ALLEGATION PROGRAM

 ANNUAL TRENDS REPORT

 Calendar Year 2006

U.S. Nuclear Regulatory Commission

Office of Enforcement

Washington, DC 20555
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ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

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

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

Safety Conscious Work Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Alternative Dispute Resolution for Discrimination Allegations. . . . . . . . . . . . . . . . . . . . . 4

New Policy Regarding Correspondence with Allegers Involving Security-Related

Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

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

Susquehanna Units 1 and 2.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Turkey Point Units 3 and 4.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Browns Ferry Unit 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Indian Point Units 2 and 3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

San Onofre Units 2 and 3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

St. Lucie Units 1 and 2.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Harris. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Salem/Hope Creek.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Sequoyah Units 1 and 2.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

South Texas Units 1 and 2.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Allegation Trends for Selected Materials Licensees. . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Allegation Trends for Selected Vendors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

CONCLUSIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

RECOMMENDATIONS.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Appendix

Allegation Statistics: Operating Reactors and Fuel Facilities.. . . . . . . . . . . . . . . . . . . . . . . . . A-1

Figures

1 Allegations Received by CY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2 Reactor Issues Nationwide 2006. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

3 Materials Licensee Types Nationwide 2006.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

4 Allegations by Source Category. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5 Susquehanna Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

6 Turkey Point Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

7 Palo Verde Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

8 Browns Ferry 1 Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

9 Indian Point Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

10 San Onofre Allegations..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

-ii11 St. Lucie Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

12 Harris Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

13 Salem/Hope Creek Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

14 Sequoyah Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

15 South Texas Allegations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

1 The 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 Web site at

http://www.nrc.gov/about-nrc/regulatory/allegations/statistics.html.

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EXECUTIVE SUMMARY

U.S. Nuclear Regulatory Commission (NRC) Management Directive 8.8, “Management of

Allegations,” requires the Agency Allegation 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. 

In addition, several staff activities in 2006 involving the Allegation Program and related policies

warrant mention in this report. The agency implemented changes to the Reactor Oversight

Process to more fully address safety culture, including changes to the safety conscious work

environment (SCWE) crosscutting area and subsequent inspector training. The allegation staff

continues to implement the agency-sponsored alternative dispute resolution (ADR) process for

discrimination allegations. One quarter of the discrimination cases offered Early-ADR reached

settlement in 2006, reducing the number of necessary investigations by nine. Lastly, staff of

the Offices of Enforcement and Nuclear Security and Incident Response developed a new

policy for corresponding with allegers who raise security-related concerns. The previous policy

made it difficult for the staff to assure allegers that their concerns had been addressed. The

Commission approved the policy change on March 28, 2007 (see SECY/SRM-07-0032,

“Recommended Staff Actions Regarding Correspondence with Allegers Involving SecurityRelated Concerns”).

With regard to allegation trends, as Figure 1 indicates, from calendar year 2002 through 2006

the number of allegations the NRC received has remained fairly steady, fluctuating each year

on average by plus or minus 55 allegations. Reductions in allegations received from several

Region I and Region III reactor facilities that

had experienced significant allegation

activity in recent years explain the

approximate 10-percent drop in reactor

allegations from 2005 to 2006. The number

of materials allegations received dropped

from an average of slightly less than 200

allegations per year in 2002 and 2003 to an

average of slightly less than 150 allegations

per year from 2004 through 2006, with two

States achieving Agreement State status in

the latter timeframe. Security-related issues

comprised the largest percentage of alleged

concerns received in 2006. 

For some reactor licensees, the NRC

received allegations in numbers that warranted additional analysis. In preparing this report, the

staff reviewed a 5-year history of allegations for reactor and material licensees and vendors to

identify adverse trends. The analysis focused on allegations that originated from onsite

sources to help inform the NRC’s review of the SCWE. The staff selected 11 reactor sites for 1

a more in-depth review—Susquehanna Units 1 and 2; Turkey Point Units 3 and 4; Palo Verde

Units 1, 2, and 3; Browns Ferry Unit 1; Indian Point Units 2 and 3; San Onofre Units 2 and 3; St.

Lucie Units 1 and 2; Harris; Salem/Hope Creek, Sequoyah Units 1 and 2; and South Texas

Units 1 and 2. The report discusses allegation trends at each of these sites. In summary, the

trends either did not suggest a weakening SCWE or the licensee is taking steps to address an

adverse trend and the NRC is monitoring those activities. No materials licensees or vendors

were the subject of allegations at a level that warranted additional analysis.
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

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ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

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OVERVIEW OF SIGNIFICANT PROGRAM ACTIVITIES

In 2006, the U.S. Nuclear Regulatory Commission (NRC) undertook certain significant activities

that affect the Allegation Program and related policies and warrant discussion in this report. 

The agency implemented changes to the Reactor Oversight Process (ROP) to more fully

address safety culture and the safety conscious work environment (SCWE). In addition, the

allegation staff continues to implement the agency-sponsored alternative dispute resolution

(ADR) process for discrimination allegations. One quarter of the discrimination cases offered

ADR reached settlement in 2006. Lastly, the Commission approved a new policy developed by

the Offices of Enforcement and Nuclear Security and Incident Response for corresponding with

allegers who raise security-related concerns. These areas are discussed in more detail below. 

Safety Conscious Work Environment

The 1996 NRC Policy Statement, “Freedom of Employees in the Nuclear Industry to Raise

Safety Concerns Without Fear of Retaliation,” outlines the agency’s expectations that licensees

and other employers subject to NRC authority will establish and maintain a SCWE. A SCWE is

defined as an environment in which (1) employees are encouraged to raise safety concerns to

their employers or the NRC without fear of retaliation, (2) concerns are promptly reviewed,

given the proper priority, and appropriately resolved, and (3) timely feedback is provided. 

In 2006, the staff continued an initiative begun in 2005 to enhance the ROP to more fully

address safety culture and the SCWE and to train NRC inspection staff based on the

Commission direction described in SECY-04-0111, “Recommended Staff Actions Regarding

Agency Guidance in the Areas of Safety Conscious Work Environment and Safety Culture,”

dated July 1, 2004, and its associated staff requirements memorandum (SRM). One aspect of

the change involved how to document findings related to three crosscutting areas (SCWE,

problem identification and resolution (PI&R), and human performance). To support the ROP

assessment process, findings with a crosscutting aspect must meet certain requirements—the

finding must be more than minor, the crosscutting aspect must be a significant contributor to

the finding, and the finding is reflective of current licensee performance. During the internal

review of the draft revised guidance, the staff expressed concern that potential findings with

SCWE crosscutting aspects might not be handled through the most appropriate process (i.e.,

either through the ROP or the Agency Allegation Program). Staff noted that inspectors could

have a difficult time making this decision in a consistent manner, and identified a need for

additional multioffice management review of the findings with SCWE crosscutting aspects to

ensure consistency across the regions. To meet that need, the agency formed the SCWE

Finding Review Group (SCWE FRG). The purpose of the SCWE FRG review is to ensure

regulatory consistency by reviewing and dispositioning all ROP potential findings in the SCWE

crosscutting area. The review group will evaluate the potential finding and the proposed SCWE

crosscutting aspects before the finding is documented in an inspection report. In addition, the

regions will be encouraged to hold discussions with SCWE FRG during the conduct of their

inspections when SCWE-related issues arise. The review group will ensure a consistent

treatment of SCWE findings and appropriate handling within the ROP and/or the Allegation

Program. The Agency Allegation Advisor chairs the SCWE FRG.

