ML20207A590
| ML20207A590 | |
| Person / Time | |
|---|---|
| Issue date: | 08/11/1987 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | NRC |
| Shared Package | |
| ML20207A593 | List: |
| References | |
| NUDOCS 8708210501 | |
| Download: ML20207A590 (8) | |
Text
_ _ - _ _ _ _. -
. p EnclosureI u
/p ass \ UNITED STATES
! . t NUCLE AR REGULATORY COMMISSION
{ ,
I wassiNovos.o. c rost s
. J
\ % .../ AUG 11 1937 MEMORANDUM F0P.: Office Directors
, Regional Administrators FROM: Victor Stello, Jr.
Executive Director for Operations
SUBJECT:
NOTIFICATION TO 01 0F POTENTIAL WRONGDOING In our recent senior management meeting I directed that the Office of Investigations (01) be promptly notified when the staff is aware of a matter w'ec h could potentially involve wrons,doing on the part of the licensees or
, -. their contractors. This is consistent with OI policy No. 26 which was approved by the Comission. The purpose of this metorandum is to provide teidance corcerning this notification.
All NRC employees should be alert fer matters which could potentially involve wrongdoing. Potential wrongdoing involves matters where regulatory violations appear to have occurred with some intynt or purpose to violate requimments in contrast to violations involving error or oversight. For purposes of this notification to 01, the tem wrongdoing should be applied as defined ir. MC 0517. ~*/
Examples of actions by a lice,tsee or licensee contractor which are indicative of potential wrongdoing are record falsifications; material false statements; cheating on examinations; intimidation, harassment and retaliation; and other such atters, especially when it appears management is involved with or is knowledgeable of the wrongtioing.
Notue to 0! shculd be siade as soon as it is detemined that the potential exists for wrongdoing, and should be made independent of and not await a subsequent decision by staff to make a formal request 19 O! for en investi-gation. Oral notifications to O! Field Offices are acceptable. Nomally, such matterr -hould be addressed thru the management chain; however, the NRC's
'open door ;cy" provides for NRC employees contacting 01 directly when .
circumstance. ske that appropriate. *
- / Wrongdoing is defined in MC 0517, Section 0517-0415 to consist ? both Tntentional violations of reg;1 story requf w nts and violations resvitT6- 9 from careless disregard of or reckless in6 5 erence to ngulatory requirements.
A reasonable basis for belief of wrongdoing exhts when, from the circumstances surrounding it, a violation of a regulatory requirement appears more Itkely to 1.sve been intentiotal or to have msulted from careless disregard or reckless indifference than from error or eversight.
W \ o SM a
.m.
l 2
In sumary, it is necessary to keep 01 fully infomed of these utters which com to the staff's attention which potentially involve wrongdoing. Please insure that your staff is aware of this requirement. ..
- l I
tor Stri10 .' }
Executive Director for Operations cc: 8. Hayes. 01 l
i 4
f 4
(
I
- 1 T
l
ENCLOSURE ?
NRC Appendix 0517 MANAGEMENT OF ALLEGATIONS Part lit, Exhibit 3 LIMITED DISTRIBUTION - NOT FOR PUBLIC DISCLOSOAE Request No. _
Region / Office year No.)
Alle0stion No.
TO:
FROM:
REQUEST FOR INVESTIGATION Licensee /Vencor/ Applicant Doche; No.
Facility or Site Location Regional Administrator / Office Date A. Request .
What is the matter that is being requested for investigation (be as t.3ecific es possible regarding the undertying incident).
LIMITED DISTRIBUTION -- t10T FOR PUBLIC DISCLOSURE W/O 01 APPROVAL 35 Approved: June 20,196i
E q
N j;) [4I.,
T,ys .p isRC Appendix 0517 h- part 111, Exhibit 3 9 -
T' ')@; .[..
hO R,- MANAGEMENT OF ALLEGATIONS 1 g- Q.e &,,!i;J&. :
li ~ .P # N W7 he LIMITED DISTRIBUTION - NOT FOR PUBLIC DISCLOSURE
% - 3WQ(t rt
}
2- hs - .4 %.Tgp 4,
+
$'; '.. ' ?I; f[g B. . Purpose of Investication _ y %"O , I 1. What is the basis for the beilef that the violation of a regulatory J;;'; % ;
- 1.;'q. .
f% f y v. J.. F. yr requirement is more likely to have been intentional or to have resulted from careless disregard or reckless indifference than from $' J ry g error or oversight? (be as specific as possible). ?-:+.*,.pi.T;'gtg ^ fk% * - ggefyy- ---- nailig T I M 4. - ig 2. { t tat are the potential regulatory requirements that may have been violated? kh p .y,3: 43 '<c, _ '.gs .
.N,N,'$
9*E . E a p'd; t tg.
~ .g .y:.
vg
. j. . ]
'8-
' k.
In M [kV : ( 3. If no violation is suspected, what is the specific regulatory concern? f.d a ).2. .w _. M y h h - I C ,. [ 4
?h't bhh>
+
E Why is an investigation needed for regulatory action and what is the .1)fk C.,",.4i
- .',..f.::
regulatory impact of this matter, if true? b .4 ? f. Q y - - B .,J ,gl.,,j 1. 62,;Q. Na . ' ' '. 4 g h Et 3ibwa M _ _- h C. Reauester's Prior;ty na wp a :;n w .. 1 *
- 1. p: 'n. - h . g ,..
