ALLEGATION PROGRAM 

 ANNUAL TRENDS REPORT

 Calendar Year 2011

U.S. Nuclear Regulatory Commission 

Office of Enforcement 

Washington, DC 20555
i

CONTENTS 

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

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

Allegation Program Guidance ............................................................................................. 3 

Late-Filed Allegations .............................................................................................. 3 

Chilling Effect Letters ............................................................................................... 3 

NRC Form 3 ............................................................................................................. 4 

Allegation Program Brochure .................................................................................. 4 

Allegation Dispute Resolution Process ............................................................................... 5 

Correlations Between Safety Culture Survey Data and Allegation Data ............................ 5 

TRENDS IN ALLEGATIONS ........................................................................................................... 6 

National Trends ................................................................................................................... 6 

Reactor Licensee Trends ........................................................................................ 7 

Material Licensee Trends ........................................................................................ 8 

Source Trends ......................................................................................................... 9 

Allegation Trends for Selected Reactor Sites ................................................................... 10 

San Onofre Units 2 and 3 ...................................................................................... 11 

Susquehanna Units 1 and 2 .................................................................................. 13 

Turkey Point Units 3 and 4 .................................................................................... 14 

Saint Lucie Units 1 and 2 ....................................................................................... 15 

Indian Point Units 2 and 3 ..................................................................................... 16 

Allegation Trends for Selected Materials Licensees ......................................................... 16 

Allegation Trends for Selected Vendors ............................................................................ 16 

Allegation State Trends ..................................................................................................... 17 

CONCLUSIONS ............................................................................................................................ 19 

APPENDIX 1 ................................................................................................................................ A-1 

FIGURES 

1 Allegations Received by Calendar Year .............................................................................. 6 

2 Reactor Issues Nationwide 2011 ......................................................................................... 8 

3 Materials Licensee Types Nationwide 2011 ........................................................................ 9 

4 Allegations by Source Category 2011 ............................................................................... 10 

5 San Onofre 2 & 3 Allegations ............................................................................................ 11 

6 Susquehanna 1 & 2 Allegations ........................................................................................ 13 

7 Turkey Point 3 & 4 Allegations .......................................................................................... 14 

8 Saint Lucie 1 & 2 Allegations ............................................................................................. 15 

9 Indian Point 2 & 3 Allegations............................................................................................ 16

10 Agreement States .............................................................................................................. 17 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

1 

EXECUTIVE SUMMARY 

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

Allegations,” dated November 15, 2010, requires the Agency Allegation Advisor to prepare an 

annual report for the Executive Director for Operations that analyzes allegation trends. This 

annual report fulfills that commitment by providing national, regional, and site-specific trend 

analyses. In addition, significant staff activity in calendar year (CY) 2011 involving the Allegation 

Program and related policies are discussed in this report. The reports also includes discussion 

on the development of enhanced guidance for the NRC staff handling allegations, and for the 

public engaged in the program, and correlations between safety culture survey scores and 

allegation data identified by the NRC’s Office of Nuclear Regulatory Research. Lastly, the 

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

process for discrimination allegations (Early ADR). Twenty-one percent of the discrimination 

cases raised in CY 2011 offered Early ADR reached settlement. 

There has been a declining trend in the total number of allegations1

 received from CY 2009 

through CY 2011. The decrease in allegations received in CY 2010 and again in CY 2011 

appears to be the result of large reductions in allegation receipt related to two reactor facilities 

that had experienced problems with their safety conscious work environment (SCWE). As 

actions were implemented at these facilities in response to the identified SCWE problem, and 

after receiving a chilling effect letter (CEL) from the NRC, the number of allegations received in 

subsequent years dropped precipitously. These decreases in allegation receipt do not appear to 

be the result of a general industry issue or other external factor because the reasons for the 

substantive changes in the numbers of allegations received about these facilities were based on 

plant-specific matters. 

Each allegation can include multiple concerns. In CY 2011, coinciding with the overall decrease 

in allegations received, the total volume of allegation concerns received decreased in three of 

the four regional offices, the Office of Nuclear Reactor Regulation, and the Office of Federal and 

State Materials and Environmental Management Programs. Region I experienced a substantial 

increase in the number of concerns received. Twelve percent of the allegations received in 

Region I in CY 2011 included four or more concerns; one allegation had more than 20 concerns. 

However, there were no apparent trends in Region I in terms of allegation concerns coming from 

particular facilities or types of facilities, or as a result of an event. The largest percentage of 

concerns received nationwide were discrimination concerns, which increased slightly from the 

number of discrimination concerns received in CY 2010. The total number of chilling effect 

concerns; however, decreased considerably in CY 2011. While the number of security-related 

concerns also remained high, most of the security concerns raised (greater than 70 percent) 

involved only a small number of reactor sites. 

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 materials 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.2

 

The staff selected five reactor sites for more in-depth review: San Onofre Units 2 and 3, 

 

1

 An allegation is defined as “a declaration, statement, or assertion of impropriety or inadequacy associated 

with NRC-regulated activities, the validity of which has not been established.” 

2

 The total number of allegations received concerning reactor licensees from all sources, as well as other 

information concerning the Allegation Program, appears on the NRC’s public Web site at 

http://www.nrc.gov/about-nrc/regulatory/allegations/statistics.html. 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

2 

Susquehanna Units 1 and 2, Turkey Point Units 3 and 4, Saint Lucie Units 1 and 2, and Indian 

Point Units 2 and 3. This report discusses allegation trends at each of these sites. In summary, 

the trends for these facilities do not suggest a concern about the environment for raising 

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

warranted additional analysis. 

Finally, in CY 2011, the NRC reviewed the effectiveness of 10 Agreement State Programs’ 

responses to concerns and concluded that the Agreement States continue to address concerns 

promptly, thoroughly document their investigations and closeout actions, inform the concerned 

individuals of the outcomes, and protect their identity.
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

3 

OVERVIEW OF SIGNIFICANT PROGRAM ACTIVITIES

In calendar year (CY) 2011, the U.S. Nuclear Regulatory Commission (NRC) undertook several 

significant activities that affected the agency’s Allegation Program and related policies. The 

agency developed guidance for the NRC staff implementing the Allegation Program on handling 

allegations that may affect agency decisions late in the decisionmaking process. The staff also 

developed guidance for the consideration and use of “chilling effect letters” (CELs). NRC 

Form 3, “Notice to Employees,” and a brochure provided to members of the public engaging in 

the Allegation Program were updated in CY 2011 to incorporate information about the 

agency-sponsored alternative dispute resolution process for discrimination allegations (Early 

ADR). At the time this report was prepared, approximately 21 percent of the discrimination 

cases offered Early ADR in CY 2011 reached settlement. Finally, the Office of Nuclear 

Regulatory Research conducted an analysis of safety culture survey data and found a 

correlation between that data and allegation program data. The sections below discuss these 

areas in more detail. 

