March 9, 2012 

MEMORANDUM TO: William M. Dean, Regional Administrator, Region I 

Victor M. McCree, Regional Administrator, Region II 

Cynthia D. Pederson, Acting Regional Administrator, Region III 

Elmo E. Collins, Regional Administrator, Region IV 

Eric J. Leeds, Director, Office of Nuclear Reactor Regulation 

Michael R. Johnson, Director, Office of New Reactors 

James T. Wiggins, Director, Office of Nuclear Security and 

 Incident Response 

Catherine Haney, Director, Office of Nuclear Material Safety 

 and Safeguards 

Mark A. Satorius, Director, Office of Federal and State 

 Materials and Environmental Management Programs 

Cheryl L. McCrary, Director, Office of Investigations 

FROM: Roy P. Zimmerman, Director 

Office of Enforcement /RA/ 

SUBJECT: ALLEGATION GUIDANCE MEMORANDUM 2012-001, “NRC 

CHILLING EFFECT LETTERS” 

The purpose of this allegation guidance memorandum (AGM) is to clarify guidance provided to 

the U.S. Nuclear Regulatory Commission (NRC) staff regarding the consideration and use of 

“chilling effect letters” (CELs) by documenting current practice. 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 agency will incorporate the 

guidance contained in this AGM into the Allegation Manual. 

CONTACT: Lisamarie Jarriel, OE 

 301-415-8529 
W. Dean, et. al. - 2 - 

BACKGROUND 

Through application of the NRC’s Enforcement Policy, appropriate enforcement action may be 

taken against a licensee1

 that has discriminated against an employee for raising safety 

concerns. The intent of such action is, in part, to prompt the licensee to take actions to mitigate 

the potential “chilling effect” that the discriminatory act may have caused. 

There are two specific situations where a CEL may be warranted. The first situation arises 

when an allegation of discrimination is made directly to the U.S. Department of Labor (DOL). A 

memorandum of understanding between the NRC and DOL states that the two agencies 

cooperate to the fullest extent possible in every case of alleged discrimination involving 

employees of NRC licensees. 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 be assured 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 Enforcement Manual appears on the 

agency’s public Web site at: 

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

DOL finding of discrimination, a CEL serves three purposes: (1) to notify the licensee publically 

of the NRC's concern that the initial DOL discrimination finding may have negatively affected the 

licensee’s SCWE, (2) to obtain information on the licensee’s assessment of its employees’ 

willingness and ability to raise safety concerns at the facility and the description of any remedial 

action the licensee has taken or plans to take to address any identified weakness as a result of 

its assessment, and (3) to obtain information on the licensee’s position with regard to whether 

discrimination occurred. 

The Enforcement Manual also recognizes a second situation that the staff may consider for the 

issuance of a CEL. Specifically, a CEL may be appropriate in certain circumstances involving 

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

of discrimination. However, the NRC Enforcement Manual does not detail any guidance 

describing such circumstances. To ensure the effective and consistent use of a CEL in this 

application, the staff will delete the current language in paragraph G of Section 6.5.4.1, “Chilling 

Effect Letter (CEL),” of the NRC Enforcement Manual and add a reference to the guidance that 

follows in the Allegation Manual. This 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. 

GUIDANCE 

The Allegation Manual will incorporate the guidance below. 

 

1

 For purposes of this guidance, the term “licensee” refers to an organization/individual, or a contractor, 

subcontractor, or vendor to an organization/individual that is an applicant for, or holder of a license, permit, 

or certification issued pursuant to NRC regulations to operate a facility or to use, manufacture, produce, 

transfer, receive, acquire, own, possess, distribute, transport, import or export specified quantities of 

byproduct, source, or special nuclear material.
W. Dean, et. al. - 3 - 

NRC Chilling Effect Letters

When the NRC substantiates the occurrence of discrimination for engaging in a protected 

activity, the agency normally takes enforcement action against the responsible licensee or 

individual or both for the specific occurrence. In addition, the NRC considers the impact the 

substantiated discriminatory action may have on the workplace environment, specifically on the 

willingness of licensee employees to raise safety concerns, known as the SCWE. To that end, 

the NRC’s notification to the licensee of the discrimination finding typically includes a discussion 

about the potential impact of the discrimination finding on the SCWE. Similarly, when an 

authority other than the NRC initially substantiates discrimination (e.g., DOL, U.S. District Court, 

or the Merit Systems Protection Board for Federal licensees), the NRC will normally engage the 

licensee independently regarding on how the finding may affect the SCWE. The NRC refers to 

this type of communication as a chilling effect letter (CEL). Section 6.5.4.1 of the NRC 

Enforcement Manual provides administrative instructions on processing a CEL under this 

circumstance. 