In addition to identifying findings with a SCWE crosscutting aspect, staff can gather insights into

the SCWE at a particular site by reviewing the number and nature of allegations received

concerning that site. Furthermore, during the baseline PI&R inspection, the staff documents

observations concerning a site’s SCWE based on interviews with licensee employees and

pertinent document reviews. Should the staff discern that a work environment may be “chilled,”

that is, potentially not conducive to raising safety concerns internally, the NRC management

can request, in writing, from the licensee information concerning its SCWE. Such

correspondence is called a chilling effect letter. The agency also initiates chilling effect letters
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

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 after a finding of discrimination related to raising safety concerns by the Department of Labor

(DOL) under Section 211 of the Energy Reorganization Act of 1974, as amended, or by the

NRC under the following employee protection regulations:

• 10 CFR Part 19, “Notices, Instructions and Reports to Workers: Inspection and

Investigations”

• 10 CFR Part 30, “Rules of General Applicability to Domestic Licensing of Byproduct

Material”

• 10 CFR Part 40, “Domestic Licensing of Source Material”

• 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities”

• 10 CFR Part 60, “Disposal of High-Level Radioactive Wastes in Geologic Repositories”

• 10 CFR Part 61, “Licensing Requirements for Land Disposal of Radioactive Waste”

• 10 CFR Part 63, “Disposal of High-Level Radioactive Wastes in a Geologic Repository

at Yucca Mountain, Nevada”

• 10 CFR Part 70, “Domestic Licensing of Special Nuclear Material”

• 10 CFR Part 72, “Licensing Requirements for the Independent Storage of Spent Nuclear

Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C

Waste”

• 10 CFR Part 76, “Certification of Gaseous Diffusion Plants”

• 10 CFR Part 150, “Exemptions and Continued Regulatory Authority in Agreement States

and in Offshore Waters under Section 274”

In 2006, the agency issued two chilling effect letters, one to a materials certificatee as a result

of a DOL finding of discrimination and the other to a reactor licensee based on indications of a

potential chilled work environment. The NRC staff will continue to monitor the SCWE of both

sites through normal inspection activities and allegation review.

Alternative Dispute Resolution for Discrimination Allegations

In October 2004, the staff implemented a pilot ADR program which included the opportunity for

using ADR early in the allegation process for 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 NRC investigation remains. Under the Early-ADR pilot

program, the staff will not pursue an investigation or subsequent enforcement of discrimination

findings that have been settled through this process. 

The pilot program operated through the first quarter of 2006. The staff’s evaluation of the pilot

program concluded that although there is no objective indication that Early-ADR has had an

immediate positive impact on any particular facility’s work environment, it is believed 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. Indications of positive improvements may be limited to facilities that have
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

2 SECY-06-0102, “Evaluation of the Pilot Program on the Use of Alternative Dispute Resolution in the

Allegation and Enforcement Programs,” May 5, 2006.

3 SECY/SRM-07-0032, “Recommended Staff Actions Regarding Correspondence with Allegers Involving

Security-Related Concerns,” March 28, 2007.

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

term. However, the staff concludes 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. 

In 2006, the NRC made 33 Early-ADR offers, of which 12 (36 percent) resulted in agreements

to mediate. Nine of the 12 (75 percent) mediated discrimination concerns resulted in the

parties agreeing to settlement terms. The NRC has estimated that ADR reduces agency

expenditures by approximately $22,200 per Early-ADR settlement agreement. Therefore, the

2

nine cases that were successfully settled represent approximately a $200,000 savings.

New Policy Regarding Correspondence with Allegers Involving Security-Related

Concerns

In the aftermath of September 11, 2001, the NRC placed restrictions on the dissemination of

sensitive security-related information outside the agency in an effort to preclude the release of

information useful to potential adversaries. These controls were also applied to the information

that is provided to allegers raising security-related concerns to the NRC. The restrictions have

made it difficult for the staff to assure allegers that their concerns have been addressed, and a

number of allegers have expressed dissatisfaction with the NRC’s limited response. Some, in

an effort to obtain a satisfactory response, have chosen to pursue their concerns publicly by

engaging elected officials and public interest groups and disseminating their concerns by

means of public Web sites or media outlets. In recent instances, these actions have required

the staff to respond in a public manner to the allegers’ concerns. While the allegers were

receptive to the feedback provided, the staff does not consider a public response to be the most

advisable primary means of addressing security-related concerns. In late 2006, the staff

drafted new guidance for responding to individual allegers who raise security-related concerns

with the goal of being as responsive to an alleger as is possible while continuing to protect any

information that could be used by an adversary to exploit a potential security vulnerability. The

staff proposed the revised policy to the Commission on February 12, 2007. The Commission

approved the recommended policy change on March 28, 2007.3

The NRC will group security-related allegation concerns into three categories:

Category I Concerns that involve a potential generic industry security vulnerability.

Category II Security-related concerns that, if true, would constitute more than a minor finding

or violation, as determined by applicable guidance or review panels.

Category III Security-related concerns that, if true, would, at most, constitute a minor finding

or violation, as determined by applicable guidance or review panels.

The following handling guidance applies to the categories:

Category I. As outlined in current guidance, the staff will provide limited information for both

substantiated and unsubstantiated security-related concerns that involve a potential generic

industry vulnerability. Letters to allegers will continue to reiterate the concerns raised in

sufficient detail to ensure a common understanding of the concerns, however, a description of

the actions taken by the staff to evaluate the concerns and the staff’s conclusion regarding the
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

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validity of the concerns will not be shared with the alleger. Based on past trends, the staff

estimates that less than 1 percent of security-related concerns will fall within this category.

Category II. For those security-related concerns that, if true, would constitute more than a

minor finding or violation, as determined by applicable guidance or review panels, the staff will

provide limited information in response to both substantiated and unsubstantiated concerns.

Letters to allegers will continue to reiterate the issues raised in sufficient detail to ensure a

common understanding of the concerns. Although the staff will not provide specific details

regarding its evaluation of the concerns, closure letters will document that an assessment was

conducted in the security area that included a review of the concerns raised and whether that

assessment resulted in a finding or not. Should deficiencies be identified, the staff will notify

the alleger that such deficiencies were promptly corrected or addressed by compensatory

action, thereby establishing licensee compliance with applicable physical protection and security

requirements. The alleger will not be told, however, if any finding was specifically associated

with the concerns he/she raised. It is estimated that approximately 10 percent of securityrelated concerns will fall within this category.

If the alleger requests additional information and the staff can verify that he/she is currently

employed at the NRC-licensed facility associated with the allegation concerns as a member of

the security force with normal access to such information, the staff will offer to discuss the

specifics of the agency’s actions and conclusions with the alleger. The agency will not seek

employment and position verification without the alleger’s prior permission.

Category III. For those security-related concerns that, if true, would at most constitute a minor

finding or violation, as determined by applicable guidance and review panels, the staff will

provide a complete response to the alleger, once required compensatory actions, if any, are in

place. The response to both substantiated and unsubstantiated concerns will include a

description of the actions taken by the staff to evaluate the concern and the staff’s conclusion

regarding the validity of the concern, but will not include a description of the compensatory

actions taken. 

If followup of a security-related concern results in a minor finding or violation requiring

compensatory actions, and if the alleger requests additional information and the staff can verify

that he or she is currently employed at the NRC-licensed facility associated with the allegation

concerns as a member of the security force with normal access to such information, the staff

will offer to discuss the compensatory actions with the alleger. The agency will not seek

employment and position verification without the alleger’s prior permission. 

Cognizant Office of Nuclear Security and Incident Response and/or regional security inspection

management will concur on all closure letters to allegers.
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

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TRENDS IN ALLEGATIONS

The NRC monitors allegations to discern trends or marked increases that might prompt the

agency to question the licensee as to the causes of such changes or trends. In preparing this

report, the staff reviewed a 5-year history of allegations received 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. Such allegations include those submitted by

current or former licensee or contractor employees or by anonymous sources that indicate an

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, the staff may perform an analysis for a particular site or licensee 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 Allegation Program, and the impact of Allegation Program

implementation on the workload in the regions, the Office of Nuclear Reactor Regulation (NRR),

and the Office of Nuclear Material Safety and Safeguards (NMSS). The Office of Federal and

State Materials and Environmental Management Programs was established in late 2006 and,

therefore, trends related to materials licensee’s under that office’s purview are included in

NMSS’s trends. The following section discusses these trends.

