ALLEGATION PROGRAM 

 ANNUAL TRENDS REPORT

 Calendar Year 2014

U.S. Nuclear Regulatory Commission 

Office of Enforcement 

Washington, DC 20555
i

CONTENTS 

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

TRENDS IN ALLEGATIONS ......................................................................................................... 3 

National Trends ................................................................................................................. 3 

Reactor Licensee Trends ...................................................................................... 4 

Materials Licensee Trends .................................................................................... 6 

Source Trends ....................................................................................................... 7 

Allegation Trends for Selected Reactor Sites ................................................................... 7 

Susquehanna Units 1 and 2 .................................................................................. 8 

Vogtle Units 3 and 4 ............................................................................................ 10 

Allegation Trends for Selected Materials Licensees ....................................................... 12 

Honeywell ............................................................................................................ 12 

Allegation Trends for Selected Vendors .......................................................................... 13 

Lake Charles Facility ........................................................................................... 13 

Trends in the Agreement States ..................................................................................... 15 

OVERVIEW OF PROGRAM ACTIVITIES .................................................................................. 17 

Requests for Information Regarding Discrimination Findings ......................................... 17 

Chilling Effect Letters ...................................................................................................... 17 

Alternative Dispute Resolution Process .......................................................................... 18 

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

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

FIGURES 

1 Allegations Received by Calendar Year ............................................................................ 3 

2 Reactor Concerns Nationwide 2014 ................................................................................. 5 

3 Allegations by Type of Materials Licensee Nationwide 2014 ............................................ 6 

4 Allegations by Source Category Nationwide 2014 ............................................................ 7 

5 Susquehanna 1 and 2 Allegations .................................................................................... 8 

6 Vogtle 3 and 4 Allegations .............................................................................................. 10 

7 Honeywell Allegations ..................................................................................................... 12 

8 Lake Charles Facility Allegations .................................................................................... 14 

9 Agreement States .......................................................................................................... 16 
ALLEGATION PROGRAM 2014 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, this report discusses staff activity in calendar year (CY) 2014 involving the 

Allegation Program and related policies. Lastly, the allegation staff continues to carry out the 

agency-sponsored alternative dispute-resolution (ADR) process for discrimination allegations 

(early ADR). This pre-investigation process gives an individual and his or her employer (or 

former employer) the opportunity to resolve an allegation of discrimination through mediation, 

potentially avoiding lengthy litigation or have the NRC start an investigation. Sixty-two percent of 

the CY 2014 mediated discrimination concerns reached settlement. 

In the CY 2010 to CY 2014 timeframe, the total number of allegations1

 received from reactor 

licensees, materials licensees, and vendors has fluctuated above and below 500 allegations per 

year, with an overall declining trend. Although the total number of allegations received in 

CY 2012 increased by 4 percent over CY 2011, allegations received in CY 2013 decreased by 

about 8 percent compared to the previous year and those received in CY 2014 decreased by 

11 percent. Although facility- or vendor-specific matters do play a significant role in allegation 

trends, anecdotal information suggests that the overall decline could be the result of increased 

efforts by the NRC and nuclear industry to focus attention on developing and maintaining 

stronger environments for raising concerns at regulated entities. 

Each allegation can include multiple concerns. Over the past 5 years, the trend in the total 

number of concerns has generally paralleled the trend in total allegations (i.e., as the number of 

allegations has increased or decreased, the number of concerns has increased or decreased 

correspondingly). In CY 2014, coinciding with the overall decrease in allegations received, the 

total volume of allegation concerns received decreased as well. More specifically, the number of 

allegations received in three of the four regional offices declined, and in all but one case 

declined by greater than 30 percent. Region I experienced an increase in the number of 

allegations and specific concerns received that was largely attributable to concerns raised in 

regard to two reactor sites. The largest percentage of concerns received nationwide was 

discrimination concerns, which decreased from the number of discrimination concerns received 

in CY 2013. These concerns involved workers primarily from operations, maintenance, security, 

and quality assurance functional organizations. Chilling effect concerns constituted the second 

highest percentage of concerns received nationwide and also decreased in CY 2014 compared 

to CY 2013. About 40 percent of the chilling effect concerns involved sites associated with the 

construction of new reactors, including the related vendor sites. The most often mentioned 

behaviors perceived by allegers to cause the chilling effect involved negative treatment after 

raising a concern; supervisors who discourage using the corrective action program or employee 

concerns program to document concerns; or supervisors who pressure workers to falsify 

documents to cover-up deficiencies. Although the number of security-related concerns 

increased slightly in CY 2014, 23 percent of those involved only two allegations concerning 

reactor sites in different regions. 

 

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” in Management Directive 8.8, 

“Management of Allegations,” November 15, 2010.
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

2 

For some in the regulated community, the NRC received allegations in numbers that warranted 

additional analysis.2 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 

environment for raising concerns. Because a large volume of allegations from onsite sources 

could be indicative of a chilled work environment, the staff selected one operating reactor site, 

one reactor site under construction; one materials facility, and one vendor site for more in-depth 

review: Susquehanna Units 1 and 2; Vogtle Units 3 and 4; Honeywell; and Lake Charles. This 

report discusses allegation trends at each of these sites. In summary, the trends for two of the 

sites did not suggest a concern about the environment for raising concerns. Of the other sites, 

the trends are indicative of a chilled work environment, the associated employers are taking 

actions to address the weaknesses, and the NRC is closely monitoring the ongoing activities. 

Finally, in CY 2013, the NRC reviewed the effectiveness of 11 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 the concerned individuals’ identities.

