a letter to the alleger, at an address designated, which will also

' acknowledge the receipt of the allegation. This process will permit  :

the alleger to review the information with the NRC to provide maximum j

assurance that the information has been correctly interpreted and j .

understood. i i i I

i  !

Al-3 Approved:

' i NRC 0517. APPENDIX 1 MANAGEMENT OF ALLEGATIONS If the alleger persists in not offering identification after the above ,

explanations, document the allegation in as much detail as.possible and '

advise the alleger that he/she may contact the OAC or designated staff member in 30 days or any other agreed upon period, for information on the status of any actions being taken on the information supplied. l l For allecations of discriaination that fall under Section 210(a) of the Energy Reorganization Act, inform the allegers that NRC will look l

into the complaint and any safety concerns identified by the alleger, and that appropriate enforcement actions will be taken against the j employer if the allegation is substantiated. To assure personal employee rights are protected, advise the alleger that the complaint i

' must be filed with DOL within 30 days of the occurrence of the I

discriminat'on event.

Part IV: Action by the Receivino Employee and

the Office Allegation Coordinator (OAC) i

1. When an allegation concerning a NRC-regulated activity is received, the

employee receiving the allegation will provide the information obtained to the Receiving Office OAC who will' complete an NRC Fors 307, Alle-l 7

gation Data Form. The Action Office is then identified and the

! completed form is forwarded to the Action Office OAC. Until ct%ct j input / update capability is provided to the Regions and Offices, a copy j

of the completed form will be forwarded to the NRR 0AC, and one copy to -

l the MSS 0AC, if appropriate for the issue. NRC Form 307 serves as l , notification to MSS and NRR that an allegation has been received that

! may affect their licensing activity; NRR will enter the pertinent information in the AMS in accordance with these procedures. All allegations must be entered into the AMS. In this way an " audit trail" will be established so that NRC actions can be properly monitored and

. completed.

]

1 2. The Action Office OAC or other designated staff member will ensure

' that the alleger is properly contacted to acknowledge receipt of the i

allegation and to confirm the specifics of the allegation. Depending 1

on the nature of an allegation, the OAC will provide copies of the allegation documentation and the letter sent to the alleger (with the j 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 or to the cognizant 0I Field Office for information. When responsibility for the handling of an allegation is transferred from one organizational unit to another, the alleger should be notified of the new point of contact (name and telephone numbers' by the individual who is relieved as contact in order to assure continuity. A single point of contact should be the rule.

The OAC will follow up on the allegation with the cognizant technical staff supervisor at periodic intervals until the matter has been

• satisfactorily resolved. When the case is closed, ari update should be made to that affeet in the AMS.

Approved: Al-4

j .

. . [

t .- IIANAGEMENT OF ALLEGATIONS APPEN0!X 1. NRC 0517 L

I 3. The OAC will coordinate allegation information with the technical i

staff and may assist in determining whether the infoimati,on is suffi- i i cient to identify the issues. If the information is determined to be

i. insufficient, the OAC or designated staff member will assist in l i

further contact with the alleger. A single point of contact with an t l

alleger provides a means of better controlling communications, aids in developing rapport, establishes continuity in the flow of information between the Regions and other NRC Offices, and aids in protection of

the alleger's identity.

4

4. The OAC assists the cognizant technical staff in identifying and i separating the issues involved in an allegation into one of the follow-  !

ing categories:

4

(

! a. Allegations that involve purely technical matters, such as- i l inadequacies in procedures, qualifications, or training; inade-  !

, quate taplementation of or inadequate corrective  !

l actions; or overexposure (s) to procedures; radiation. I

(

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

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

ments; discrimination under Section 210(a) of the Energy

.A Reorganization Act; or other improper conduct.

s  !

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

i 5. Technical issues in category 4a involving failure to meet requirements have the potential for being willful or deliberate violations. However, (

! i in the absence of specific allegations.of v111 fulness or deliberateness,  !

such issues will normally be tracked separately as technical issues and resolved using program resources. If an allegation covers issues that '

,

• affect other Regions or Offices, follerup activities will be coordin-ated with the affected Offices and a Lead Office will be designated. The i

0AC will contact the affected Offices which should result in a mutual i agreement as to which Office or Region should have the lead. If agree-j eent cannot be reached at the OAC level, then the Regional Adminis- ,

j trators or Office Directors will resolve which Office or Region should take the lead.

j i  !