 

Allegation Program Guidance

Late-Filed Allegations

In March 1985, the Commission issued criteria for addressing late allegations in the form of a 

policy statement, “Handling of Late Allegations.” The purpose of the policy statement was to 

explain to all stakeholders how the staff would address allegations brought to its attention shortly 

before the date on which the agency was to make a decision authorizing the issuance of an 

operating license under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, “Domestic 

Licensing of Production and Utilization Facilities.” 

The staff incorporated guidance from the 1985 Commission policy statement into the Agency 

Allegation Program policy guidance in existence at that time and carried the guidance over into 

the initial issuance of Management Directive (MD) 8.8, “Management of Allegations,” in 1996. 

In 2010, the NRC issued the latest revision of MD 8.8. This revision, among other changes, 

streamlined the directive handbook to retain primary policy guidance while transferring 

nonpolicy-related information (e.g., clarifying implementation guidance, situational examples, 

and letter templates) from the MD to a separate Allegation Manual. During CY 2011, however, 

questions arose about whether the streamlined guidance in MD 8.8 on the handling of late 

allegations still clearly reflected previous Commission direction on which allegations needed to 

be resolved before the agency made decisions. To that end, the staff re-incorporated enhanced 

guidance for the staff on this topic into the MD and issued Allegation Guidance Memorandum 

2011-001, “Late-filed Allegations,” dated November 20, 2011 (Agencywide Documents Access 

and Management System (ADAMS) Accession No. ML11227A241). 

Chilling Effect Letters

Although not finalized until early 2012, the staff also developed enhanced guidance on the 

consideration and use of CELs. A CEL is a regulatory tool that the agency uses to ensure that 

licensees and other entities subject to NRC authority are taking appropriate actions to foster a 

workplace environment that encourages employees to raise safety concerns and to feel free to 

do so without fear of retaliation. The NRC refers to such an environment as a safety conscious 

work environment (SCWE). 

The staff gathers insights into the SCWE at a particular site in several ways (e.g., reviewing the 

number and nature of allegations concerning that site and documented observations based on 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

4 

interviews with the licensees’ employees and the review of pertinent documents during the 

baseline problem identification and resolution inspections). If the staff discerns that a work 

environment is “chilled” (i.e., not conducive to raising safety concerns internally), the NRC may 

request, in writing, information about the licensee’s SCWE (i.e., a CEL). 

A CEL may be warranted in two specific situations. The first situation arises when an allegation 

of discrimination is made directly to the U.S. Department of Labor (DOL). When an initial DOL 

investigation concludes that discrimination occurred, the NRC staff considers how the DOL 

finding will affect the SCWE. In particular, the staff needs to ensure that awareness in the 

workplace of DOL’s discrimination finding has not created a chilling effect (i.e., has not 

discouraged other employees and contractors from raising safety concerns). The NRC 

Enforcement Manual currently provides detailed guidance on considering the issuance of a CEL 

in such cases. (The NRC Enforcement Manual appears on the agency’s public Web site at: 

http://www.nrc.gov/about-nrc/regulatory/enforcement/guidance.html#manual.) 

The NRC Enforcement Manual also recognizes a second situation in which the staff may 

consider issuing a CEL; however, it provides no detailed guidance to the staff. For situations 

involving allegations and other indications of a chilled work environment that do not involve a 

DOL finding of discrimination, but nonetheless may warrant the issuance of a CEL, the staff 

prepared new guidance to ensure the effective and consistent use of this tool, Allegation 

Guidance Memorandum 2012-001, “NRC Chilling Effect Letters,” dated March 9, 2012 (ADAMS 

Accession No. ML12025A055). The guidance does not represent new policies or practices; 

instead, it documents the NRC staff’s existing practices regarding the factors that have been 

considered when deciding to issue a CEL, the process used to make that determination, the 

contents of the CEL, the evaluation of a CEL response, and the closure of the CEL. 

No CELs were issued in CY 2011, although one issued in CY 2010 for the San Onofre Nuclear 

Generating Station was closed in September 2011. This issue is discussed in more detail later 

in this report. 

NRC Form 3

The NRC updated two publications related to the Allegation Program in CY 2011. The NRC’s 

Form 3, “Notice to Employees,” is required under Title 10 of the Code of Federal Regulations 

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

Investigations,” to be posted by NRC licensees and applicants to inform their workers about 

employee protections against radiation and protections against discrimination for raising safety 

concerns. In August 2011, Form 3 was updated to incorporate clarifying information about the 

agency’s Early ADR process. The form was updated again in CY 2012 to reflect new contact 

information following NRC regional office moves. The latest version of Form 3 can be found on 

the NRC’s public Web site at: http://www.nrc.gov/reading-rm/doc-collections/forms/. 

Allegation Program Brochure

The same Early ADR information was also incorporated into a September 2011 update of the 

agency’s brochure provided to concerned individuals interested in the allegation process 

(NUREG/BR-0240, “Reporting Safety Concerns to the NRC”). A new section was added 

describing the NRC’s SCWE policy and, in response to public comments, the brochure was also 

revised to clarify that the process applies to both members of the general public as well as 

workers in the nuclear industry. The brochure can be found on NRC’s public Web site at: 

http://www.nrc.gov/about-nrc/regulatory/allegations-resp.html. 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

5 

Alternative Dispute Resolution Process 

The NRC’s ADR Program includes the opportunity to use ADR early in the allegation process for 

cases of alleged discrimination before the NRC investigates the allegation. Early ADR provides 

parties additional opportunities to resolve their differences outside the normal regulatory 

framework, and it uses a neutral third party to facilitate discussions and the timely settlement of 

the discrimination concern. The NRC believes that voluntary dispute resolution by the parties 

using the communication opportunities that the Early ADR process provides can stem the 

inherent damage such disputes can inflict on the SCWE more quickly than an investigation. At 

any time, either party can exit the ADR process; an NRC investigation remains an option if the 

alleger still wants to pursue the discrimination matter. Should such an investigation and 

resulting enforcement panel conclude that enforcement is warranted, the NRC and licensee still 

may engage in was the agency refers to as “Post-Investigation ADR.” For more information on 

that process, please go to http://www.nrc.gov/about-nrc/regulatory/enforcement/adr/postinvestigation.html on the NRC’s public Web site. If during Early ADR, however, the parties reach 

a settlement, the staff will not pursue an investigation or subsequent enforcement of 

discrimination findings. The NRC also considers settlements resulting from licensee-initiated 

mediation as equivalent to settlements reached under the Early ADR Program. 