 

2

 The total number of allegations received concerning reactor and fuel facility 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 2014 ANNUAL TRENDS REPORT 

3 

TRENDS IN ALLEGATIONS

The U.S. Nuclear Regulatory Commission (NRC) monitors allegations to discern trends or 

marked increases that might prompt the agency to question a licensee about the causes of such 

changes. In preparing this report, the staff reviewed a 5-year history of allegations received for 

reactor and materials licensees and vendors. Additionally, the staff focused on allegations with 

the potential to offer insights into the environment for raising concerns (i.e., safety conscious 

work environment (SCWE)) at a given facility. Such allegations include those submitted by 

current or former licensees, contractor employees, or anonymous sources that indicate an 

unwillingness or hesitance 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) mid-cycle and end-of-cycle assessments. In addition, the staff might analyze a particular 

site or licensee whenever allegations or inspection findings indicate that such an analysis is 

warranted. 

The staff also reviews 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 NRC regional and program offices. The following section discusses these trends. 

National Trends

National trends inform the staff about the effect of external factors, plant events, and industry 

efforts to improve the SCWE at NRC-licensed facilities. They can help develop budget and 

planning assumptions to 

support future agency and 

Allegation Program needs. 

Figure 1 shows that the 

NRC receives about 500 to 

600 allegations each year 

and that there has been an 

overall declining trend in 

the total number of 

allegations received from 

calendar year (CY) 2010 

through CY 2014. The 

decrease in allegations 

received in CY 2011 was 

the result of large 

reductions in allegations 

received for two reactor 

facilities that experienced 

SCWE problems in previous years. As actions were carried out at these facilities in response to 

the identified SCWE problem, the number of allegations received dropped precipitously in 

subsequent years. And although the number of allegations received in CY 2012 increased 

slightly, the following year the number of allegations continued its downward trend. Although 

there was a decrease in allegations involving reactor licensees in CY 2013, allegations involving 

a number of materials licensees increased. The decrease in allegations involving reactor 

licensees continued in CY 2014, and those involving materials decreased as well. Over the 

5-year period represented in Figure 1 the number of allegations has decreased approximately 

25 percent. Although facility- or vendor-specific matters (e.g., significant outage activity, 

construction activity, security activity, process/program changes, or company 

0

200

400

600

800

2010 2011 2012 2013 2014

FIGURE 1 ALLEGATIONS RECEIVED BY

CALENDAR YEAR

Reactor Materials Agreement State
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

4 

restructuring/staffing adjustments) do play a significant role in allegation trends, anecdotal 

information suggests that the overall decline may be the result of increased efforts by the NRC 

and nuclear industry to focus attention on developing and maintaining stronger environments for 

raising concerns at regulated entities. 

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 individuals who contact the NRC with concerns about Agreement State 

licensees, most 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 only uses the 

Allegation Program 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 

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

Typically, each allegation represents two to three concerns. Over the past decade, the trend in 

the total number of concerns in all but one year has paralleled the trend in total allegations 

(i.e., as the number of allegations has increased or decreased, the number of concerns has 

increased or decreased correspondingly).3

 In CY 2014, coinciding with the overall decrease in 

allegations received, the total volume of allegation concerns received decreased as well. More 

specifically, the number of allegations received in three of the four regional offices, as well as in 

the Office of Nuclear Reactor Regulation and the Office of New Reactors declined, and in all but 

one case declined by greater than 30 percent; Region II was the exception, which only saw a 

small decline. Region I, the Office of Nuclear Material Safety and Safeguards (including the 

former Office of Federal and State Materials and Environmental Management Programs), and 

the Office of Nuclear Security and Incident Response experienced increases in the number of 

concerns received coinciding with their increased number of allegations. The greatest increase 

in allegations and concerns, received by Region I, was largely attributable to concerns raised in 

regard to two reactor sites. 

 

Reactor Licensee Trends

To offer further insight into areas in which the NRC is allocating resources for the evaluation of 

reactor-related allegations, Figure 2 shows the 14 functional areas that represent approximately 

80 percent of the issues about which allegations were received nationwide in CY 2013.4

Figure 2 shows that the largest percentage of concerns in allegations received nationwide was 

discrimination concerns, which, nonetheless, decreased by 28 percent from the number of 

discrimination concerns received in CY 2013. A review of all discrimination concerns received in 

CY 2014 found trends in both the source and site variables. Claims were made by three times 

as many former contractor employees as former licensee employees. Of current workers, 

however, licensee employees were twice as likely to raise discrimination concerns as 

 

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 allegations about concerns in areas not shown in Figure 2, which represent the 

remaining 20 percent of the issues received. These areas include civil/structural, electrical, emergency 

preparedness, Employee Concerns Programs, environmental qualifications, falsification, fire protection, 

industrial safety, instrumentation and control, licensing, maintenance, mechanical, nondestructive 

evaluation, operations, procurement, and safeguards. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

5 

Discrimination

15%

Chilling Effect

14%

Security

12%

Fitness for Duty

7%

Quality Assurance

7%

Health Physics

7%

Wrongdoing 

6%

Engineering

6%

Access Authorization

6%

Training 

/Qualifications

5%

Safety Culture

4%

Corrective Action

4% Fatigue/Overtime

3%

Construction

3%

FIGURE 2 REACTOR CONCERNS NATIONWIDE 2014

contractors. Workers at reactor and vendor sites in Regions II raised more discrimination 

concerns than workers in the other Regions. These concerns involved workers primarily from 

operations, maintenance, security, and quality assurance functional organizations. 

The total number of chilling effect concerns in CY 2014 declined slightly. 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. In CY 2014, about 40 percent of the chilling effect 

concerns involved the environment for raising concerns at the sites associated with the 

construction of new reactors, including the related vendor sites. Most were raised by contractor 

employees and, not surprisingly, most involved work environments in the construction and 

quality assurance departments. The most often mentioned behaviors perceived by individuals to 

cause the chilling effect involved negative treatment, such as harassment or discrimination, after 

raising a concern; supervisors who discourage using the corrective action program or employee 

concerns program to document concerns; or supervisors who pressure workers to falsify 

documents to cover-up deficiencies. About 13 percent of chilling effect allegation concerns were 

substantiated in CY 2014 and 10 percent remained open at the time this report was being 

prepared. Of note, very few concerns were raised to the NRC related to schedule pressure 

causing a chilling effect. 