6. Allegations in category 4b, should be referred to O! Field or Head-  !

! querters personnel except for those involving INtc employees or NRC t contractors. .

i l 7. When applicable and after coordination, the Action Office should j notify other agencies such as the Occupational safety and Health

! Aministration. 00E, etc. in dealing with allegations in category i i

4c. Notification to . ether Federal law enforcement agencies and j State and local jurisdictions of poss161e criminality involved in t i

allegations should be handled by the appropriate O! Office or the  ;

i Office of Inspector and Auditor (for matters falling within its  ;

{ purview only.)  ;

1 '

i 1

[

1 .

j Al-5 Approved: I I

L _.___ _ _

.. i l . . .

j .

i '-

NRC 0517. APPENDIX 1 MANAGEMENT 0F ALLEGATIONS  !

i i 8. i i

The OAC ensures that a discrimination complainant under Section 210(a) of the Energy Reorganization Act is properly referred

• to 00L (the  !

i complaint must be filed with D0L within 30 days of its occurrence),

i and that 00L is promptly notified of the complaint.. Complaints should '

l be filed with the Office of the Ahinistrator, Wage and Hour Division, l j

Employment Standards A41nistration, U. 5. Department of Labor, Room 53502, 200 Constitution Avenue, N. W. , Washington, D. C. 20210. The Regional Ahinistrator or Office Director should be promptly informed.

The OAC also maintains awareness, of D0L's investigative intent, and ensures NRC consideration of the need for its own investigation by timely referral to 01. The OAC will take reasonable steps to facilitate l 00L's investigation by assisting 00L in obtaining access to licensed facilities and any necessary security clearances. This type of l

) allegation should also be entered into the AMS.  ;

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

Offices and/or Regions with responsibilities that may be affected will be appropriately notified by the Action Office (e.g., AE00 for opera-tional data, RES for concerns affecting research activities, etc.)  !

j 10. l i 4 - Information regarding suspected improper conduct by NRC employees and '

NRC contractors will be brought to the attention of appropriate 1

management for possible referral to the Office of Inspector and

- Auditor (0!A). -

3 j part V:

Documentina Allocations

~

i 1. When an allegation is received and the action office identified,

! a i working file should be established to contain all related documentation  !

! concerning the allegation, including all correspondence memorandum to i

- files, interviews, and summaries of telephone conversa,tions, discus-sfons, and meetings. This flie 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 l documented about each allegation. In addition to obtaining basic l information, attempts should be made to expand and clar<fy the j i information so that the issue is well defined. All allegations, l reilardless of source or how re eived, must be documented. Records or  !

fines containing the name of a confidential source or other identifying  :

information (i.e. a confidentiolity agreement has been executed) should (

, be stamped "This material contains confidential source information."  !

l

. .. 2. There will be occasions when the allegations obviously have to sub-stance and appear to represent a distortion of facts. However, even

'in these cases, doceentation is necessary that identifies the con-j tact, the general content of any communications, and the basis for a

conclusion that the matter need nut. be pursued. Instances such as l these will be coordinated with the appropriate technical staff by I

I the OAC to ensure proper disposition.

! 3. The importance of obtaining and documenting all pertinent information i about an allegation cannot be overemphasized. Evaluation and screen-  !

1;.p of the allegation, as well as the proposed course of action that 3 wi 1 be adopted to resolve the issue will be based primarily on this information. In some cases, a person,al interview with the Approved: Al-5

.. l

, l

.. MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517 alleger may be warranted. In these cases, the OAC will consult with NRC management to determine the best way to obtain the details re-quired. Depending on the nature of the allegation and the time sensi-tivity, assistance from the Office of Investigations (0I) or other resources may be requested. '

4. As soon as possible after receiving an allegation or becoming aware of )

information that indicates inadequate or improper activities, the person receiving the allegation shall notify the OAC. Normally, no action will be taken to verify the validity of the allegations, nor shall such matters be discussed with licensees, if necessary, until i i

after the OAC or designated staff member has briefed appropriate NRC  !

management.