In addition to chilling effect concerns resulting from findings of discrimination, other licensee 

actions that the workforce perceives to be discriminatory, repressive, or otherwise unresponsive 

to employee concerns, could potentially affect the SCWE. The NRC Enforcement Manual 

recognizes that circumstances may warrant the issuance of a CEL if the NRC, when considering 

such circumstances, becomes concerned about the licensee’s recognition of a chilled work 

environment or about the effectiveness of any actions taken by the licensee in response. The 

following discussion describes the circumstances under which the issuance of a CEL may be 

warranted in the absence of a finding of discrimination and the process for its issuance, 

evaluation, and closure. 

1. What is a CEL? 

A CEL is a regulatory tool targeted toward ensuring that the licensee is taking appropriate 

actions to foster a workplace environment that encourages employees (including 

contractors) to raise safety concerns and to feel free to do so without fear of retaliation. 

Recall that throughout this guidance the term “licensee” refers to any entity subject to NRC 

authority including organizations applying for or holding a license, permit, or certification 

issued pursuant to NRC regulations to operate a facility or to use, manufacture, produce, 

transfer, receive, acquire, own, possess, distribute, transport, import or export, specified 

quantities of byproduct, source, or special nuclear material. Section 2 discusses situations 

that potentially warrant the issuance of a CEL to any of these entities in the absence of a 

finding of discrimination. The purpose of the CEL is: 

A. to notify the licensee of the NRC's concern with the SCWE at its facility on the public 

record 

B. to obtain information about the licensee’s assessment of its employees’ willingness to 

raise safety concerns at the facility and the description of any remedial action the 

licensee has taken or plans to take to address any identified weakness as a result of its 

assessment 
W. Dean, et. al. - 4 - 

2. Situations That Warrant CEL Issuance 

CELs are intended to have a positive impact on a licensee’s workforce and, specifically, on 

that part of the workforce that the NRC believes is “chilled,” (i.e., workers who perceive that 

the licensee is suppressing or discouraging the raising of safety concerns or is not 

addressing these concerns when they are raised). These letters are the tool that the NRC 

uses to inform workers that the agency has engaged their management about its SCWE 

concern and that the agency will be monitoring the licensee’s actions to address that 

concern. Such communication can have a positive effect on the workers’ willingness to 

raise issues. However, the agency recognizes that issuing a CEL when an already healthy 

SCWE exists could negatively affect the SCWE (i.e., cause individuals to become 

concerned about raising concerns simply based on the NRC’s assertion that others on site 

are chilled). For that reason, the NRC must issue a CEL only when appropriate in the 

absence of a finding of discrimination. The discussion below describes situations of this 

type in which the NRC would normally issue a CEL. 

Below is a nonexclusive list of factors that provides insight into the licensee’s SCWE. The 

staff should consider these factors when evaluating whether the issuance of a CEL is 

warranted. The staff should evaluate each case on its own merit; however, it should 

consider past examples with similar facts, circumstances, and organizational structure to 

ensure consistency and predictability relating to the issuance of CELs. A list of previously 

issued CELs is available on OE’s webpage at http://www.internal.nrc.gov/OE/ under “Quick 

Links”. No one factor is considered to be inherently determinative of a chilled environment. 

Accordingly, the following factors, as applicable, should be considered collectively rather 

than in isolation. In addition, from case to case, the same factor may weigh differently 

depending on the facts and circumstances of each case. 

Lastly, the staff should counterbalance the perceived need for the issuance of a CEL in 

these situations with a determination as to whether the licensee is taking timely and effective 

remedial actions that the NRC anticipates will enhance the SCWE in a timely manner.