Although the number of security-related concerns increased slightly in CY 2014, 23 percent of 

those involved allegations raised by only two individuals concerning two different reactor sites. 

Most security-related allegation concerns were received in CY 2014 from licensee employees. 

No specific trends were found in the types of concerns raised. Allegations included concerns 

about discrimination, inattentiveness, compensatory measures, inadequate procedures and 

testing, and training qualifications. Of note, very few security-related chilling effect concerns 

were submitted in CY 2014. 

The number of fitness-for-duty concerns remained the same. Over 40 percent were drug- or 

alcohol-related including alleged drug or alcohol abuse, concerns about the licensee’s drug 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

6 

Fuel Facililty

42%

Exempt Distribution

15%

Radiography

11%

Medical

11%

Nuclear Gauges

6%

Decommissioning 

Materials

6%

Research and 

Development

5% Decommissioning 

Reactors

4%

FIGURE 3 ALLEGATIONS BY TYPE OF MATERIALS

LICENSEE NATIONWIDE 2014

testing policy, or concerns about attempted fitness-for-duty test subversion. No site or licensee 

trends were identified in the data. 

Materials Licensee Trends

A comparison of the types of materials issues in received allegations does not produce 

meaningful results because there are many different types of materials licensees and the 

activities they perform vary greatly. To offer insights into areas in which the NRC focused its 

attention on materials-related allegations, Figure 3 shows the eight types of materials licensees 

that accounted for about 80 percent of allegation concerns that the NRC received nationwide.5

The NRC received slightly fewer materials allegations in CY 2014 compared to the numbers 

received in the previous year. Since CY 2004, the number of allegations related to fuel cycle 

facilities has constituted the highest percentage (30 percent to 50 percent) of materials 

allegations. For this reason, overall fluctuations in the receipt rate of materials allegations have 

primarily been the result of changes in the receipt rate of allegations involving one or more fuel 

cycle facilities. The second highest percentage of materials-related allegations in CY 2014 

involved allegations in the exempt distribution area. Such allegations involve concerns about the 

alleged unauthorized sale of products containing exempt quantities of byproduct material by 

retailers that do not retain appropriate exempt distribution or possession licenses. 

 

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

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

special nuclear material, transportation, tritium light sources, uranium recovery, and well logging. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

7 

Licensee Employee

33%

Contractor Employee

27% Anonymous

11%

Private Citizen

11%

NRC Staff

9%

Licensee Identified

9%

FIGURE 4 ALLEGATIONS BY SOURCE CATEGORY 

NATIONWIDE 2014

Source Trends

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

received in CY 2014.6

 The data indicate that the distribution of source categories remained 

consistent from CY 2010 to CY 2014. That is, employees of licensees (or former employees) 

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

Because the total number of allegations received in CY 2014 was about 11 percent lower than 

the number received in CY 2013, it follows that there was a notable decline in the number of 

allegations raised by these two groups. Persons wishing to remain anonymous continued to be 

the third largest source of allegations but their numbers increased somewhat. In considering 

those allegation sources mentioned previously that have the potential to offer 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 has 

consistently remained around 75 percent annually. 

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 because 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 evaluation progress related to 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 NRC staff uses to monitor the SCWE at reactor sites. The appendix 

to this report offers statistics on allegations for all operating and non-operating reactor sites. The 

NRC received the listed allegations during the 5-year period between January 2010 and 

December 2014 and includes only allegations received from onsite sources (i.e., those that 

might indicate the health of the SCWE). Onsite sources include current or former licensee 

 

6

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

include state/federal agencies, and special interest groups. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

8 

employees, current or former contractor employees, and 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 might indicate a SCWE at risk, the 

staff conducted a more in-depth SCWE review of certain sites with larger numbers of onsite 

allegations. And because sites with a larger population of employees and contractors (such as 

three-unit reactor sites) typically generate more allegations, it is important to normalize the data 

to help ensure that those sites are not disproportionally chosen for further analysis. The 

following algorithm based on the median number of allegations received at operating reactor 

sites over the calendar year, and that considers the varying workforce size at different sites, 

determines what sites warrant this additional review: 

• 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 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 takes into consideration when applying the above criteria, that during 

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

For CY 2014, the median number of allegations per operating reactor site was three. 

Susquehanna Units 1 and 2, with 14 onsite allegations therefore, met these criteria. The criteria 

were also applied to non-operating (pre-operating license) sites and one, Vogtle Units 3 and 4 

with 16 onsite allegations, also met these criteria. The staff’s analyses of the SCWE at both of 

these reactor sites are discussed below. 

Susquehanna Units 1 and 2

After declining for two years in a row, the number of allegations received from onsite sources at 

the Susquehanna site increased last year. However, given the amount of outage activity, 

management changes, and union activities experienced at the site in CY 2014, the number and 

nature of allegations received does not appear to indicate weaknesses in the environment for 

raising concerns. In addition, no 

allegation concerns were raised 

related to chilling effect or a 

chilled work environment. This is 

a significant departure from past 

years in which a substantial 

portion of allegation concerns 

raised about the site involved 

assertions of a chilled work 

environment. Finally, an analysis 

of the subject matter of the 

technical allegation concerns 

received in CY 2014 does not 

indicate a trend in any specific 

functional area or concern type. 

0

10

20

30

2010 2011 2012 2013 2014

FIGURE 5 SUSQUEHANNA 1 AND 2

ALLEGATIONS

Substantiated Closed Received
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

9 

Although a number of discrimination concerns associated with Susquehanna Units 1 and 2 rose, 

none were concentrated in a specific plant department; none focused on a specific event or 

company policy issue, nor were otherwise indicative of a systemic pattern of concern. Of the 

discrimination issues raised in CY 2014, two remain open and under investigation and two were 

not investigated because a third party asserted discrimination. The NRC does not pursue thirdparty discrimination concerns because it is necessary to have the cooperation of the individual 

allegedly retaliated against to investigate the issue effectively. Instead, the NRC suggests that 

the alleger reporting the concern supply the third party with information so that they may contact 

the agency directly, if so desired. The remaining discrimination concerns were not investigated 

because the alleger did not establish a prima facie showing of potential discrimination. For 

clarification, to consider a matter of potential discrimination under Title 10 of the Code of 

Federal Regulations, an alleger must present a certain pattern of facts, called a prima facie 

showing. Specifically, the allegation must initially establish that an employee has engaged in a 

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

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

protected activity was, in part, a reason for the adverse personnel action. None of the 

discrimination concerns received by the NRC in the four years before CY 2014 were 

substantiated. 

