ML20206D844
| ML20206D844 | |
| Person / Time | |
|---|---|
| Issue date: | 01/28/1985 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206D809 | List: |
| References | |
| FOIA-87-622 PROC-850128, NUDOCS 8811170299 | |
| Download: ML20206D844 (3) | |
Text
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- Regional Office Policy Guide No. 0206 - Revision 0 g og g COMPLETENESS OF 0FFICIAL FILES A.
Purpose:
- 1. To establish procedures to ensure that official files contain all relevant documents with respect to regional activities.
- 2. To provide additional assurance that all legitimate request's made to Region IV for official reccrds are responded to fully and efficiently.
- 8. Of scussion:
Reference:
Regional Office Policy Guide No. 0203, Rev., Freedom of Information and Privacy Acts
- 1. For the purposes of Region IV, official files are those files maintained by the Region IV file room. All official records
.iecessary to support flegion IV actions will be in the file room thereby facilitating efficient conduct of agency business and efficient response to Freedom of Information Act (FOIA) requests.
- 2. These procedures do not require the staf f to maintain or create additional documents. Rather, they are designed to ensure that all.
relevant documents are placed in the official files and, therefore, are readily accessible to NRC staff members performing official duties.
- 3. The procedures required by this Guide will provide for complete official files, and will help assure the completeness of responses to FOIA, discovery, or other appropriate and necessary requests for documents.
C. Action All regional staff should become f amiliar with, and adhere to, tha following procedures:
- 1. Drafts - Once a final document is issued, employees should review the drafts in their possession to determine if there is a reason to keep any of them, such as the draft containingIfsubstantive information no such reason exists, on the agency actions not contained in final. If an employee determines that draft should promptly be disposed of.
a draft should be kept, the employee shall clearly note on the draft 4
Attachment 8811170299 001006 PDR FOIA
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the reason for retaining it. The note and the draft shall then be submitted to the file room through the employee's supervisor to i i assure supervision has knowledge of all substantive issues concerning the record. ,
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- 2. Notes or Memoranda to Files - Notes or memoranda to files are written i for a variety of reasons such as explaining the basis for agency ,
action, preserving a view on a given issue, or to document verbal j coanunications.
Whenever an employee writes a note or memorandum to files which contains substantive information about agency action, a copy of the f note shall be sent to the file room through his or her supervisor for inclusion in the official files. In all such cases, a copy must also be provided to the employee's supervisor to ensure supervisory knowledge of substantive agency actions.
) If the employee believes that retention of a note or memorandum is ,
- desirable for more effective or efficient perf'rsance o and such a note l or memorandum does not contain substantive information about agency l action, the employee may keep the document as a personal record. !
However, if the employee wishes to preserve the record as "personal" l and does not wish to place the note or memorandum into the official i i files, he ar she must maintain it in a separate personal file located j j
in the employee's office or residence, and not have it typed by NRC [
personnel other than the employee himself. The note or memorandum .
- also must not be distributed to, shown, or otherwise shared with ,
other employees. Notes or memoranda hand W under these controls ~
3 will remain the employee's personal property and will not be !
- considered agency records. l 1 L l With respect to personal records as oMosed to NRC records, the definition of personal records are those maintained as described
! above that (1) are not required to be taken by NRC policy or t i procedures; (2) are prepared for the employee's own use to aid (
recollection; (3) are retained or discarded solely at the author's :
discretion; and (4) over which the NRC exercises no control er 1 dominion. This definition is also used for determining agency versus l personal records in the context of F0!A requests. ;
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- 3. Nontscord Documents - In the case of nonrecord documents not included I
- above, all employees should revjew these documents to determine the !
i necessity for maintaining the documents. As a matter of sound record l management' principles, the retention of nonrecord material should be i kept to a minimum. Should er employee dntermine in reviewing i nonrecord documents that they are important to understanding agency l
! actions, the document shall be forwarded to the file room for ;
inclusion in the official files. !
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4 Workina Files - Prior to agency records becoming final and being placed in the official files, documents will exist in various stages of development. Employees should maintain such nonfinal documents in a "working file" which is accessible to each employee's secretary and supervisor. This will facilitate locating records when an employee is absent and will provide for efficient response to FOIA requests by allowins for prompt identification of documents not in the official files., l
- 5. Duplicate copies of official records should not be maintained by individual employees strictly for convenience. Such copies ~say be t maintained, when necessary, by the Branch secretary or resident inspector's office.
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- 6. During the period from publication of this Guide until the effective date t.1 this Guide, all cr.sployees shall review their files to [
i determine if they possess any documents which should be in the '
official files. As of the effective date of this Guide, F0!A searches will be conducted by searching the official files, which should contain all final dncuments relevant to agency action, and by j searching the working files of the appropriate employees to identify -
nonfinal documents. ,
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- 7. In reviewing all documents, it should be noted that the FOIA does not require the maintenance of any document prior to receipt of an F0!A request applicable to the document. Thus, absent other requirements '
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to the contrary, such as specific retention periods required by i i
regulation, an employee may choose to dispose of the document rather .
i than fonvarding the document to the file roce. The important thing '
to remember is that employees should not be maintaining agency records '
in their Dersonal files which are not also in the official files.
- D.
Contact:
Questions regarding this Guide should be directed to the Regional Counsel. .
E. Effective Date:
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This guide becomes effective 45 days af ter the date of this Guide. I (e
obert D. Martin Regional Administrator Distribution List: A8 !
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