A. Allegations: Number, Receipt Rate, Nature, and Source 

• Number of Allegations – Of interest is the number of allegations coming from onsite 

sources2

 over a particular review period compared to the reactor industry median 

over that same review period. The reactor industry median is used for both reactor 

and materials licensees (and other employers subject to NRC authority) because it is 

derived from a homogeneous population and, therefore, is a good comparative 

number for this exercise. Taking into account the varying workforce size at different 

sites, the following guideline can be used to determine which sites may warrant 

further consideration: 

 

2

 Onsite sources of allegations 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. Note: It may be appropriate to include a review of allegation 

concerns from other sources as well (e.g., chilling effect concerns from offsite sources or concerns from 

allegers claiming to be providing them on behalf of onsite individuals).
W. Dean, et. al. - 5 - 

− 1-unit reactor sites (or any site with fewer than 800 persons) with an onsite 

allegation volume greater than 2.25 times the median 

− 2-unit reactor sites (or any site with 800-1100 persons) with an onsite 

allegation volume greater than 3 times the median 

− 3-unit reactor sites (or any site with more than 1100 persons) with an onsite 

allegation volume greater than 4.5 times the median 

The staff should recognize and take into consideration when using the above 

algorithm that during times of significant site activity, the site population may 

increase substantially (e.g., construction or extensive modification activities). For 

example, if a site with typically less than 800 persons is experiencing a prolonged 

shutdown period during which the site population is significantly increased, 

application of the algorithm for a larger site population may be considered more 

appropriate. 

• Receipt Rate – The staff should consider whether the allegations were received 

during the review period at an increasing, decreasing or steady rate. 

• Nature of Concerns – Of interest is: 

− any concern specifically indicating fear or reluctance to raise concerns (e.g., 

claims of discrimination, chilled environment concerns, or indications of 

fundamental problems with the licensee’s corrective action program) 

− any substantiated chilling effect concern determined by either the NRC or the 

licensee 

− any concern that may have a significant impact on safety or security 

• Source of Allegations – Of interest is: 

− a trend in a particular functional organization or contractor group (Note: an 

organization’s direct impact on safe operations or decision-making should be 

taken into consideration) 

− multiple concerned individuals vs. many allegations from a small number of 

allegers. (Note: the staff should be careful not to assume a single source of 

multiple allegations represents only one alleger. The one alleger may 

represent others that have asked the one to submit their concerns because 

they are not comfortable doing so themselves.) 

− the percentage of anonymous allegers 
W. Dean, et. al. - 6 - 

B. NRC Inspection Observations: In addition to observations and findings identified by 

routine NRC inspections, the Problem Identification and Resolution (PI&R), and Special 

or Supplemental Inspections can provide historical insight into the SCWE. 

• PI&R SCWE Observations – Inspection Procedure (IP) 71152, “Problem 

Identification and Resolution,” dated December 5, 2011, provides a list of questions 

that the staff can use to assess whether impediments to raising concerns exist. The 

questions are designed to address four primary elements of a SCWE: (1) the 

employees’ willingness to raise concerns and whether management’s behaviors 

encourage them to do so, (2) employee perception of the effectiveness of the 

corrective action program as the primary avenue to raise concerns, (3) employee 

perception of the effectiveness of an alternative program if one exists, such as an 

employee concerns program (ECP), and (4) employee perception of the 

effectiveness of management actions to detect and prevent retaliation and chilling 

effects. 

• SCWE Observations in Special and Supplemental Inspections – The following 

special and supplemental inspections may also generate observations about the 

SCWE: 

− IP 40001, “Resolution of Employee Concerns,” dated June 3, 1997 

− IP 40100, “Independent Safety Culture Assessment Followup,” dated April 5, 

2011 

− IP 40504, “Part 52, Identification and Resolution of Construction Problems,” 

dated October 3, 2007 

− IP 88110, “Quality Assurance: Problem Identification, Resolution and Corrective 

Action,” dated May 18, 2005 

− IP 93100, “Safety-Conscious Work Environment Issue of Concern Followup,” 

dated August 18, 2011 

− IP 95001, “Supplemental Inspection for One or Two White Inputs in a Strategic 

Performance Area,” dated February 9, 2011 

− IP 95002, “Supplemental Inspection for One Degraded Cornerstone or Any Three 

White Inputs in a Strategic Performance Area,” dated February 9, 2011 

− IP 95003, “Supplemental Inspection for Repetitive Degraded Cornerstones, 

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

February 9, 2011 

 

C. Licensee Tools to Establish, Maintain and Assess Their SCWE: Assessments, Policies, 

Communications, Training, and Corrective Action Programs 
W. Dean, et. al. - 7 - 

• SCWE/Safety Culture3

 Assessments – Of interest is the scope of a self-assessment 

or independent survey, significant findings (e.g., functional area pockets of concern), 

and actions taken by the licensee to address identified SCWE weaknesses. (See 

Section 5.) 