The most recent biennial Problem Identification and Resolution inspection at the Susquehanna 

site was completed in June 2014 (Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML14216A216). Although the inspection team identified some 

weaknesses in the corrective action area involving the prioritization, efficiency and timeliness of 

actions taken in response to concerns raised, the team also found an overall willingness of site 

workers to raise safety concerns. Interviews were conducted in multiple departments and found 

no evidence of conditions that impaired the SCWE onsite, and also that employees had 

adequate knowledge of the avenues available for raising safety concerns including the 

corrective action program and employee concerns program. 

In July 2014, a supplemental inspection using inspection procedure 95002, “Supplemental 

Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic 

Performance Area” was completed at Susquehanna Unit 2 because of the site being in the 

degraded cornerstone column of the ROP Action Matrix due events involving unplanned reactor 

trips (ADAMS Accession No. ML14255A250). The inspection team conducted interviews and 

focus groups with licensee staff. Seventy individuals were interviewed, including 21 supervisors 

and senior managers who were interviewed separate from the staff-level personnel. The input 

gathered in the interviews and focus groups identified an overall willingness to raise issues and 

use the corrective action program, and that workers would not hesitate to stop work if a problem 

was encountered. Of the corrective action area, the interviewees indicated that the licensee was 

good at identifying problems, but could be more effective at resolving them. Workers perceived 

that change management is a recurring weakness at Susquehanna. Examples supplied 

included the transition to new corrective action program software (put into place in late 2013) 

and the implementation of new procedures. Specific difficulties were identified as a lack of 

communication concerning the changes, using ineffective methods to communicate to the 

workforce, failure to get input from the workforce during the development of changes, and not 

thoroughly evaluating the effect of a change before it was carried out. 

 

A discussion with the licensee’s employee concerns program personnel, both onsite and at the 

licensee’s corporate office revealed that the employee concerns program also received more 

concerns in CY 2014. Higher than normal traffic was encountered in March–May 2014, a time 

frame that included a Susquehanna Unit 2 outage to repair a non-safety-related pump and the 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

10 

Susquehanna Unit 1 refueling and maintenance outage. This was also the period of time 

leading up to the NRC’s 95002 inspection. In addition to multiple outages that took place at 

Susquehanna in CY 2014, the employee concerns program personnel attributed concern 

increases in CY 2014 to significant union activity, multiple senior management changes, and a 

change in the long-term general contractor. The employee concerns program personnel noted 

that Susquehanna employees are not reluctant to raise concerns or to confront management. 

Workers are aware of the various avenues for raising concerns but primarily use the corrective 

action program. Some concerns were submitted to the employee concerns program about the 

implementation of a new corrective action program database in early 2014, but no concerns 

were submitted to the employee concerns program about the corrective action program in the 

last 6 months of CY 2014. 

In the area of SCWE maintenance, a safety culture survey, which included an assessment of 

the environment for raising concerns trait, was conducted at Susquehanna in January 2013. 

The survey identified concerns in employee recognition and change management. Some work 

environment issues were identified in the Health Physics, Training, and Security organizations. 

The survey results prompted the licensee to develop a “Plan for Excellence.” The plan’s 

emphasis in CY 2013 was the corrective action program, equipment reliability and work 

management, while its emphasis in CY 2014 was improvement in operations focus and 

leadership. Employee concerns program representatives noted that the performance indicators 

developed for the Plan indicate the licensee made significant improvement in operations and 

leadership. The next SCWE survey at the Susquehanna site was taking place at the time this 

report was being prepared. 

In summary, given the amount of outage activity, management changes, and union activities 

experienced at Susquehanna Units 1 and 2 in CY 2014, the number and nature of allegations 

received from onsite sources at does not appear to indicate a work environment problem. The 

NRC will maintain its oversight of the SCWE at Susquehanna in CY 2015 through normal 

inspection activities. 

Vogtle Units 3 and 4

Representing a departure from the gradual increasing trend experienced over the past five 

years, the number of allegations the NRC received from onsite sources about Vogtle Units 3 

and 4, two units under construction, 

increased significantly in CY 2014 

from the number received in CY 2013. 

More than half of the CY 2014 

allegations from onsite sources were 

received in the third quarter of the 

year as hiring peaked to 

accommodate new construction 

activities and future operations. 

Allegation sources, not surprisingly, 

were concentrated in the contractor 

category and many involved Chicago 

Bridge & Iron (CB&I) or its 

subcontractors’ employees. Only one 

alleger came to the NRC 

anonymously. Almost half the 

concerns received were chilling effect 

0

5

10

15

20

2010 2011 2012 2013 2014

FIGURE 6 VOGTLE 3 AND 4

ALLEGATIONS

Substantiated Closed Received
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

11 

concerns and most of those involved CB&I and a subcontractor. Lesser trends were observed in 

welding and discrimination concerns. 

In the second quarter of the year, the NRC substantiated a chilled work environment allegation 

in the Security organization, based on an evaluation by the licensee and independently verified 

by the NRC. Most of the security officers that were interviewed during the licensee’s evaluation 

reportedly stated that they were reluctant to raise any concern to their management, or the 

licensee’s, for fear of retaliation and described examples of management behaviors that 

contributed to that perception, including the perception that no actions were taken by their 

supervisors to address concerns previously raised. They did, however, express comfort raising 

concerns to CB&I supervisors and using CB&I’s employee concerns program. The licensee 

committed to address this concern by, in part, SCWE refresher training. 