] Is the priority of the investigation high, normal, or low? . e 4 $ 'j 2
- 2. What is the estimated date v.t.en the results of the investigation are needed?
fi'?...v'.? ; ef* 5.. ,,9 s f'r.. h 34 .n,s l' y ; . K;g.;.:.
- 3. . .
k What is the basis for the date and the imoact of not meeting this iM $N
- b y
date? (For example, is there an immediate safety issue that must be addressed or are the results necessary to resolve any ongoing h}.yh' 4N regulatory issue and if so, what actions are dependent on the out- *! :.'g.e 4 %/s
.i , 2 r
come of the investigation?) n'.' ' ' ka
;N' ? ".ag V4 * ,. l's+.
.g. . ; ,
o q.. m , . .,y CQ ' D.N
- 3 =
LIMITED DISTRIBUTION -- NOT For, PUBLIC OlSCLOSURE W/O 01 APPROVAL - .h h8N (?Qb 'l*ff.l* s.
. .s .
p.. . -
'[ 4 '
.g .% f. 'g .. ..
Approved: June 20,1987 .:.',p c _ - 3.; . y;{; .N F" - ". t'..- .s e 36
)V s ,-
y
" v ._ . . , , ;' . ,
- i ll& p.,W 2 . -
(f.,yw1 )**Q /-); ].3,. .
tpumwi A . . 7 Er E_ NRC Appendix 0517 E_ MAN AGEMENT OF ALLEGATIONS Part lit, E x hibit 3 LIMITED DISTRIBUTION -- NOT FOR PUBLIC DISCLOSURE m 3 - J D. Contact L
. 1. Staf f members:
N W-h 2. Allegers identification with address and telephone 1 not confidential. (Indicate if any confidential sources are number involvecd 4 .
=
I r and who may be contacted for the identifying details. ) [ F. Other Relevant In fnrma tion
~
a s
, . h kl.
C = i [. .
- - .- .1 Signature ~
cc: 01 '/ l ED6 y N R R /NMSS/C , as approp-late */ _ OGC p Regional Administrator [/ DE 7 .
*/ If generated by region.
= ^ h/ if generatec by NRR/NMSS/OSP - LIMITED DISTRIBUTION -- NOT FOR PUBLIC DISCLOSURE W/O 01 APPROVAL 37 Approved : June 20,1987
I_ ENCLOSURE 3 NRC Appendix 0517 _Part til MANAGEMENT OF ALLEGATIONS
- a. &
(1) Current manager, licensed operator or other employee a involved significance, safety in deliberate violation of requirements having high e.g. continutng potential for unnecest,ary radiation expos,,re the public. u to employeet or members of (2) Suspected reactor. tampering with vital equipment at a power (3) Allegations inspectic'n of falsification of records available for NRC or submittals to the NRC or deliberate , withholding of information required to be reported to the NRC, where the situation involved presents an immediate
]
and continuing health and safety concern, g, (a) falsification icance, of records having high safety signif-such as falsifications which conceal a repeated failure to perform a required test; (b) alleged seism'.: withholding of significant design flaw or or criteria information for an operating facility; (c) level of Individuai involved in the alleged withholding of information or falsification is such that a serious cuestion of the willingness of management to conduct safe operations is raised. (4) Allegations of falsification of records available for NRC inspection or deliberate violations of NRC requirements concerning licensing. an area of significant safety concern for (5) Allegations of wrongdoing where immediate investigation is necessary evidence or to 6,nsure preservation and availability of which are in some other way time perishable.
- b. Normal (1)
Allegations of lotimidation or harassm*nt of QC inspectors or workers on safety-related equipment at a facility under construction. (M Allegations of deliberate violations of NRC requirements where there is no indication the violation is recurring or causing immediate and direct health and safety impact on the general public or empicyees. (3) Allegations of falsification of records available for NRC inspection or deliberate violation of NRC requi,tments of safety concern in the licensing process. Approved: June 20,1987 30
^
/ . 1 NRC Appendix 0517 MAN AGEME NT OF At,l,EG ATIONS Part til C. Low l (1) Allegations of deliberate vlotations of NRC requirements, falsification of records or submittals to NRC, or harastment or intimidation of workers where the licensee is aware of the allegation and has already undertaken corrective action. (2) Allegations of deliberate violation of NRC requirements at an operating facility where there is no near; term safety concernj Q, the reactor is in kmg-term shutdown.
- 4. program offices are responsible to the EDO for assuring that within their areas of responsibilities necessary investigations are conducted, if the program office believes that a priority for a matter should be different than that requested by the Reglen, the Region should be contacted immediateiy to resolve the matter.
- 5. Once a matter has been accepted by 01 for investigation, if the
, reque tor of the investigation determines that the need for or priori y of an investigation has changed, that information will be provided to the Director, 01, for his/her consideration.
1
. l l' e e
t 4
-= - -- e .n. - - - .--,_. -- ----_.n. - - -- -
ra a l [ "f 0/WgYI N63 The enclosures to flRR Office Letter flo.1000, Revision 2 that was issued on August 15, 1988 were inadvertentif omitted. } A corrected copy is enclosed. Qf o 1}}