The NRC made 68 Early ADR offers in association with discrimination allegations raised in 

CY 2011. At the time this report was prepared, 24 cases (35 percent) had resulted in 

agreements to mediate. Of those 24 cases, 14 (58 percent) mediated discrimination concerns 

resulted in the parties reaching a mutually agreeable settlement. 

Correlations between Safety Culture Survey and Allegation Data 

The Institute of Nuclear Power Operations conducted a safety culture survey in 2010 at 

97 percent of the operating power plants nationwide. The survey asked a sample of at least 

30 employees from each site about their opinions on various aspects of the safety culture at their 

organization. Although the overall survey was not significantly correlated with allegation counts 

in 2010, based on an analysis conducted by the NRC’s Office of Nuclear Regulatory Research in 

CY 2011, there was a significant, moderate correlation between the overall survey scores at 

each site and counts of allegations in the following year. Furthermore, the “questioning attitude” 

factor of the survey which is meant to measure how comfortable individuals are challenging 

assumptions, investigating anomalies, and considering potential adverse consequences of 

planned actions, had a moderately sized, significant correlation with counts of allegations 

during 2010 and also correlated with counts of allegations in 2011. These correlations suggest 

that sites with lower safety culture survey scores were more likely to have higher numbers of 

allegations in the following year, and sites with lower scores on the “questioning attitude” factor 

of the safety culture survey were more likely to have higher counts of allegations in the same 

year and the following year. 

The NRC issued the Safety Culture Policy Statement in June 2011 which provides the agency’s 

expectation that individuals and organizations performing regulated activities establish and 

maintain a positive safety culture commensurate with the safety and security significance of their 

activities and the nature and complexity of their organizations and functions. The Policy 

Statement can be found on the NRC’s public Web site at: http://www.nrc.gov/aboutnrc/regulatory/enforcement/safety-culture.html. The staff will monitor future allegation trends for 

indications that the Policy Statement has had an impact on licensees’ questioning attitude, 

environments for raising concerns, and other safety culture traits.
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

6 

TRENDS IN ALLEGATIONS

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

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

report, the staff reviewed a 5-year history of allegations received for reactor and materials 

licensees and vendors. The staff focused on allegations with the potential to provide insights 

into the SCWE at a given facility. Such allegations include those submitted by current or former 

licensees, contractor employees, or anonymous sources that indicate an unwillingness to raise 

safety concerns internally. For power reactor facilities, the staff analyzes recent allegation 

activity twice a year in support of the Reactor Oversight Process (ROP) midcycle and 

end-of-cycle assessments. In addition, the staff may analyze 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, 

shifts in users of the Allegation Program, and the effect that the implementation of the program 

has on the workload in the regions and program offices. The following section discusses these 

trends. 

National Trends

National trends provide general information to the staff about the effect of external factors, plant 

events, and industry efforts to improve the SCWE at NRC-licensed facilities. They can be useful 

in developing budget and 

planning assumptions to 

support future agency and 

Allegation Program needs. 

 Figure 1 shows that the 

NRC receives 

approximately 

600 allegations each year 

and that there has been a 

declining trend in the total 

number of allegations 

received from CY 2009 

through CY 2011. In 

CY 2008, the total number 

of allegations received 

increased by about 

10 percent over the total 

received in CY 2007, 

primarily because of substantive increases in allegations received about several reactor facilities 

and one fuel cycle facility. The decreases in allegations received in CY 2010 and again in 

CY 2011 appear to be the result of large reductions in allegations received for two reactor 

facilities that experienced SCWE problems in previous years, which resulted in the NRC issuing 

a CEL. As actions were implemented at these facilities in response to the identified SCWE 

problem and the related CEL, the number of allegations received dropped precipitously in 

subsequent years. The increases and decreases in allegation receipt described above do not 

appear to be the result of a general industry issue or other external factor, since the reasons for 

the substantive changes in the number of allegations received about these facilities were plantspecific and varied (e.g., significant outage activity, construction activity, security issues, work 

environment issues, work planning, or Corrective Action Program changes). 

0

200

400

600

800

2007 2008 2009 2010 2011

FIGURE 1 - ALLEGATIONS RECEIVED BY 

CALENDAR YEAR

Reactor Materials Agreement State
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

7 

The number of allegations that the NRC processed for Agreement State matters continues to be 

minimal. The total number of Agreement States remains at 37. Once the Agreement State 

Program is explained to them, most individuals who contact the NRC with concerns about 

Agreement State licensees indicate a willingness to contact and be contacted directly by 

Agreement State personnel about the evaluation of their concern(s). The NRC forwards these 

matters to the Agreement State and does not process them as allegations. Generally, the NRC 

uses the Allegation Program only to track the evaluation of concerns about Agreement State 

licensees when the concerned individual does not want his or her identity to be revealed to the 

Agreement State. 

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

provide more specific information on the staff effort needed for an appropriate response. Over 

the last several years, the trend in the total number of concerns in all but one year3

 has 

paralleled the trend in total allegations (e.g., if the number of allegations decreased, the number 

of concerns decreased as well). In CY 2011, coinciding with the overall decrease in allegations 

received, the total volume of allegation concerns received decreased in three of the four regional 

offices, the Office of Nuclear Reactor Regulation, and the Office of Federal and State Materials 

and Environmental Management Programs. Region I experienced a substantial increase in the 

number of concerns received. Twelve percent of the allegations received in Region I in CY 2011 

included four or more concerns; one allegation had more than 20 concerns. However, there 

were no apparent trends in Region I in terms of allegation concerns coming from particular 

facilities, types of facilities, or as the result of an event. 