5. The OAC or other designated staff member is responsible for reviewing l all information received in conjunction with an allegation and for ensuring that management and cognizant technical staff members are fully informed. t l

6. Allegations normally should not be addressed in Preliminary Notifica-

' l tions (PNs) or Daily Reports (DRs); ho sever, if it is determined that 4 PM or DR entries are appropriate, the approval of an Office Director l or a Regional A h inistrator should be obtained,  ;

i l

7. If allegation documents must be sent to other NRC personnel, they should '

be appropriately handled to protect the identity of the confidential l alleger. The confidential alleger's identity or other identifying i

information should not be released unless there is a "need to know" (See Basic Requirement 054). -

Part VI: Evaluation by connizant Technical staff  !

1. When an allegation package is received, the technical staff within the Office or Region will review the documentation to determine if there is a safety concern that rec,uires immediate action. The technical  !

staff is responsible for development, initiation, and follow-through on corrective actions. Allegations or documents containing a sub- i I

stantial number of allegations once entered in the ANS can be screened using the following criteria: <

l

s. Is there an immediate safety concern which must be quickly addressed? -

1 - .

b. .

Is the allegation a specific safety or quality issue or 'a gener-i -

alized concern? .

c. Mas the staff previously addressed this issue?

d. Determine whether the allegation package contains sufficient information for a thorough evaluation. If it does not, identify t the additional information that is needed, i 1

Al-7 Approved:  :

[

. NRC 0517. APPENDIX 1 MANAGEMENT OF ALLEGATIONS

{

q i

e. Determine whether all aspects of the allegation are adequately I i defined and described to pemit or require a meaningful and exten-  !

sive evaluation. This is a screening process that may result in a  !

l decision not to consider the allegat' on further. If the latter is  !

' the decided course of action, the alleger should be so informed in

! a courteous and diplomatic manner along with the rationale for not I considering it further. The potential for adverse publicity must be recognized when taking this action. l o

f.

Determine whether the identity of the alleger is necessary for a  !

j thorough evaluation. '

r i

g. Determine what specific issues are involved in the allegation and whether the issues can be adequately addressed by 'a technical inspection. >

,' I

, h. Determine if the allegation can be examined and resolved during

! a routine, scheduled inspection. If this is not possible, deter-i eine the best wqy to address the issues. i

, 1. Determine 'whether Itcensee/ vendor redources can reasonably be l 4 used in resolving the allegation to conserve staff resources.

Consider potential problems associated with " turning the issue over to the licensee." ,

l I

j. Determine whether the allegation has the potential to require t

, escalated enforcement action.

3 k. Determine the time sensitivity of the allegation, and what immed-inte actions are necessary.

i

, 1. Determine whether investigative assistance will be needed.

s. Identify peripheral issues ghat could develop. l i

n. Consider if any licensing actions or board proceedings are pending i

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 19455 as soon as possible to assist in the i determination of whether er not a board notification should be

, ande. This decision must be made promptly by NRR or 19455 in l

.. . . accordance with office procedures. - '

i t J

e. Determine if other NRC Dffices that any have an interest should be notified,  !

i

p. As soon as possible after the receipt of an allegation and the l j/ .

relevant information has been reviewed and evaluated, the Action Office will aske a preliminary determination of the safety sioni-i d ficance of the item and the need for 1smediate regulatory act< on.

This determination will be reported in the next ANS update.

l

} Approved: Al-8 l

a .

.,,

• t

L

, MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517 l l .

4

q. Establish a schedule for the resolution of each allegation which is consistent with the licensing schedule, if applicabl,e. l I

r. Notify the OAC or designated staff member when the status changes

! or action (s) is complete. i

2. It is the responsibility of the technical staff within the Office or Region to resolve each allegation that falls under its jurisdiction, '

i and subsequently, to notify the OAC or designated staff member of the action taken so that the status of each allegation can be tracked to 4

closeout. Final resolution of an allegation shall be documented and ,

l l i placed in the working file along with all supporting docismentation. The

' final report should state the facts clearly, in a style that does not j belittle or disparage the alleger.

