ALLEGATION PROGRAM

2005 ANNUAL TRENDS REPORT
CONTENTS

EXECUTIVE SUMMARY .......... .......... .......... .......... .......... .... 1

OVERVIEW OF SIGNIFICANT PROGRAM ACTIVITIES .......... .......... ......... 3

Safety Conscious Work Environment and Safety Culture .......... .......... ... 3

Alternative Dispute Resolution for Discrimination Allegations .......... .......... 5

Implementation of Guidance Regarding Release of Security-Related Information ..... 6

TRENDS IN ALLEGATIONS .......... .......... .......... .......... .......... . 7

National Trends .......... .......... .......... .......... .......... ..... 7

Reactor Licensee Trends .......... .......... .......... .......... . . 8

Materials Licensee Trends .......... .......... .......... .......... 10

Source Trends .......... .......... .......... .......... ......... 11

Allegation Trends for Selected Reactor Sites .......... .......... .......... . 12

Salem and Hope Creek .......... .......... .......... .......... . . 12

Browns Ferry Unit 1 .......... .......... .......... .......... ..... 14

Palo Verde Units 1, 2 & 3 .......... .......... .......... .......... . 15

Susquehanna Units 1 & 2 .......... .......... .......... .......... 16

St. Lucie Units 1 & 2 .......... .......... .......... .......... .... 17

Oyster Creek .......... .......... .......... .......... .......... 18

Point Beach Units 1 & 2 .......... .......... .......... .......... . . 19

Byron Units 1 & 2 .......... .......... .......... .......... ....... 20

Callaway .......... .......... .......... .......... .......... ... 21

Millstone Units 2 & 3 .......... .......... .......... .......... .... 23

Sequoyah Units 1 & 2 .......... .......... .......... .......... ... 23

Seabrook .......... .......... .......... .......... .......... ... 24

Shearon Harris Units 1 & 2 .......... .......... .......... ......... 25

Dresden Units 2 & 3 .......... .......... .......... .......... ..... 26

Comanche Peak Units 1 & 2 .......... .......... .......... ........ 27

Allegation Trends for Selected Materials Licensees .......... .......... ...... 28

Allegation Trends for Selected Vendors .......... .......... .......... ..... 28

CONCLUSIONS .......... .......... .......... .......... .......... ......... 29

RECOMMENDATIONS .......... .......... .......... .......... .......... .... 29

APPENDIX 1 .......... .......... .......... .......... .......... .......... . 30
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 1 of 33

EXECUTIVE SUMMARY

Management Directive 8.8, “Management of Allegations,” requires the Agency Allegations

Advisor to prepare an annual report for the Executive Director for Operations that provides an

analysis of allegation trends. This annual report fulfills that commitment by providing national,

regional, and site specific trend analyses. 

There were also several agency activities in 2005 involving the Allegation Program that warrant

mention in this report, including new guidance prepared by the staff in the area of safety

conscious work environment. After appreciable stakeholder involvement and endorsement by

the Committee to Review Generic Requirements, Regulatory Issue Summary 2005-18,

“Guidance for Establishing and Maintaining a Safety Conscious Work Environment,” was issued

on August 25, 2005 in accordance with direction provided by the Commission in Staff

Requirements Memorandum (SRM) SECY-04-0111. In the same SRM, the Commission also

directed the staff to enhance the Reactor Oversight Process (ROP) to more fully address safety

culture. This report summaries the significant progress achieved in 2005 on this initiative as

well. ROP enhancements included changes to the Safety Conscious Work Environment crosscutting area and related inspection documents. In addition, the allegations staff continues to

implement the agency sponsored Alternative Dispute Resolution Program for discrimination

allegations and has made revisions to the Allegation Program based on feedback during the

pilot phase of the program. Lastly, an Allegation Guidance Memorandum was developed in

2005 implementing Commission direction to severely limit the release of security-related

information to the public, including allegers. To address concerns that these changes have the

potential to impact the public’s willingness to raise security-related concerns to the Nuclear

Regulatory Commission (NRC), the staff continues to work with the Office of Nuclear Security

and Incident Response to define further guidance on the level of information that is appropriate

to provide to allegers in response to security-related allegations.

With regard to allegation trends, as the figure to the right indicates, from calendar year 2001

through 2005 the number of allegations received by the NRC has remained steady with

incremental annual increases in the reactor area from 2003 to 2005. With the exception of

Region III, increases were seen in each region. Significant contributors to the decrease in

allegations received in Region III since

2002 included the transfer of oversight

responsibility for two large fuel cycle

facilities from Region III to Region II; the

addition of another Agreement State; and

the completion of the extended shutdown

at the Davis-Besse plant. The number of

security-related issues increased in 2005

and again, comprised the largest

percentage of alleged concerns received

in the calendar year. The increase is

attributed to concerns raised during a

national broadcast regarding security at

research and test reactors.

For some licensees, the NRC received allegations in numbers that warranted additional

analysis. In preparing this report, a 5-year history of allegations was reviewed for reactor and

material licensees and vendors to identify adverse trends. The analysis focused on allegations
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 2 of 33

1The total number of allegations received concerning reactor licensees from all sources,

as well as other information concerning the Allegation Program, can be found on the NRC’s

public website at http://www.nrc.gov/what-we-do/regulatory/allegations-resp.html.

that originated from onsite sources to help inform the NRC’s review of the safety conscious

work environment.1 The staff identified 15 reactor sites for a more in-depth review: Salem/Hope

Creek, Browns Ferry Unit 1, Palo Verde Units 1, 2 & 3, Susquehanna Units 1 & 2, St. Lucie

Units 1 & 2, Oyster Creek, Point Beach Units 1 & 2, Byron Units 1 & 2, Callaway, Millstone

Units 2 & 3, Sequoyah Units 1 & 2, Seabrook, Shearon Harris Units 1 & 2, Dresden Units 2 & 3,

and Comanche Peak Units 1 & 2. Allegation trends at each of these sites are discussed in the

report. In summary, the trends either did not suggest a weakening safety conscious work

environment or the licensee is taking steps to address trends and the NRC is monitoring those

activities. No materials licensees or vendors were the subject of allegations at a level that

warranted additional analysis. 
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 3 of 33

OVERVIEW OF SIGNIFICANT PROGRAM ACTIVITIES

Several significant agency activities took place in 2005 that affect the Allegation Program and

warrant discussion in this report. Guidance for establishing and maintaining a safety conscious

work environment was issued in accordance with direction provided by the Commission in Staff

Requirements Memorandum (SRM) SECY-04-0111, dated August 30, 2004. In this SRM, the

Commission also directed the staff to enhance the Reactor Oversight Process to more fully

address safety culture, while continuing to monitor industry and foreign efforts in this area. 

Significant progress was achieved in 2005 on the agency’s safety culture initiative. In addition,

the allegations staff continues to implement the agency sponsored Alternative Dispute

Resolution process for discrimination allegations and has made revisions to the program based

on feedback during the pilot phase of the program. Lastly, the allegations staff responded to

initial guidance from the Commission regarding the release of security-related information to the

public. Consistent with more recent direction from the Commission in SRM-SECY-05-0082, the

allegation staff continues to work with the Office of Nuclear Security and Incident Response to

develop additional guidance on the level of information that is appropriate to provide to allegers

in response to security-related allegations. These areas are discussed in more detail below. 

Safety Conscious Work Environment and Safety Culture

The Commission directed the staff in March 2003 to prepare further guidance for licensees on

establishing a safety conscious work environment (SCWE), that is, an environment where

employees in the nuclear industry are encouraged to raise safety concerns to their employers

or the Nuclear Regulatory Commission (NRC) without fear of retaliation, and where concerns

are effectively addressed. The Commission’s expectation that licensees establish and maintain

a SCWE was outlined in a May 19, 1996, Policy Statement, “Freedom of Employees in the

Nuclear Industry to Raise Safety Concerns Without Fear of Retaliation.” However, the

guidance provided by the policy statement is very broad, and, with the staff continuing to see

SCWE concerns at a variety of facilities, the Commission directed the staff to provide further

guidance to the industry in this area. 

In the Fall of 2003, the staff formed a working group and outlined a draft SCWE guidance

document based on the content of the 1996 Policy Statement. This outline was published in the

Federal Register for comment and was the basis for discussion at a public meeting on February

19, 2004. While most of the stakeholders at the meeting, including representatives from the

industry and whistleblower advocates, agreed on the content of such a document, there were

many comments concerning the format, potential inappropriate use of the guidance, and the

appropriateness of the NRC issuing such guidance. 

Coincident with these comments, the Commission requested through ticketed correspondence

that the staff provide recommended actions regarding agency guidance in the areas of SCWE

and safety culture. In the paper that addressed the Commission’s request, the staff sought

further guidance from the Commission on whether to continue to pursue issuance of the

guidance document, in light of the comments received. In SRM-SECY-04-0111, the

Commission directed the staff to continue its efforts to issue the guidance, following a brief

comment period. In October 2004, the Office of Enforcement (OE) staff published in the

Federal Register for comment the full guidance document, which incorporated many of the

suggestions made as a result of the first public comment period. The staff reviewed all

comments received and made significant revisions in response to comments that the guidance

was too prescriptive and that much of the guidance was applicable only to larger facilities. The
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 4 of 33

Committee to Review Generic Requirements endorsed issuance of the guidance in June of

2005, and Regulatory Issue Summary 2005-018, “Guidance for Establishing and Maintaining a

Safety Conscious Work Environment,” was issued on August 25, 2005. 