• SCWE Policy Statements – Of interest is language describing expectations for 

management behavior to proactively encourage employees to raise concerns, 

unrestricted access to multiple avenues for raising concerns, and prohibitions on 

retaliation. 

• SCWE Communications – Of interest is the media that management uses to 

communicate its SCWE expectations, its message, and the frequency of such 

communication. 

• SCWE Training – Of interest is who is being trained (e.g., all supervisors), the 

content of the training (e.g., employee rights, avenues for raising concerns, related 

policies, and supervisor expectations) and whether refresher training is offered and 

at what frequency. 

• ECP – Of interest is the licensee’s ECP data in comparison to allegation program 

data trends (e.g., the number of concerns raised within the ECP, the rate of these 

concerns over the review period, the nature and safety significance of the concerns, 

the source of concerns, any substantiated chilling effect or discrimination concerns, 

and the percentage of anonymous concerns). 

• Corrective Action Program – Of interest are any changes in usage trends, restrictions 

(if any) on writing a condition report, and the existence of any incentives for limiting 

the number of employee-raised concerns. 

D. Specific Events with the Potential to Chill the SCWE 

The staff should consider the number of individuals who witnessed the event or who are 

potentially affected by it; the notoriety of the event; the position, responsibility, and level 

of influence of the individual(s) causing the chilling effect; and the egregiousness of the 

behavior. 

E. Reporting Avenues Affected by the Chilling Effect 

Of interest is which and how many avenues for reporting concerns are potentially 

impacted, including, but not limited to direct communication with a supervisor, the 

corrective action program, ECP, and the agency. 

 

3

 Safety culture assessments often include insights on the cultural SCWE component. 
W. Dean, et. al. - 8 - 

F. Licensee’s Remedial Actions in Response to Negative SCWE Trends or an Event 

The staff should place greater weight on this factor than those articulated above. Of 

interest is whether the staff views the licensee’s remedial actions to be timely and 

appropriate and to have a likelihood of success in enhancing the SCWE and negating 

any prior chilling effect. 

3. Process for Considering a CEL and Administrative Coordination 

The Allegation Review Board (ARB) deliberates on the issuance of a CEL that is not 

associated with a finding of discrimination. As discussed earlier, the process for considering 

and issuing CELs related to a finding of discrimination can be found in the Enforcement 

Manual. Representatives from the Office of Enforcement (OE) and from the appropriate 

region or program office must participate in these deliberations. The process for considering 

the issuance of a CEL and the necessary administrative coordination include the following: 

A. The appropriate region or program office shall draft an ARB briefing sheet that describes 

the basis and the rationale for issuing the CEL, using the factors discussed in Section 2. 

B. The Agency Allegation Advisor (AAA) or his or her designee should participate on the 

ARB. If the AAA or designee is not available, the ARB Chair shall contact the AAA, 

review the ARB decisions, and determine the need for additional ARB discussion. 

C. The ARB Chair, after consultation with the Regional Administrator, will make the final 

determination on whether to draft a CEL for concurrence. 

D. If the ARB Chair determines that the staff should issue a CEL, an Enforcement Action 

(EA) number for the CEL will be obtained to track all related documents. The EA 

number should appear on the CEL and all related NRC correspondence. The EA 

number should not be closed until the staff issues a letter that acknowledges the NRC’s 

acceptance of the licensee’s actions, completed and planned, in response to the CEL. 

(See Section 5.) 

E. The OE Director or his or her designee shall be on concurrence for the CEL. CELs 

issued by a region or program office shall be under the signature authority of the 

applicable Regional Administrator, Office Director, or his or her designee. 