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 NRClicensed facilities. In addition, they can be useful in developing budget and planning

assumptions to support future agency and allegation program needs. Figure 1 shows that the

5-year national trend in allegation receipt has remained relatively steady with some fluctuation

in the number of allegations received in the reactor area. 

Reductions in allegations received from several Region I and Region III reactor facilities that

had experienced significant allegation activity in recent years explain the approximate 10-

percent drop in reactor allegations from 2005 to 2006. The number of materials allegations

received dropped from an average of slightly less than 200 allegations per year in 2002 and

2003 to an average of slightly less than 150 allegations per year from 2004 through 2006, with

two States achieving Agreement State status in the latter timeframe.

Because each allegation can include multiple concerns, the number of concerns received can

provide more specific information in terms of the staff effort needed for appropriate response. 
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

4 The agency received few concerns in the areas not depicted in Figure 2, which represent the remaining 20

percent of the issues received. 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, I&C,

Licensing, Mechanical, Nondestructive Evaluation, Other, Procurement, Radwaste, and Safeguards.

-8-

The trend in the total number of concerns received has paralleled the trend of total allegation

receipt over the last 5 years; that is, generally the number of concerns received about operating

power reactor facilities increased in the 2002 to 2005 timeframe in all regions except Region III,

while all regions experienced a decrease in the number of reactor concerns received in 2006. 

The number of materials concerns received in every region has trended downward in the 2002

to 2006 timeframe, with the exception of Region I. 

From a regional perspective, the following activity is noteworthy. The volume of reactor

concerns received in Region I trended upward from 2002 to 2005, but dropped in 2006,

coinciding with the culmination of efforts by one Region I site to resolve concerns in the SCWE

area identified in the 2003–2004 timeframe. The transfer of responsibility for oversight of all

former Region II materials licensees to Region I in 2003 has sustained the rate of receipt of

materials concerns in Region I. The volume of concerns in Region II trended upward from 2002

through 2005 which is likely associated with 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 in the reactor area decreased in

Region II in 2006, although the number of security concerns continued to increase, primarily as

a result of an increase in security issues at one Region II reactor facility. The number of

concerns received in Region III was higher than the other regions in 2002 and 2003, but has

decreased steadily since that timeframe. A significant contributor to the decrease in concerns

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

facilities from Region III to Region II in 2003. Also, since 2003, two States in the Region III

geographical area have achieved Agreement State status, thus, materials licensee concerns

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

Events that have also contributed to the reduction in Region III concerns 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 2002 through 2006, generally at lower totals

than the other regions from 2002 through 2004. The number of reactor concerns received in

Region IV in 2005 and 2006 were comparatively high, which are largely attributable to activity at

one multiplant site.

Reactor Licensee Trends

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

allegation followup, Figure 2 on the following page depicts the 12 functional areas that

represent approximately 80 percent of the issues received nationwide in 2006.

4

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

concerns received in 2006. Since the terrorist attacks of September 11, 2001, security-related

concerns have continued to represent the greatest percentage of allegation concerns received

in each subsequent calendar year. The number of security concerns received has fluctuated

between 2002 and 2006. In previous years, increases in the number of these concerns were

attributable to issues related to the effectiveness with which reactor licensees implemented

changes to the facility and the physical security plan based upon NRC security orders issued in

2003 (licensees were required to be in full compliance with the orders by October 2004). A

sharp increase in the number of security-related concerns was noted in 2005 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 the observations, a

continuing review of site-specific security enhancements, and knowledge of low potential risks
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

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associated with such small quantities of radioactive material, the Nation’s research and test

reactors remain safe and secure. The agency did not receive concerns in 2006 about security

at the research and test reactors, causing the number of security concerns to decrease to the

level of prior years.

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

retaliation or are discouraged from raising safety concerns has trended slightly upward over the

last 5 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 sustained

percentage of chilling effect concerns received (approximately 7 percent of all reactor concerns

received each year for the last 3 years) may reflect increasing awareness of SCWE concepts

by the nuclear workforce resulting from an increased industry focus in this area, media interest

concerning increased NRC focus on this area at some sites, and recent guidance made publicly

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). It is also

noted that in 2005, the NRC modified the database that tracks allegations and allegation

concerns to allow concerns to be attributed to the concept of “safety culture.” As such,

concerns that reflect components of safety culture that are broader than the SCWE (or chilling

effect) may now be placed in a separate category. Therefore, it is likely that part of the reason

for the overall decrease in the number of chilling effect concerns in the past few years is the

fact that concerns may now be applied to safety culture that in the past may have been applied

to “chilling effect” in the absence of a more descriptive category. 

Some notable changes in the distribution of the same 12 concern categories illustrated in

Figure 2 among the four regional offices and NRR occurred between 2005 and 2006. 

Specifically, the percentage of issues that relate to security in Region II and Region IV

increased. These increases are the result of a series of security-related allegations at a site in

each of these regions. Unlike 2005 when NRR received a considerable number of security

concerns, the agency received no concerns in 2006 about the security at research and test

reactors. The percentage of health physics issues in Region II and engineering issues in

Region IV decreased significantly in 2006. The high numbers in 2005 were caused primarily by

a health physics issue at one Region II site and specific incidents involving engineering matters

at two Region IV sites. Figure 2 also identifies a substantive percentage of discrimination

concerns. It should be noted that this area was not properly reflected in previous reports. This

was the result of an error in data collection. In actuality, the percentage of discrimination
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

5 The agency received few concerns about the materials licensee types not depicted in Figure 3, which

represent the remaining 20 percent of issues received. These licensee types include Decommissioning

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

and Waste Disposal.

-10-

concerns raised in 2002 through 2005 (approximately 9 percent per year) was similar to the

percentage reflected in Figure 2.

Materials Licensee Trends

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

performed by these 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.5

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 from 2002 through

2005, with a notable increase from 2004 to 2005. In 2006, the number of fuel facility allegations

received returned to the level received in 2004. The increase from 2004 to 2005 was largely

attributable to a number of issues received about one fuel facility following a specific event, a

change in management expectations regarding procedural adherence, and a planned workforce

reduction in fall 2005. Allegations received regarding decommissioning reactors and gaseous

diffusion plants have steadily decreased since 2004. Decreases in allegations regarding

gaseous diffusion plants coincide with site efforts to enhance the SCWE, including

management training and improvements to the processes for resolving employee concerns.

Furthermore, it follows that the numbers of concerns regarding decommissioning reactors will

diminish as the facilities’ activities and staffing decrease over time. For example, the sharp

decrease in the number of decommissioning reactor allegations in Region I from 2004 to 2005

coincided with the cessation of decommissioning activities at two sites. In addition, the

functional area of exempt distribution has been one of the primary contributors to the

allegations received in the materials area in 2005 and 2006, primarily because of concerns
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

6 The NRC received few concerns from the 1 percent of sources not depicted in Figure 4. These sources

include Federal and State agencies.

-11-

received regarding the Internet sale of products containing exempt quantities of radioactive

material.

Source Trends

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

allegations received in 2006. The data indicate that the distribution of source categories 6

remained consistent between 2003 and 2006. 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 over the review period. The only notable change

in the data resulted from the role of the news media as a more prominent source of allegations

in 2005. The increase in allegations was primarily caused by 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, the largest source for both is consistently licensee (or former licensee) employees.

It is worth noting, however, that while contractor employees are the second most frequent

source of reactor allegations, private citizens are the second most frequent source of materialsrelated allegations. 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 that a regulatory requirement has been

violated deliberately or as a result of careless disregard, prompting the initiation of an

investigation by the NRC Office of Investigations. The source category of “Licensee” is applied

when a licensee representative, acting in his/her official capacity, reports a potential

wrongdoing to the NRC. Agency staff assigns an allegation process tracking number to such

items which allows staff to track the progress of efforts to review the potential wrongdoing

issue.
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

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Allegation Trends for Selected Reactor Sites 

Trending the number and nature of allegations received concerning individual reactor sites is

one method the NRC staff uses to monitor the SCWE at reactor sites. Appendix 1 to this report

provides statistics on allegations received concerning all operating reactor sites. The listed

allegations were received during the 5-year period between January 2002 and December 2006

and include only allegations received from onsite sources (i.e., those that may be indicative of

the health of the SCWE). Onsite sources include 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 submitted by onsite personnel.