Regarding the related area of safety culture, the Commission approved, also in SRM-SECY-04-

0111, the following actions: (1) continue to monitor industry efforts to assess safety culture and

ensure that the Commission remains informed of industry efforts and progress; (2) enhance the

Reactor Oversight Process (ROP) treatment of cross-cutting issues to more fully address safety

culture; (3) include as part of enhanced inspection activities for plants in the degraded

cornerstone column of the reactor oversight action matrix, a determination of the need for a

specific evaluation of the licensee’s safety culture and a method for conducting such an

evaluation; and (4) continue to monitor developments by foreign regulators in this area. The

Commission emphasized the need for inspector training in this area and stakeholder

involvement in the process of enhancing the ROP.

In order to address the Commission’s direction, the OE staff formed a safety culture working

group comprised of members representing the Offices of Nuclear Reactor Regulation (NRR),

Research (RES), Nuclear Material Safety and Safeguards (NMSS), and OE who have expertise

in human factors, SCWE, or inspection. The working group was supplemented by regional

inspectors who provided their expertise in development of the approach to enhance the ROP. 

In addition, OE formed a Safety Culture Steering Committee which is comprised of

management representatives from OE, NRR, RES, NMSS, and Region II to provide policy

direction to the working group and review working group draft products.

In the fall of 2005, the working group, along with internal and external stakeholders, held a

series of public meetings during which an approach to addressing the Commission’s direction to

more fully address safety culture was developed. The approach is consistent with the ROP

framework and involves aligning the current cross-cutting areas with what is important to safety

culture. As such, inspector findings of performance deficiencies identified under the ROP will

be evaluated to determine whether the components of safety culture (i.e, cross-cutting aspects)

contributed to the deficiency. The approach is graded, in that as plant performance

deteriorates and plants move across the ROP action matrix from the “Licensee Response”

column to the “Multiple/Repetitive Degraded Cornerstone” column, NRC inspection and

oversight of the site’s safety culture appropriately becomes more intrusive. The approach also

involves providing more defined assessment criteria for the Safety Conscious Work

Environment cross-cutting area and provides that if a plant is determined to have a substantive

cross-cutting area for three consecutive plant assessments, the NRC may engage the licensee

with respect to safety culture, including requesting that the site conduct an assessment of

safety culture. 

The staff is in the final stages of drafting revisions to several of the baseline, special, and

supplemental reactor oversight inspection procedures, as well as other documents that guide

the staff’s assessment and documentation of findings, to more fully address the area of safety

culture. Initial implementation of the revisions will begin in July 2006. In addition, the staff is

developing training for the NRC staff regarding safety culture and the changes to the inspection

process. This training will also include additional guidance for inspectors in the area of safety

conscious work environment. The staff intends to train inspectors on the revised process

before July 2006. Training for new inspectors with regard to the enhanced ROP and safety

culture will be developed by the end of 2006.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 5 of 33

Consistent with the Commission’s direction, the staff has also continued to monitor industry and

international efforts in the area of safety culture. For example, the staff observed two Institute

of Nuclear Power Operations (INPO) plant evaluations which included safety culture

assessments and used industry and international attributes of safety culture to inform the

NRC’s development of safety culture components. With regard to foreign developments in

safety culture, the working group continues to collect information on safety culture efforts from

foreign regulators, the International Atomic Energy Agency, and the Nuclear Energy Agency. 

The staff reviews such documents to determine their potential usefulness in the agency’s safety

culture initiatives.

The staff intends to provide the Commission with a more detailed status of the staff’s efforts in

this area in a Commission paper in mid-2006.

Alternative Dispute Resolution for Discrimination Allegations

In October 2004, the staff implemented a pilot Alternative Dispute Resolution (ADR) program

which included the opportunity for using ADR early in the allegation process in cases of alleged

discrimination, before the NRC conducts its investigation of the allegation. This allows

additional opportunity for the parties to resolve their differences outside of the normal regulatory

framework. Early-ADR involves the use of a neutral third party to facilitate discussion and

timely settlement of the discrimination concern in an effort to minimize potential negative impact

on the SCWE at the facility involved. At any time, either party can exit the ADR process and, if

the alleger still wants to pursue the discrimination matter, the option of an investigation by the

NRC remains. The staff’s policy under the Early-ADR pilot program is not to pursue an

investigation or subsequent enforcement of discrimination findings which have been settled

through this process. 

From the initiation of the pilot program in October 2004, through the end of calender year 2005, 

24 allegers and their employers, of the 95 that were offered Early-ADR, have agreed to

mediate. Mediation resulted in 8 settlement agreements between the alleger and the licensee

(6 of the 24 are still in progress). The OE staff is continuing to monitor this program with regard

to the number of cases where Early-ADR is pursued, the number of cases that settle, and

indications of the effect of Early-ADR on the SCWE at the involved facilities. 

In October 2005, the NRC staff held a public meeting to discuss stakeholder comments on the

Early-ADR process. Feedback during the meeting was primarily positive with regard to the

effectiveness of the Early-ADR program. However, as a result of feedback received, the staff

has identified several initiatives that will be undertaken to improve the process including: (1)

enhancing the type and amount of information shared between the parties prior to mediation;

(2) clarifying the process for handling technical safety issues raised by the alleger; (3) providing

information to the public on the number of Early-ADR offers, meditations, and settlements; and

(4) providing additional orientation to ADR mediators regarding the NRC’s process and

regulations in the area of discrimination. Stakeholder feedback received and experience in

processing Early-ADR cases has provided insight regarding additional potential enhancements

to the program including: (1) more timely responses of the parties where Early-ADR is offered

and, (2) ensuring appropriate representation of the licensee by individuals who are familiar with

the issue and authorized to make decisions regarding any settlement. 

As stated above, the primary objective of Early-ADR is to minimize potential negative impact on

the safety conscious work environment. The Office of Enforcement recently evaluated the
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 6 of 33

effectiveness of the program to assess its progress toward achieving the objective. Based

upon the evaluation, the staff believes that voluntary dispute resolution by the parties using the

communication opportunities afforded in Early-ADR can stem the inherent damage such

disputes have on the SCWE more quickly than an investigation; however, there is no objective

indication that Early-ADR has had an immediate positive impact on any particular facility’s work

environment. Indications of positive improvements may be limited to facilities that have

successfully used ADR more than once and developed an improved environment over the long

term. The staff concluded that, to date, the information available indicates that the assumed

benefits of the Early-ADR process, including decreased costs and the impact on the SCWE,

warrant continued use of Early-ADR in the Allegation Program. A more detailed assessment of

the pilot program will be provided in a Commission paper.

Implementation of Guidance Regarding Release of Security-Related Information

Because of recent concerns about the release of information related to potential security

vulnerabilities at licensed facilities, the Commission directed the staff, in SRM-SECY-04-0002,

to no longer make certain types of security-related information available to the public. Although

allegation correspondence is not normally made public, the potential does exist that

correspondence to allegers and licensees that could reveal potential security-related

vulnerabilities could be unnecessarily released. 

In 2005, the staff drafted guidance concerning the marking and control of security-related

allegation material (which was subsequently issued in March of 2006). The guidance

incorporated the recommendations of the task group on Sensitive Unclassified Non-Safeguards

Information with regard to the marking and control of security-related material. Consistent with

the Commission’s direction, the guidance reflects that only the stated concern can be provided

to the alleger. Except in cases where there is adequate justification, letters to allegers raising

security-related information no longer provide information on the agency’s inspection activity or

actions taken to resolve the allegation. In such cases where more information is proposed to

be released, coordination with the Office of Nuclear Security and Incident Response (NSIR) is

required. Because this marks a significant change in the amount of information provided to

allegers on security-related issues, the Agency Allegations Advisor has been monitoring the

potential effects of this guidance on the willingness of individuals to raise security allegations to

the NRC. The staff continues to receive negative feedback from allegers and other external

stakeholders regarding this practice and recently has noted an increase in the use of media

outlets and other more public venues to raise such concerns, prompting a more public response

by the agency. Although security-related allegations continue to be a major contributor in the

allegations received by the NRC, even increasing in 2005 compared to the prior year, the staff

continues to look for improved ways to protect sensitive information while still being responsive

to allegers. In particular, in accordance with the Commission’s more recent direction in SRMSECY-05-0082, “Assessment Process for the Security Cornerstone of the Reactor Oversight

process,” to provide more security-related information via the ROP, the staff is coordinating with

NSIR to define further guidance concerning the level of detail which can appropriately be

provided to allegers in response to security-related allegations. The staff will work to develop

an Allegation Guidance Memorandum to provide such guidance during 2006.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 7 of 33

TRENDS IN ALLEGATIONS

The NRC monitors both technical and discrimination allegations to discern trends or marked

increases that might prompt the NRC to question the licensee as to the causes of such

changes or trends. In preparing this report, a 5-year history of allegations received was

reviewed for reactor and material licensees and vendors. The staff focused on those

allegations that have the potential to provide insights into the SCWE at a given facility, that is,

those allegations submitted by current or former licensee or contractor employees or by

anonymous sources that indicate unwillingness to raise safety concerns internally. The staff

performs an analysis of recent allegation activity twice a year in support of the ROP mid-cycle

and end-of-cycle assessments. In addition, an analysis for a particular site or licensee may be

performed whenever allegations or inspection findings indicate that such an analysis is

warranted. 