F. The region or program office will communicate the decision to issue a CEL to the Office 

of the Executive Director for Operations and, if appropriate, to the Commission. 

4. Contents of a CEL 

If the staff determines that a CEL is warranted, the CEL should: 

A. Describe the NRC’s concern and its basis and include specific considerations that led 

the agency to issue the CEL while recognizing the need to protect the identities of any 

allegers involved. 
W. Dean, et. al. - 9 - 

B. Reference the NRC’s SCWE Policy Statement entitled, “Freedom of Employees in the 

Nuclear Industry to Raise Safety Concerns without Fear of Retaliation” (Volume 61 of 

the Federal Register, page 24336; May 14, 1996), or Regulatory Issue Summary 05-

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

Environment,” dated August 25, 2005, or both, to make the licensee aware of the NRC’s 

expectations in this area. 

C. Request that the licensee respond to the NRC’s concerns (typically within 30 days). The 

nature of the requested response may differ depending on the extent of the SCWE 

concern. For example, the letter may include a request for a management meeting as 

well as a written response, or it may request (for broader or more significant issues) the 

licensee conduct an assessment of the SCWE. 

D. Request that the licensee provide information on its SCWE assessment and any 

associated corrective actions and to describe how it will measure the effectiveness of 

any corrective actions. 

E. Instruct the licensee to provide the basis for determining that the number and the crosssection of individuals interviewed or surveyed as part of its review and the scope of the 

interviews and surveys was appropriate. 

F. Request that the licensee notify the affected members of the workforce of the issuance 

of the CEL and the NRC’s concerns and focus on the SCWE. 

G. Explain that the licensee’s response will be made public. (The staff should add the final 

copy of the CEL to the Agencywide Documents Access and Management System and 

make it publically available.) 

H. Request that persons independent of the organization or group associated with the 

NRC’s concern conduct an assessment of the SCWE. 

5. Evaluation of the Licensee’s Response and Closure of CELs 

After the licensee has responded to a CEL, the office responsible for the issuance of the 

CEL, in collaboration with other NRC offices (e.g., the region, program office, or OE, as 

appropriate) will review the scope of the licensee’s assessment of the work environment, the 

independence of those involved in the evaluation, and the adequacy and effectiveness of 

any corrective actions proposed or taken. Closure of a CEL is contingent upon an NRC 

determination that the licensee has made reasonable progress toward addressing the 

underlying issues that led to the issuance of the CEL. 

A. If the licensee conducted surveys or interviews, the staff should evaluate the results and 

conclusions and should: 

• Evaluate the survey/interview questions to determine whether they involve an 

employee’s reluctance to raise concerns, his or her reluctance to self-identify 

problems, his or her awareness of others who have experienced negative 
W. Dean, et. al. - 10 - 

• consequences for raising concerns, management support for raising concerns and 

maintaining a SCWE, and the effectiveness of the licensee’s corrective action 

program and employee concerns program (if applicable) in addressing concerns. 

• Evaluate the sample size of the surveys or interviews, or both, and determine 

whether they included participants from an appropriate cross-section of the 

population (e.g., management/non-management, bargaining unit/non-bargaining 

unit, part time/full time workers, or contractors) and whether they are representative 

of the population being assessed. 

• Consider conducting followup interviews or focus groups to validate the licensee’s 

assessment. 

B. If the licensee’s assessment indicates areas of weakness, the staff should evaluate the 

licensee’s corrective actions for appropriateness and should: 

• Consider whether the actions address the underlying problems, whether they are of 

sufficient scope and depth, and whether the licensee will implement them in a timely 

fashion. 

• Examine the adequacy of the effectiveness measures for monitoring the results of 

the corrective actions. 

• Follow up, as appropriate, to monitor the licensee’s progress toward improving the 

SCWE and to determine whether the actions taken have been effective. For a 

reactor licensee, the staff has historically conducted such followup activities during 

quarterly assessments of the corrective action program. 

C. If any aspect of the licensee’s response is not satisfactory, the staff should contact the 

licensee to discuss the need for additional information or should conduct inspections to 

obtain the needed information, or do both. 