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

either of the following two criteria:

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

reactor industry, but does not exceed 3 times the median, and there is a 50-percent

increase in the number of allegations received over the previous year.

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

For 2006, the median number of onsite allegations per reactor site was three. The 11 reactor

sites that met one of these criteria are Susquehanna Units 1 and 2 (19); Turkey Point Units 3

and 4 (18); Palo Verde Units 1, 2, and 3 (16); Browns Ferry Unit 1 (16); Indian Point Units 2 and

3 (15); San Onofre Units 2 and 3 (15); St. Lucie Units 1 and 2 (15); Harris (14); Salem/Hope

Creek (14); Sequoyah Units 1 and 2 (11); and South Texas Units 1 and 2 (8). The first 10 sites

listed exceeded 3 times the industry median, while South Texas exceeded 2 times the median

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

site. A detailed discussion of each of the sites follows. In summary, the trends either do not

suggest a weakening SCWE or the licensee is taking steps to address trends, and the NRC is

monitoring those activities.

Susquehanna Units 1 and 2

The volume of allegations regarding Susquehanna was comparable to last year’s numbers,

and, like last year, the allegations continue to exhibit a trend in the Maintenance discipline. The

bulk of the allegations was received in

the first three quarters of the year. The

NRC conducted a PI&R inspection in

early 2006 (Inspection Report Nos.

05000387/2006006 and

05000388/2006006), including a review

of the site’s SCWE. Agency staff

interviewed licensee employees from

each functional organization during the

inspection; these employees expressed

a willingness to raise issues and

believed the work environment was free

from retaliation.

The licensee has taken a number of

actions in the past few years to improve

the site’s SCWE, including revising the

company policy, improving

communications regarding management’s SCWE commitment, improving visibility of the

Employee Concerns Program (ECP), and improving supervisory training. The licensee has

conducted SCWE surveys at Susquehanna periodically since 1997, most recently in fall 2006. 
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

-13-

The NRC staff reviewed the results and documented that review in a fourth quarter 2006

inspection report (Inspection Report Nos. 05000387/2006005 and 05000388/2006005). The

survey showed a slightly improving trend in the overall SCWE and ECP ratings. Survey results

revealed a significant improvement in the workforce’s perception of the ECP. An increase in

the volume of concerns being raised to the ECP also indicates that the workforce considers the

ECP to be a viable avenue for raising concerns. Finally, the survey showed a notable

improvement in employee willingness to raise issues as a result of the responsiveness of the

Corrective Action Program and management’s reaction to workers who raise issues. The

survey confirmed work environment concerns in the maintenance organization where the

negative response rate to questions concerning the SCWE was higher than the site norm. The

licensee plans to take further corrective actions in the maintenance area, as well as in other

organizations noted in the survey as needing management attention. The NRC will continue to

follow these developments. 

The volume of discrimination allegations over the review period concerning Susquehanna has

been high. Three such allegations were filed in 2006. One was withdrawn by the alleger; one

was investigated but not substantiated; and one 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 Part 50.7, “Employee Protection,” 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 4 years (2002 through 2005), 13 allegations of discrimination were raised. Four of

these allegations were closed because a prima facie showing of potential discrimination was not

articulated, and, although the remaining nine were investigated, none were substantiated.

The NRC will maintain oversight of the Susquehanna SCWE through normal inspection

activities to assess the licensee’s progress with its indicated initiatives and corrective actions.

Turkey Point Units 3 and 4

The number of allegations received from onsite sources at Turkey Point increased in 2006, with

the overall allegation receipt rate increasing from 2002 through 2006. More than half of the

allegations received in 2006 were

focused in the security area, and most

of these were received in the first half of

the year. The site Speakout Program

(now the Employee Concerns Program

(ECP)) received concerns in the

security area in a similar concentration

and timeframe. A review of the

allegation data suggests that a

considerable amount of focused NRC

investigation activity in the security area

in the first half of 2006 may have

impacted the volume of security issues

received. Only one allegation concern

was received in 2006 that involved an

issue related to the willingness of

employees to raise concerns. 

A SCWE survey conducted by the licensee in August 2005 revealed the reluctance of some

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

identified the condition reporting system as an area of concern. In response, the licensee

implemented a new electronic reporting system, established a performance improvement

department which monitors the Corrective Action Program’s effectiveness, and completed
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

-14-

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

understand how management prioritizes issues raised based on their safety significance. The

licensee has acknowledged that negative perceptions continue to exist about the ECP, as

evidenced by the internal SCWE survey results. In response, the licensee is taking actions to

address these perceptions, including the standardization of the organizational makeup and

function of the ECP across the Florida Power & Light fleet (St. Lucie, Turkey Point, Seabrook,

and Duane Arnold), better communications about ECP program functions and policies, and the

initiation of “cultural meetings” with employees to discuss topics related to the SCWE and

safety culture. The licensee completed a subsequent SCWE survey in late 2006, but the

analysis of the survey results had not been completed at the time of this report.

In addition to interviewing site personnel about the environment for raising safety issues during

the PI&R inspection in February 2006 (Inspection Report Nos. 05000250/2006007 and

05000251/2006007), the NRC inspection team reviewed a sample of ECP files from the

2004–2005 timeframe to verify that the licensee had properly reviewed and addressed concerns

and entered them into the Corrective Action Program when appropriate. In general, the

inspection team concluded that a SCWE exists at Turkey Point and that ECP reviews were

complete and appropriate.

One allegation of discrimination was raised in 2006, but no followup was conducted because

the concerned individual was not responsive to repeated contact efforts. In 2005, three

allegations of discrimination were received. One was resolved via Early-ADR, and, although

the NRC did not open investigations into the other two, the agency is monitoring the DOL

review. The agency received four allegations of discrimination from 2002 through 2004. Two

of these allegations were investigated, but not substantiated. One was not investigated

because the alleger reached a prompt settlement with the licensee through DOL/Occupational

Safety and Health Administration which met the intent of an Early-ADR settlement, and the

other was not investigated because a prima facie showing of potential discrimination was not

articulated.

Based upon the similarity in the nature and number of the allegations received regarding Turkey

Point to concerns being raised internally, as well as the coincidence of the increase in receipt of

security-related allegations with a period of focused NRC investigation activity in the security

area in the first half of 2006, there does not appear to be a problem with the SCWE at Turkey

Point. The NRC will continue to monitor the work environment at Turkey Point through normal

inspection activities, including a review of internal SCWE surveys, any actions taken by the

licensee to address issues that could have a negative impact on SCWE if they went

unaddressed (such as the current licensee actions to mitigate certain negative perceptions

about the ECP), and allegation trends.

Palo Verde Units 1, 2, and 3

The number of allegations received from

onsite sources at Palo Verde remained

relatively high, but decreased

approximately 25 percent from the

previous year. Since the 16 allegations

received in 2006 came from a variety of

different plant functional areas, and a

very small percentage of the allegation

concerns raised involved issues directly

related to the willingness of employees

to raise concerns, the number and

nature of allegations received regarding

Palo Verde do not appear to indicate a

broader SCWE problem. The licensee’s
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

-15-

Employee Concerns Program saw a decrease in the number of concerns raised in 2006 from

the previous year, which is likely because outage activity in 2006 did not involve major

equipment replacement (as occurred in 2005).