The staff also conducts reviews to identify national trends for reactor and materials allegations

received, shifts in users of the NRC Allegation Program, and the impact of Allegation Program

implementation on the workload in the regions, NRR and NMSS. These trends are discussed

in the following section.

National Trends

National trends are of interest because they provide general information to the staff concerning

the impact of external factors, plant events, and industry efforts to improve the SCWE at NRC

licensed facilities. In addition, they are useful developing budget and planning assumptions to

support future agency and allegation program needs. Figure 1 below shows that the 5-year

national trend in allegation receipt has remained steady with incremental annual increases in

the reactor area from 2003 to 2005.

As each allegation can include multiple concerns, the number of concerns received provides

more specific information with regard to staff effort needed for appropriate response. The trend

in the total number of concerns received has paralleled the trend of total allegation receipt over

the last five years; that is, the number of concerns received at operating power reactor facilities

over the last five years has increased in all regions except one, and the number of materials

issues received in every region has decreased. The volume of concerns received in Region I

trended upward between 2003 and 2005. The increase in reactor issues during this time frame
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 8 of 33

2Few concerns were received in the areas representing the 20 percent not depicted in

Figure 2. These areas include Access Authorization, Chemistry, Civil/Structural, Construction,

Electrical, Emergency Planning, Employee Concerns Programs, Environmental, Environmental

Qualification, Falsification, Fatigue/Overtime, Industrial Safety, Inservice Testing,

Instrumentation & Control, Licensing, Mechanical, Non-destructive Evaluation, Other,

Procurement, Radwaste, Safeguards, Safety Culture, and Wrongdoing.

can be largely attributed to the identification of a significant SCWE concern at a Region I site. 

Additionally, the responsibility for oversight of all Region II materials licensees was transferred

to Region I in 2003, and in 2004, several Region I reactor sites underwent contract negotiations

or reorganizations. The volume of concerns in Region II has also trended upward for the last

several years. The upward trend in reactor concerns at Region II since 2002 is likely due to

plant specific occurrences related to construction activities at one reactor facility, and an

increasing number of security concerns at several Region II reactor facilities in 2005. The

number of concerns received in Region III over the past five years peaked in 2002, but has

decreased steadily from 2003 to 2005. A significant contributor to the decrease in allegations

received at Region III since 2002 was the transfer of oversight responsibility for two large fuel

cycle facilities from Region III to Region II in 2003. Also in 2003, another state in the Region III

geographical area achieved Agreement State status, wherein materials licensee allegations that

would formerly have been processed by the NRC are now addressed by the Agreement State. 

Events that have also contributed to the reduction in Region III allegations were the resolution

of union/strike issues at one plant and the end of the extended shutdown of another. The

number of concerns received in Region IV fluctuated from 2001 through 2005, generally at

lower totals than the other regions, but did increase notably from 2004 to 2005. This increase

can largely be attributed to one multi-plant site. Overall, there has been an increase in the

number of concerns received at operating power reactor facilities over the last five years in all

regions except for Region III. In contrast, the number of materials issues has declined over the

five-year period in every region. 

Reactor Licensee Trends

To provide further insight into areas in which the NRC is spending resources on reactor-related

allegation follow-up, Figure 2 below depicts the twelve functional areas that represent

approximately 80 percent of the issues received nationwide in 2005.

2

 
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 9 of 33

As indicated in the pie chart, security issues comprised the largest percentage of alleged

concerns received in 2005. Since the terrorist attacks of September 11, 2001, security-related

concerns continue to represent the greatest percentage of concerns received, and in 2005 in

particular, the program saw a 56 percent increase in security-related concerns. In previous

years, increases were attributable to concerns about the effectiveness with which licensees

implemented new NRC Security Orders. Licensees were required to be compliant with those

orders, issued in 2003, by October 2004. More recently, a sharp increase in the number of

security-related concerns was noted in association with a national broadcast in October 2005

regarding security at research and test reactors. In a public response, the NRC noted that

based on the agency’s review of those observations, a continuing review of site-specific security

enhancements, and knowledge of low potential risks associated with such small quantities of

radioactive material, the Nation’s research and test reactors remain safe and secure.

Assertions related to “chilling effect” or a “chilled” work environment in which individuals fear

retaliation or are discouraged from raising safety concerns, has trended upward overall in the

last five years, although the number of issues received in this area has declined from a peak in

2003. While positive industry accomplishments in the SCWE area are believed to have

contributed to the decrease in the receipt of “chilling effect” concerns after 2003, the recent

upward trend (25 percent increase between 2004 and 2005) may reflect an increasing

awareness of SCWE concepts by the nuclear workforce due to increased industry focus in this

area, media interest concerning increased NRC focus in this area at some sites, as well as

recent guidance made publically available by the NRC (i.e., Regulatory Issue Summary 2005-

018, “Guidance for Establishing and Maintaining a Safety Conscious Work Environment,”

issued in August 2005). An increase in the number of sites where potential chilled work

environment issues have been identified is also indicative of increased workforce awareness of

SCWE concepts. 

Regarding the distribution in the four regional offices and NRR of the same twelve areas

illustrated in Figure 2, notable changes from 2004 to 2005 include: (1) a significant increase in

the percentage of issues that relate to security in Region II and NRR. The increase in NRR was

primarily due to the public broadcast regarding research and test reactors discussed above and

the increase in Region II was due to a series of security-related allegations at a few reactor

sites; (2) an increase in the percentage of health physics issues in Region II, primarily due to

one circumstance at one Region II site; and (3) an increase in the number of engineering

concerns in Region IV primarily due to specific incidents at two sites.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 10 of 33

3Few concerns were received for the materials licensee types representing the 20

percent not depicted in Figure 3. These licensee types include Decommissioning Materials,

General Licensee, Irradiators, Nuclear Pharmacies, Other, Transportation, Uranium Recovery,

and Waste Disposal.

Materials Licensee Trends

Because of the many different types of materials licensees and because the activities

performed by materials licensees are not as homogeneous as those performed by reactor

licensees, a comparison of the types of issues received does not produce meaningful results. 

For insights into the areas in which the NRC is spending resources on materials-related

allegations, the following chart depicts the eight materials licensee types from which

approximately 80 percent of the issues have been received nationwide.3

Notable changes in the distribution of materials-related allegation issues received nationally

include an increasing trend in the number of issues related to fuel facilities since 2003, with a

notable increase from 2004 to 2005. Notwithstanding the recent upward trend, the number of

issues received related to fuel facilities from 2003 to 2005 is considerably smaller than those

received in 2001 and 2002. The increase from 2004 to 2005 was largely attributable to a

number of issues received at one fuel facility following a specific event, a change in

management expectations regarding procedural adherence, and a planned workforce reduction

in Fall 2005. There is a decreasing trend in the number of medical and radiography issues

received in the last five years. An analysis of the data indicates no notable reason(s) for the

decreases. In addition, the functional area of exempt distribution was one of the primary

contributors to the allegations received in the materials area, primarily due to concerns received

regarding the sale of products on the internet containing exempt quantities of radioactive

material.

In the regions and program offices, notable changes include a sharp decrease in the number of

decommissioning reactor allegations in Region I from 2004 to 2005 coinciding with the

cessation of decommissioning activities at two sites. In addition, the number of allegations

received related to decommissioning reactors in Region IV increased significantly from 2004 to

2005, primarily due to the receipt of an allegation regarding one facility with numerous

concerns.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 11 of 33

4Few concerns were received from sources representing the 1 percent not depicted in

Figure 4. These sources include Federal Agency and State Agency.

Source Trends

Figure 4 below provides a breakdown of 99 percent of the sources for reactors and materials

allegations received in the last three years.4 The data indicates that the distribution of source

categories remained steady in the 2003 to 2005 time frame. That is, the primary sources of

allegations continue to be licensee (or former licensee) employees and contractor (or former

contractor) employees. It follows that the percentage of reactors and materials allegations from

other sources has also remained largely unchanged for the last three years. One notable

change in the data was the indication of the news media as a more prominent source of

allegations in 2005. This was primarily due to a series of allegations in association with the

October 2005 national broadcast about security at research and test reactors discussed

previously.

In comparing the sources of materials allegations to those of reactor allegations over the past

few years, consistently the largest source for both are licensee (or former licensee) employees. 

It is worth noting, however, contractor employees are a less prevalent source of materialsrelated allegations while private citizens are a more prevalent source. This is understandable

given that materials licensees employ fewer contract personnel and their activities involve more

direct interaction with the public.

Two of the source categories deserve some explanation. The source category designation of

"NRC" is used when an NRC staff member suspects a regulatory requirement has been

violated deliberately or due to careless disregard, prompting the initiation of an investigation by

the NRC Office of Investigations. The source category of "Licensee" is applied in similar

circumstances wherein a licensee representative, acting in their official capacity, reports a

potential wrongdoing matter to the NRC. An allegation process tracking number is assigned to
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 12 of 33

such items so that the staff can track the progress of efforts to review the potential wrongdoing

issue.