A second chilling effect allegation was substantiated in the late summer, involving the same 

contractors and sub-contractors on a particular shift in the Modular Assembly Building. Based 

on an earlier NRC-requested evaluation by the licensee, the Commission concluded this 

particular group of employees was chilled. In a related matter, a 2013 confirmatory order 

associated with an apparent violation of employee protection regulations by CB&I included a 

number of required actions to address weaknesses in the SCWE. Although the infraction 

involved personnel at the Lake Charles facility, the confirmatory order extended the required 

actions to CB&I nuclear activities elsewhere, including the Vogtle 3 and 4 site. The 2013 

confirmatory order was superceded by a 2014 confirmatory order associated with willful 

violations that supplemented the required actions. 

The number of discrimination allegations also trended upward in CY 2014. The NRC received 

four discrimination concerns in 2014. At the time of this report one was still open and in the early 

alternative dispute resolution process; one was open and being investigated; one was 

withdrawn by the alleger; and one did not make a prima facie showing. Three of the four 

discrimination allegations in CY 2014 involved CB&I or their subcontractors. None of the 

10 discrimination allegations raised in the previous four years has been substantiated. 

The NRC’s annual inspection of the licensee’s corrective action program was completed in late 

February 2014 (ADAMS Accession No. ML14087A320) and, with regard to the site’s 

environment for raising concerns, identified no concerns. The scope of the inspection in this 

regard was limited to inspectors observing meetings and activities in the field and reviewing 

documentation. The inspection report noted that adequate staffing levels appeared to prevent 

excessive overtime and no instances of concerns were being identified repeatedly because of 

inadequate corrective actions—two issues that can cause an unwillingness or hesitation to raise 

concerns. 

About 4000 people worked on the Vogtle construction site during this review period, the 

overwhelming majority of which are CB&I contractors and subcontractors. CB&I maintained its 

own employee concerns program that received nearly 200 concerns for investigation, 50 of 

which were chilling effect concerns. Half of all concerns were received anonymously; most in 

drop boxes. By mid-year, the employee concerns program had substantiated 11 chilling effect 

concerns and initiated a corrective action plan to address this trend and management behaviors 

related to the chilling effect concerns. 

CB&I contracted a third-party to assess comprehensively the safety culture. Such assessments 

are mandated under the 2013 confirmatory order mentioned earlier. The assessment took place 

in July 2014 and surveyed about 3,000 workers on site, with a response rate of 94 percent. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

12 

Although the assessment concluded that nuclear safety was not compromised by production 

priorities, weaknesses requiring management attention were identified, including trust, training, 

and leadership behaviors. The contractor reported that 79 percent of those surveyed thought 

the organization effectively put a policy into place that supports workers’ rights to raise safety 

concerns and does not tolerate retaliation. And although several of the write-in comments 

indicated workers did not seem to have a clear picture of what constituted the expected 

threshold for writing a condition report, during interviews personnel consistently expressed a 

willingness to raise concerns to their immediate or next-level supervision without fear of 

retaliation, and most were able to identify alternate means for raising concerns. 

CB&I indicated the actions taken, including reinforcing leadership expectations, leadership 

training on those expectations, changes made to management personnel, and a better working 

relationship between the human resources and employee concerns program organizations, 

appear to have improved the work environment and the number of chilling effect concerns 

dropped significantly in the second half of the year. 

In summary, although allegations increased sharply at the Vogtle construction site and many of 

those involved chilling effect concerns, the licensee and their primary contractor, CB&I, 

identified a negative trend in their employee concerns program data with respect to leadership 

behaviors and started actions to address those trends and corroborating evidence identified by 

the third-party safety culture assessment that took place in July 2014. Furthermore, the 

licensee’s investigations of chilling effect allegation concerns requested by the NRC appear to 

have been thorough and actions were taken to address found weaknesses. The NRC will 

maintain its oversight of the SCWE at Vogtle Units 3 and 4 to ensure corrective actions are 

completed and result in sustained performance improvements. 

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 workforce 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 offered 

publicly or included in this report. One fuel 

cycle facility received a sufficient number of 

allegations to warrant a more in-depth 

review of the SCWE and is discussed in the 

following section. 

Honeywell

As seen in Figure 7, the number of 

allegations received from onsite sources at 

Honeywell continued to trend upward in CY 

2014. Most issues raised involved Health 

Physics or Operations concerns. Although 

there was a union lockout in August 2014 

and in prior years similar actions 

contributed to the increase in allegations, in 

CY 2014 a majority of the allegations were 

received in the first two quarters of the year, 

0

5

10

15

20

2010 2011 2012 2013 2014

FIGURE 7 HONEYWELL

ALLEGATIONS

Substantiated Closed Received
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

13 

before the lockout. Also, in October 2014 there was an event involving a uranium hexafluoride 

leak that was classified as an “alert” under the NRC’s emergency classification guidelines 

because of its potential to degrade the level of safety of the plant. The NRC defines 

emergencies at fuel facilities according to three levels of increasing significance: unusual event, 

alert, and site area emergency. The purpose of the alert classification is to ensure that 

emergency personnel are readily available to respond if the situation becomes more serious or 

to confirm radiation monitoring if required, and offer offsite authorities current information on 

plant status and parameters. The NRC concluded, however, that no detectable radioactive 

material was released from the site during this event. Although such events can trigger an 

increase in allegations, in this instance there was no resulting significant increase in concerns 

received. 

To monitor the environment for raising concerns, the licensee reports it often conducts SCWE 

surveys of the workforce and did so in June 2014. In response to the survey’s findings, the 

licensee revised their annual SCWE training and offered extra supervisory training. In addition 

to the corrective action program, the licensee supplies a number of alternative avenues to the 

workforce for raising concerns, including an employee concerns hotline and suggestion boxes; 

both of these avenues allow for reporting concerns anonymously. Although no concerns were 

received through these avenues in CY 2014, the licensee stated that several employees took 

advantage of quarterly Health, Safety, and Environmental Committee meetings to raise 

concerns. In CY 2014 this committee was reinstituted and the meetings designed to offer an 

open forum to raise concerns. 