 

Reactor Licensee Trends

To provide further insight into areas in which the NRC is allocating resources in the followup of 

reactor-related allegations, Figure 2 depicts the 15 functional areas that represent approximately 

80 percent of the issues received nationwide in CY 2011.4

Figure 2 indicates that the largest percentage of concerns received nationwide were 

discrimination concerns, which increased slightly from the number of discrimination concerns 

received in CY 2010. A review of all discrimination concerns received in CY 2011 found no 

significant patterns or trends. Claims were made by an almost equal number of licensee 

employees as contractor employees at a consistent rate throughout the calendar year. Workers 

at reactor sites in Regions I and II raised more discrimination concerns than workers in 

Regions III and IV. These concerns involved workers from a variety of functional organizations, 

although there was a concentration of discrimination concerns raised by personnel in security 

organizations. 

While the number of security-related concerns also remained at a high level, many of the 

concerns raised (greater than 70 percent) involved only a small number of reactor sites. The 

majority of security-related allegation concerns were received in CY 2011 from licensee 

employees. There were concentrations of concerns regarding security staff training and 

 

3 Although the total number of allegations in CY 2007 decreased, the number of concerns for reactor facilities 

actually increased in almost every region and program office. 

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 chemistry, civil/structural, construction, criticality 

safety, electrical, emergency preparedness, Employee Concerns Programs, environmental, environmental 

qualifications, nondestructive evaluation, fatigue/overtime, fire protection, heating, ventilation, and air 

conditioning, in-service testing, instrumentation and control, licensing, mechanical, procurement, 

reciprocity, and safeguards. 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

8 

compliance with post or rounds requirements, but no issue trends were seen at a particular site. 

 

The total number of chilling effect concerns decreased considerably in CY 2011. The NRC uses 

the term “chilling effect” to describe a condition that occurs when an event, interaction, decision, 

or policy change results in a perception that the raising of safety concerns to the employer or to 

the NRC is being suppressed or is discouraged. The decrease can be attributed to the 

continued efforts by one reactor site to address previously identified concerns with the SCWE, 

which resulted in a significant number of chilling effect allegations in CY 2010. In 

September 2011, the NRC ended its enhanced oversight activities related to the SCWE at this 

site. In general, there were concentrations of chilling effect concerns in the health physics and 

security functional areas, and an upward trend in the area of maintenance, but no functional 

area trends were seen at a particular site. 

There was a slight decrease in the volume of wrongdoing concerns received in CY 2011. The 

NRC defines “wrongdoing” as the willful violation of regulatory requirements through deliberate 

action or a violation resulting from careless disregard of regulatory requirements. Wrongdoing 

allegation concerns involved a number of disciplines; the largest volume involved the areas of 

security and health physics. 

Lastly, there was a notable increase in the number of concerns related to health physics and 

notable decreases in maintenance, fitness-for-duty, and worker fatigue and overtime concerns. 

However, these changes could not be attributed to a particular facility, work group, or event. 

Materials Licensee Trends

A comparison of the types of issues received does not produce meaningful results because 

there are many different types of materials licensees and the activities they perform vary greatly. 

To provide insights into areas in which the NRC focused its attention on materials-related 

FIGURE 2 - REACTOR ISSUES NATIONWIDE 2011

Security

12%

Safety Culture

6%

Chilling Effect

10%

Health Physics

8%

Corrective 

Action

6%

Training/Quals

6%

Operations

6%

Maintenance

4%

Access 

Authorization

4%

Wrongdoing

7%

Quality 

Assurance

4%

Engineering

4%

Discrimination

14%

Fitness-forDuty

5%

Falsification

4%

Discrimination Security Chilling Effect

Health Physics Wrongdoing Corrective Action

Training/Qualifications Operations Safety Culture

Fitness-for-Duty Maintenance Access Authorization

Quality Assurance Engineering Falsification
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

9 

allegations, Figure 3 depicts the eight types of materials licensees that accounted for 

approximately 80 percent of allegation concerns that the NRC received nationwide.5

The NRC received 22 percent fewer allegations in CY 2011 in the materials area. Since 

CY 2004, the number of allegations related to fuel cycle facilities constituted the highest 

percentage (30 percent to 50 percent) of such allegations. For a number of years, allegations in 

the medical area have constituted the second highest percentage of materials-related 

allegations. However, these allegations dropped significantly in CY 2011, while those 

associated with nuclear gauge licensees, radiography, and both decommissioning reactors and 

materials facilities increased. 

Source Trends

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

allegations received in CY 2011.6

 The data indicate that the distribution of source categories 

remained consistent from CY 2007 to CY 2011. That is, employees of licensees (or former 

employees) and contractors (or former contractors) continue to be the primary sources of 

allegations. It was noted, nonetheless, that the number of allegations raised by licensee 

employees declined somewhat, while the number of allegations raised by contractors rose over 

the previous year. Persons wishing to remain anonymous continued to be the third largest 

source of allegations, although that number declined in CY 2011 by approximately 25 percent. 

In considering those allegation sources mentioned previously that have the potential to provide 

insights into the SCWE at a given facility (i.e., allegations submitted by current or former 

licensee or contractor employees or by anonymous sources), the percentage of allegations from 

these sources since CY 2007 has notably remained consistent around 75 percent. 

 

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

which represent the remaining 20 percent of the issues received. These licensee types include academic, 

casks, exempt distribution, general licensee, high-level waste, irradiators, nuclear pharmacies, special 

nuclear material, test and research reactors, well logging, and other types. 

6

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

include the news media and special interest groups. 

FIGURE 3 - MATERIALS LICENSEE TYPES NATIONWIDE 2011

Fuel Facililty

45%

Nuclear Gauges

16%

Radiography

12%

De commissioning 

Materials

10%

De commissioning 

Reactor

8% Medical

9%

Fuel Facililty Nuclear Gauges Radiography

Decommissioning Materials Medical Decommissioning Reactor
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

10 

Two of the source categories deserve some explanation. The source category “NRC Staff” 

designates an NRC staff member who suspects that a regulatory requirement has been violated 

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

by the NRC Office of Investigations. The source category “Licensee Identified” denotes that a 

licensee representative, acting in his or her official capacity, has reported potential wrongdoing 

to the NRC. The agency staff assigns an allegation process tracking number to such items so 

that the evaluation progress of the alleged wrongdoing issue may be tracked. 

Allegation Trends for Selected Reactor Sites

Trending the number and nature of allegations for specific reactor sites, individually and in the 

aggregate, is one method the NRC staff uses to monitor the SCWE at reactor sites. The 

appendix to this report provides statistics on allegations for all operating reactor sites. The NRC 

received the listed allegations during the 5-year period between January 2007 and 

December 2011 and included 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 assumed that anonymous allegations came from onsite personnel. 