Allegation Trends for Selected Reactor Sites 

As noted previously, the trending of allegations received concerning individual reactor sites is

one method the NRC staff uses to monitor the safety conscious work environment at reactor

sites. Statistics on allegations received concerning all operating reactor sites are provided in a 

table in Appendix 1. The allegations in the table cover the 5-year period January 2001 through

December 2005 and include allegations received from onsite sources only; that is, allegations

from current or former licensee employees, current or former contractor employees, or

anonymous allegers. For the purpose of this analysis, the NRC assumes anonymous

allegations are from onsite personnel.

In determining which reactor sites should receive a more in-depth review, the staff applied the

following criteria:

1) The number of onsite allegations received exceeds 2 times the median value for the

reactor industry, but does not exceed three times the median, and there is a 50 percent

increase in the number of allegations received over the previous year; or;

2) The number of onsite allegations received exceeds 3 times the median value.

For CY 2005, the median number of onsite allegations per reactor site was four. The fifteen

reactor sites that met one of these criteria are Salem and Hope Creek (23), Browns Ferry Unit 1

(23), Palo Verde Units 1, 2 & 3 (22), Susquehanna Units 1 & 2 (20), St. Lucie Units 1 & 2 (16),

Oyster Creek (14), Point Beach Units 1 & 2 (13), Byron Units 1 & 2 (11), Callaway (11),

Millstone Units 2 & 3 (10), Sequoyah Units 1 & 2 (10), Seabrook (9), Shearon Harris Units 1 & 2

(9), Dresden Units 2 & 3 (9), and Comanche Peak Units 1 & 2 (9). The first seven sites listed

exceeded 3 times the industry median, while the remaining sites exceeded 2 times the median

and experienced more than a 50 percent increase in the number of allegations concerning the

site. In summary, the trends either do not suggest a weakening safety conscious work

environment or the licensee is taking steps to address trends and the NRC is monitoring those

activities. A more detailed discussion of each of the sites follows.

Salem and Hope Creek

NRC receipt of allegations concerning

Salem and Hope Creek trended upward in

2005 from an already high level in 2004,

indicating continuing issues in the SCWE

area. While the facilities addressed

significant SCWE findings identified in

2003-2004, additional changes at the

facilities in 2005 presented new challenges

to SCWE improvement, including the

licensee’s entrance into a Nuclear

Operating Services Contract with Exelon in

the first quarter, numerous senior

management changes on site, and the
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 13 of 33

implementation of initiatives to address long-standing performance problems. The licensee’s

inconsistent use of the Executive Review Board process early in 2005, the numerous

management changes, and worker uncertainty about the pending merger with Exelon

contributed to a range of worker perceptions regarding the advisability of raising issues or

challenging decisions. 

In the 2005 mid-cycle assessment for Salem and Hope Creek, the staff documented a

substantive cross-cutting issue in the SCWE area based on the results of the NRC’s ongoing

review of the work environment. As a result, Salem and Hope Creek will remain under

enhanced NRC oversight per the Reactor Oversight Program Deviation Memorandum dated

July 29, 2005, which was renewed to closely monitor the licensee’s actions to address issues

associated with SCWE. It should be noted that a substantive cross-cutting issue in Problem

Identification and Resolution (PI&R) was closed in early 2006 after actions taken by the

licensee to improve the resolution of concerns proved effective.

By mid-year, the number of allegations coming to the NRC tapered off and in September 2005,

the staff completed a SCWE inspection at the site which concluded that progress has been

made in addressing work environment issues. The SCWE inspection team noted some issues

that require additional action and focused attention. Specifically, the team identified that, while

the licensee had recognized that there was a wide range of perceptions concerning the work

environment, they had not taken actions to address and resolve the negative perceptions in the

Operations organization in a timely manner. Near-term follow-up actions by the licensee

include, plans to implement actions in response to the NRC SCWE inspection report, (IR

05000272/2005013, 05000311/2005013, and 05000354/2005013), conduct a survey of the

work environment, perform a self-assessment of SCWE, and provide the results of these efforts

to the NRC. 

There were five allegations of discrimination at Salem and Hope Creek in 2005. One of these

is still under investigation, two were not investigated because the concerned individuals

declined to participate in an NRC investigation, and two did not meet the requirements for

initiation of an investigation. In order for the NRC to pursue a matter of potential discrimination,

pursuant to 10 CFR 50.7, a certain pattern of facts, called a prima-facie showing, must be

articulated. Specifically, it must be initially established that an employee has engaged in a

protected activity, that an adverse personnel action was taken against the employee, that

management knew that the employee had engaged in the protected activity, and that the

protected activity was, in part, a reason for the adverse personnel action. In the previous four

years (2001 through 2004), nine allegations of discrimination were raised. Two of these were

closed because a prima facie showing of potential discrimination was not articulated, and

although the remaining seven were investigated, none were substantiated.

In summary, the NRC intends to maintain its enhanced oversight of the SCWE at Salem and

Hope Creek until a licensee self-assessment has concluded that substantial, sustainable

progress has been made, and the NRC has completed a review, the results of which confirm

the licensee's assessment results. 
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 14 of 33

Browns Ferry Unit 1

The number of allegations at Browns Ferry, Unit 1, while high in comparison to the industry

median, has remained fairly steady from 2004 to 2005. The number of allegations increased in

2003 coincident with plant construction activities. 

Unit 1 of the Browns Ferry site is under

construction and has a significant

number of contractors on site. The

majority of concerns received are

consistent with the type of issues

expected at a plant under construction,

in that they involve the training of

individuals performing work or specific

maintenance issues. Almost half of the

allegations received involved health

physics concerns related to one

circumstance. The licensee also noted

that the issues received internally were

consistent with concerns typical of a

plant under construction and the

increase in health physics issues. In

response to the increase in health physics issues raised internally, the licensee trained its

contractor on the as-low-as-is-reasonably-achievable concept in late 2005.

The licensee has taken a number of steps to monitor the SCWE. These included providing

SCWE training for contractor personnel, performing assessments of the safety conscious work

environment, and implementing program improvements such as assignment of a new

Organizational and Cultural Manager to oversee the Employee Concerns Program (ECP). The

licensee’s Office of the Inspector General completes a SCWE assessment of all of the TVA

sites every other year. The assessment in 2004 showed an improvement in the safety

conscious work environment with regard to individuals’ willingness to raise concerns and their

knowledge of the avenues available for raising concerns. However, the assessment indicated

that only 73 percent of individuals surveyed at Browns Ferry had confidence that problems on

site are resolved. The licensee attributed this less positive result to several issues associated

with the corrective action program, including concerns that the threshold for writing corrective

action documents was too low, unfamiliarity with the site’s new electronic corrective action

system, problems with the software upon start up of this new system, perceptions that the root

causes of problems were not always addressed, and a perception that corrective action

documents are written in a punitive manner, including naming individuals involved in problems

identified. In response to this information, the licensee has taken actions to provide information

to employees on the type of issue and information that is not appropriate for entry into the

corrective action system, address the software issues associated with the electronic corrective

action system, and communicate information regarding the purpose and changes to the

corrective action system.

In the past three years, there has been an increasing number of allegations of discrimination

received. However, the results of investigations performed in response to these issues has not

substantiated that discrimination occurred. Of the three discrimination allegations received in

2004, two were withdrawn by the concerned individual and one was investigated, but not
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 15 of 33

substantiated. Of the four received in 2005, two are still ongoing and one was withdrawn by the

concerned individual. The licensee noted a slight decrease in the number of discrimination

complaints raised internally in 2005. 

The nature of allegations received, the lack of a trend in the total number received, along with

the volume of concerns being raised internally, do not indicate a weakening SCWE. However,

the NRC will continue to monitor the work environment through normal inspection activities,

including a review of the actions the licensee takes to improve it, and the general allegation

trends at the Browns Ferry Unit 1 site.

Palo Verde Units 1, 2 & 3

The number of allegations from onsite sources concerning the Palo Verde site increased to its

highest level in the last five years. An increasing trend in engineering-related concerns was

evident in the issues raised. However,

the NRC does not believe the increased

number of allegations represents a

SCWE concern given that several of the

issues were very similar in nature and

were from a small number of allegers. 

The licensee’s Employee Concerns

Program also saw an increase in the

number of concerns raised in 2005,

although not as significant as the

increase in allegations and mostly

attributed by the licensee to the unique

activities related to steam generator

replacements late in the year.

The licensee, Arizona Public Service (APS), has taken several actions to monitor and maintain

a healthy SCWE at Palo Verde. In the first quarter of 2005, APS commissioned an

independent assessment and survey of the safety culture and safety conscious work

environment. In August 2005, the NRC met publically with APS to discuss the results of the

survey. The results indicate the workforce believed the SCWE was “very good to excellent.” A

significant percentage of employees indicated they would raise safety concerns to their

supervisor or write a condition report and, if unsatisfied with the response, escalate the matter

up the chain of command. Additionally, very few indicated they were aware of any negative

reactions to employees raising concerns. According to the licensee, leadership training in

safety culture and SCWE principles was also recently completed.

There have been no substantiated allegations of discrimination during this review period. Four

claims were made in 2005, all of which are still open. Five allegations of discrimination were

made between the years 2001 and 2004. All were investigated but the agency did not find

sufficient evidence to substantiate the discrimination as alleged.