Of the environment for raising concerns, there were no chilling effect allegation concerns raised 

to the NRC in CY 2014, nor has there been one raised for several years. In the past 5 years, 

three discrimination concerns have been raised to the NRC about Honeywell. One 

discrimination concern was raised in CY 2014 and is still open. Of the remaining two, one was 

settled under the NRC’s early ADR process and the other resulted in an apparent violation of 

the NRC’s Employee Protection regulations and a confirmatory order was issued in early 2015 

as part of a post-investigation Alternative Dispute Resolution settlement agreement (ADAMS 

Accession No. ML15055A094). Honeywell committed to take a number of actions to strengthen 

the environment for raising concerns, including reviewing and updating their SCWE policy and 

incorporating applicable aspects of the NRC’s Safety Culture Policy. 

In conclusion, the number and nature of allegations received concerning the Honeywell site do 

not indicate a problem with the site’s environment for raising concerns. The NRC will continue to 

monitor the licensee’s compliance with the confirmatory order and otherwise maintain its 

oversight of the SCWE at the facility through normal inspection activity. 

Allegation Trends for Selected Vendors 

Neither this report nor the NRC Web site offers statistics by contractor or vendor for reasons 

similar to those outlined above for materials licensees. Nonetheless, the allegation trends of one 

large vendor warrant discussion in this report. 

Lake Charles Facility

The number of allegations received by the NRC from onsite sources about the Chicago Bridge 

and Iron Lake Charles facility in CY 2014 decreased significantly from the number received in 

CY 2013. All but three allegations included a claim of discrimination and many of the technical 

concerns raised involved quality assurance associated with welding activities, although minor 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

14 

0

10

20

30

2010 2011 2012 2013 2014

FIGURE 8 LAKE CHARLES FACILITY

ALLEGATIONS

Substantiated Closed Received

trends also were noted in the areas of chilling effect, training, and falsification concerns. Nine 

discrimination allegations concerns were received in CY 2014, less than half the number 

received in CY 2013. Of these, two remained open at the time this report was prepared; one in 

the ADR process and one being investigated by the NRC. Three others were settled in the ADR 

process and the others were 

either withdrawn by the alleger 

or did not make a prima facie 

showing. The number of 

allegation concerns received in 

CY 2014 asserting a chilled 

work environment also 

declined considerably. Two 

were substantiated early in the 

year as CB&I continued to take 

actions to address the 

weaknesses in the work 

environment identified by the 

NRC in CY 2013 and one 

remained open at the time this 

report was prepared. 

 

Of the environment for raising concerns, on April 18, 2013, the NRC issued a chilling effect 

letter (ADAMS Accession No. ML13092A077) notifying the vendor that the NRC had concluded, 

based on inspection observations and investigations into allegations received in CY 2012 and 

the first quarter of CY 2013, that portions of the Lake Charles facility workforce, especially 

employees with nuclear and quality control backgrounds, perceived that they were not free to 

raise safety concerns, that they believed they would be retaliated against for raising such 

concerns, and that management had not been effective in assuring employees that they could 

raise safety issues without fear of retaliation. 

The NRC issued a confirmatory order to CB&I on September 16, 2013, because of a successful 

post-investigation ADR session with the Agency (ADAMS Accession No. ML13231A271). The 

confirmatory order represents a settlement agreement between the NRC and the vendor 

concerning a notice of violation and Proposed Imposition of Civil Penalties issued by the NRC 

on April 18, 2013 (ADAMS Accession No. ML13050A597). The violation involved employment 

discrimination in violation of 10 CFR 52.5, “Employee Protection.” 

In response to both the chilling effect letter and confirmatory order, CB&I committed to taking a 

number of actions at all nuclear locations including Lake Charles. These include reinforcing 

through communications its strategy and commitment to improve its nuclear safety culture and 

SCWE; updating its related policies to ensure their consistency with the NRC and industry 

guidance; developing and revising the company’s employee-protection, safety culture, and 

SCWE training; improving or developing a number of safety culture processes, such as the 

employee concerns program and safety culture monitoring tools; and assessing 

comprehensively nuclear safety culture of all CB&I nuclear business entities. 

In February 2014, a vendor inspection at the Lake Charles facility took place that included a 

review of the safety culture and the actions taken in response to the chilling effect letter and 

confirmatory order (ADAMS Accession No. ML14072A315). Overall, the SCWE had improved 

since previous inspections. Most personnel stated that they were willing to raise safety concerns 

and were aware of the various avenues available for raising safety concerns. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

15 

As required by the 2013 confirmatory order, an independent nuclear safety culture assessment 

was conducted in late April 2014. According to the contractor’s report, the assessment team 

identified no strengths, one positive observation, and a number of weaknesses and negative 

observations concerning several safety culture traits. 

Although the number of NRC allegations decreased in CY 2014, the vendor reports that the 

number of employee concerns program concerns increased significantly at Lake Charles. 

Similar to the NRC’s experience, the numbers declined in the last quarter of the year. 

SCWE-related training required by the 2013 confirmatory order, as well as a number of 

reductions-in-force executed throughout the calendar year, is suspected to have contributed to 

the increased number of concerns raised to the employee concerns program. Although the 

program received a number of chilling effect concerns, the trend declined throughout the year. 

Furthermore, the percentage of concerns received anonymously declined as well indicating an 

improved comfort with the program and raising concerns. 

On September 25, 2014, the NRC issued a second confirmatory order that superceded the first 

to enhance actions that CB&I had previously agreed to take to further address issues related to 

willful violations of NRC requirements and deliberate misconduct that occurred at the Lake 

Charles facility in CY 2010 (ADAMS Accession No. ML14248A445). Other actions by the vendor 

include training to highlight the errors behind the violations and enhanced monitoring of the 

safety culture. 