Because a large volume of allegations from onsite sources may be indicative of a SCWE at risk, 

the staff conducted a more in-depth SCWE review of sites with onsite allegations exceeding 

three times the median value for operating reactor sites. For CY 2011, the median number of 

allegations per operating reactor site was four. San Onofre Units 2 and 3 (23), Susquehanna 

Units 1 and 2 (22), Turkey Point Units 3 and 4 (17), Saint Lucie Units 1 and 2 (16), and Indian 

Point Units 2 and 3 (15), are the five operating reactor sites that met this criterion. The sections 

below discuss the staff’s analysis of the SCWE at each of these sites. 

In CY 2011 the Agency Allegation Advisor requested that the NRC’s Office of Research conduct 

a study and identify a straightforward way to appropriately weight the allegation data. Because 

sites with a larger population of employees and contractors (such as 3-unit reactor sites) typically 

would generate more allegations, normalizing the data would help ensure that those sites were 

not disproportionally chosen for further analysis. The study supported the use of the following 

FIGURE 4 - ALLEGATIONS BY SOURCE CATEGORY 2011

Licensee Employee

39%

Contractor 

Employee

29%

Anonymous

11%

Licensee Identified

7%

NRC Staff

6%

Fed/State/Local 

Govt.

1%

Private Citizen

7%

Licensee Employee Contractor Employee Anonymous

Licensee Identified Private Citizen NRC Staff

Federal/State/Local Govt.
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

11 

criteria to consider the varying workforce size at different sites, both reactor and material. The 

staff will begin using these criteria in CY 2012 to determine which sites’ SCWE may warrant 

further consideration: 

• 1-unit reactor sites (or any site with fewer than 600 persons) with an onsite allegation 

volume greater than 2.25 times the median 

• 2-unit reactor sites (or any site with 600 to1,000 persons) with an onsite allegation 

volume greater than 3 times the median 

• 3-unit reactor sites (or any site with more than 1,000 persons) with an onsite allegation 

volume greater than 4.5 times the median 

The staff recognizes, and will take into consideration when using the above criteria, that during 

times of significant site activity, the site population may increase substantially. 

San Onofre Units 2 and 3

During 2011, the NRC received allegations from onsite sources concerning San Onofre Units 2 

and 3 at a decreasing rate compared to the very high number of allegations received in 

CY 2010. Analysis of the 

subject matter of the CY 2011 

allegations indicates that 

allegations were received in 

many functional areas and 

were not indicative of a trend in 

a particular department or 

discipline. Allegations were 

received consistently 

throughout the year (i.e., not 

concentrated in a specific 

timeframe). Most of the 

allegations received were from 

former and current licensee 

employees, rather than contractors, who contributed significantly to the large volume of 

allegations received in CY 2010. 

NRC inspection follow-up activities in early 2010 relating to a previous licensee assessment of 

site safety culture found that some employees in multiple workgroups at San Onofre perceived 

that they were not free to raise safety concerns using all available avenues. Furthermore, they 

felt that management had not been effective in encouraging employees to use all available 

avenues without fear of retaliation. (The NRC had requested the licensee to conduct the safety 

culture assessment). As a result, in March 2010, the NRC issued a CEL (ADAMS Accession 

No. ML100601272), asking the licensee to provide an action plan to improve the SCWE at 

San Onofre and to specifically address how it would improve each avenue for raising concerns. 

With the issuance of the CEL, the NRC substantiated a number of chilling effect allegations. Of 

the 29 allegations closed and substantiated in CY 2010, over half were associated with one 

regulatory action; namely, the issuance of the CEL. 

In response, the licensee initiated several actions to improve the SCWE, including (1) supervisor 

and workforce training on SCWE behavior expectations and avenues available to raise 

concerns, respectively, (2) the improvement of avenues to raise concerns, and (3) the 

2007 2008 2009 2010 2011

0

20

40

60

FIGURE 5 - SAN ONOFRE 2 & 3 ALLEGATIONS

Substantiated Closed Received
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

12 

enhancement of monitoring tools, including surveys, focus groups, and metrics. Multiple 

inspections, including two focused problem identification and resolution inspections in January 

and May 2011 (ADAMS Accession No. ML111250473), and public meetings were conducted to 

review the licensee’s corrective actions to address the issues identified in the CEL. In early 

2011, the NRC also closed a substantive cross-cutting issue in the problem identification and 

resolution area, indicating that sustained improvement in that area likely would improve the 

SCWE. In September 2011, the NRC ended its enhanced oversight activities related to the 

SCWE, based on the results of inspections conducted in early to mid-2011 and a noted 

decreasing trend in NRC receipt of allegations and SCWE-related concerns (ADAMS Accession 

No. ML112490114). 

Chilling effect concerns continued to be raised from various sources in 2011 as the licensee was 

completing implementation of corrective actions related to the previously identified SCWE issue. 

While the total number of chilling effect concerns brought to the NRC in 2011 about San Onofre 

were notably fewer than those identified during the peak of the site’s SCWE challenges, it 

remains a relatively high number compared to the industry. Chilling effect concerns were raised 

in a number of different departments at the facility in 2011. More than a third of the chilling effect 

concerns were found to have been addressed directly by licensee corrective actions in response 

to the previously identified SCWE problem. More than half of the chilling effect concerns 

received in 2011 about San Onofre lacked specifics and did not indicate that the corrective 

actions the licensee had taken were ineffective. 

The licensee’s Employee Concerns Program saw similar declining trends in CY 2011. 

According to informal discussions with the licensee, employees (not contractors) reported most 

of the concerns. Many licensees establish such programs to provide a way to report, 

investigate, and resolve safety concerns that is independent of the concerned individual’s chain 

of command. A SCWE assessment conducted in CY 2011 also indicated a positive trend in 

staff perceptions. A new Employee Concerns Program Manager was appointed in late CY 2011 

and he conducted a number of outreach activities to introduce himself to the staff. 

From CY 2007 through CY 2011, the NRC received more discrimination concerns regarding 

San Onofre than any other reactor facility. More than half of these discrimination concerns were 

received in the 2009–2010 timeframe, when the facility was experiencing significant challenges 

associated with its SCWE. Seven discrimination concerns were received in CY 2011. This was 

fewer than the number received in both 2010 and 2009. To date, none of the discrimination 

concerns received in the 2007–2011 timeframe have been substantiated; however, 14 remain 

under review. Fewer than half of the discrimination concerns received in 2011 were from a 

contractor or former contractor, in contrast to a significant concentration of discrimination 

concerns received from those sources in previous years. 