D. The staff should consider closure of the CEL after reviewing the licensee’s response(s) 

and any additional information gathered through followup inspections. After the office 

that issued the CEL, in consultation with the other NRC offices (e.g., the region, program 

office, or OE, as appropriate), determines that the licensee’s response is acceptable 

(i.e., that reasonable progress has been made in addressing the underlying issues that 

led to the issuance of the CEL), that office shall issue a letter acknowledging the NRC’s 

acceptance of the licensee’s response. If appropriate, the letter should indicate the 

NRC’s intent to monitor the licensee’s progress toward improving the SCWE through 

baseline inspection activities to verify sustainability of any actions taken. 

For power reactor licensees, the issuance of a CEL represents a theme as defined by 

the Reactor Oversight Process, and the staff’s review of the licensee’s response will be 

instrumental in determining whether a substantive cross-cutting issue exists in the 

SCWE cross-cutting area (See Manual Chapter 0305, “Operating Reactor Assessment 
W. Dean, et. al. - 11 - 

Program,” dated July 6, 2011). For that reason, the staff’s assessment and closure of a 

CEL issued to a power reactor may be documented in the mid-cycle or end-of-cycle 

assessment letter, or in a separate letter. 

Direct any questions about this guidance to Lisamarie Jarriel in OE by telephone at (301) 415-

8529 or by e-mail at Lisamarie.Jarriel@nrc.gov. 

cc (electronic): 

S. Bernal, NRO J. Heller, RIII P. Pelke, RIII R. Urban, RI 

A. Campbell, OE N. Hilton, OE T. Powell, FSME M. Virgilio, DEDR 

M. Checkle, RII D. Holody, RI R. Raspa, OIG D. Vito, OE 

S. Coker, NSIR L. James, NRR R. Schmitt, NRR J. Weaver, RIV 

O. DeMiranda, RII K. Mattern, NMSS B. Sheron, RES M. Weber, DEDMRT 

C. Evans, RII J. McFadden, RI D. Solorio, OE J. Wray, OE 

H. Gepford, RIV S. Orth, RIII N. Taylor, RIV 
W. Dean, et. al. - 11 - 

Program,” dated July 6, 2011). For that reason, the staff’s assessment and closure of a 

CEL issued to a power reactor may be documented in the mid-cycle or end-of-cycle 

assessment letter, or in a separate letter. 

Direct any questions about this guidance to Lisamarie Jarriel in OE by telephone at (301) 415-

8529 or by e-mail at Lisamarie.Jarriel@nrc.gov. 

cc (electronic): 

S. Bernal, NRO J. Heller, RIII P. Pelke, RIII R. Urban, RI 

A. Campbell, OE N. Hilton, OE T. Powell, FSME M. Virgilio, DEDR 

M. Checkle, RII D. Holody, RI R. Raspa, OIG D. Vito, OE 

S. Coker, NSIR L. James, NRR R. Schmitt, NRR J. Weaver, RIV 

O. DeMiranda, RII K. Mattern, NMSS B. Sheron, RES M. Weber, DEDMRT 

C. Evans, RII J. McFadden, RI D. Solorio, OE J. Wray, OE 

H. Gepford, RIV S. Orth, RIII N. Taylor, RIV 

ADAMS ML12025A055 Distribution: OE r/f L. Jarriel D. Vito R. Zimmerman 

OFFICE RI RII RIII RIV NRR 

NAME W. Dean by 

JMcFadden via email 

V. McCree by LWert 

via emal 

C. Pederson by 

SOrth via email 

E. Collins by AHowell 

via email 

E. Leeds by LJames via 

email 

DATE 02/24/2012 02/15/2012 02/23/2012 02/16/2012 03/06/2012 

OFFICE NRO NSIR NMSS FSME OI 

NAME M. Johnson by VHall 

via email 

J. Wiggins by 

MDapas via email 

C. Haney by 

KMattern via email 

M. Satorius by JPIccone 

via email 

C. McCrary by SLangan 

via email 

DATE 02/17/2012 02/21/2012 02/14/2012 02/16/2012 02/24/2012 

OFFICE OGC OE OE OE Tech Editor 

NAME C. Scott by 

MLemoncelli via email 

D. Vito L. Jarriel R. Zimmerman Via email 

DATE 03/08/2012 02/27/2012 03/06/2012 03/08/2012 02/07/2012 

 OFFICIAL RECORD COPY