Late in the calendar year, consistent with the philosophy of the Enforcement Policy regarding 

violations with similar root causes for which enforcement action was taken, the NRC twice 

exercised enforcement discretion. The first instance involved two additional apparent violations 

of the NRC’s deliberate misconduct regulation and three nonconformances related to the NRC’s 

quality assurance regulations (ADAMS Accession No. ML14311A838). The second time the 

NRC exercised enforcement discretion was for a discrimination violation and based on the 

September 2013 confirmatory order (ADAMS Accession No. ML14337A190). Discretion was 

considered appropriate because the violations and nonconformances occurred before or during 

implementation of the corrective actions specified in the 2013 and 2014 confirmatory orders. 

The NRC continues to monitor the vendor’s SCWE and to assess CB&I’s compliance with the 

terms of the confirmatory order and chilling effect letter. 

Trends in the Agreement States

Under the authority granted in Section 274b of the Atomic Energy Act of 1954, as amended (the 

Act), the NRC may relinquish its authority to regulate certain byproduct material, source 

material, 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 11 shows the 37 Agreement States. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

16 

FIGURE 9 AGREEMENT STATES 

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

to ensure that they maintain programs that are 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 and 

IMPEP is available on the Web site for the NRC’s Office of Federal and State Materials and 

Environmental Management Programs at http://nrc-stp.ornl.gov/. 

In CY 2014, the NRC completed routine IMPEP reviews of 11 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 80 cases 

cumulatively received by all of the programs reviewed. The NRC referred 25 of the 80 cases 

reviewed to the Agreement State Programs; the States received the other concerns directly 

from 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 2014 adequately protected the identity of any concerned individual who 

requested anonymity. In general, the results of the CY 2014 IMPEP reviews demonstrate that 

the Agreement States continue to treat response to concerns from external sources as a high 

priority in protecting public health and safety. 

 

Agreement States (37)

NRC States (13)

AK

HI

CA

OR

WA

NV

ID

AZ

NM

UT

CO

WY

MT ND

SD

NE

KS

OK

TX LA

AR

MO

IA

MN

WI

IL

MS AL GA

FL

SC

NC

TN

KY

IN

MI

OH

VA

WV

PA

NY

ME

MD

DE

NJ

CT

MA

NH

VT

RI 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

17 

OVERVIEW OF PROGRAM ACTIVITIES

Activities in CY 2014 in areas closely related to the Allegation Program and SCWE Policy are 

discussed below, including statistics associated with the agency-sponsored ADR program. The 

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

number and nature of allegations concerning that site and through documented observations 

based on interviews with the licensees’ workers 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) or there is a 

finding of discrimination that has the potential to chill the work environment, the NRC may 

request, in writing, information about the licensee’s SCWE. 

 

Requests for Information Regarding Discrimination Findings 

In early CY 2014, the NRC revised its guidance to the staff concerning the handling of 

discrimination concerns substantiated by the U.S. Department of Labor (DOL) under 

Section 211 of the Energy Reorganization Act of 1974 (ERA). While NRC enforcement action is 

being considered, NRC staff typically will issue a request for information to the regulated entity. 

Such letters inform the licensee or contractor of the NRC’s knowledge of the DOL finding and 

interest in understanding the licensee’s or contractor’s position, including any actions that have 

been taken or are planned to assess and mitigate the potential chilling effect that might be 

caused by the finding. It also informs the workforce of the NRC’s interest in the state of the 

environment for raising concerns at the site or facility. At the time such letters are issued, the 

NRC has confirmed neither that enforcement is necessary nor that the work environment is 

chilled. Rather, information is sought to help inform the NRC’s potential evaluation efforts going 

forward. 

Although the NRC issued two requests for information regarding DOL discrimination findings in 

CY 2013, none were issued in CY 2014. The NRC’s review of the information offered in the 

earlier cases concluded that the safety conscious work environments of the facilities in question 

were adequately protected. 

Chilling Effect Letters

Sometimes even in the absence of a finding of discrimination, NRC inspection observations or 

allegation insights result in the NRC’s conclusion that a licensee or contractor’s work 

environment is chilled and corrective actions are warranted. In such cases the NRC will issue 

what is referred to as a chilling effect letter to ensure that the licensee is taking appropriate 

actions to foster a workplace environment that encourages employees and contractors to raise 

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

No chilling effect letters were issued in CY 2014. Actions continued, however, to assess 

responses to two previous chilling effect letters issued by the staff in CY 2013. At the time this 

report was prepared, the staff had concluded one recipient had taken appropriate corrective 

actions to address the identified weaknesses in the SCWE and returned to normal oversight of 

that site. The second case, involving CB&I and discussed in the previous section of this report, 

is still under review. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

18 

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 gives 

parties extra 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 supplies, 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, at which point an NRC investigation remains an option if 

the alleger is still interested in pursuing the discrimination matter. Should such an investigation 

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

may engage in what the agency refers to as “post-investigation ADR.” More information on that 

process can be found by going to 

http://www.nrc.gov/about-nrc/regulatory/enforcement/adr/post-investigation.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 about the discrimination finding. The NRC 

also considers settlements resulting from licensee-initiated mediation as equivalent to 

settlements reached under the Early ADR Program. 

At the time this report was prepared, 24 of the early ADR offers made by the NRC in association 

with discrimination allegations raised in CY 2014 resulted in agreements to mediate. Of those 

24 cases, 15 resulted in the parties reaching a mutually agreeable settlement. The remaining 

9 cases are either still being processed or were referred to the NRC’s Office of Investigations 

because the parties did not reach a settlement or the parties changed their mind before 

mediation. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

19 

CONCLUSIONS

The total number of allegations received from CY 2010 through CY 2014 declined by about 

25 percent over the 5-year period. Although facility- or vendor-specific matters do play a 

significant role in allegation trends, anecdotal information suggests that the overall decline may 

be the result of increased efforts by the NRC and nuclear industry to focus attention on 

developing and maintaining stronger environments for raising concerns at regulated entities. 