The NRC received two allegations of discrimination in 2006. One was settled via Early-ADR

and the other was investigated and not substantiated. Of the four allegations of discrimination

received in 2005, two were investigated and not substantiated, one was not investigated

because the concerned individual did not wish to participate in an investigation, and the other

remains under investigation. The agency received five allegations of discrimination from 2002

through 2004. All were investigated but none were substantiated.

To monitor the status of the SCWE at Palo Verde, Arizona Public Service (APS) plans to

administer an independent assessment and survey of the safety culture and SCWE

approximately every 2 years and perform directed assessments in alternate years of

workgroups identified by the independent assessment and survey as being in need of focused

attention. The results of the last independent assessment and survey in 2005 produced very

positive results regarding the health of the SCWE at Palo Verde. The directed assessments

conducted by the licensee in 2006 did not reveal any significant SCWE-related concerns, but

did identify some leadership and morale issues.

The NRC PI&R inspection conducted in early 2006 (Inspection Report Nos. 05000528/2006008,

05000529/2006008, and 05000530/2006008) found that a SCWE exists at Palo Verde but

noted isolated concerns regarding the effectiveness of corrective actions and the corrective

action process. For example, issues were raised with regard to corrective action timeliness,

confusion with methods of entering items into the Corrective Action Program, and insufficient

staffing to accomplish long-term improvements. It is noted that an ROP Yellow finding has

been in effect for all three units at Palo Verde since late 2004 because of problems with the

scope and effectiveness of corrective actions. A supplemental inspection of the Yellow finding

completed in July 2006 found that corrective actions taken in response to the root causes and

related programmatic concerns involving questioning attitude, technical rigor, and operability

determinations had not been fully effective. Additionally, special inspections in the second half

of 2006 involving the ultimate heat sink for all three units and an inoperable emergency diesel

generator at Palo Verde Unit 3 resulted in similar findings with regard to the effectiveness of

corrective actions.

The NRC assessment of facility performance in 2006 has resulted in the continuation of ROP

substantive crosscutting issues in the areas of human performance and PI&R at Palo Verde. 

Additionally, the NRC annual assessment of performance at Palo Verde for 2006 resulted in

maintaining Palo Verde Units 1 and 2 in the Degraded Cornerstone Column and moving Palo

Verde Unit 3 to the Multiple/Repetitive Degraded Cornerstone Column of the ROP Action

Matrix. In accordance with NRC Manual Chapter 0305, “Operating Reactor Assessment

Program,” APS is expected to perform an independent assessment of the Palo Verde safety

culture in addition to evaluating the root and contributing causes for the identified issues. As

part of the performance of Inspection Procedure 95003, “Inspection for Repetitive Degraded

Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input,” the

NRC will review the APS independent safety culture evaluation and will subsequently perform

an independent assessment of the safety culture at Palo Verde. 

Although the number and nature of allegations received regarding Palo Verde, as well as the

results of both the 2006 NRC P&IR inspection assessment of SCWE and the licensee’s 2005

independent evaluation of the safety culture and SCWE have not indicated a broader SCWE

problem, sustained problems in the ROP crosscutting areas of human performance

(decisionmaking, resources, work practices) and PI&R could have a deleterious effect on the

safety culture, including the SCWE, if conditions persist. The completion of an independent

safety culture assessment by APS at Palo Verde in 2007 and the NRC’s followup assessments

via the implementation of Inspection Procedure 95003 will provide an appropriate and timely
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

7 The NRC’s Enforcement Policy can be found on the NRC’s public Web site at:

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html 

-16-

opportunity for a thorough overview of the safety culture and environment for raising safety

concerns at Palo Verde.

Browns Ferry Unit 1

Although the 5-year trend line in Figure 8 indicates an increase in the number of allegations, the

volume of allegations received concerning the Browns Ferry Unit 1 site decreased between

2005 and 2006 as construction activities wound down. The allegations received in 2006

addressed a variety of issues with no

clear trend of interest noted. The

licensee also indicated that the volume of

concerns received internally through the

Employee Concerns Program also

declined. 

The licensee’s Office of the Inspector

General completes a SCWE assessment

of all Tennessee Valley Authority (TVA)

sites every other year. Based on

discussions with the licensee, the

assessment in 2006 concluded that the

work environment was healthy, but

employee confidence in the Corrective

Action Program had declined, particularly

regarding nonsafety issue resolution. An

NRC inspection in late 2005 found that the licensee maintained an effective program for

identifying and resolving conditions adverse to quality and, based on interviews of employees

from various departments, did not reveal any reluctance on the part of employees to report

safety concerns.

The number of discrimination allegations also declined in 2006 to two after receiving five the

previous year. The two were withdrawn before investigations could be initiated. Of the five

received in 2005, one remains under investigation, two were investigated, but the staff was

unable to substantiate them, one was withdrawn by the alleger, and one was investigated and

substantiated. The NRC acknowledged that the contractor involved identified the issue and

took prompt corrective actions to address the specific issue and the SCWE within its

organization with little government intervention. In view of the immediate investigation and

prompt corrective action, the NRC exercised enforcement discretion in accordance with Section

VII.B.5 of the Enforcement Policy and did not issue a Notice of Violation in this matter. The 7

agency will consider any future violation of 10 CFR 50.7 for full application of the Enforcement

Policy. In the previous 3 years, the agency received five discrimination allegations. Of the four

received in 2004, two were investigated, but could not be substantiated, one was closed after

repeated unsuccessful attempts to contact the alleger for interview, and one was withdrawn by

the alleger. The one allegation received in 2003 was investigated, but not substantiated. 

The nature of allegations received in 2006 does not indicate a concern with the SCWE at the

Browns Ferry Unit 1 site. The NRC will continue to monitor the site’s work environment through

normal inspection activities.
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

-17-

Indian Point Units 2 and 3

After a declining trend over the last 4 years, the number of allegations concerning the Indian

Point site increased in 2006. The rate of receipt was steady throughout the year. Many of the

allegations raised to the NRC indicated concerns with the environment for raising issues

internally. A decline in the volume of

concerns received by the licensee’s

internal Employee Concerns Program

also suggested a potentially

weakening SCWE.

Four allegations of discrimination were

raised in 2006. Two of these are still

open and under investigation. The

alleger for the third allegation withdrew

the allegation, and the final case was

not pursued because a prima facie

showing was not articulated. In the

previous 4 years (2002 through 2005),

16 discrimination allegations were

raised. Of these sixteen, 10 were

investigated, but were not

substantiated. The others were not investigated because the allegers did not make a prima

facie showing.

In June 2006, the NRC referred a concern to the licensee, Entergy, regarding a potential

chilling effect. The alleged concern was based on the findings of a teamwork assessment

conducted in 2005 and the results of a sitewide assessment of the safety culture in early 2006. 

In the fall, the NRC conducted a P&IR inspection (Inspection Reports 05000247/2006006 and

05000286/2006006). Based on interviews with site personnel, the NRC team observed that

most workers indicated that they would raise issues that they recognized as nuclear safety

issues. However, as indicated by the allegations received, and supported by the licensee’s

earlier self-assessments, the interviews also identified some workers who expressed reluctance

to raise issues under certain circumstances because of the perception that there would be

negative consequences from management for doing so. While most workers made a

distinction between nuclear safety issues and other concerns, the NRC team found, through

illustrative examples, that some of the types of issues that employees indicated that they may

be hesitant to raise, could, in fact, have nuclear safety implications. The team also found that

Entergy had made only limited progress in evaluating and responding to both the referred NRC

concern and the results of the licensee’s safety culture assessment, specifically the declining

trends related to the SCWE. As a result, in a letter dated December 21, 2006, transmitting the

results of the NRC inspection, the agency requested that the licensee provide a plan for

evaluating and responding to the potential chilling effect on site. In January 2007, Entergy

responded to the NRC’s December 21, 2006, letter with a plan of actions intended to 

(1) improve communications, (2) identify and prevent retaliation, chilling effect, and the

perception of retaliation, (3) enhance the Corrective Action Program, (4) enhance the Employee

Concerns Program, and (5) improve the broader work environment at Indian Point. On

February 26, 2007, the NRC responded that Entergy’s proposed actions appear to be

reasonable and emphasized the importance of effective metrics to monitor progress. 