Although Palo Verde has a high number of allegations, the trends do not suggest a weakening

SCWE; neither do the results of the licensee’s 2005 independent evaluation of the safety

culture and SCWE. The NRC will continue to monitor, through its normal inspection,

investigation, and allegation review processes, the SCWE at Palo Verde.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 16 of 33

Susquehanna Units 1 & 2

Although NRC receipt of allegations regarding Susquehanna trended downward from 2001

through 2003, the number of allegations increased significantly in 2004 and continued an

upward trend in 2005. While review of

individual allegation issues prior to

mid-2005 found no particular pattern or

trend in the disciplines involved, numerous

issues received in the latter half of 2005

highlighted outage maintenance support

activities. NRC follow-up efforts with

regard to this area are in progress. 

In the Fall of 2004, the licensee conducted

an independent review of the effectiveness

of their ECP. The contractor found that

although the program effectively addresses

employee concerns, it does not always

recognize the potential impact

management actions may have on the work environment and recommended a number of

enhancements. Follow-up actions from that assessment were completed in 2005, including a

revision of company policy and communications reinforcing the licensee’s commitment to

SCWE, presentations to work groups by ECP, improved supervisory training, and expansion of

responsibilities for the Employee Concerns Oversight Team. SCWE surveys have been

conducted by the licensee at Susquehanna periodically since 1997, and most recently in 2003. 

The licensee has been addressing issues noted in the maintenance and design engineering

areas during the 2003 SCWE survey, and is continuing to address more recent issues in the

maintenance area resulting from scheduling and assignment changes. Another SCWE survey

will be conducted later in 2006 to assess the effectiveness of actions taken. The licensee also

intends to use outside consultants with SCWE expertise to examine the work environment

within certain work groups at Susquehanna, including Maintenance. 

There were six allegations of discrimination filed in 2005 at Susquehanna. One of these was

closed because a prima facie showing of potential discrimination was not articulated, one is

currently under investigation, and one is in the Early-ADR process. The three remaining

allegations of discrimination were received late in 2005, and were in the early stages of review

when this report was written. In the previous four years (2001 through 2004), ten allegations of

discrimination were raised. Five of these were closed because a prima facie showing of

potential discrimination was not articulated, and although the remaining five were investigated,

none were substantiated.

The NRC will continue to monitor with interest the licensee’s progress with their indicated

initiatives and assessments, in an effort to obtain a clearer picture of work environment issues

at Susquehanna. Similarly, the willingness of personnel to raise safety concerns will be probed

during interviews conducted as part of the ongoing NRC investigations of discrimination

allegations at the site.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 17 of 33

St. Lucie Units 1 & 2

Although St. Lucie’s allegation trend over the past five years is down, the number of allegations

from the site increased in 2005 over the previous year. There were some activities on site

during 2005 which likely contributed to the

noted increase. For example, the licensee

completed two refueling outages, and,

during the fall outage, the licensee

replaced the reactor vessel head and

pressurizer head, which were both

significant and unique activities. In

addition, a union contract was voted down

during 2005. An increase in the number of

concerns raised through the ECP and to

the NRC coincided with the fall outage.

A review of the allegations received in

2005 indicated that approximately a fifth of

the concerns received related to the

willingness of employees to raise concerns. However, a review of the actual content of the

concerns did not indicate a specific SCWE-related trend that concerns the NRC; that is, since

the concerns involved very isolated incidents or narrowly focused issues they did not represent

a broader SCWE issue. The NRC also received several allegations regarding security. To

ensure that we are not unnecessarily releasing information that would reveal any potential

security-related vulnerabilities, the NRC staff is not at liberty to discuss specific information

concerning actions taken by the agency or licensee in the security area. The NRC and licensee

have taken all necessary actions to address potential security-related concerns that may have

been identified during the course of the NRC’s review of these allegations. The licensee

similarly noted a slight increase in the number of concerns raised internally through the ECP

and the Corrective Action Program, and many of these concerns were in the area of security.

In response to an NRC-identified concern with the plant’s SCWE in late 2003, the licensee

initiated several actions to measure and improve the work environment on site, including

restructuring the organization, monitoring the SCWE annually using survey tools, providing

SCWE training, enhancing the corrective action program, and initiating a Leadership

Development Academy. The licensee indicated that there was evidence of an improving SCWE

in 2004. A 2004 PI&R inspection (IR 05000335/2004007 and 05000389/2004007) conducted

by the NRC staff similarly did not identify any reluctance by the plant staff to report safety

concerns. In 2005, the NRC staff reviewed the effectiveness of the ECP and Corrective Action

Program in dealing with SCWE issues (IR 05000335/2005003 and 05000389/2005003). In

general, the NRC found that the SCWE at the St. Lucie plant appeared to be healthy and

employees felt free to raise issues to their management without fear of retaliation, the

licensee’s ECP organization was effective in investigating and facilitating the resolution of

employee concerns and appropriately addressed individual’s concerns, and the licensee was

timely in responding to employee concerns with the appropriate prioritization placed on the

safety significance of the issue. 

The licensee’s annual SCWE survey in August 2005 indicated that some individuals may be

reluctant to raise concerns through one or more of the methods available and, in particular, the

condition reporting system was identified as an area of concern by the workforce. In response,
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 18 of 33

the licensee implemented a new electronic reporting system, established a performance

improvement department which monitors the Corrective Action Program’s effectiveness, and

completed training on the new program. The purpose of the training was to ensure that

employees have an understanding of how management prioritizes issues raised based on their

safety significance.

The licensee indicated that SCWE issues remain in some organizations on site, and that in

many cases these issues resulted from management styles that were not conducive to a

healthy SCWE. During 2004 and 2005, senior licensee management emphasized the

importance of a healthy SCWE, through supervisory development training and reorganization or

removal of supervisors when necessary.

The number of discrimination allegations received over the last five years has remained fairly

steady. In 2005, there were four allegations of discrimination filed. One was not substantiated

and three were still being investigated at the time this report was written. In 2004, there were

three allegations of discrimination raised. Of these three, concerned individuals in two of the

cases withdrew their allegations, and one was investigated, but not substantiated. Between

2001 and 2003, there were six discrimination allegations filed; all were investigated, but none

were substantiated.

The similarity in the number and nature of concerns raised internally and externally and the

timing of the receipt of these concerns with significant and unique onsite activities indicates that

the increase noted in 2005 was likely not the result of a decline in the SCWE. However,

recognizing that isolated SCWE issues exist in certain organizations on site, the NRC will

continue to monitor the work environment at the St. Lucie site to assess the effectiveness of the

licensee’s recent actions and take further regulatory actions if necessary.

Oyster Creek

Although the volume of allegations concerning the Oyster Creek experienced a 50 percent drop

from 2003 to 2004, an increase in 2005 from the prior year was noted. A review of the

individual issues received in 2005 found no particular pattern or trend in the disciplines involved.

There were two allegations of

discrimination in 2005 concerning activities

at Oyster Creek. One is under

investigation, and one is in the Early-ADR

process. Eight allegations of

discrimination were raised at Oyster Creek

from 2001 to 2004. Six of the eight were

closed because a prima facie showing of

potential discrimination was not articulated. 

The other two discrimination issues were

investigated, but not substantiated.

The licensee, Exelon, performed a selfassessment of the ECPs across the

Exelon Fleet, including Oyster Creek, in 2005. The self-assessment looked at licensee

employee and contractor familiarity with ECP, the categorization of concerns received, ECP

issue trending and follow-up, and corrective action effectiveness. Results of the self-
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 19 of 33

assessment with regard to Oyster Creek were positive. A SCWE self-assessment is scheduled

to be conducted at Oyster Creek in June 2006.

The NRC will continue to monitor the safety conscious work environment through its normal

inspection and oversight processes. The NRC will also monitor the actions the licensee takes

to improve the work environment as well as the general allegation trend at the Oyster Creek

site.

Point Beach Units 1 & 2

The volume of allegations received concerning the Point Beach site reflects a slightly increasing

trend over the past five years. Discussions with the licensee identified that, while the number of

allegations increased in 2005, concerns

raised via the licensee’s ECP declined by

approximately 40 percent. A review of the

issues raised in the 2005 allegations indicates

a number of the concerns were related to

weaknesses in the SCWE, in that they

involved either claims of discrimination, a

chilling effect of the environment for raising

concerns internally, or concerns about the

effectiveness of the Corrective Action

Program. The NRC staff identified a

substantive cross-cutting issue in the area of

PI&R in 2002 and subsequent assessment

periods. The licensee’s commitments to

make sustained improvements were documented in an NRC Confirmatory Action Letter (CAL)

dated April 21, 2004. A review of the licensee’s actions recently concluded that the licensee

had made progress on most of the CAL commitments and the NRC determined in the most

recent annual assessment that the PI&R substantive cross-cutting issue would be closed. 

The NRC’s evaluation of the SCWE during the 2004 PI&R inspections (IR 05000266/2004008,

05000301/2004008) and 2005 (IR 05000266/2005012, 05000301/2005012), determined that

workers at the site felt free to input nuclear safety concerns into the Corrective Action Program. 

However, the NRC noted that an independent safety culture assessment in mid-2004 and a

survey of the workforce commissioned by the licensee in late 2004 identified that some workers

did not trust management’s ability to appropriately address issues raised. Actions taken in

response to the CAL and the mid-year assessment, prior to the results of the survey being

known, were designed to improve 1) site leadership behaviors related to safety culture and

SCWE, 2) the prioritization of site initiatives, and 3) communication of operational decisions. 