In CY 2014, coinciding with the overall decrease in allegations received, the total volume of 

allegation concerns received decreased as well. Although the number of security-related 

concerns increased slightly in CY 2014, 23 percent of those involved allegations raised by only 

two individuals concerning two different reactor sites. 

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

has taken action to engage licensees about their work environment when this has been 

warranted and will continue to monitor these sites with interest. 

The agency’s early ADR process resulted in 15 cases of discrimination allegations being settled 

between the parties before the start of an NRC investigation. The staff believes that voluntary 

dispute resolution by the parties using the communication opportunities afforded in early ADR 

can stem the inherent damage such disputes can have on the SCWE more quickly than could 

an investigation. 
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

A-1

APPENDIX 

ALLEGATION STATISTICS FOR 

OPERATING REACTORS, NON-OPERATING REACTORS, AND FUEL CYCLE FACILITIES

OPERATING REACTOR ALLEGATIONS RECEIVED FROM ONSITE SOURCES 

Site 2010 2011 2012 2013 2014 

ARKANSAS 1 & 2 4 3 6 1 3

BEAVER VALLEY 1 & 2 2 1 1 1 5

BRAIDWOOD 1 & 2 4 2 2 2 

BROWNS FERRY 1, 2 & 3 12 11 16 15 11

BRUNSWICK 1 & 2 1 3 6 1 

BYRON 1 & 2 6 3 3 

CALLAWAY 3 1 5 6 3

CALVERT CLIFFS 1 & 2 3 1 1 3 2

CATAWBA 1 & 2 2 3 3 1 6

CLINTON 4 1 1 1 

COLUMBIA PLANT 4 5 1 5 1

COMANCHE PEAK 1 & 2 2 3 2 3 5

COOK 1 & 2 3 5 5 4

COOPER 5 5 3 4 2

DAVIS-BESSE 2 4 5 5

DIABLO CANYON 1 & 2 12 9 5 6 1

DRESDEN 2 & 3 1 2 2 7

DUANE ARNOLD 1 1 2 3 4

FARLEY 1 & 2 7 12 9 6 3

FERMI 3 3 1 1 

FITZPATRICK 2 2 2 1

FORT CALHOUN 5 4 3 5 4

GINNA 4 10 4 1

GRAND GULF 5 3 10 2 

HARRIS 5 3 6 2 2

HATCH 1 & 2 8 4 5 3 5

INDIAN POINT 2 & 3 6 15 17 13 6

LASALLE 1 & 2 1 2 2 1

LIMERICK 1 & 2 2 3 5 1 3

MCGUIRE 1 & 2 6 5 1 3 1

MILLSTONE 2 & 3 4 11 9 4 6

MONTICELLO 3 2 1 3

NINE MILE POINT 1 & 2 1 5 2 1

NORTH ANNA 1 & 2 2 1 1 1 

OCONEE 1, 2, & 3 11 4 6 3 6

OYSTER CREEK 4 3 1 2

PALISADES 3 5 5 11 8

PALO VERDE 1, 2, & 3 16 8 7 10 12
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

A-2

Site 2010 2011 2012 2013 2014 

PEACH BOTTOM 2 & 3 4 3 1 7 2

PERRY 2 5 10 7 1

PILGRIM 5 5 2 4 5

POINT BEACH 1 & 2 8 6 4 3 4

PRAIRIE ISLAND 1 & 2 8 7 9 11 8

QUAD CITIES 1 & 2 1 1 3 1

RIVER BEND 7 3 2

ROBINSON 4 6 4 4 

SALEM/HOPE CREEK 6 4 5 12 8

SEABROOK 1 7 5 5 2

SEQUOYAH 1 & 2 6 19 5 7

SOUTH TEXAS 1 & 2 5 5 8 5 4

ST LUCIE 1 & 2 12 16 7 8 4

SUMMER 1 4 1 4

SURRY 1 & 2 6 4 1 1 1

SUSQUEHANNA 1 & 2 12 22 21 9 14

THREE MILE ISLAND 1 3 3

TURKEY POINT 3 & 4 15 17 17 6 2

VERMONT YANKEE 3 2 1 1

VOGTLE 1 & 2 4 12 5 2 3

WATERFORD 4 2 4 4 3

WATTS BAR 1 2 5 21 8 5

WOLF CREEK 2 4 5 6 9
ALLEGATION PROGRAM 2014 ANNUAL TRENDS REPORT 

A-3

NON-OPERATING REACTOR ALLEGATIONS RECEIVED FROM ONSITE SOURCES 

Site 2010 2011 2012 2013 2014 

BELLEFONTE 1 2 1 

BELLEFONTE 3 & 4 2 1 

CRYSTAL RIVER 3 1 1 1 

HUMBOLDT BAY 4 2 2 

KEWAUNEE 1 1 

LA CROSSE 1 1 

SAN ONOFRE 1 2 1 

SAN ONOFRE 2 & 3 59 23 29 9 3

SOUTH TEXAS 3 & 4 1 

SUMMER 2 & 3 10 6 12

VOGTLE 3 & 4 3 7 6 16

WATTS BAR 2 26 10 7 14 9

ZION 1 3 1 2 1

FUEL CYCLE FACILITY ALLEGATIONS RECEIVED FROM ONSITE SOURCES 

Site 2010 2011 2012 2013 2014 

AMERICAN CENTRIFUGE PLANT 1 1 

BWX TECH. 1 1 2

FRAMATONE-RICH. 1 1

GE-HITACHI GLE 1 

GLOBAL NUCLEAR 6 5 5 2 1

HONEYWELL 17 3 6 6 10

LOUISIANA ENERGY SVCS. 6 12 2 9 5

NUCLEAR FUEL SVCS. 10 4 8 6 5

PADUCAH 4 6 2 2 1

SHAW AREVA MOX 4 11 4 3

WESTINGHOUSE 1 

YUCCA MTN. 2