3. For those allegations resulting in the need for corrective action, the

affacted organization (s) shall be properly informed. j 1

Part VII: Allegation Resolution Documentation

! , 1. Allegation resolution documentation ' officially closes the file for 4 that case and shall be placed in the working file which new becomes

a closed case file. Closed case files shalL be retired to inactive

! storage through the Document Management Oranch TIOC, and destroyed i

according to the Comprehensive Records Disposition Schedule - '

(NOREG-0910). Appropriate documents, including those 'necessary for an individual to understand the incoming allegation and its resolution, '

shall be placed in the NRC records system (POR, LPOR, Docket File, j subject File, DCS) and must be treated to protect the identity of the j alleger.

i

, 2. A final report should be prepared that sets forth the facts about the l allegation and its resolution clearly and conclusively. The final re- i i port can be a memorandum for a relatively minor matter, an investiga-j i

tion / inspection report, or a technical paper for a complex or major generic matter. It can be an SER supplement for multiple allegations l 2

proximate to OL issuance. It should not contain the name of, or l material that could be used to identify, the alleger (See Basic j 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

f. .'-

be written in a style that does not belittle or disparage the alleger.

1

\

4.

j Appropriate entries should be made in the AMS to close out the a11ega-tion. l j 5.

' When the final report has been approved (i.e., the case is closed), all

(

allegation documentation is subject te release under the F0IA with appropriate precautions to prc+.ect confidentiality. Until that time.

l 'all allegation documentatica is exempt from release under the F0IA in i

accordance with 10 CFR 9.5 Exemption (7) due to actual, or the potential for, ' w enforcement i, tien.

File documents, however, are frozen by I the F0IA request for release when the case is closed should a

' i subsequent Fo!A request be received.

Al-9  !

Approved:  !

j I

NRC 0517. APPENDIX 1 MANAGEMENT OF ALLEGATIONS Part VIII: 01ssemination of Final Report  !

2. A copy of the final report shall be sent to the alleger and, if appro-  !

priate, to the affected outside organization (s). A transmittal letter may be needed to summarize the matter. ~

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

3. The foregoing does not apply to DI investigative reports.

PART IX: ALLEGATION MANAGEMENT SYSTEM

1. General

a. For purposes of the Allegation Management System (AMS) the defini-

! . tion provided for an allegation is very general and broad. The

{ *

. significance or nonsignificance of an allegation will be judged i

during the Action Office review and follow-up activities. There J. is to be no screening of allegations for possible deletion prior

to entering them into the system (except of course for duplication

! of entries). The AMS should provide a vehicle for collecting, i

storing and retrieving all key information regarding all allega- '

tions. The Action Office determines the necessary action to be taken based upon the specifics of the case. Some allegations may

l. be received and closed out the same day. ,  ;

b. The AMS provides basic descriptive and status information and ,

serves as a referral system. It identifies the office and staff l to contact for more specifics on an allegation. Additionally, it I keeps the staff informed as to how the allegation was resolved  :

and provides reference to the close out documentation,

c. When an allegation is received, it is not necessary to identify by separate entry into the AMS every component or subset of the allegation. For example, if an allegation is received that con-sists of 15 separate concerns of wrongdoing and technical def t-ciencies, the allegation may be entered as one allegation. However, 1 the description of the allegation should include the number of '

separate concerns and their subject area. In some cases there may

. be a distinct grouping of concerns, for example, in two areas such as training and quality assurance. In such a case it may be appropriate to enter two allegations. A main objective is to ensure that the receipt of an allegation is entered and tracked in the system. An allegation is not completed and closed until an Action Office supervisor determines that appropriate action has been taken.

Approved: Al-10

7 . . _ _ _ _ _ _ _

MANAGEMENT OF ALLEGATIONS APPENDIX 1. NRC 0517 d.

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

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

3 purposes of entering the allegation into the AMS either separate  ;

1 entries should be made for each Action Office for their assigned j i' action or one entry may be made with the involved 0ACs agreeing '

on the lead Action Office for followup of the allegation. If another Office is involved in responding to an allegation, it should be so indicated in the " remarks" section. l

2. Interfaces with the Office of Investinations i 4

i a.