The licensee expects these actions to also address the declining trust issues identified in the

most recent survey. The survey also characterized a number of specific departments on site

that warranted near-term management attention due to their significantly lower SCWE ratings

and declining trends. The NRC reviewed the actions taken by the licensee during the 2005

PI&R inspection. The inspectors provided the observation that the licensee’s actions regarding

increased management attention fell short of that called for by the survey’s independent

assessor. 

On March 23, 2006, the staff held a public meeting with the licensee to further discuss actions

taken or planned for these specific departments and general work environment. The licensee
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 20 of 33

again described the general actions mentioned above, but provided no information specific to

the departments identified with declining SCWE trends during the meeting. The NRC is aware

that leadership assessments conducted by the licensee resulted in the coaching or replacing of

some supervisors in these departments. Training described by the licensee to improve

leadership behaviors related to safety culture and SCWE has not yet been completed. Shortly

after the public meeting, the licensee told the NRC it would conduct another survey early in the

summer 2006 to assess the effectiveness of their corrective actions. The NRC will review the

survey’s findings and licensee’s actions to address the findings during the normal inspection

process.

The NRC also saw an increasing trend with regard to allegations of discrimination. Five

discrimination allegations were raised in 2005, two of which were not investigated because a

prima-facie showing of potential discrimination was not articulated, and three of which are still

open. Of the three allegations of discrimination raised in 2004, two are still open and one was

investigated and not substantiated. Between 2001 and 2003, six discrimination claims were

made, four of which were investigated but not substantiated and two which did not make a

prima-facie showing.

The NRC continues to closely monitor the SCWE at the Point Beach site, including the ongoing

investigations of discrimination allegations and the licensee’s actions to address the SCWErelated findings identified in the 2004 survey, and will continue to take additional actions if

warranted.

Byron Units 1 & 2

Although allegations concerning the Byron site have trended down for several years, in 2005

the trend reversed itself. A review of the individual issues found no pattern or trend in the

disciplines involved that would indicate a significant weakness in the SCWE. Similarly, the

licensee indicated that the number of

concerns going to their ECP increased

significantly in 2005. The licensee’s Nuclear

Safety Review Board questioned the

increase and management took actions to

improve communications to the workforce

concerning events and decisions thought to

have contributed to the increased concerns. 

After an increase particularly in the first two

quarters of the year, concerns to the ECP

trended down during the remainder of the

year. A Fall 2005 licensee initiated selfassessment of the ECP resulted in actions to

improve workforce understanding of the

licensee’s SCWE policy at Byron, and other Exelon sites.

The NRC assessed the health of the SCWE during the June 2005 PI&R inspection (IR

05000454/2005008, 05000455/2005008) and found that workers expressed no concerns about

identifying issues, and felt comfortable discussing them with supervision without fear of reprisal. 

The team also observed that all personnel interviewed were aware of the different avenues

through which they could express concerns including the Corrective Action Program, informing

their supervisor or plant managers, contacting the ECP coordinator, or coming to the NRC;
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 21 of 33

however, many workers said they preferred reporting issues directly to their immediate

supervisor. Workers were generally familiar with the ECP and expressed no concerns with

utilizing it. 

Three allegations of discrimination were raised in 2005. One was settled between the parties

without NRC investigation using the NRC’s Early-ADR Program. The other two remain open

and under investigation. In 2001, a discrimination allegation was substantiated by the NRC. 

Corrective actions by the licensee were comprehensive and taken fleet-wide. Regarding the

intervening three years, four discrimination allegations were raised. In 2004, the alleger did not

articulate a prima-facie case and the concern could not be investigated. The allegation raised

in 2003 was investigated but not substantiated. Of the two allegations raised in 2002 neither

was investigated; one did not make a prima facie showing and the other was a third-hand

complaint of suspected retaliation. The NRC does not pursue third-party complaints due to the

lack of specific information about the alleged act and permission from the individual named to

release his/her name to the licensee. 

The NRC will monitor the open investigations into the claims of discrimination and continue to

monitor trends in the allegation data for indications of a weakening safety conscious work

environment.

Callaway

The number of concerns received regarding the site increased significantly from 2004 to 2005.

The licensee noted a similar increase in the number of concerns raised internally through the

ECP. Trending of the allegations received indicated that the majority of the concerns related to

security. To ensure that we are not unnecessarily releasing information that would reveal any

potential security-related vulnerabilities, the

NRC staff is not at liberty to discuss specific

information concerning actions taken by the

agency or licensee in the security area. The

NRC and licensee have taken all necessary

actions to address potential security-related

concerns that may have been identified during

the course of the NRC’s review of these

allegations. The licensee similarly noted that

many of the concerns raised internally related

to security. The licensee noted that in 2005,

the security force at the site voted in a labor

union and that contract negotiations to date

have not been successful. These negotiations

may have contributed to the increase in allegations noted. 

In addition to contract negotiations in the security force, the licensee noted that in the fall of

2005, a major outage was conducted during which four steam generators and several low and

high pressure turbine rotors were replaced. These major and unique activities likely impacted

the number of concerns raised internally. Additionally, in 2005 the Board of Directors tasked

the current plant management with improving plant performance. As part of this effort, several

senior managers on site were replaced and expectations and accountability of the plant staff

have been increased. The change in management, higher expectations regarding the need to
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 22 of 33

identify and resolve safety issues, and some anxiety regarding the changes may have impacted

the number of allegations received by the NRC.

The number of discrimination complaints also indicates an increasing trend, with the number

increasing from 0 in 2004 to four in 2005. Of the discrimination concerns received in 2005, one

was settled through the NRC’s Early-ADR pilot process, and three are still being evaluated by

the NRC. Between 2001 and 2003, there were three allegations which included a claim of

discrimination, one in each of the three years. None of these allegations were substantiated.

The licensee indicated that in the last few years, significant emphasis has been placed on

improving the visibility of the ECP and establishing a SCWE. For example, since 2003, the

licensee has developed a website for the ECP, incorporated SCWE concepts and expectations

into supervisory skills training, and provided briefings regarding the SCWE for contractors

working on site. The most recent PI&R inspection conducted by the NRC staff in May 2004

indicated that most individuals were aware of the changes to the program (IR

05000483/2004006). The licensee attributes a noted increase in the number of concerns raised

internally both through the ECP and in condition reporting, to these efforts. The licensee also

noted a decreasing trend in the number of corrective action documents filed anonymously,

which indicates that individuals feel free to document issues without fear of retaliation.

During the NRC’s PI&R inspection, the NRC staff concluded that a SCWE exists at the site. 

However, some negative comments regarding confidence in the Corrective Action Program

were made during interviews. The NRC did determine in 2004 that a cross-cutting issue in the

area of PI&R existed. However, since that time, the NRC has determined that the licensee has

taken sufficient actions to address the issues related to PI&R, such as revising the methodology

for conducting root causes and the threshold for initiating problem reports. As a result, the

cross-cutting issue was closed. A recent assessment conducted by the NRC (IR

05000483/2006002) concluded that further improvements in the area of corrective actions were

needed, but that the licensee had made significant improvements. 

The licensee had a site survey conducted by an independent contractor in May 2005. The

results of the survey demonstrated that workforce perceptions of the SCWE and ECP had

improved significantly. The employee concerns staff provided recommendations to address

specific issues in some departments following the survey. The licensee attributes the

improvement to changes in site senior management and efforts to address equipment reliability

and human performance issues. The new management team continues to emphasize

accountability and increased standards, and the licensee has noted some concerns internally

related to this increased accountability.

The similarity in the type and number of concerns raised internally and externally, the site

activities which likely contributed to the noted increase in the number of allegations received by

the NRC, and improvements noted in the SCWE as a result of the recent independent survey

results indicate that the increase in allegations noted does not represent a decline in the site’s

safety conscious work environment. However, the NRC staff will continue to monitor allegation

trends, efforts taken by the licensee to improve the SCWE, and results of the site’s SCWE

assessments for insights into the work environment at Callaway.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 23 of 33

Millstone Units 2 & 3

There was a significant increase in allegations regarding Millstone in 2005, primarily in the

security area. To ensure that the NRC is not unnecessarily releasing information that would

reveal any potential security related

vulnerabilities, the NRC staff is not at liberty to

discuss specific information concerning

actions taken by the agency or licensee in the

security area. The NRC and licensee have

taken all necessary actions to address

potential security-related concerns that have

been identified during the course of the NRC’s

review of these allegations. The licensee has

acknowledged the increasing level of concern

from onsite sources in the security area.

There were six allegations of discrimination in

2005 concerning activities at Millstone. All six

are still under investigation, and several are interrelated. The state of Connecticut (Attorney

General and Department of Public Utility Control) has shown an interest in some of the

discrimination cases and is conducting its own investigation of at least one alleged

discrimination case. Four allegations of discrimination were raised at Millstone from 2001 -

2004 (three in 2002 and one in 2004). Of the three discrimination allegations raised in 2002,

one was investigated and not substantiated, and the others were not investigated because a

prima facie assertion of discrimination was not articulated. The alleger in 2004 was also

determined not to have articulated a prima facie assertion of discrimination.