The NRC will continue to monitor the results of the licensee’s ongoing and proposed actions

through baseline inspection activities at Indian Point.
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

-18-

San Onofre Units 2 and 3

The number of allegations received from onsite sources at San Onofre increased in 2006, and

the allegation receipt rate has trended slightly upward from 2002 through 2006. The 15

allegations received in 2006 came from

several different plant functional areas,

with the largest contributions being from

the maintenance and security areas. A

very small percentage of the allegation

concerns raised directly involved issues

related to the willingness of employees to

raise concerns. As such, the number

and nature of allegations received

regarding San Onofre do not appear to

indicate a SCWE problem at the facility. 

The licensee’s Nuclear Safety Concerns

Program received concerns at a rate

consistent with previous years and saw

concentrations in functional areas similar

to those seen in the allegations provided

to the NRC. 

The NRC received three allegations of

discrimination in 2006, and all are still under investigation at this time. Of the three allegations

of discrimination received in 2005, two were investigated and not substantiated, and the other

was not pursued because the concerned individual would not provide his/her identity. The

agency received nine allegations of discrimination between 2002 through 2004. Seven of these

allegations were investigated, but not substantiated. One was closed because a prima facie

showing of potential discrimination was not articulated, and the other was not investigated

because the concerned individual did not wish to participate in the investigation.

The NRC PI&R inspection conducted in September 2006 (Inspection Report Nos.

05000361/2006/013 and 05000362/2006013) found that a healthy SCWE exists at San Onofre.

Site personnel interviewed during the inspection demonstrated a willingness to raise safety

concerns and an awareness of the means available for raising concerns. A few individuals

voiced concerns to the PI&R team about a decrease in confidence that the Corrective Action

Program will adequately address low-level problems, but none of the individuals indicated that

this would inhibit them from raising concerns in the future. The NRC also reviewed the results

of the licensee’s 2005 third-party independent survey of safety culture at San Onofre and the

licensee’s efforts in response. The results were similar to those of a previous survey conducted

in 2003 and were very positive with regard to the health of the SCWE at San Onofre. The NRC

staff found the licensee’s action plan for identified areas for improvement to be appropriately

focused, including extensive efforts to train managers at all levels on numerous elements of

safety culture. 

In general, the nature and number of the allegations received regarding San Onofre and the

similarity in trends of concerns raised internally do not indicate a SCWE problem. The NRC will

continue to monitor the work environment through normal inspection activities, including a

review of the periodic efforts by the licensee to monitor the SCWE and the general allegation

trends at San Onofre.

St. Lucie Units 1 and 2

The number of allegations received from onsite sources at St. Lucie in 2006 (15) was similar to

that received in 2005 (16). The NRC received two-thirds of the allegations in 2006 during the

timeframe of the mid-year refueling outage at St. Lucie Unit 2 (late April to late June 2006).

The St. Lucie Unit 2 refueling outage included reactor vessel head inspection activity and
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

-19-

control rod drive mechanism work, but did not involve major equipment replacement. One-third

of the allegations received were in the security area, with the disciplines of the remaining

allegations being spread among multiple workgroups. The site’s Speakout Program (now the

Employee Concerns Program (ECP))

received similar concentrations of

concerns. Some of the allegation

concerns received in 2006 involved

issues directly related to the willingness

of employees to raise concerns.

However, a review of the specific

concerns found that they involved

different issues with different workgroups

and were not indicative of a broader

SCWE problem. It is also noted that the

NRC did not receive any allegations

regarding St. Lucie during the last 4

months of 2006.

In response to an NRC-identified

concern with the SCWE at St. Lucie in

2003, the licensee took actions to measure and improve the onsite work environment, 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 noted evidence of an improving SCWE in 2004, and a

2004 NRC PI&R inspection (Inspection Report Nos. 05000335/2004007 and

05000389/2004007) did not identify any reluctance on the part of plant staff to report safety

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

Program in dealing with SCWE issues (Inspection Report Nos. 05000335/2005003 and

05000389/2005003) with generally positive results. In addition to interviewing site personnel

about the environment for raising safety issues during the PI&R inspection in August 2006

(Inspection Report Nos. 05000335/2006008 and 05000389/2006008), the NRC inspection team

reviewed a large sample of ECP files to assess the effectiveness of the ECP in capturing and

resolving concerns received that involved conditions adverse to quality and the responsiveness

and quality of feedback provided to concerned individuals. In general, the inspection team

found that the SCWE at St. Lucie is healthy and that employees feel free to raise issues to their

management without fear of retaliation. The ECP was found to be generally effective in

investigating and facilitating the resolution of employee concerns. However, during the 2006

P&IR inspection, some individuals indicated a problem with the timeliness of ECP feedback and

suggested that this may cause some to be reluctant to use the ECP in the future. The licensee

has acknowledged that negative perceptions continue to exist about the ECP, as evidenced by

both recent internal SCWE survey results and the results of the NRC 2006 PI&R inspection. In

response, the licensee is taking actions to address these perceptions, including the

standardization of the organizational makeup and function of the ECP across the Florida Power

& Light fleet (St. Lucie, Turkey Point, Seabrook, and Duane Arnold), better communications

about ECP program functions and policies, and the initiation of “cultural meetings” with

employees to discuss topics related to the SCWE and safety culture. 

As indicated in the previous discussion about Turkey Point, another in the Florida Power & Light

fleet, 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,

identified the condition reporting system as an area of concern. In response, 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

understand how management prioritizes issues raised based on their safety significance. The

licensee completed a subsequent SCWE survey in late 2006, but the analysis of the survey

results had not been completed at the time of this report. The results of this more recent
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

-20-

survey should provide insight as to whether any SCWE issues remain. It is noted that, while

the August 2006 NRC PI&R inspection did identify some weaknesses in selected corrective

action process items involving trending, extent of condition review, and program administration,

the agency concluded that, in general, the licensee is effective in identifying problems,

prioritizing and scheduling corrective actions, considering operating experience, and

implementing corrective actions in a timely manner.

One allegation of discrimination was raised in 2006, but was not investigated because the

concerned individual did not wish to participate in an investigation. In 2005, the NRC received

four allegations of discrimination. Three were investigated and not substantiated, and the other

alleger did not wish to participate in an investigation. For the three allegations of discrimination

raised in 2004, the concerned individuals in two of the cases indicated that they did not wish to

pursue the matter via NRC investigation. The other case was investigated, but not

substantiated. In 2003, four discrimination allegations were raised. All were investigated, but

none were substantiated. No discrimination allegations were raised in 2002.

In general, the nature and number of the allegations received regarding St. Lucie, similar trends

in concerns being raised internally, and the coincidence of allegation receipt with a period of

increased activity at the facility do not indicate a problem with SCWE. The NRC will continue to

monitor the work environment through normal inspection activities, including a review of the

annual internal SCWE surveys, any actions taken by the licensee to address issues that could

have a negative impact on the SCWE if left unaddressed (such as the current licensee actions

to mitigate certain negative perceptions about the ECP), and allegation trends. 

Harris

The NRC receipt of allegations concerning the Harris plant trended upward in 2006 from an

already high level in 2005, although most of the allegations were received in the first quarter of

the calendar year. As in the previous year, the majority of the concerns received were in the

area of security. To ensure that the agency avoids the unnecessary release of information that

would reveal any potential securityrelated 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. Nonetheless, the agency did

release limited information to the public

concerning inspection activities at the

plant in the security area in early 2006. 

These activities, which involved

interviews with 91 contract security

officers and reviews of numerous

security-related documents, identified no

findings of significance. The NRC also

did not identify widespread reluctance

among workers at the plant to raise

safety concerns.

The licensee indicated that it also saw an increase in concerns raised internally to its Employee

Concerns Program in 2006, and it also noted a trend in the security area in early to mid-2006. 