The office of Investigations has jurisdication over all allegations of wrongdoing ,

except those involving NRC employees or NRC contractors and will forward all allegations of a technical nature d to the appropriate Office or Region. The office or Region will be  !

g responsible for entering all allegations--even those under the i 4

purview of 01--into the AMS using a Region or Office AMS number.  :

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

• i (1) The Region or Office OAC will coordinate with the 01 Field i Director or 01 Headquarters representative to determine if  !

sensitive information is included which should not be placed l

' into the AMS. All sensitive information 'is to be deleted and the word " sensitive" put in its place. However an atteset should be made to provide descriptive material to assist the i AMS user to the maximum extent possible.

i  !

i

~

(2) The Region or ' Office OAC will assign a Region or Office AMS number. The 01 assigned number should be entered in the AMS as a cross-reference.

7 (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 Ofrector will keep th'e Region or Office OAC I L

apprised of the status of the allegation investigation and {

provide timely information necessary to determine the safety i 4

e significance of the allegation to appropriate Regional or  !

Office manage' ment and for use in updating the AMS. i I

i!

j l

l l'

i l .

Al-11 Approved:

5 j

NRC 0517. APPENDIX 1 MANAGEMENT OF ALLEGATIONS (5) The allegation will be considered closed when the investiga-I tion report has been issued and as long as no technical issues remain. If technical issues or an investigation remain, the i allegation remains open, reference is made to the technical report or 01 investigation report if either-is complete, and a schedule for resolution of the allegation is placed in the i Allegation Data Form or in the AMS update, c.

For allegations of wrongdoing received by 01, the OI Headquarters or Field Director will coordinate with the respective Office or

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

d.

For allegations of a technical nature received by 01, the OI Head-quarters or Field Director will contact the respective Office or Region and follow the procedures as indicated in item 3 below for the Receiving Office.

3. Receiving Office d Upon receipt of an allegation involving an NRC-regulated activity, the person receiving the allegation will provide the information rela-

't tive to the allegation (see Exhibit 1) to the OAC who will initiate steps into gation required 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 concurrence from the Action Office before transfer of responsibility.

4. Action office. The Action Office shall :

. a.

Complete that portion of the Allegation Data Form marked " Action Office," assign an allegation number to it, and forward a copy of the form to the NRR OAC for entry into the AMS, and to the HMSS DAC, of the ifallegation appropriate, within 10 working days of the date of receipt for information, b.

Provide AMS updates to the NRR 0AC on a monthly basis by indicating updates on the previous month's status report. Updates are due to NRR by the 25th of each month. All input to NRR for the AMS should be sent in " addressee only" envelopes to, " Allegation Management System, Mail Stop 528. Completion of the follow-up -

action status for an allegation will be recorded by updating the monthly 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 0ACs 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 latory action. of safety significance and the need for any regu-update.

This determination will be reported in the next AMS Approved: Al-12

.  ?

MANAGEMENT OF ALLEGATIONS APPENDIX 1, NRC 0617

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

. e. Make a determination regarding the need for a board notification to NRR or 255. If the initial board notificat' ion is preliminary ,

in nature, a follow-up notification is sent to boards when '

evaluation is completed, or whenever significant relevant informa-tion is identified during the course of evaluating the allegation.  !

This determination should be made as soon as possible in '

accordance with the Action Office board notification procedures.

f. Develop and maintain a working file for each allegation, which will  !

contain all related documentation. For those allegations comprised of multiple concerns, separate working files any need to be estab-  !

lished for each concern.

/

g. Provide status information to the MRR DAC for the AMS regarding items c-f, above.  !

t d h. Thirty days prior to the construction completion date (appli-  !

cant's estimate) for each pending OL, each Action Office will i

). fomard to the Division of Licensing /NRR, an evaluation of the safety significance of all allegations ,

not scheduled to be resolved before the construction completion date, with a recour- ,

l mandation as to whether any or all of them constitute grounds for t

delaying issuance of (or othemise restricting) an operating license.

i '

Thirty days prior to a Commission decision on . authorizing full-  !

power operation, a report similar to item h above, will be j prepared.

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

5. NRR 0AC

s. Upon receipt of an Allegation Data Form and updates, the NRR OAC I'

will perform a quality check and will transmit the information to the Office of Resource Management (RN) for input into the AMS. i This procedure will be modified when direct input or update  !

capability ~ to the AMS can be obtained for Offices and Regions. - I

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

l l

t Al-13 Approved:

• f(ANAGEMENT OF ALLEGATIONS EXHIBIT 1. NRC 0517 NRC Form 307 ALLEGATION DATA FORN

1. ALLEGATION NUMER: - -A-H 2. FACILITY:

Name Unit No. , Docket No, a.

b.

c.