An analysis of the trends in allegations does not suggest a SCWE problem at Millstone. The

licensee continues to monitor their work environment using survey tools. A facility-wide culture

survey was conducted in late 2004 and identified no areas of concern. Another culture survey

is planned for late 2006. The staff will continue to monitor the general trend of allegations,

particularly in the security area. The staff will also continue to monitor trends in the licensee’s

internal reporting programs through normal inspection and oversight processes, as well as the

open discrimination case files.

Sequoyah Units 1 & 2

The number of allegations at Sequoyah has been relatively steady over the review period and

has remained near the median number for

operating power reactors. However, from

2004 to 2005 there was a notable increase in

the number received. No trend was noted in

the 2005 allegation data. The licensee also

noted an increase in the number of concerns

raised through the site’s employee concerns

program. Most of the issues received

internally were reported during the site’s

spring outage; the number of concerns

received by the NRC similarly increased
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 24 of 33

coincident with the spring outage. The number of condition reports generated by site

employees has remained relatively constant.

Contacts with NRC regional staff and the site indicate that no unusual activities occurred on site

which may have contributed to the increase in allegations in 2005. None of the performance

deficiencies identified during the NRC’s baseline inspection program had cross-cutting aspects

in the areas of SCWE or PI&R as it relates to willingness to raise concerns. 

As discussed under Browns Ferry Unit 1 above, the licensee’s Office of the Inspector General

completes a SCWE assessment of all of its sites every other year. The last assessment,

conducted in 2004, did not identify significant problems. The survey indicated that employees

at Sequoyah would raise safety concerns and that they knew what venues were available to

them for raising concerns. Slightly fewer employees, however, believed that the licensee was

resolving safety issues that were raised. The corrective actions described for Browns Ferry

Unit 1 were also taken at the Sequoyah plant in response to these findings. The licensee has

also created a position for organizational cultural initiatives that reports to the company Chief

Nuclear Officer and oversees the licensee’s efforts with regard to the ECP. The licensee is

planning to conduct a safety culture assessment in May 2006 to assess the effectiveness of

actions taken improve the SCWE.

The lack of a trend in the types of allegations received and the timing of the issues received

indicates that there is not a concern with a weakening SCWE. The NRC will continue to

monitor the number and nature of allegations received as well as the results of the upcoming

SCWE assessments during normal inspection activities to further evaluate the safety conscious

work environment.

Seabrook

There was a noted increase in allegations regarding Seabrook in 2005, primarily in the security

area. The licensee also had some similar concerns raised internally. To ensure that the NRC

is not unnecessarily releasing information that

would reveal any potential security-related

vulnerabilities, the NRC staff is not at liberty to

discuss specific information concerning

actions taken by the agency or the licensee in

the security area. The NRC and licensee

have taken all necessary actions to address

potential security-related concerns that have

been identified during the course of the NRC’s

review of these allegations. The licensee has

acknowledged and is addressing the

increasing level of concern from onsite

sources in the security area.

There were three allegations of discrimination in 2005 concerning activities at Seabrook. All are

still under investigation. Two allegations of discrimination were raised at Seabrook from 2001

to 2004. A 2002 discrimination concern was investigated and was not substantiated. In 2004,

after review of a Department of Labor Administrative Law Judge finding of discrimination, the

NRC sent "chilling effect letters" to Florida Power and Light (FPL, the licensee for Seabrook) as

well as to another affected utility and a contractor, requesting information on any actions
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 25 of 33

planned or taken to mitigate potential impacts of this finding on their respective SCWEs. FPL’s

November 2004 response to the chilling effect letter emphasized the company’s commitment to

maintaining a SCWE, and discussed recent initiatives that included training and assessment

with regard to SCWE, such as a Leadership Forum/Supervisory Development Academy

initiated in 2004, safety culture training provided to FPL Nuclear Division managers in 2003 on

lessons learned from the Davis-Besse incident, development of company policy documentation

regarding SCWE in December 2004, and conduct of an annual SCWE survey at each FPL

plant in October 2005. While the results of the SCWE survey are being independently

evaluated, the licensee has taken some actions to gather supporting information from the

workforce through focus groups to help structure any actions needed to respond to the findings.

Based on a review of the Office of Investigation’s report and DOL documentation related to the

2004 matter, the NRC concluded that the concerned individual voluntarily left a position at the

other facility and was not discriminated against in that instance. However, an apparent violation

was identified at Seabrook and was considered for escalated enforcement in accordance with

the NRC Enforcement Policy. The apparent violation of 10 CFR 50.7, "Employee Protection,"

involved the individual’s de-selection for employment by a contractor at Seabrook, for engaging

in a protected activity (for expressing a safety concern at another facility). After taking into

consideration that FPL had no knowledge of the decision by the concerned individual’s contract

employer not to hire him/her, and the actions taken by FPL in response to the chilling effect

letter of October 20, 2004, the NRC decided not to pursue enforcement action against the

licensee. 

An analysis of the trends in allegations does not suggest a SCWE problem at Seabrook. The

licensee continues to monitor its work environment through annual SCWE surveys along with

SCWE training and guidance provided by other established processes. The NRC will continue

to monitor the general trend of allegations through normal inspection and oversight processes,

particularly in the security area. The NRC will also monitor trends in the licensee’s internal

reporting programs, as well as the open discrimination case files at Seabrook.

Shearon Harris Units 1 & 2

The number of allegations at Shearon Harris increased significantly from zero in 2004 to nine in

2005. The number received in 2005 was a significant difference from the number received in

any of the last 5 years. The majority of the

concerns received were in the area of

security. To ensure that we are not

unnecessarily releasing information that would

reveal any potential security-related

vulnerabilities, the NRC staff is not at liberty to

discuss specific information concerning

actions taken by the agency or the licensee in

the security area. The NRC and licensee

have taken all necessary actions to address

potential security-related concerns that may

have been identified during the course of the

NRC’s review of these allegations. 

The licensee confirmed that they too had seen a notable increase in the volume of concerns

raised internally by their employees specifically in the area of security. The similarity of the
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 26 of 33

information indicates that licensee employees were willing to raise issues internally as well as to

the NRC. There are a number of factors which may have impacted the increase in the number

of allegations at the site. For example, there is an ongoing effort to unionize many positions on

site and there was a voluntary reduction in force in 2005. There has also been frequent

turnover in security management.

The licensee identified that there was an increase in the number of concerns received internally

and externally in the area of security by mid-2005 and, as a result, conducted an assessment of

the safety conscious work environment in that department. The licensee assessment indicated

actions to improve the SCWE were warranted and the licensee has instituted a plan to address

such issues. Discussions with the site indicated that some improvements in the work

environment in the security department have been noted, such as a willingness of the security

force to interact directly with a newly appointed Project Manager. The NRC recently conducted

an inspection of security concerns at Shearon Harris, including issues that involved SCWE. 

The NRC did not identify widespread reluctance among workers at the plant to raise safety

concerns; rather, the issues in the security department related to one type of issue. The

licensee took appropriate steps to address this concern.

The number of discrimination concerns has not increased in the last five years. Only one

allegation of discrimination has been received in the last five years. That allegation was

received in 2002, but later withdrawn at the request of the individual. 

The data supports that issues impacting the SCWE in the security department are limited to

that department and the NRC found that the issues in the department are related to one type of

issue. The licensee is addressing the issues in a proactive manner. The NRC will continue

under the normal inspection and oversight processes to monitor allegation trends and the work

environment.

Dresden Units 2 & 3

Similar to the trends at Byron, another Exelon site, the allegations concerning the Dresden site

have trended down for several years, but in 2005 the trend reversed itself. A review of the

issues, however, found no pattern or trend

indicating a weakening SCWE site-wide or in

any one particular area. Based on

discussions with the licensee, the number of

concerns raised internally to the licensee’s

ECP remained steady over the last two

calendar years. A Fall 2005 licensee initiated

self-assessment of the ECP resulted in

actions to improve the visibility of ECP

personnel at Dresden, and other Exelon sites.

With regard to allegations of discrimination

there was a slight increase in 2005. Three

allegations of discrimination were made to the

NRC in 2005. Two of the allegations were not investigated because a prima facie showing of

discrimination was not articulated. The remaining 2005 discrimination allegation is still open

and under investigation. Two allegations of discrimination, one in each year, were raised in

2002 and 2003 and investigated, but the agency did not find sufficient evidence to substantiate
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 27 of 33

the allegation. Nonetheless, the allegations remain open pending conclusion of Department of

Labor proceedings on the same cases. There were 10 allegations of discrimination raised at

Dresden in 2001; seven of the 10 were investigated by the agency but not substantiated, one

did not make a prima facie showing, and two were withdrawn by the concerned individuals. 

Corrective actions, including conducting SCWE training for supervisory personnel, were taken

by the licensee at all its sites, including Dresden, after a finding of discrimination at Byron in

2001.

The NRC will continue to monitor the SCWE at the Dresden site through normal processes,

including the ongoing investigations of discrimination allegations, inspections, and allegation

program data reviews. 

Comanche Peak Units 1 & 2

The number of allegations at the site increased sharply from two to nine from 2004 to 2005. A

review of the allegations received indicates that many of the concerns related to technical

issues in the Quality Assurance organization

and chilling effect allegations in both the

Quality Assurance and Operations

organizations. The number of discrimination

complaints has also risen from zero in the last

four years, to three in 2005.