Of note, the licensee reports that the new security force union is actively encouraging

improvements to the environment for raising concerns internally. The licensee conducted an

assessment of the safety culture, including the SCWE, in summer 2006. The licensee

communicated to the staff that no significant SCWE issues were identified. 
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

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The number of discrimination concerns raised in the last 5 years is low. The agency received

one allegation of discrimination in 2002, which was later withdrawn at the request of the

individual. An issue raised in 2006 is currently under investigation. 

An analysis of the trends and nature of the allegations raised concerning the Harris plant do not

suggest a concern with the SCWE. Similarly, trends in the licensee’s Employee Concerns

Program suggest an improving environment and willingness to raise concerns internally. The

NRC will continue through the normal inspection and oversight processes to monitor allegation

trends and the work environment.

Salem/Hope Creek 

The number of allegations concerning Salem/Hope Creek decreased significantly from 23 in

2005 to 14 in 2006. This is reflective of improvements made in the SCWE area in response to

significant SCWE findings identified

during the 2003–2004 timeframe. 

Before 2006, the number of allegations

received concerning Salem/Hope Creek

had steadily increased from 2003

through 2005 as the SCWE issues

emerged and as the efforts of the

licensee’s Public Service Enterprise

Group (PSEG) to resolve them

progressed. 

In mid-2004, the NRC informed PSEG

of the final results of a special NRC

SCWE review. While no serious safety

violations were identified, the agency

concluded that there were numerous

indications of weaknesses in corrective

actions and management efforts to

establish an SCWE. The licensee’s self-assessments during this timeframe revealed similar

findings. The 2004 ROP mid-cycle assessment for Salem/Hope Creek prompted a Deviation

from the ROP Action Matrix to provide enhanced oversight for the SCWE area, including

management meetings with the licensee, the establishment of an oversight coordination team,

and additional inspections. 

While the licensee put forth significant effort in 2004–2005 to address the SCWE findings,

facility changes in 2005 presented new challenges to SCWE improvement, including PSEG

entrance into a nuclear operating services contract with Exelon, numerous senior management

changes, and the implementation of initiatives to address long-standing performance problems. 

These changes contributed to continuing negative worker perceptions regarding the advisability

of raising issues or challenging decisions. As a result, the 2005 ROP mid-cycle assessment for

Salem/Hope Creek identified a substantive crosscutting issue in the SCWE area based on the

results of the NRC’s ongoing review. The agency renewed the ROP Deviation Memorandum to

allow for continued close monitoring of PSEG efforts to address issues associated with SCWE. 

In September 2005, the staff completed a SCWE inspection at the site which concluded that

progress had been made in addressing work environment issues, but noted some issues

requiring additional action and focused attention. The results of a PI&R inspection conducted in

late 2005 (Inspection Report Nos. 05000354/2005007, 05000272/2005012, and

05000311/2005012) revealed progress in the SCWE area. However, the agency retained the

SCWE substantive crosscutting issue at the 2005 ROP end-of-cycle assessment because of

remaining followup actions from the 2005 NRC SCWE inspection. 

The results of a third-party site safety culture survey administered by PSEG in early 2006

indicated improvement in nearly all cultural metrics when compared to the results of a similar
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

-22-

survey conducted in 2005. Also in that timeframe, PSEG commissioned an independent peer

assessment of SCWE at Salem/Hope Creek. The peer assessment team concluded that

substantial and sustainable progress had been made in the work environment at both facilities.

In June 2006, the NRC completed a followup SCWE team inspection which also concluded that

the progress realized in the SCWE area at Salem/Hope Creek was substantial and that

processes are in place for sustaining these improvements (Inspection Report Nos.

05000354/2006011, 05000272/2006012, and 05000311/2006012). As a result, the NRC closed

the SCWE substantive crosscutting issue at the 2006 ROP mid-cycle assessment. The agency

had previously closed a substantive crosscutting issue in PI&R in early 2006 after actions taken

by PSEG to improve the resolution of concerns proved effective.

The receipt of allegations by the NRC in 2006 from Salem/Hope Creek onsite sources was

spread evenly throughout the calendar year. A significant portion of the allegations received in

2006 involved a particular workgroup at one of the facilities. PSEG was aware of

communications and accountability issues within this workgroup based upon the receipt of

similar concerns internally and is taking actions to address them. 

There were four allegations of discrimination at Salem/Hope Creek in 2006. One of these is

being considered for mediation under Early-ADR, and the other three did not meet the

requirements for initiation of an investigation. In the previous 4 years (2002 through 2005), 14

allegations of discrimination were raised. Four of these were closed because a prima facie

showing of potential discrimination was not articulated, and four were not investigated because

the concerned individuals did not wish to participate in the investigation. The remaining six

were investigated, but none were substantiated.

The NRC has concluded that the progress realized in the SCWE area at Salem/Hope Creek in

2006 was substantial and that processes are in place for sustaining these improvements. As a

result, the agency closed the SCWE substantive crosscutting issue at the 2006 ROP mid-cycle

assessment. The NRC will continue to monitor the SCWE at Salem/Hope Creek by means of

the baseline inspection program and allegation trending, with attention given to PSEG efforts to

resolve communications and accountability issues within a particular workgroup at one facility

that has recently been the source of a number of concerns raised both internally to PSEG and

as allegations to the NRC. 

Sequoyah Units 1 and 2

The volume of allegations concerning the Sequoyah site remained fairly steady when compared

to the previous year, and, like the previous year, the allegations addressed a variety of issues

with no trends of interest noted. 

Discussions with the licensee indicate

the number of concerns going to the

Employee Concerns Program (ECP)

increased significantly over the same

time period. The increase is credited

to the addition of a new, full-time ECP

manager on site. It should be noted

that the number of concerns requiring

investigation, after a spike in 2005,

actually dropped in 2006 to levels

typically seen in the program. The

increase in overall traffic to the ECP

was from informal ECP contacts, which

tripled last year. The ECP data noted

trends in the concerns about a

particular demographic, and the
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

-23-

licensee has taken steps to improve communications within that demographic.

The licensee conducted an assessment of its safety culture, including the SCWE in June 2006. 

Ninety percent of the work force participated in this assessment, which was primarily conducted

through a survey. Results show that SCWE ratings were high overall, including employee

willingness to raise issues without fear of retaliation. Organizations that had lower ratings in

SCWE and other categories, as compared to the site norm, developed action plans to address

the findings. Other actions have been identified to improve the SCWE sitewide, including

increased monitoring and accountability of management support of SCWE principles.

Additionally, the licensee established an Employee Advisory Counsel (EAC) to improve

communications between employees and company executives. Representatives from the rated

organizations were added to the EAC. A second assessment, the Cultural Health Index,

conducted every 2 years at TVA plants, and a third conducted by the Inspector General, also

identified high SCWE ratings, but found that employees were concerned with the effectiveness

of the Corrective Action Program and the visibility of the ECP. The licensee is addressing these

findings as well.

One allegation of discrimination was made in 2006. Four discrimination allegations were raised

in 2005; three were investigated, but the NRC was unable to substantiate them, while one was

withdrawn at the request of the alleger. No other claims of discrimination were alleged during

the review period (2002 through 2006).

An analysis of the trends and nature of the allegations raised concerning the Sequoyah plant do

not suggest a concern with the SCWE. Similarly, trends in the licensee’s Employee Concerns

Program suggest an improving environment and willingness to raise concerns internally. The

NRC will continue to monitor allegation trends and the work environment through the normal

inspection and oversight processes.