In summary, there were substantive decreases in the total number of allegations received from 

onsite sources and in the number of discrimination and chilling effect concerns that the NRC 

received regarding San Onofre in CY 2011. These decreases are attributable to corrective 

actions the licensee took in response to a CEL issued in March 2010, which ultimately resulted 

in the cessation of enhanced NRC oversight activities in September 2011. However, the number 

of allegations and SCWE-related concerns the NRC received about San Onofre in 2011 remain 

high compared to the industry. The NRC will continue to monitor the licensee’s efforts to 

improve the SCWE at San Onofre 2 and 3 through baseline inspection efforts focused on 

whether SCWE improvements are sustained. 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

13 

Susquehanna Units 1 and 2

In the midcycle Reactor Oversight Program (ROP) assessment letter for CY 2010 (ADAMS 

Accession No. ML102440462), the NRC concluded that the SCWE theme highlighted in the 

2008–2009 timeframe no longer 

existed at the Susquehanna 

Steam Electric Station (SSES). 

Furthermore, the CEL issued in 

January 2009 no longer would be 

considered for plant assessment 

purposes. The 2010 ROP 

midcycle assessment letter also 

indicated that the NRC would 

continue to monitor the licensee’s 

activities to address SCWE issues 

at Susquehanna through the 

Baseline Inspection Program. The 

rate of receipt of allegations from 

onsite sources at Susquehanna in 

2009 and 2010 showed a steadily 

decreasing trend as a result of the improvements the licensee made to address SCWE issues 

and monitor improvement in the SCWE. For CY 2011, however, there was a substantial 

increase in the number of allegations received from onsite sources compared to the previous 

year. Several factors appear to have contributed to the notable increase in CY 2011. These 

include significant outage activity and influx of onsite outage support contractors, numerous 

senior-level management changes, and the launch of a new performance improvement initiative, 

the Responsible Behavior Program. This program is associated, in part, with efforts to raise 

standards, increase accountability, and improve human performance. 

An analysis of the subject matter of the technical allegation concerns received in CY 2011 about 

SSES does not indicate a trend in any specific functional area or concern type. However, 

several concerns continue to be raised about the effectiveness of the Corrective Action 

Program, and the quality of related root cause and apparent cause analyses, which has been an 

area of interest at SSES for several years. Some chilling effect concerns continued to be raised 

in CY 2011, as they were to a similar degree in CY 2010. For the first 10 months of CY 2011, 

the chilling effect concerns were not focused in a specific functional area. However, from the 

end of October through the end of 2011, most of the chilling effect concerns received involved 

the operations department and appear to be related to the implementation of the new 

Responsible Behavior Program in that department. 

The number of discrimination concerns that the NRC received in 2011 regarding SSES was 

similar to the number received each year over the past five years, except for 2008, the year 

before the issuance of the CEL, when eight discrimination concerns were received. None of the 

discrimination concerns received from 2007–2011 have been substantiated. The discrimination 

concerns received over the past few years do not indicate a trend from a particular department. 

The SSES Employee Concerns Program experienced a similar substantive increase in the 

overall number of contacts in CY 2011 versus CY 2010 (about a 20 percent increase). Program 

staff attribute the increase primarily to the factors noted above. The most recent independent 

SCWE survey of the site, completed in March 2011, noted overall improvements in the SCWE 

and the general work environment. 

2007 2008 2009 2010 2011

0

10

20

30

40

FIGURE 6 - SUSQUEHANNA 1 & 2 

ALLEGATIONS

Substantiated Closed Received
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

14 

The volume of outage activities at SSES in CY 2011, the number of senior-level manager 

changes that occurred throughout the year, and the licensee’s implementation of its new 

Responsible Behavior Program were significant factors in the allegations that the NRC received 

regarding SSES in CY 2011. As such, the number and nature of allegations received do not 

appear to be indicative of a SCWE concern at the site. The NRC will maintain its oversight of 

the SCWE at SSES through normal inspection activities. 

Turkey Point Units 3 and 4

The volume of allegations that the NRC received from onsite sources regarding the Turkey Point 

site in CY 2011 was consistent with the volume received over the previous 3 years. After 

peaking in the second quarter of the 

year, the rate of allegations received 

declined over the remainder of 

CY 2011. An analysis of the sources 

and subject matter of the allegations 

received in CY 2011 shows no 

SCWE-related trends. Concerns 

received involved a variety of functional 

organizations and were provided by 

both contractor and licensee 

employees. A quarter of the allegations 

were received from anonymous 

sources in 2011, which was smaller 

than the percentage received in 

CY 2010. Some chilling effect 

concerns were received in CY 2011, but 

none were substantiated. The number 

of discrimination concerns received 

increased slightly in CY 2011 after a steady decline the previous two years. One discrimination 

concern remains under review by the NRC. None of the discrimination concerns that the NRC 

has investigated over the past five years have been substantiated. 

The site population increased significantly in CY 2010 and continued to increase in CY 2011 

because of extended power uprate activities. The substantial site population increase has 

affected the volume of concerns that both the NRC and the site Employee Concerns Program 

have received. Based on discussions with the licensee, contractors raised most of the concerns 

in that program. The majority of SCWE-related concerns that the Employee Concerns Program 

received in CY 2011 involved discrimination or chilling effect concerns, one of which was 

substantiated by the licensee and corrective actions were taken. A new manager was assigned 

to the Turkey Point program in CY 2011 and considerable effort was expended on outreach 

activities to introduce the individual to the site workforce. 

The most recent NRC inspections, including a problem identification and resolution inspection 

conducted in May 2010 (ADAMS Accession No. ML101830300), and recent surveys conducted 

by the licensee indicate that the workforce is more knowledgeable of the various avenues 

available to them for raising nuclear safety concerns. The workforce feels personally supported 

by the supervisors for raising concerns and knows of no one who was treated negatively for 

raising concerns or challenging unsafe acts. 

Given the substantial increase in the site population beginning in late CY 2010 for Turkey Point 

extended power uprate activities, the number and nature of allegations received regarding the 

2007 2008 2009 2010 2011

0

10

20

FIGURE 7 - TURKEY POINT 3 & 4 

ALLEGATIONS

Substantiated Closed Received
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

15 

site in CY 2011 are not indicative of a SCWE concern at the site. The NRC will maintain its 

oversight of the SCWE at Turkey Point 3 and 4 through normal inspection activities. 