The licensee similarly noted an increase in

the number of quality assurance issues raised

internally. The licensee attributes the issues

raised mostly to an audit conducted by the

quality assurance group of the procurement

quality assurance group within the same

organization which created some animosity

among the groups. The licensee had recognized the potential impact of this animosity on the

SCWE and had completed a cultural survey of the organization in 2005. The survey identified

that there were issues of trust and resentment among the staff in the Quality Assurance

organization. The licensee continues to take actions to address the work environment in the

organization through implementation of a communication plan, completing personality analysis

of the individuals in the organization to glean insights about the manner in which those in the

organization could work to improve the environment, and emphasizing behavioral expectations. 

The licensee had also identified the work environment issues in the Operations department and

attributed the issues to a rapid turnover in Operations management over the last few years. 

The new management has emphasized the importance of using human performance tools and

has held individuals accountable for the use of such tools; these changing expectations may

have caused some tension among the workforce that was reflected in concerns raised to the

NRC. In 2003, the licensee performed a SCWE survey of shift personnel and found a

significant percentage of shift operations personnel felt intimidated or discouraged from raising

safety issues. A follow-up survey in 2004 indicated marked safety culture and organizational

improvements, mostly in the area of management styles, that were more conducive to

encouraging raising concerns. However, approximately 30 percent of licensed reactor

operators continued to express that they felt intimidated or discouraged from raising safety

concerns.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 28 of 33

The PI&R inspection conducted by the NRC staff in July 2005 concluded that the licensee had

established a SCWE at Comanche Peak (IR 05000455/2005009 and 05000446/2005009). The

team determined that employees and contractors felt free to enter issues into the Corrective

Action Program and raise safety concerns to their supervision, to the ECP, and to the NRC. All

plant personnel interviewed by the team, stated that potential safety issues were addressed by

the licensee. However, the licensee had identified long-term organizational effectiveness

issues within the Operations department, which continued to challenge the SCWE for shift

operations personnel. The team concluded that licensee's past actions to improve the

Operations department organizational effectiveness had not been fully effective.

A survey completed by an independent contractor in the fall of 2005 indicated improvements in

the overall SCWE at the site and the site was categorized as being in the top quartile of the

commercial nuclear power sites in the contractor’s database for almost all key cultural metrics. 

However, the results of the survey reiterate that some SCWE issues exist within the Quality

Assurance and Operations organizations. The survey also identified an additional area of focus

in the warehouse department, which is responsible for procurement activities. The licensee

plans to solicit input from employees in these areas regarding the reasons for their negative

responses such that action plans can be developed to address the causes of the work

environment issues in these departments.

There is similarity in the areas identified by the NRC staff and the licensee as having challenges

to the safety conscious work environment. Actions are continuing to be taken by the licensee to

address these issues. The NRC staff will continue to monitor the licensee’s actions to improve

the safety conscious work environment in areas identified as warranting increased attention.

Allegation Trends for Selected Materials Licensees

Recently the NRC began posting certain fuel cycle facilities’ allegation statistics on its website

(see Appendix 1). Similar information has been available for reactors for a number of years. 

But because of the small number of allegations received concerning other smaller materials

licensees and because of the potential for a licensee or contractor to identify an alleger, tables

of statistics on allegations concerning materials licensees other than fuel cycle facilities have

not been provided publically or included in this report. None of the material licensees, fuel cycle

facilities or otherwise, received a sufficient number of allegations to discern a trend or pattern,

or provide insights into the safety conscious work environment, therefore, more in-depth

reviews of specific materials licensees were not performed. 

Allegation Trends for Selected Vendors

Because none of the vendors received a sufficient number of allegations to discern a trend or

pattern, or provide insights into the work environment, more in-depth reviews of specific

vendors were not performed. Statistics by contractor or vendor are not given in this report or

otherwise provided publically because publishing the number of allegations received has the

potential of identifying an alleger.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 29 of 33

CONCLUSIONS

From calendar year 2001 through 2005 the number of allegations received by the NRC has

remained steady with incremental annual increases in the reactor area from 2003 to 2005. 

From a regional perspective, there has been an increase in the number of concerns received

for operating power reactors over the last five years in all regions except for Region III. In

contrast, the number of materials issues has declined over the five-year period in every region. 

The analyses of allegations has provided insights into the SCWE at several facilities. The staff

has taken action to engage licensees concerning their work environment where warranted and

will continue to monitor these sites with interest. Training to be conducted in 2006 associated

with the agency’s safety culture initiative will include additional guidance for the NRC inspection

staff in this area. 

Based on information available to date on the agency’s Early-ADR process the staff has

concluded that the assumed benefits, including decreased costs and the impact on the SCWE,

warrant its continued use in the Allegation Program.

Finally, based on concerns that changes to the process by which the NRC handles securityrelated allegations have the potential to impact the public’s willingness to raise such concerns to

the NRC, the staff is working with NSIR to improve guidance concerning the level of detail

which can appropriately be provided to allegers.

RECOMMENDATIONS

The Agency Allegations Advisor has no recommendations for program changes at this time.
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 30 of 33

APPENDIX 1

ALLEGATIONS STATISTICS 

OPERATING REACTORS AND FUEL FACILITIES
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 31 of 33

OPERATING REACTOR ALLEGATIONS RECEIVED FROM ONSITE SOURCES

Site 2001 2002 2003 2004 2005

SALEM/HOPE CREEK 3 11 6 18 23

PALO VERDE 1, 2, & 3 3 2 19 8 22

SUSQUEHANNA 1 & 2 15 9 3 13 20

ST LUCIE 1 & 2 25 11 24 4 16

OYSTER CREEK 5 9 18 8 14

POINT BEACH 1 & 2 7 7 9 11 13

BYRON 1 & 2 20 13 11 6 11

CALLAWAY 6 7 3 1 11

TURKEY POINT 3 & 4 11 2 3 9 10

MILLSTONE 2 & 3 2 7 6 1 10

SAN ONOFRE 2 & 3 7 11 11 13 10

SEQUOYAH 1 & 2 2 5 7 4 10

PILGRIM 3 2 5 14 9

SEABROOK 3 6 3 3 9

INDIAN POINT 2 & 3 17 29 20 19 9

HARRIS 1 & 2 1 6 1 9

DRESDEN 2 & 3 32 11 3 3 9

DAVIS-BESSE 2 27 17 12 9

COMANCHE PEAK 1 & 2 5 2 1 2 9

LIMERICK 1 & 2 2 7 4 4 8

BEAVER VALLEY 1 & 2 7 1 1 9 7

COOK 1 & 2 12 14 9 12 7

GRAND GULF 5 6 6 7

COLUMBIA PLANT 13 5 4 6 7

PEACH BOTTOM 2 & 3 2 1 2 1 5

PRAIRIE ISLAND 1 & 2 5 2 4 5

BROW NS FERRY 2 & 3 2 2 6 5

VOGTLE 1 & 2 1 3 1 1 5

SOUTH TEXAS 1 & 2 4 6 2 6 4

FARLEY 1 & 2 3 1 3 1 4

THREE MILE ISLAND 5 5 1 6 4

ARKANSAS 1 & 2 2 3 4 6 4

NINE MILE POINT 1 & 2 4 5 2 4 4

PALISADES 4 9 7 10 4

BRAIDWOOD 1 & 2 5 5 1 3 4

PERRY 7 5 5 12 4

FITZPATRICK 1 1 7 3

W OLF CREEK 4 1 3

KEW AUNEE 4 3 4 3 3

HATCH 1 & 2 2 3 2 1 3

BRUNSW ICK 1 & 2 1 1 3 2 3
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 32 of 33

Site 2001 2002 2003 2004 2005

OCONEE 1, 2, & 3 5 1 3 11 3

W ATTS BAR 4 8 2 4 2

CRYSTAL RIVER 2 2 3 4 2

DIABLO CANYON 1 & 2 6 3 2 2 2

W ATERFORD 2 7 1 2

MCGUIRE 1 & 2 2 2 2

QUAD CITIES 1 & 2 1 3 1 1 2

FORT CALHOUN 2 2 3 2 2

RIVER BEND 1 1 4 3 2

GINNA 1 2 2

SURRY 1 & 2 2 4 2 1 2

NORTH ANNA 1 & 2 1 10 1 4 2

MONTICELLO 1 2

FERMI 3 4 2 2 2

LASALLE 1 & 2 2 1 2 2

CLINTON 1 3 2 4 1

ROBINSON 1 1

CALVERT CLIFFS 1 & 2 2 3 4 5 1

DUANE ARNOLD 3 2 2 8 1

COOPER 8 6 8 10 1

VERMONT YANKEE 4 3 1

SUMMER 3 2 4 3

CATAW BA 1 & 2 7 2 2
ALLEGATION PROGRAM 2005 ANNUAL TRENDS REPORT - Page 33 of 33

FUEL CYCLE FACILITY ALLEGATIONS RECEIVED FROM ONSITE SOURCES

Site 2001 2002 2003 2004 2005

Fram atone-Lynchburg 1

Framatone-Richland 1 1 1

Global Nuclear Fuel 1 2

Honeywell 3 2 7

Paducah 32 15 22 10 7

Portsm outh 9 6 2 7 2

W estinghouse 1 8