South Texas Units 1 and 2

The number of allegations received by the NRC concerning the South Texas site increased in

2006. A trend in the security area was evident. The NRC staff is generally not at liberty to

discuss specific information concerning actions taken by the agency or the licensee in the

security area to ensure that staff

avoids the unnecessary release of

information that would reveal any

potential security-related

vulnerabilities. However, the agency

did release to the public limited

information concerning inspection

activities at the plant in the security

area in late 2006. That inspection

included interviews with 75 security

officers and other plant personnel and

a review of a number of securityrelated documents. The inspectors

concluded that a SCWE existed on

site. In general, interviewed

employees felt free to raise nuclearsafety-related concerns through a

variety of avenues, both internally and

externally. However, some issues identified, although outside NRC regulatory jurisdiction,

could potentially impact the SCWE on site if not effectively addressed by the licensee.

Discussions with the licensee indicated that the volume of concerns raised internally through

the Employee Concerns Program during the last 2 years remained steady, however, a much

larger percentage of issues were security related in 2006 as compared to 2005. The licensee
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

-24-

conducted a safety culture assessment in mid-2005, which included a review of the SCWE. 

Overall, that assessment found that the majority of those surveyed felt free to raise concerns

without fear of retaliation and believed their managers wanted concerns raised. The security

organization rated aspects of the culture lower than the rest of the site. The licensee continues

to address those findings. In 2006, the licensee integrated security contract personnel into the

licensee’s training program, formed an officers/management team to strengthen relationships

and communications, and implemented an oversight panel to monitor security contractor

personnel actions.

Two allegations of discrimination were raised in 2006; one is still under investigation, while the

other was investigated, but not substantiated. Between 2002 and 2005, three discrimination

allegations were raised. One raised in 2002 was withdrawn after the alleger did not respond to

NRC requests for contact, and the remaining two were investigated, but the staff was unable to

substantiate that discrimination took place.

Based on recent inspections and the trends noted above, the NRC believes that the SCWE at

South Texas is conducive to raising nuclear safety concerns. The staff will continue to monitor

the work environment, particularly in the security area, through normal inspection activities.

Allegation Trends for Selected Materials Licensees

The NRC Web site posts allegation statistics for certain fuel cycle facilities (see Appendix 1).

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 publicly 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

to provide insights into the SCWE, therefore, this report does not include more in-depth reviews

of specific materials licensees.

Allegation Trends for Selected Vendors

Because none of the vendors received a sufficient number of allegations to discern a trend or

pattern or to provide insights into the work environment, this report does not include more indepth reviews of specific vendors. The report also does not provide statistics by contractor or

vendor because publishing the number of allegations received has the potential of identifying an

alleger.
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

-25-

CONCLUSIONS

From calendar year 2002 through 2006 the number of allegations received by the NRC has

remained fairly steady, fluctuating each year on average by plus or minus 55 allegations.

Reductions in allegations received from some reactor facilities that had experienced significant

allegation activity in recent years explain the approximate 10-percent drop in reactor allegations

from 2005 to 2006. From a regional perspective, the number of concerns received at operating

power reactor facilities decreased slightly in all regions in 2006. The number of materials

issues received in each region has trended downward, with the exception of Region I. The

transfer of responsibility for oversight of all former Region II materials licensees to Region I in

2003 has sustained the rate of receipt of materials allegation concerns in Region I. Securityrelated concerns continue to be the largest percentage of concerns received. 

The analyses of allegations have provided insights into the SCWE at several facilities. The

staff has taken action to engage licensees concerning their work environment when warranted

and will continue to monitor these sites with interest. The agency has also provided additional

training and guidance in this area to the NRC inspection staff as part of the initiative to enhance

the ROP to more fully address safety culture and SCWE.

The agency’s Early-ADR process resulted in nine cases in which discrimination allegations were

successfully settled between the parties before the start of an NRC investigation. 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.

Finally, the allegation and security staff successfully developed a new policy for corresponding

with allegers who raise security-related concerns. The previous policy had made it difficult for

the staff to assure allegers that their concerns had been addressed. The Commission

approved the policy change on March 28, 2007. 

RECOMMENDATIONS

The Agency Allegation Advisor has no recommendations for program changes at this time.
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

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ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

APPENDIX 1

ALLEGATION STATISTICS 

OPERATING REACTORS AND FUEL FACILITIES
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

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ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

-A-1-

OPERATING REACTOR ALLEGATIONS RECEIVED FROM ONSITE SOURCES

Site 2002 2003 2004 2005 2006

 Arkansas 1 & 2 3 4 6 4 4

 Beaver Valley 1 & 2 1 1 9 7 3

 Braidwood 1 & 2 5 1 3 4 6

 Browns Ferry 2 & 3 2 6 5 1

 Brunswick 1 & 2 1 3 2 3 1

 Byron 1 & 2 13 11 6 12 3

 Callaway 7 3 1 11 3

 Calvert Cliffs 1 & 2 3 4 5 1 2

 Catawba 1 & 2 2 2

 Clinton 3 2 4 1 3

 Columbia Plant 5 4 6 7 3

 Comanche Peak 1 & 2 2 1 2 9 3

 Cook 1 & 2 14 9 12 7 7

 Cooper 6 8 10 1 3

 Crystal River 2 3 4 2 4

 Davis-besse 26 18 12 9

 Diablo Canyon 1 & 2 3 2 2 2 2

 Dresden 2 & 3 11 3 3 9 7

 Duane Arnold 2 2 8 1 1

 Farley 1 & 2 1 3 1 4 4

 Fermi 4 2 2 2 3

 Fitzpatrick 1 7 3 3

 Fort Calhoun 2 3 2 2 6

 Ginna 1 2 2 2

 Grand Gulf 6 6 7 4

 Harris 6 1 9 14

 Hatch 1 & 2 3 2 1 3 1

 Indian Point 2 & 3 29 20 19 9 15

 Kewaunee 3 4 3 3 4

 Lasalle 1 & 2 1 2 2 1

 Limerick 1 & 2 7 4 4 8 4

 Mcguire 1 & 2 2 2 2

 Millstone 2 & 3 7 6 1 10 9

 Monticello 1 2 1

 Nine Mile Point 1 & 2 5 2 4 4 5

 North Anna 1 & 2 10 1 4 2 1

 Oconee 1, 2, & 3 1 3 11 3 2

 Oyster Creek 9 18 8 14 4

 Palisades 9 7 10 3 6

 Palo Verde 1, 2, & 3 2 19 8 22 16

 Peach Bottom 2 & 3 1 2 1 5 6

 Perry 5 5 12 4 1

 Pilgrim 2 5 14 9 6

 Point Beach 1 & 2 7 9 11 13 2

 Prairie Island 1 & 2 5 2 4 5 5

 Quad Cities 1 & 2 3 1 1 2 1

 River Bend 1 4 3 2 3

 Robinson 1 1

 Salem/Hope Creek 11 6 18 23 14

 San Onofre 2 & 3 11 11 13 10 15

 Seabrook 6 3 3 9 4
2006 ANNUAL TRENDS REPORT ALLEGATION PROGRAM

Site 2002 2003 2004 2005 2006

-A-2-

 Sequoyah 1 & 2 5 7 4 10 11

 South Texas 1 & 2 6 2 6 4 8

 St Lucie 1 & 2 11 24 4 16 15

 Summer 2 4 3 3

 Surry 1 & 2 4 2 1 2 1

 Susquehanna 1 & 2 9 3 13 20 19

 Three Mile Island 5 1 6 4 1

 Turkey Point 3 & 4 2 3 9 10 17

 Vermont Yankee 4 3 1 4

 Vogtle 1 & 2 3 1 1 5 5

 Waterford 7 1 2 2

 Watts Bar 8 2 4 2 6

 Wolf Creek 1 3 1
ALLEGATION PROGRAM 2006 ANNUAL TRENDS REPORT

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FUEL CYCLE FACILITY ALLEGATIONS RECEIVED FROM ONSITE SOURCES

Site 2002 2003 2004 2005 2006

 Framatone-Lynchburg 1

 Framatone-Richland 1 1 1

 Global Nuclear Fuel 1 2

 Honeywell 3 2 7

 Paducah 15 22 10 7 3

 Portsmouth 6 2 7 2 4

 Westinghouse 1 8 2