Saint Lucie Units 1 and 2

The NRC has received allegations related to the Saint Lucie site at a consistent and relatively 

high rate since CY 2007, except for CY 2008, when the number received was reduced. The 

number of allegations received from 

onsite sources increased from 

CY 2010 to CY 2011. However, an 

analysis of the subject matter of the 

allegations received in CY 2011 does 

not indicate a trend in any specific 

functional area or concern type. A 

significant concentration of allegations 

was received from onsite sources in 

the November–December 2011 

timeframe. Most of the concerns 

received in that timeframe were 

related to contractor activities 

associated with the Saint Lucie Unit 1 

extended power uprate outage that 

began in November 2011. The 

remaining allegations from onsite 

sources were received during the first 

half of CY 2011. No allegations were 

received in a 4-month period between 

early July 2011 and early November 2011. Concentrations of allegations received from a 

particular onsite source were evenly spread among licensee employees, contractors, and 

anonymous allegers. There were few chilling effect concerns raised in CY 2011 from various 

sources and none were substantiated. 

The NRC received a relatively high number of discrimination concerns related to the Saint Lucie 

site from CY 2007 through CY 2011 compared to the rest of the industry (only three other reactor 

facilities received more in this timeframe). To date, however, none of those discrimination 

concerns have been substantiated. It is noted that most discrimination concerns received from 

CY 2007 through CY 2011 were submitted by contractors. 

 

The most recent NRC problem identification and resolution inspection at Saint Lucie 1 and 2 

was completed in March 2010 (ADAMS Accession No. ML101100013). The inspectors noted no 

reluctance on the part of site workers to raise safety concerns and workers were aware of the 

various avenues available for raising safety concerns. 

Given the substantial increase in the site population beginning in late CY 2010 for the Saint 

Lucie extended power uprate outage (a more than two-fold increase), the number and nature of 

allegations received regarding Saint Lucie in CY 2011 are not indicative of a SCWE problem at 

the site. The NRC will maintain its oversight of the SCWE at Saint Lucie 1 and 2 through normal 

inspection activities. 

2007 2008 2009 2010 2011

0

5

10

15

20

FIGURE 8 - SAINT LUCIE 1 & 2 

ALLEGATIONS

Substantiated Closed Received
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

16 

Indian Point Units 2 and 3

The volume of allegations that the NRC received from onsite sources concerning Indian Point 2 

and 3 in CY 2011 represented a significant increase from CY 2010. Many of the concerns 

involved training related to equipment modifications or technical issues in the security area. In 

addition, insights from the allegation 

process and inspections indicate that 

some security officers are dissatisfied 

with the effectiveness of the Corrective 

Action Program to address security 

equipment issues. Very few concerns 

were received about a chilled work 

environment and none were 

substantiated. 

The trend in discrimination allegations 

increased slightly in CY 2011 after a 

steady decline the last three years. 

None of the discrimination concerns 

received in the past 5 years have been 

substantiated; however, one received in 

CY 2011 remains under review. 

Informal discussions with site Employee Concerns Program management indicated a similar 

trend in the receipt of security-related concerns. The licensee is initiating actions to address the 

increasing numbers of concerns in the security organization. The NRC will continue to complete 

baseline inspections to ensure the reliability of security equipment and processes. 

The number and nature of allegations received regarding Indian Point 2 and 3 in CY 2011 are 

not indicative of a SCWE problem at the site. The NRC will maintain its oversight of the SCWE 

at Indian Point 2 and 3 through normal inspection activities and will maintain a focus on the 

corrective action process and other avenues for reporting concerns with regard to usage by the 

security workforce. 

Allegation Trends for Selected Materials Licensees

The NRC Web site posts allegation statistics for certain fuel cycle facilities (see the appendix to 

this report). Because of the small number of allegations and the smaller work force sizes 

associated with the overwhelming majority of other smaller materials licensees, the potential for 

a licensee or contractor to identify an alleger is increased. For this reason, tables of statistics on 

allegations about materials licensees other than fuel cycle facilities have not been provided 

publicly or included in this report. None of the materials licensees or fuel cycle facilities 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 

in-depth reviews of specific vendors. The report also does not provide statistics by contractor or 

vendor because publishing the number of allegations could identify an alleger.

2007 2008 2009 2010 2011

0

10

20

FIGURE 9 - INDIAN POINT 2 & 3 

ALLEGATIONS

Substantiated Closed Received
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

17 

Agreement State Trends

Under the authority granted in Section 274b of the Atomic Energy Act, as amended (the Act), the 

NRC may relinquish its authority to regulate certain byproduct, source, and limited quantities of 

special nuclear material to a State Government through a mutual agreement. A State that has 

entered into this agreement with the NRC is called an Agreement State. Before entering into 

this agreement, States must first demonstrate that their regulatory programs are adequate to 

protect public health and safety and are compatible with the NRC’s program. Figure 10 depicts 

the 37 Agreement States. 

FIGURE 10 - AGREEMENT STATES 

The NRC has statutory responsibility to review periodically the actions of the Agreement States 

to ensure that they maintain programs adequate to protect public health and safety and are 

compatible with the agency’s program. This authority is granted under Section 274j of the Act. 

The NRC uses the Integrated Materials Performance Evaluation Program (IMPEP) to satisfy its 

statutory responsibility. More information on the NRC’s Agreement State Program or IMPEP is 

available on the NRC’s Office of Federal and State Materials and Environmental Management 

Programs Web site at http://nrc-stp.ornl.gov/. 