3. TYPE OF REGULATED ACTIVITY:

a. Reactor Ob. Vendor Oc. Meterials Od. Safeguards

e. Other

4. ERIAL5 LICENSE NUM ER:

5. FUNCTIONALAREA(s):

8 O a. Operations O b. Construction O c. Safeguards c d. Transportation O e. Emergency areparedness 3 f. Onsite health and safety 'J g. Offsite health and safety

h. Other I 4. DESCRIPTION:

. 7. nurutn w wm.tana:

8. SOURCE:

'J. a. Contractor employee O b. Licensee employee

c. NRC employee Q d. Former employee

e. News media O f. Private citizen

g. Organization 0 1. Anonymous *

h. Other

g. CONFIDENTIALITY nagututu: -

O Yes O no

10. DATE ALLEGATION RECEIVED: J/

IL. EWLOVEE/0FFICE RECEIVING ARERTTlk: .

i IH. ACTION OFFICE CONTACT / PHONE:

13. SAFETY $1GNIFICANCE: O Nigh O Redium O Low O None .

14. BOARD NOTIFICATION REC 0 MENDED: O Ves O No

15. 01 NOTIFIED: Oyes O No

16. STATUS:

0 0 pen O Closed scheduled Cos ,1etion Deto: JJ_

Date Closed: / / -

g 17. NA5 ALLEGATIO N !ATEO: O yes O No O Partially

18. WAS ENFORCEMENT ACTION TAKEN: O ves No O ln Process

$ SEVERITV LEVEL: OI 1g. WAS 01 INVESTIGATION PERFORMED: O ves O II III O 1V OV j No O ln P ss 20.DID015P051T10NRESULTINLETTER70M00fFYORREV0KELINE: l t O ves O No O so.54(f) 0 30.32(d) 070.22(d) 0 40.31(b) f 4 pisposition:

. 21. ALLESER NOTIFate w uuntuui, O Tes o no l

. ..- gg, ggggggs: .

. I P 23. unna strantm.t:  !

I4. PROJECT MANAGER /Nums:

OE /J-

'I fl. APPLICANT'S CONSTRUCT 10ffTIN LTTTIK M Tri

.,j'a

=

26. 00AA0 NOTIFICATION ISSUED: O Ves - -

El-1 Approved:

, . n NRC05172 EXHIBIT 1 MANAGEMENT OF ALLEGATIONS _

.' INSTRUCTIcas ..

1. Allegation Number Action office fill in the boxes to uniquely iden .

l tify this allegation OFFICE official NRC office abbreviation for the Office responsible for follomup activities.

VEAR last two digits of the calendar year in  ;

which the allegation was reported to NRC.

, A identifies this num6er as an allegation ,

- r4aber. '

, inseER sequential number assigned by the Office or  !

Region responsible for the followup activities.

EXAMPLE The 14th allegation received by IE in 1982 would be shown as IE-82-A-0024

! 2. Facility (ies) Give the name of the facility (ies) or company (ies)

j. Involved about whom the allegation is made. Write the l docket number. if appropriate, in the spaces to l the right. If the allegation is made about a specific individual or if the information in this i

item is otherwise sensitive, write SENSITIVE. If more than three facilities or companies are in-i volved write GENERIC.

5. Description Briefly describe the allegation (1 or 2 sentences).

Se concise. If an allegation includes several in-stances of technical deficiencies'or wrongdoing, l

, . list the assertions separately or group them by E$ If the description of the allegation is

I sensitive, write only SENSITIVE.  !

7. Number of. Write the total number of concerns given in the Concerns, allegation. Note that each Office or Region may need to establish a working file for each concern. *

8. Source Check the box that most clearly describes the affiliation. DO NOT include the name of the indi-vidual making the allegation..

g. Confidentiality Indicate whether confidentiality has specifically- *

~

Requested been requested. .