In CY 2011, the NRC conducted routine IMPEP reviews of 10 Agreement State Programs. The 

review teams evaluated the effectiveness of the Agreement State Programs’ responses to 

concerns from external sources by reviewing the casework and documentation for 52 cases 

cumulatively received by all of the programs reviewed. The NRC referred 35 of the 52 cases 

reviewed to the Agreement State Programs; the States received the other concerns directly from 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

18 

concerned individuals. In all cases, the review teams concluded that the States consistently 

took prompt and appropriate action in response to concerns raised. In all cases, the review 

teams noted that the States documented the results of their investigations and closeout actions, 

which included notifying concerned individuals of the outcomes of the investigations when the 

individuals’ identities were known. The review team determined that the States reviewed in 

CY 2011 adequately protected the identity of any concerned individual who requested 

anonymity. In general, the results of the CY 2011 IMPEP reviews demonstrate that the 

Agreement States continue to rank response to concerns from external sources as a high priority 

in protecting public health and safety. 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

19 

CONCLUSIONS

There has been a declining trend in the total number of allegations received from CY 2009 

through CY 2011. The decreases do not appear to be the result of a general industry issue or 

other external factor, since the reasons for the substantive changes in the numbers of 

allegations received regarding these facilities were based on plant-specific matters. The total 

volume of specific allegation concerns received decreased in three of the four regional offices, 

the Office of Nuclear Reactor Regulation, and the Office of Federal and State Materials and 

Environmental Management Programs. Region I experienced a substantial increase in the 

number of concerns received; however, there were no apparent trends in concerns coming from 

particular facilities, types of facilities, or as the result of an event. The largest percentage of 

concerns received nationwide were discrimination concerns, which increased slightly from the 

number received in CY 2010. The total number of chilling effect concerns; however, decreased 

considerably in CY 2011. While the number of security-related concerns also remained at a high 

level, most of the security concerns raised involved only a small number of reactor sites. 

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

has taken action to engage licensees about their work environment when warranted and will 

continue to monitor these sites with interest. 

The agency’s Early ADR process resulted in 14 cases in which discrimination allegations were 

settled successfully 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 NRC developed enhanced guidance for the staff responsible for handling allegations 

in the areas of late-filed allegations and processing CELs, and updated information tools that the 

public used while engaged in the allegation process. In addition, the NRC’s Office of Nuclear 

Regulatory Research identified correlations in CY 2011 suggesting that sites with lower safety 

culture survey scores were more likely to have higher numbers of allegations in the following 

year, and sites with lower scores on the “questioning attitude” factor of the safety culture survey 

were more likely to have higher counts of allegations in the same year and the following year. 
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

A-1

APPENDIX 

ALLEGATION STATISTICS 

OPERATING REACTORS AND FUEL CYCLE FACILITIES
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

A-2

OPERATING REACTOR ALLEGATIONS RECEIVED FROM ONSITE SOURCES 

Site 2007 2008 2009 2010 2011 

ARKANSAS 1 & 2 8 6 3 4 3

BEAVER VALLEY 1 & 2 1 3 1 2 1

BRAIDWOOD 1 & 2 5 3 3 4 2

BROWNS FERRY 1, 2 & 3 11 18 8 12 11

BRUNSWICK 1 & 2 3 2 5 1 3

BYRON 1 & 2 9 8 9 6 3

CALLAWAY 17 2 2 3 1

CALVERT CLIFFS 1 & 2 1 3 1

CATAWBA 1 & 2 2 3 2 2 3

CLINTON 1 1 4 4 1

COLUMBIA PLANT 3 1 9 4 5

COMANCHE PEAK 1 & 2 4 5 1 2 3

COOK 1 & 2 3 5 5 3 5

COOPER 2 3 2 5 5

CRYSTAL RIVER 4 2 4 4 1

DAVIS-BESSE 4 1 2 4

DIABLO CANYON 1 & 2 2 13 15 12 9

DRESDEN 2 & 3 8 5 1 2

DUANE ARNOLD 1 2 1 1 1

FARLEY 1 & 2 5 5 6 7 12

FERMI 10 3 3 3 3

FITZPATRICK 1 2 3 2 2

FORT CALHOUN 1 4 5 4

GINNA 2 4 2 4 10

GRAND GULF 8 4 2 5 3

HARRIS 14 1 2 5 3

HATCH 1 & 2 6 7 5 8 4

INDIAN POINT 2 & 3 18 3 11 6 15

KEWAUNEE 1 3 1

LASALLE 1 & 2 5 1 1 2 

LIMERICK 1 & 2 1 3 14 2 3

MCGUIRE 1 & 2 3 3 6 5

MILLSTONE 2 & 3 5 8 5 4 11

MONTICELLO 1 2 2 3

NINE MILE POINT 1 & 2 6 1 1 5 

NORTH ANNA 1 & 2 3 1 1 2 1

OCONEE 1, 2, & 3 2 1 1 11 4

OYSTER CREEK 2 6 14 4 

PALISADES 5 6 8 3 5

PALO VERDE 1, 2, & 3 18 17 15 16 8

PEACH BOTTOM 2 & 3 8 3 8 4 3

PERRY 1 6 9 2 5

PILGRIM 7 8 1 5 5

POINT BEACH 1 & 2 1 5 4 8 6

PRAIRIE ISLAND 1 & 2 6 5 14 7 7
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

A-3

Site 2007 2008 2009 2010 2011 

QUAD CITIES 1 & 2 4 4 2 1

RIVER BEND 2 8 5 7 

ROBINSON 1 4 6

SALEM/HOPE CREEK 16 11 7 6 4

SAN ONOFRE 2 & 3 12 18 33 57 23

SEABROOK 4 10 2 1 7

SEQUOYAH 1 & 2 13 19 6 6 

SOUTH TEXAS 1 & 2 6 8 12 5 5

ST LUCIE 1 & 2 11 6 15 12 16

SUMMER 2 3 1 5

SURRY 1 & 2 1 2 2 6 4

SUSQUEHANNA 1 & 2 13 32 15 12 22

THREE MILE ISLAND 1 2 9 1 3

TURKEY POINT 3 & 4 4 19 14 15 17

VERMONT YANKEE 3 1 2 3 2

VOGTLE 1 & 2 7 1 2 4 12

WATERFORD 2 4 3 4 2

WATTS BAR 1 3 9 3 2 5

WOLF CREEK 1 7 6 2 4
ALLEGATION PROGRAM 2011 ANNUAL TRENDS REPORT 

A-4

FUEL CYCLE FACILITY ALLEGATIONS RECEIVED FROM ONSITE SOURCES 

Site 2007 2008 2009 2010 2011 

AMERICAN CENTRIFUGE PLANT 2 1

BWX TECHNOLOGIES, INC. 1 2 1 

GLOBAL NUCLEAR FUEL 1 1 6 6 5

HONEYWELL 1 4 7 16 3

LOUISIANA ENERGY SERVICES 1 11 29 6 12

NUCLEAR FUEL SERVICES, INC. 3 3 5 10 4

PADUCAH 5 3 4 5 6

PORTSMOUTH 2 1 

SHAW AREVA MOX SERVICES 2 1 1 4

WESTINGHOUSE 2 4 2 1

YUCCA MOUNTAIN 1 5 2