13. Safety provide an estimate of the safety significance of Significance allegation t Exasple (a) Check "high" for an alleged deft-l ciency in an operating plant that could have an issediate and great effect on pblic health and safety (b) Check" Low for an alleged deficiency in a plant under construction that would have a minor effect on public health and safety

20. Did Disposition Check appropriate box (es) and briefly describe Result in Letter

to Modify or method of disposition report inspection report. (e.g..

SER letter,) technical etc. and identify Revoke License document. .

22. Remarks Include additional information as appropriate.

j EXAWLES: list other allegations related to this all I for1ations 011owuplist other NRConoffices activities responsible this allegation.

, 23. Cross Reference Identify other related allegations and.investiga-t .. . tions hy alpha-numeric designation. .. .

25. Applicant's .

For plants under construction, enter the appit '

Construction cant's estimated construction completion date; Completion Cata there is no need to provide this information untti 3 or 4 months prior to the estimated date.

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

. Issued A El-2

. ._ _PP. roved: _ _ _ _

, b .. '

e- 246:30 i

etsf eAft: ce/es/e4 **

STAT ST: CAL - Y

• 3847 less g.

m ALLteAT 0NS ALLEGAT OWs TUTAL TUfAL l ALLteATGNS OptB Insete CF z j RECEIVED CLOSED OPER ALLEGAT M Insete CF H DURIIIe DURIIIe AtW TWEW ALLEGATIW S ALLEGATIWe OFFICE THE HDIffM THE DEDIffM OF THE HOIffM se DAYS OLD III THE SYSTEN CLOSEO o

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, RUN DATE: 94/09/84 .

. I PAGE f LIST OF ALL ALLE0ATIONS EI <

52 j FACILITY NAME ALLEGATION NUMBER CONTACT rn

'i FTS. PHONE STATUS

} ISISCB FIRE SEALS) mRIII-83-A-0929 o M SULDEMOND 388-5408 DPEN AMERICAN TESTINO LABS DIR4-83-A-0043 RE MERR

! AMERICAN TESTIN0 LASS RIV-83-A-0023 728-8110 SPEN AMERSHAM CORP TF WESTERMAN 728-8800 CLOSES F1 5 URYC RII-84-A-0026 242-4393 j ARRANSAS 982 ARRANSAS 98 2 RIV-84-A-0008 TF WESTERMAN 724-8100 OPEN OPEN l}

-4 I

RIV-84-A-0041 TF WESTERMAN 728-4100 OPEN **

ARMED FORCES RADIOSIOLOGY RES INST RI-83-A-0089 JD KINNEMAN 488-1252 j ARMS / SAP CORP. MICHISAN CIIY. IN WRIII-84-A-0013 DPEN  !$

DJ SREMIAWSKI 388-5688 CLOSES U' ATLANTIC CITY MEDICAL CENTER RI-84-A-0024 JE GLEMM 488-1260 ATLANTIC NUCLEAR SERVICES CLOSES RII-83-A-0107 GA T000 242-4193 CLOSES AUBURN STEEL MILL RII-83-A-00tS GA TODO 242-4993 CLOSED BANNSON. INC. RII-84-A-0049 3 URYC BARCLAY INTERNATIONAL 242-4993 CLOSED RIV-83-A-0082 TF WESTERMAN 728-8800 OPEN i BASIC ENGINEERS NATIONAL VALVE. PA mIE-84-A-0003 EM MERSCit0FF 492-4572 OPEN E3 BAYTOWN INDUST X-RAY CONST CO i

• BEAVER VALLEY 1 RII-83-A-6423 0A TODO 242-4193 CLOSES i "'

BEAVER VALLEY I RI-8 3- A-00 74( **) LE TkIPP 488-1227 CLOSED 1 SEAVER VALLEY 1 RI-83-A-0080 LE TRIPP 488-8227 CLOSED

' RI-83-A-0044 LE TRIPP 488-1227 CLOSED BEAVER VALLEY I RI-84-A-0006 LE TRIPP  !

I BEAVER VALLEY 1 488-1227 CLOSED RI-84-A-0007 LE TRIPP 488-1227 DPEN l BEAVER VALLEY 2 RI-83-A-0088 LE TRIPP BEAVER WALLEY 2' 488-8227 OPEN RI-84-A-0009 LE TRIPP 488-1227 OPEN BEAVER VALLEY 2 RI-84-A-0043 LE TRIPP BECNTEL 488-1358 OPEN BELLEFONTE I RIV-83-A-0035 TF WESTERMAN 728-8800 CLOSED BELLEFDNTE 1 R II-8 3- A-0 0 3 9(**) OA TODO 242-4193 CLOSED SELLEFONTE I RII-83-A-0040 GA TOOD 242-4193 CLOSED RII-83-A-0090 OA TODO 242-4193

47 BELLEFONTE 1

• RII-83-A-0122 B URYC 242-4193 CLOSED OPEN 12 BELLEFONTE I RII-83-A-0123 5 URYC i

2 BELLEFDMTE 1 242-4893 OPEN l < SELLEFONTE 1

. RII-84-A-0003 3 URYC 242-4193 DPEN RII-84-A-0009 GA TODD 242-4t93 '

OPEN p,

i j[ BELLEFONTE 1 RII-84-A-0036 JB LANRFORD BELLEFONTE I 242-4894 DPEN RII-84-A-0052 JB LAWRFORD 242-4194 CLOSES 25 as BEST INDUSTRIES INC. ARLTNSTON VA RII-84-A-0027 A TILLMAN 242-5613 BETMESDA NOSP. CINCINNATI SMIS CLOSES [j RIII-83-A-0079 DJ SRENIAMSKI 388-56tl CLOSED SIO ROCK POINT .

RIII-83-A-0067 LR GREGER 388-5644 h8 CLOSED BRE WASTE DUMP. M. C9VINA. CA

• RV-84-A-0048 RD THOMAS 463-3743 CLOSED BORS WARMER RIV-83-A-0029 BORIDE PRODUCTS INC TF WESTERMAN 728-Ss00 OPEN. 3r RIV-83-A-0060 RK NERR 728-Site OPEN BOVARI ELECTRIC INC OIR4-83-A-0077 RK NERR 728-8110 $$

OPEN BPB INSTRUMENTS INC. EVANSVILL. IN RIII-84-A-0030 DJ SRENIAWSKI 388-54II CLOSE9 BRAIDWOOD 1

• MS LITTLE 388-5578 $l mR I II A-0010(**) OPEN >=

%4 6 ASSOCIATED WITH TNIS ALLEGATI000 NUMBER

• • mseber Of enar s -tavai M h +' '- -"

.' IWiAGEMENT OF ALLEGATIONS EXHIBIT 4 NRC 0517 CONFIDENTIALITY AGREEMENT I have infomation Regulatory Commission that (NRC).I wish to provide in confidence to the U.S. Nuclear tiality as a condition of providing this infomation to the NRC.I I will requ

. not provide tiality this information being extended to me. voluntarily to the NRC without such confiden-agreeing to this confidentiality, will adhere to the follo 1

(1)

NRC The NRC will not identify me by name or personal identifier in any initiated document, conversation, or communication released to the public which relates directly to the information provided by me. I under-4 stand the term 'public release" to encompass any distribution outside of the NRC with the exception of other public agencies which may require this information trust. in furtherance of their responsibilities under law or public (2) i required for the conduct of NRC-related activities.The NRC w (3) j -

make every effort consistent with the investigative nee

!  ;' to avoid ' actions which would clearly be expected 'to result in the disclo-sure of my identity to persons subsequently contacted by the NRC. At a i later stage I understand that even though the NRC will make every reason-i able effort to protect my identity, av identification could be ccapelled by orders legal entities.or subpoenas issued by courts of law, hearing boards, or similar ,

fidentiality and any other relevantIn such cases, the basis for granting this pr facts willtobemaintain communicated to the authority ordering the disclosure in an tiality. effort my confiden-If this effort proves unsuccessful, a representative of the NRC will attempt to inform me of any such action before disclosing my identity

!.

• confidentiality if I take any action that may be disclose my identity.

reasonaI als expected to to have waived m I further understand that the MRC wi consider me vlously provided)y rights to confidentiality if I provide (or have pre-information to any other party that contradicts the information that I provided to the NRC or if circumstances indicate that I L

as intentionally providing false information to the NRC.

1 Other Conditions: (if any)

• I have read and full with its provisions. y understand the contents of this agreement. I agree Date

• Rame:

, Address:

• l

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

l, .

h gate signature Name:

Title:

L E4-1 Approved:

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